Dongguan Meishida E Commerce Co Ltd v. Kelley

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Meishida E-commerce Co., Ltd. d/b/a JEEVONY (China)
  • Defendant: Kevin Patrick Kelley (North Carolina)
  • Plaintiff’s Counsel: Aronberg Goldgehn
• Case Identification: 2:25-cv-00106, W.D.N.C., 05/22/2025
• Venue Allegations: Venue is alleged to be proper in the Western District of North Carolina because the Defendant, an individual, resides in the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its magnetic dryer vent connectors do not infringe Defendant’s patent and/or that the patent is invalid, following Defendant's infringement assertions in an Amazon enforcement proceeding.
• Technical Context: The technology concerns magnetic couplings for clothes dryer vent hoses, a consumer product accessory designed to simplify installation and improve safety.
• Key Procedural History: The complaint was filed after the Defendant initiated an Amazon Patent Evaluation (“APEX”) proceeding alleging infringement. The complaint also details the prosecution history of the patent-in-suit, noting that the patent owner filed a terminal disclaimer to overcome a double patenting rejection. This disclaimer ties the scope of the asserted patent to that of earlier family members, which may become a central issue for claim construction.

Case Timeline

Date	Event
2010-07-27	Earliest Priority Date ('855 Patent, from App. No. 12/804,691)
2017-11-29	Filing Date of parent application 15/825,998
2020-04-24	Filing Date of parent application 16/858,023
2022-04-20	Filing Date of application for '855 Patent (App. No. 17/725,073)
2023-04-25	Issue Date of U.S. Patent No. 11,634,855
2025-03-27	Plaintiff receives notice of Defendant's Amazon APEX complaint
2025-05-22	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,634,855 - "Magnetically positioned and engaged dryer vent attachment and method"

• Patent Identification: U.S. Patent No. 11,634,855, “Magnetically positioned and engaged dryer vent attachment and method,” issued April 25, 2023.

The Invention Explained

• Problem Addressed: The patent background describes the difficulty of connecting dryer vent hoses in the confined space behind a clothes dryer. This often leads to kinked or compressed hoses, which restricts airflow, reduces dryer efficiency, and creates a fire hazard from lint buildup (ʼ855 Patent, col. 1:16-34).
• The Patented Solution: The invention is a two-part coupling that uses magnets to create a self-aligning and self-engaging connection between the dryer’s exhaust port and the wall vent duct. One part attaches to the dryer hose and the other to the wall. As the dryer is pushed into place, the magnets attract and pull the two halves together, forming a secure seal without requiring the user to manually reach behind the appliance (ʼ855 Patent, col. 2:15-28; Abstract). This process is intended to be confirmed by an "audible snapping sound" indicating a proper connection ('855 Patent, col. 4:41-45).
• Technical Importance: The technology aims to provide installers and homeowners with a "fast and effective means to complete the dryer exhaust circuit, particularly useful in confined installations," thereby increasing both safety and ease of installation ('855 Patent, col. 2:44-48).

Key Claims at a Glance

• The complaint identifies independent claims 1 and 10 as being at issue (Compl. ¶34).
• Independent Claim 1 recites the core elements of the coupling device:
  • A flexible exhaust duct connecting the dryer port and a wall port.
  • A first mounting substrate at one end of the duct, comprising a first magnet.
  • A second mounting substrate for the wall port, comprising a second magnet with an opposite polarity to the first.
  • The first and second mounting substrates comprising "respective complementary surfaces configured to nest together between said inner and outer perimeters."
  • A "whereby" clause stating that upon close proximity, the magnets attract to "self-align and self-assemble," creating an "audible snapping sound."
• The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaratory judgment on "every claim" of the patent (Compl., Prayer for Relief ¶1).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the "Magnetic Dryer Vent Coupling DV180 Airtight Seal Dryer Vent Connector Kit" sold by Plaintiff under the brand name "Jeevony" on Amazon.com (ASIN BODRRYM7GL) (Compl. ¶¶20-21).

Functionality and Market Context

• The accused product is a kit for connecting a dryer vent hose using a two-part magnetic connector (Compl. ¶21). The product is advertised as having a "self-align mechanism" for "quick connecting/disconnecting of dryer vent hose" (Compl. ¶21). The complaint includes a screenshot from the Amazon product listing, which shows the two primary components of the connector separated. A key feature highlighted by the Plaintiff for its non-infringement argument is that the mating surfaces of its product are flat (Compl. ¶47). The complaint alleges the product is "popular on Amazon" and that Amazon is its "primary sales channel" (Compl. ¶¶22-23).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiff's central non-infringement arguments as presented in the complaint.

• ’855 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Plaintiff's Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
...said first and second mounting substrates comprising respective complementary surfaces configured to nest together between said inner and outer perimeters...	Plaintiff alleges its product "clearly and obviously includes two flat surfaces (A, B) that do not nest together."	¶47	col. 7:19-22
...whereby when moved into close proximity, said first and second magnets magnetically attract to one another to self-align and self-assemble said first and second mounting substrates...	Plaintiff contrasts its flat-surfaced product with the patent’s description of an alternative embodiment with "nesting cones," arguing its product does not perform the claimed nesting.	¶41, ¶45	col. 6:50-52

• Identified Points of Contention:
  • Scope Questions: The central dispute presented in the complaint concerns the definition of "nest together." The complaint argues that this term requires a specific geometry where one component fits inside another, such as the "nesting cones" disclosed as an alternative embodiment in the patent's Figure 6 (Compl. ¶41; '855 Patent, col. 6:50-52). A key question for the court will be whether the term is limited to this specific geometry or if it can be construed more broadly to cover the magnetic alignment of two flat surfaces, as allegedly featured in the accused product. The complaint provides a visual from the patent's Figure 6 showing "nesting cones" to support its narrower interpretation (Compl. ¶41). It also provides a photo of its own product, labeling the flat mating surfaces 'A' and 'B' to argue they do not nest (Compl. ¶47).
  • Technical Questions: The case may turn on the factual and technical distinctions between the patent's disclosed embodiments and the accused product. A primary question will be whether the self-alignment of the Plaintiff's product via magnets on flat surfaces is technically and legally distinct from the claimed "nesting" configuration. The complaint alleges that the patent's own prosecution history, where the applicant allegedly distinguished prior art with "flat surface" plates, supports this distinction (Compl. ¶76).

V. Key Claim Terms for Construction

• The Term: "complementary surfaces configured to nest together"
• Context and Importance: The construction of this term appears to be the dispositive issue for infringement as framed by the complaint. Plaintiff’s entire non-infringement argument rests on the assertion that its product’s flat mating surfaces do not "nest together" as required by the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Narrower Interpretation: The complaint points to specific language in the specification that may support a narrower construction. The patent explicitly describes an "alternate coupling geometry" for the embodiment of Figure 6 "where the two halves...are nesting cones" ('855 Patent, col. 6:50-52; Compl. ¶44). Plaintiff argues this is the patent's own definition of nesting and contrasts it with the "flat surfaces" of the embodiment in Figure 2, which it claims "do not nest" (Compl. ¶45, ¶46).
  • Evidence for a Broader Interpretation: A party seeking a broader interpretation might argue that the term does not require a specific conical shape. The claim language requires the surfaces to nest "at any orientation upon magnetic attraction" to achieve substantial alignment of the inner openings ('855 Patent, col. 7:23-28). It could be argued that any configuration where the magnetic force causes the two parts to self-center and form a sealed, aligned opening meets the functional requirements of "nesting," regardless of whether the mating surfaces are flat, curved, or conical.

VI. Other Allegations

• Willful Infringement: This is a declaratory judgment action, but the Plaintiff makes allegations that correspond to an exceptional case finding under 35 U.S.C. § 285. The complaint alleges that the Defendant’s infringement accusations in the Amazon APEX proceeding are "baseless," "frivolous and egregious," and lack "any legitimate basis in law or fact" (Compl. ¶¶53, 59-60). Plaintiff further alleges that the Defendant's counsel, having prosecuted the patent, should have been "clear and obvious" that the Plaintiff's product did not infringe the "nest together" limitation, suggesting the enforcement action was not taken in good faith (Compl. ¶52).

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

1. Definitional Scope: The primary issue will be the construction of the claim term "nest together." Can this term, which the patent specification explicitly associates with a "nesting cones" embodiment, be interpreted broadly enough to read on the allegedly flat mating surfaces of the accused product, or is its meaning limited by the patent's disclosure and prosecution history?
2. Prosecution History Impact: The complaint alleges that the applicant filed terminal disclaimers and distinguished prior art with "flat surfaces" during prosecution (Compl. ¶¶ 76, 83). A critical question will be whether these actions created a prosecution history estoppel or disclaimer that prevents the patent owner from now asserting a claim scope that covers flat-surfaced products like the one sold by the Plaintiff.
3. Exceptional Case: Should the court find non-infringement based on the "nest together" limitation, a secondary question will be whether the Defendant's pre-suit assertion of infringement through the Amazon APEX platform was so baseless as to render the case "exceptional," potentially entitling the Plaintiff to attorneys' fees.