DCT
2:25-cv-00633
Signode Industrial Group LLC v. Hangzhou Youngsun Intelligent Equipment Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Signode Industrial Group LLC (Delaware)
- Defendant: Hangzhou Youngsun Intelligent Equipment Co., Ltd. d/b/a Youngsun Pack (China)
- Plaintiff’s Counsel: K&L GATES LLP
- Case Identification: 2:25-cv-00633, E.D. Tex., 06/13/2025
- Venue Allegations: Plaintiff alleges that because Defendant is a foreign corporation not resident in the United States, venue is proper in any judicial district pursuant to 28 U.S.C. § 1391(c). The complaint also alleges Defendant transacts business in the district through third-party retailers with distribution facilities in Texas.
- Core Dispute: Plaintiff alleges that Defendant’s battery-powered industrial strapping tools infringe three utility patents and three design patents related to the mechanical operation, control systems, and ornamental appearance of such devices.
- Technical Context: The technology concerns handheld, battery-powered tools used in packaging and logistics to apply tension to plastic straps and weld them to secure goods for transit.
- Key Procedural History: The complaint states that Plaintiff sent a cease and desist letter to Defendant on March 28, 2025, providing notice of alleged infringement of U.S. Patent Nos. 11,731,794 and 10,518,914. Plaintiff alleges Defendant did not respond to the letter. This pre-suit notice may form a basis for allegations of willful infringement regarding those two patents.
Case Timeline
| Date | Event |
|---|---|
| 2008-04-23 | Priority Date for ’238, ’794, and ’914 Patents |
| 2019-10-29 | U.S. Design Patent No. D864,688 Issues |
| 2019-12-31 | U.S. Patent No. 10,518,914 Issues |
| 2020-02-11 | U.S. Design Patent No. D874,897 Issues |
| 2020-07-07 | U.S. Design Patent No. D889,229 Issues |
| 2023-08-22 | U.S. Patent No. 11,731,794 Issues |
| 2025-02-11 | U.S. Patent No. 12,221,238 Issues |
| 2025-03-28 | Plaintiff sends cease and desist letter to Defendant |
| 2025-06-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,221,238 - Strapping Device, issued February 11, 2025
- The Invention Explained:
- Problem Addressed: The patent’s background describes prior art mobile strapping tools as often being heavy, voluminous, and functionally unreliable due to the use of multiple motors and numerous components required for automation, leading to poor weight distribution and high maintenance costs (ʼ238 Patent, col. 2:22-32).
- The Patented Solution: The invention proposes a more compact and reliable strapping device that uses a single common drive, such as a brushless DC motor, coupled with a planetary gear system to perform multiple functions, including both tensioning the strap and actuating the friction welder that joins the strap ends. This integrated approach aims to reduce component count, improve weight distribution, and increase functional reliability (ʼ238 Patent, col. 3:4-14, 5:26-37).
- Technical Importance: This design allows for a more ergonomic, automated, and functionally robust handheld tool by simplifying the internal drive train architecture (ʼ238 Patent, col. 2:56-62).
- Key Claims at a Glance:
- The complaint asserts independent claim 1 (Compl. ¶48).
- Claim 1 requires, in relevant part:
- a tensioning wheel;
- a welding shoe movable from a rest position to a connecting position;
- a transitioning device configured to move the welding shoe;
- a rotatable component comprising a protrusion shaped to exert a force on the transitioning device to move the welding shoe;
- a motor configured to rotate the rotatable component; and
- a specific spatial relationship wherein part of the transitioning device extends between the welding shoe and the rotatable component.
U.S. Patent No. 11,731,794 - Strapping Device, issued August 22, 2023
- The Invention Explained:
- Problem Addressed: The patent identifies a need for increased functional reliability in moving the welding mechanism between its rest and active welding positions. Without a secure positioning mechanism, the welder could be accidentally moved or fail to apply consistent pressure during welding (ʼ794 Patent, col. 3:15-21).
- The Patented Solution: The invention describes using a toggle lever system to actuate the strap connector (welder). A toggle lever mechanism is characterized by having two stable "dead point" positions. A spring holds the lever in these end positions, requiring a user or motor to overcome a significant force to transition between them, which prevents accidental movement and ensures the welder is held firmly in place during operation (ʼ794 Patent, col. 3:15-34, 4:24-34). Figure 8 of the patent illustrates the toggle lever mechanism moving through its intermediate position (ʼ794 Patent, Fig. 8).
- Technical Importance: This use of a bistable mechanical linkage provides a robust and reliable method for actuating the welding mechanism, improving both safety and the consistency of the weld connection (ʼ794 Patent, col. 4:28-34).
- Key Claims at a Glance:
- The complaint asserts independent claim 1 (Compl. ¶75).
- Claim 1 requires, in relevant part:
- a tensioning wheel;
- a movable strap connector;
- a pivoting element;
- a toggle lever coupled to the pivoting element and the strap connector;
- a spring circumscribing at least part of the toggle lever; and
- a specific functionality where the pivoting element and toggle lever move between a first configuration (rest position) and a second configuration (connecting position), with the spring configured to exert forces on the pivoting element and toggle lever when in the second configuration.
Multi-Patent Capsule: U.S. Patent No. 10,518,914 - Strapping Device, issued December 31, 2019
- Technology Synopsis: This patent is directed to the control systems of a strapping device. It discloses a device with multiple operating modes, including a "first operating mode" (fully automatic) where a single operator input triggers a complete, automated sequence: the tool first tensions a strap to a predetermined level, and then, without further operator input, automatically operates the strap connector to weld the strap ends (’914 Patent, Abstract; col. 4:5-13).
- Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶89).
- Accused Features: The complaint alleges that the accused Eagle Q31 Strapping Tool’s "Fully automatic mode (AUT)" infringes by performing the claimed sequence of automatically tensioning to a set level and then welding in response to a single button press (Compl. ¶¶ 95-97).
Multi-Patent Capsule: U.S. Design Patent Nos. D864,688, D874,897, and D889,229
- Technology Synopsis: These three design patents claim the ornamental, non-functional designs for a strapping device, covering the overall visual appearance, shape, and configuration of the tool's housing. They are collectively referred to in the complaint as the "BXT3 Design Patents" (Compl. ¶¶ 16-22).
- Asserted Claims: The single claim of each respective design patent (Compl. ¶¶ 103, 113, 123).
- Accused Features: The complaint alleges that the overall ornamental design of the Benchmark 950, Benchmark 1200, and Baoshishan strapping tools is substantially the same as the claimed designs, such as to deceive an ordinary observer (Compl. ¶¶ 108, 118, 128). To support this, the complaint provides side-by-side visual comparisons of the accused products and figures from the design patents (Compl. ¶¶ 105-107, 115-117, 125-127).
III. The Accused Instrumentality
Product Identification
- The complaint identifies several models of battery-powered strapping tools, including the Baoshishan Strapping Tool, the U.S. Solid Banding Machines, the Hightop Q1 Strapping Tool, the Benchmark 950 and 1200 Strapping Tools, and the Eagle Q31 Strapping Tool (Compl. ¶¶ 31, 33, 39, 40).
Functionality and Market Context
- The accused products are handheld, battery-powered tools designed to tension and weld plastic straps around objects for packaging and shipping (Compl. ¶¶ 31-33). They incorporate a tensioning wheel to tighten the strap and a welding mechanism (referred to as a "welding shoe" or "strap connector") to fuse the strap ends together (Compl. ¶¶ 50-51, 78-79). Certain accused models, like the Eagle Q31, are alleged to feature multiple user-selectable operating modes, including manual, semi-automatic, and fully automatic modes (Compl. ¶96). The complaint provides an image from the Eagle Q31's manual detailing these different modes (Compl. ¶96). Plaintiff alleges its own tools embodying the patented technology command over half of the global market for high-end battery plastic strapping tools (Compl. ¶29). The complaint includes a visual comparison suggesting that the accused Benchmark 950 Strapping Tool is the same product as the VONPACK Q2L manufactured by Defendant (Compl. ¶37).
IV. Analysis of Infringement Allegations
’238 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a tensioning wheel | The Baoshishan Strapping Tool includes a tensioning wheel for tightening the strap. | ¶50 | col. 20:49-50 |
| a welding shoe movable from a rest position downward to a connecting position to connect overlapping upper and lower strap layers together | The accused tool includes a welding shoe that moves from a rest to a connecting position to join strap layers. An annotated image in the complaint depicts this component and its movement (Compl. ¶51). | ¶51 | col. 19:40-45 |
| a transitioning device configured to move the welding shoe from the rest position downward to the connecting position | The accused tool includes a transitioning device (cam follower, orange) that moves the welding shoe. An image highlights this component's position (Compl. ¶52). | ¶52 | col. 19:57-60 |
| a rotatable component configured to rotate relative to the transitioning device...the rotatable component comprising a protrusion positioned to contact the transitioning device, wherein the protrusion is shaped such that rotation...causes the protrusion to exert a force on the transitioning device to move the welding shoe | The accused tool includes a rotatable shaft (purple) and cam (blue) that contacts the transitioning device (orange) to move the welding shoe. The complaint provides a color-coded diagram of this mechanism (Compl. ¶53). | ¶53 | col. 19:61-20:1 |
| a motor configured to rotate the rotatable component about the rotational axis | The accused tool includes a motor that rotates the shaft via a pinion and sector gear. | ¶54 | col. 17:12-14 |
Identified Points of Contention
- Scope Questions: The analysis may focus on whether the accused tool's cam mechanism falls within the scope of the claim language "rotatable component comprising a protrusion." A central question for the court could be whether a standard mechanical cam, as depicted in the complaint's color-coded image (Compl. ¶53), constitutes a "protrusion" as that term is used and described in the patent.
- Technical Questions: What evidence demonstrates that the accused cam is "shaped such that rotation" causes the specific force application recited in the claim? The infringement analysis will depend on how the geometry of the accused cam interacts with the cam follower ("transitioning device") throughout its rotation.
’794 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a tensioning wheel | The Eagle Q31 Strapping Tool includes a tensioning wheel, identified as part number Q-0010 in a parts diagram. | ¶78 | col. 21:50-52 |
| a strap connector operable to connect two areas of a strap to one another, the strap connector movable from a rest position downward to a connecting position | The accused tool's upper weld pad (Q-2022) acts as a strap connector that moves between a rest and connecting position to weld the strap. | ¶79 | col. 17:1-6 |
| a pivoting element | The accused tool's mechanism includes a component identified as a "pivoting element" (purple). | ¶80 | col. 20:5-7 |
| a toggle lever coupled to the pivoting element and to the strap connector | The tool includes a "toggle lever" (orange) coupled to the pivoting element and strap connector. A color-coded diagram shows this linkage (Compl. ¶80). | ¶80 | col. 20:8-12 |
| a spring circumscribing at least part of the toggle lever | The tool includes a spring (green) that surrounds a portion of the toggle lever. | ¶80 | col. 20:10-12 |
| wherein the pivoting element and the toggle lever are movable between a first configuration and a second configuration | The pivoting element and toggle lever are alleged to move between two different configurations corresponding to the strap connector's rest and connecting positions. | ¶81 | col. 20:13-16 |
| wherein the spring is configured to, when...in the second configuration, exert a first force on the pivoting element and a second force on the toggle lever | The spring (green) is alleged to exert forces to maintain pressure on the strap during welding when the mechanism is in the second configuration. | ¶83 | col. 20:10-12 |
Identified Points of Contention
- Scope Questions: The dispute may turn on the definition of "toggle lever." This term implies a specific mechanical function involving an over-center locking action to create stable positions. The question will be whether the accused linkage (Compl. ¶80) operates as a true toggle lever as understood in the art and described in the patent, which emphasizes overcoming "dead point positions" for reliability ('794 Patent, col. 3:18-21).
- Technical Questions: Does the spring in the accused device "circumscribe" the toggle lever as required by the claim? The visual evidence in the complaint (Compl. ¶80) suggests it does, but the precise physical arrangement will be subject to examination.
V. Key Claim Terms for Construction
For the ’238 Patent
- The Term: "protrusion"
- Context and Importance: The infringement theory for the '238 patent depends on the cam of the accused device being construed as a "protrusion." The scope of this term is central, as Defendant may argue that a cam is a distinct mechanical element, not merely a "protrusion."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not appear to provide a special definition for "protrusion," which may support giving the term its plain and ordinary meaning, which could be broad enough to encompass a cam lobe. The patent describes the function broadly as exerting a force through contact and rotation (ʼ238 Patent, col. 19:61-20:1).
- Evidence for a Narrower Interpretation: The figures in the patent, such as the cam 32 on cam wheel 33, depict a specific shape (ʼ238 Patent, Fig. 7). A defendant could argue that the term "protrusion" should be limited to the specific ramp-like shape shown in the patent's embodiments, rather than any feature that projects from a surface.
For the ’794 Patent
- The Term: "toggle lever"
- Context and Importance: This term is the core of the asserted claim of the '794 patent. Whether the accused linkage infringes will depend on whether it meets the technical definition of a "toggle lever," which typically involves a bistable, over-center locking mechanism.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not explicitly recite "over-center" or "dead point" functionality, which could support an argument that any lever system that toggles between two positions is sufficient.
- Evidence for a Narrower Interpretation: The specification explicitly describes the advantages of the invention in terms of overcoming "two dead point positions" to hold the device in its end positions, which "contributes to further increasing the functional reliability." (ʼ794 Patent, col. 3:18-31). This strong statement of purpose may support construing "toggle lever" to require this specific over-center, bistable functionality.
VI. Other Allegations
- Indirect Infringement: The complaint focuses on allegations of direct infringement under 35 U.S.C. § 271(a) and does not plead separate counts for indirect infringement.
- Willful Infringement: Willfulness is alleged for all asserted patents. For the ’794 and ’914 patents, the allegation is based on alleged pre-suit knowledge from a cease and desist letter sent on March 28, 2025 (Compl. ¶¶ 86, 100). For the ’238, D’688, D’897, and D’229 patents, the allegation is based on knowledge acquired no later than the filing and service of the complaint (Compl. ¶¶ 72, 110, 120, 130).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural scope: do the mechanical actuators in the accused products—specifically the cam-and-follower mechanism accused of infringing the ’238 patent and the spring-loaded linkage accused of infringing the ’794 patent—fall within the construction of the claim terms "protrusion" and "toggle lever" as interpreted from the patents' specifications and drawings?
- A key question for the ’914 patent will be one of operational equivalence: does the accused products' "fully automatic mode" function in the specific manner claimed, particularly by initiating the welding step "without additional operator input" only "after the predetermined tension is reached," or are there material differences in its control logic?
- For the design patents, the central question for the fact-finder will be one of visual identity: is the overall ornamental appearance of the accused strapping tools "substantially the same" as the patented designs from the perspective of an ordinary observer, or are the visual differences sufficient to distinguish them?