DCT

2:25-cv-01826

Shenzhen Zhanpusida Technology Co Ltd v. Individuals Partnerships Unincorp Associations

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01826, W.D. Pa., 11/24/2025
  • Venue Allegations: Venue is alleged on the basis that the defendants are foreign entities not resident in the United States and are therefore subject to venue in any judicial district, and on the basis that defendants solicit and transact business in the district.
  • Core Dispute: Plaintiff alleges that numerous foreign-based entities selling emergency vehicle power supplies through online marketplaces infringe two U.S. patents related to the internal mechanical construction of such devices.
  • Technical Context: The technology concerns portable, multi-function power supplies, commonly known as jump starters, which are a significant product category in the consumer automotive accessory market.
  • Key Procedural History: The complaint alleges that Plaintiff's licensee sells products embodying the patented technology on Amazon.com under the brand name "ACMOUNT." It further alleges that the numerous, unidentified defendants are selling infringing products that are "substantially identical" and likely originate from the same foreign manufacturer, creating what the complaint characterizes as an enforcement challenge against "countless anonymous scofflaws."

Case Timeline

Date Event
2023-11-16 Priority Date for ’125 and ’129 Patents
2024 Period of Plaintiff's licensee's significant sales
2025 Period of Plaintiff's licensee's sales allegedly falling to "nearly zero"
2025-06-17 Issue Date for U.S. Patent No. 12,336,125
2025-06-17 Issue Date for U.S. Patent No. 12,336,129
2025-11-24 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,336,125 B2 - “Emergency Starting Power Supply for a Vehicle”

  • Patent Identification: U.S. Patent No. 12,336,125 B2, "Emergency Starting Power Supply for a Vehicle," issued June 17, 2025 (the "'125 Patent"). (Compl. ¶17).

The Invention Explained

  • Problem Addressed: The patent's background section identifies issues in existing portable vehicle power supplies related to the "mounting instability and poor reliability of the power source, circuit board, and output terminals within the shell," which leads to a "relatively low lifespan." (’125 Patent, col. 1:28-35).
  • The Patented Solution: The invention claims to solve this problem through a specific internal mechanical arrangement. It describes a multi-part shell where one part contains a "first mounting part" for the components, and the other part contains a "second protrusion" that is configured to physically "limit the output terminal." (’125 Patent, Abstract). This design is intended to securely confine the high-current output terminal within the device housing, preventing movement and enhancing durability. (’125 Patent, col. 9:3-13).
  • Technical Importance: This mechanical design approach aims to improve the robustness and longevity of portable jump starters by securing internal components against physical shock and operational stress. (’125 Patent, col. 5:21-30).

Key Claims at a Glance

  • The complaint asserts infringement of independent Claim 1. (Compl. ¶53).
  • The essential elements of Claim 1 are:
    • An emergency starting power supply for vehicles, comprising a shell, a power source, a circuit board, and an output terminal.
    • The shell has a first accommodating space and a first mounting part.
    • The power source and circuit board are housed in the first accommodating space.
    • The power source is electrically connected to the circuit board and output terminal.
    • The output terminal and first mounting part have detachably connected first and second coupling parts.
    • The output terminal is configured to output current for starting a vehicle engine.
    • The shell comprises a first shell and a second shell; the first shell has the first mounting part, and the second shell has a second protrusion configured to limit the output terminal.
  • The complaint also alleges infringement of dependent claims 2, 6, 13, 14, 15, 18, 19, and 20. (Compl. ¶¶54-61).

U.S. Patent No. 12,336,129 B2 - “Emergency Starting Power Supply for Vehicle”

  • Patent Identification: U.S. Patent No. 12,336,129 B2, "Emergency Starting Power Supply for Vehicle," issued June 17, 2025 (the "'129 Patent"). (Compl. ¶19).

The Invention Explained

  • Problem Addressed: Like its counterpart, the ’129 Patent addresses the problem of "mounting instability and poor reliability" of internal components within the shell of existing emergency power supplies. (’129 Patent, col. 1:28-35).
  • The Patented Solution: This invention discloses a different mechanical solution centered on the use of a "first through-hole" located in the "first mounting part." The claim requires this through-hole to be specifically "configured for mounting the output terminal." (’129 Patent, Abstract). This provides a distinct structural method for securing the output terminal, where the hole itself is an integral part of the mounting mechanism rather than merely a pass-through for wiring. (’129 Patent, col. 10:20-27).
  • Technical Importance: The invention provides a specific and robust mechanical interface for the output terminal, aiming to enhance the device's durability and reliability under real-world use conditions. (’129 Patent, col. 5:21-30).

Key Claims at a Glance

  • The complaint asserts infringement of independent Claim 1. (Compl. ¶69).
  • The essential elements of Claim 1 are:
    • An emergency starting power supply for vehicles, comprising a shell, a power source, a circuit board, and an output terminal.
    • The shell has a first accommodating space and a first mounting part.
    • The power source and circuit board are housed in the first accommodating space.
    • The power source is electrically connected to the circuit board and output terminal.
    • The first mounting part is provided with a first through-hole.
    • The output terminal and first mounting part have detachably connected first and second coupling parts.
    • The output terminal is configured to output current for starting a vehicle engine.
    • The first through-hole is configured for mounting the output terminal.
  • The complaint also alleges infringement of dependent claims 2, 3, 5, 6, 8, 13, 15, and 18. (Compl. ¶¶70-77).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "emergency power supply devices for vehicles" sold by the defendants listed in Schedule A via online marketplaces, including Amazon.com. (Compl. ¶1, p. 9-11). The complaint identifies these products by their Amazon Standard Identification Numbers (ASINs). (Compl. p. 9-11).

Functionality and Market Context

The complaint alleges the accused products are "near replicas" of Plaintiff's licensed technology and replicate features such as "on-demand charging of car batteries, a flash light, rapid care tire inflation, and super compact size." (Compl. ¶26). The complaint provides photographic exemplars of the accused products with their shells opened, showing the internal arrangement of the battery, circuit board, and other components. (Compl. p. 9). Plaintiff alleges that a "flood of infringing products" has caused its licensee's sales to drop from "hundreds of thousands of dollars in sales in 2024, to nearly zero sales in 2025." (Compl. ¶31, 65).

IV. Analysis of Infringement Allegations

The complaint alleges that the accused products infringe the asserted claims of the ’125 and ’129 Patents but does not provide claim charts or a detailed element-by-element mapping of accused features to claim limitations in the body of the complaint. (Compl. ¶¶53, 69). Instead, it refers to charts contained in an "Exhibit D," which was not included with the filed complaint. (Compl. ¶49).

The general infringement theory is that the defendants' products are "substantially identical" to each other and to Plaintiff's licensed products, and that they "achieve these patented benefits using the same internal technologies claimed in the Asserted Patent." (Compl. ¶26-27). The photographic evidence provided shows the internal components of several accused products, which generally include a shell, a battery pack (power source), a main circuit board, and output terminals. (Compl. p. 9). The infringement case will depend on whether the specific mechanical arrangements within these products meet the structural limitations of the asserted claims, such as the "second protrusion" of the ’125 Patent or the "first through-hole configured for mounting" of the ’129 Patent.

V. Key Claim Terms for Construction

’125 Patent

  • The Term: "second protrusion... configured to limit the output terminal"
  • Context and Importance: This is a central structural element of Claim 1 of the ’125 Patent. The infringement analysis will likely turn on what type of structure qualifies as a "protrusion" and what degree of physical constraint is required to "limit" the output terminal.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes the function of this element as ensuring the terminal is "confined," "preventing the output terminal 140 from moving or detaching." (’125 Patent, col. 9:6-10). This functional language may support a construction covering any internal feature that prevents movement.
    • Evidence for a Narrower Interpretation: The figures depict a specific, molded feature (11021) on the second shell half. (’125 Patent, Fig. 3). A defendant may argue that the term should be limited to a structure of a similar form and location as shown in the preferred embodiment.

’129 Patent

  • The Term: "first through-hole is configured for mounting the output terminal"
  • Context and Importance: This is the key distinguishing feature of Claim 1 of the ’129 Patent. The dispute will likely focus on whether an opening in the accused device's shell is merely a pass-through for cables or if it serves a "mounting" function as required by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes this feature functionally, stating it "achieves the function of mounting the output terminal 140 on the first mounting part 112." (’129 Patent, col. 10:25-27). This may support a broad interpretation covering any hole used as part of the mounting assembly.
    • Evidence for a Narrower Interpretation: The patent's figures show a specific implementation where the through-hole (1126) works in conjunction with coupling parts and a screw to secure the terminal. (’129 Patent, Figs. 12-14). An argument could be made that "configured for mounting" requires a structure that is more than a simple opening and is specifically shaped or adapted for a mechanical connection.

VI. Other Allegations

  • Indirect Infringement: The complaint pleads both induced and contributory infringement. (Compl. ¶52, 68). The basis for contributory infringement is the allegation that defendants sell products knowing they will be used by consumers in an infringing manner and that the products "have substantially no non-infringing uses." (Compl. ¶63-64, 79).
  • Willful Infringement: The complaint alleges that defendants acted "knowingly and intentionally, or with reckless disregard or willful blindness to Plaintiff's rights." (Compl. ¶48). The factual basis alleged for willfulness includes defendants having "actual knowledge of Plaintiff's ownership of the... Patent[s], of the fame, popularity and success of the patent-protected ACMount car charger" and choosing to sell what are alleged to be "virtual identical cop[ies]." (Compl. ¶48-49).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A central evidentiary question will be one of structural identity: can discovery demonstrate that the internal mechanical arrangements of the numerous accused products, as depicted in the complaint's photographs (Compl. p. 9), contain the specific structures required by the asserted claims, namely the "second protrusion configured to limit" of the ’125 Patent and the "first through-hole configured for mounting" of the ’129 Patent?
  • A key procedural issue will be one of joinder and enforcement: given the defendants are a large group of foreign sellers alleged to be sourcing products from a common manufacturer, can the Plaintiff successfully establish that the accused products are the "same" in all relevant respects, thereby satisfying the requirements for joinder under 35 U.S.C. § 299 and allowing for an efficient, consolidated action?
  • The case may also turn on a core question of claim scope: can the structural terms at the heart of each patent—"protrusion" and "through-hole"—be construed broadly enough to read on the features of the accused devices, or will they be narrowed by the specific embodiments shown in the patents' figures, potentially creating a path for non-infringement arguments?