Shenzhenshiposhenkejifazhanyouxiangongsi v. Shenzhen Zhanpusida Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: SHENZHENSHIPOSHENKEJIFAZHANYOUXIANGONGSI; SHENZHEN COCOTOXIN TECHNOLOGY CO.; SHENZHEN AISHANGHOU TRADING CO., LTD.; and SHENZHEN BAIMO TRADING CO. (People's Republic of China)
  • Defendant: Shenzhen Zhanpusida Technology Co., Ltd. (People's Republic of China)
  • Plaintiff’s Counsel: ShinyRise PLLC
• Case Identification: 2:25-cv-02027, W.D. Pa., 12/31/2025
• Venue Allegations: Plaintiffs allege that venue is proper in any U.S. judicial district because Defendant is not a resident of the United States.
• Core Dispute: Plaintiffs, a group of Amazon sellers, seek a declaratory judgment that their vehicle jump starter products do not infringe two of the Defendant’s patents related to the internal mechanical structure of such devices.
• Technical Context: The technology at issue involves the internal construction of portable emergency power supplies for vehicles, commonly known as jump starters, a competitive segment in the automotive accessories market.
• Key Procedural History: This declaratory judgment action follows infringement assertions made by the Defendant against the Plaintiffs through Amazon.com's patent enforcement program. The complaint states these assertions led to the removal of product listings and required Plaintiffs' participation in the Amazon Patent Evaluation Express (APEX) program. The complaint also notes the existence of a concurrent infringement lawsuit filed by the Defendant against the Plaintiffs in the same district, asserting different but related patents from the same family. During the prosecution of the '570 Patent, the USPTO issued a non-statutory double patenting rejection over the '079 Patent, which was overcome by filing a terminal disclaimer, indicating the claims of the two patents are not patentably distinct.

Case Timeline

Date	Event
2023-11-16	Priority Date for ’079 and ’570 Patents
2024-12-17	’079 Patent Issued
2025-03-27	USPTO issues double patenting rejection for ’570 Patent application
2025-04-28	Terminal disclaimer filed for ’570 Patent application
2025-07-08	’570 Patent Issued
2025-10-27	Defendant initiates first Amazon complaint against Plaintiffs
2025-11-21	Defendant initiates Amazon complaint against Plaintiff SCATACH POWER
2025-11-22	Defendant initiates Amazon complaint against Plaintiff GILLAWAY
2025-11-24	Defendant files concurrent infringement action (25-cv-1826)
2025-12-11	Defendant initiates Amazon complaints against Plaintiffs
2025-12-12	Defendant asserts ’570 Patent in Amazon complaint against Plaintiff
2025-12-31	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,171,079 - *"Emergency Starting Power Supply for Vehicle"*

• Patent Identification: U.S. Patent No. 12,171,079, "Emergency Starting Power Supply for Vehicle," issued December 17, 2024 (the ’079 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a technical problem in existing portable vehicle jump starters, namely the "mounting instability and poor reliability of the power source, circuit board, and output terminals within the shell," which contributes to a "relatively low lifespan" for the devices (Compl. Ex. 1, '079 Patent, col. 1:30-35).
• The Patented Solution: The invention proposes a specific internal structural arrangement to improve mechanical stability. It describes a shell containing a main "first accommodating space" for the power source and circuit board, and a distinct "first mounting part" which, in turn, provides a "second accommodating space" dedicated to housing the output terminal ('079 Patent, Abstract; col. 7:53-63). This compartmentalized design, illustrated in figures such as Figure 1, is intended to secure each component against movement and shock, thereby increasing device reliability ('079 Patent, col. 8:6-14).
• Technical Importance: The claimed design focuses on enhancing the physical durability and operational reliability of portable jump starters by improving the internal mounting and stability of their core electrical components ('079 Patent, col. 5:16-24).

Key Claims at a Glance

• The complaint identifies Claim 1 as the basis for Defendant's infringement assertions (Compl. ¶17).
• Essential elements of Independent Claim 1 include:
  • An emergency starting power supply 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 "first mounting part" is provided with a "second accommodating space" that houses at least a portion of the output terminal.
  • The output terminal has a "first coupling part," the first mounting part has a "second coupling part," and the first coupling part is "detachably connected" to the second coupling part.

U.S. Patent No. 12,356,570 - *"Emergency Starting Power Supply for Vehicle"*

• Patent Identification: U.S. Patent No. 12,356,570, "Emergency Starting Power Supply for Vehicle," issued July 8, 2025 (the ’570 Patent).

The Invention Explained

• Problem Addressed: The ’570 Patent shares an identical specification with the ’079 Patent and thus addresses the same problem of "mounting instability and poor reliability" of internal components within portable jump starters (Compl. Ex. 2, '570 Patent, col. 1:30-35).
• The Patented Solution: The solution is also a specific internal structural arrangement for securing components. While based on the same core mechanical design as the ’079 Patent, the independent claim of the ’570 Patent adds the requirement of a "display device" to the combination of elements ('570 Patent, Claim 1). The display device is specified as being "arranged on a side of the circuit board" ('570 Patent, Claim 1).
• Technical Importance: This patented design also aims to enhance device durability through improved internal stability, while specifically addressing the integration of a user display within that robust mechanical framework ('570 Patent, col. 5:16-24).

Key Claims at a Glance

• The complaint identifies Claim 1 as the basis for Defendant's infringement assertions (Compl. ¶17).
• Essential elements of Independent Claim 1 include all the structural elements of Claim 1 of the ’079 Patent, with the addition of:
  • A "display device."
  • The display device is "arranged on a side of the circuit board."

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are various "jump starter devices for vehicles sold by Plaintiffs on the Amazon platform" (Compl. ¶14). The complaint provides a chart identifying the specific products accused of infringement by their Amazon Standard Identification Number (ASIN), the patent asserted against each, and the date of the assertion (Compl. ¶11).

Functionality and Market Context

The complaint describes the products as being part of the "jump starter segment on Amazon.com," where Plaintiffs are "leading sellers" (Compl. ¶5). The core function of these devices is to provide emergency power to start a vehicle with a dead battery. The complaint alleges that Defendant's enforcement actions targeted Plaintiffs' "key revenue-generating products" during the "peak holiday sales season," suggesting their commercial importance (Compl. ¶12). The complaint does not provide technical details regarding the internal construction of the accused products.

IV. Analysis of Infringement Allegations

The complaint, being a declaratory judgment action for non-infringement, does not contain a detailed infringement theory or claim chart from the plaintiff's perspective. It notes that the infringement notices received from the Defendant via Amazon were "cursory and contained no infringement analysis or patent claim chart" (Compl. ¶¶14, 17).

The narrative infringement theory, as can be inferred from the Defendant's assertions, is that Plaintiffs' jump starter products, identified by ASIN in the complaint's chart, practice the structural limitations of Claim 1 of the '079 Patent and Claim 1 of the '570 Patent (Compl. ¶¶11, 17). These assertions were submitted to Amazon, resulting in the removal of product listings and requiring Plaintiffs to participate in Amazon's APEX patent evaluation program (Compl. ¶¶14, 16).

• Identified Points of Contention:
  • Structural Questions: A primary point of contention will be factual: do the accused jump starters contain the specific internal architecture required by the claims? This includes the two-tiered structure of a "first accommodating space" for the power source/PCB and a separate "second accommodating space" within a "first mounting part" for the output terminal.
  • Scope Questions: The dispute may turn on the scope of "detachably connected." The analysis will question whether the connection mechanism between the output terminal and the mounting part in the accused products, if any, falls within the scope of this term as it is used in the patent.
  • Technical Questions (’570 Patent): For the ’570 Patent, a key question will be whether the accused products that have a display arrange it "on a side of the circuit board" as claimed. The specification describes an embodiment where the display is mounted at a "fourth through-hole" in the circuit board, which may raise the question of whether the claim requires more than simple adjacency (Compl. Ex. 2, '570 Patent, col. 14:18-24).

V. Key Claim Terms for Construction

’079 Patent & ’570 Patent

• The Term: "first mounting part"

• Context and Importance: This term is foundational to the claimed structural invention. The definition will be critical in determining whether a generic internal support structure within an accused product constitutes the claimed element. Practitioners may focus on this term because it appears to be the primary point of novelty over generic portable power supply housings.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims do not explicitly define the term, which may support an argument for its plain and ordinary meaning as any structure used for mounting.
  • Evidence for a Narrower Interpretation: The specification and figures consistently show the "first mounting part" (112) as an integral, molded feature of the shell that is itself configured to provide a distinct "second accommodating space" (1121) specifically for the output terminal (Compl. Ex. 1, '079 Patent, Fig. 1; col. 7:57-63). This suggests the term may require a structure that both mounts the output terminal and defines a separate cavity for it.

• The Term: "detachably connected"

• Context and Importance: This term defines the critical relationship between the output terminal (via its "first coupling part") and the "first mounting part" (via its "second coupling part"). Whether the accused products meet this limitation will be a central infringement question.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be construed broadly to cover any non-permanent method of attachment, such as by a screw, clip, or friction fit. The specification discloses an embodiment where the connection is made "by a screw" (Compl. Ex. 1, '079 Patent, col. 10:21-23).
  • Evidence for a Narrower Interpretation: The specification also describes a specific embodiment where the parts are "slidingly connected" via a "third protrusion" and a "receiving groove" (Compl. Ex. 1, '079 Patent, col. 9:56-62). An accused infringer may argue that the term should be interpreted in light of these more specific disclosed examples.

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

This declaratory judgment action will likely center on the resolution of three key questions for the court:

• A core issue will be one of structural correspondence: Do the internal mechanical structures of the Plaintiffs' accused jump starters—which are not detailed in the complaint—actually contain the specific, multi-part architecture recited in the asserted claims, particularly the nested "accommodating spaces" and dedicated "first mounting part"?
• The case will also depend heavily on definitional scope: How will the court construe key structural terms such as "first mounting part" and "detachably connected"? The outcome may turn on whether these terms are afforded a broad, plain-meaning interpretation or are narrowed by the specific sliding-groove and screw-based embodiments detailed in the shared patent specification.
• Finally, for the ’570 patent, a key evidentiary question will be one of component placement: Assuming an accused product meets the other limitations, does its display satisfy the requirement of being "arranged on a side of the circuit board," and can this limitation be met if the display is merely adjacent to the circuit board rather than integrated with it via a through-hole as suggested in the patent's detailed description?