DCT

4:25-cv-01168

Chen v. Ah Technology Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01168, E.D. Tex., 10/24/2025
  • Venue Allegations: Venue is asserted on the basis that the defendant is a foreign entity not residing in the United States, and therefore may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s magnetic building block toys, sold online, infringe two patents related to the internal structure and magnetic assembly methods of such toys.
  • Technical Context: The technology concerns innovations in magnetic construction toys, specifically internal mechanisms designed to allow for more versatile, multi-angle connections between blocks beyond simple face-to-face stacking.
  • Key Procedural History: The complaint notes that U.S. Patent No. 12,151,182 is a continuation-in-part of the application that matured into U.S. Patent No. 11,766,622, indicating a close technical and legal relationship between the asserted patents.

Case Timeline

Date Event
2021-09-01 Plaintiff begins selling magnetic block products under the Toylogy brand
2022-05-01 Plaintiff begins developing new internal structure design
2022-08-01 Plaintiff completes prototype design and validation
2022-10-01 Plaintiff initiates mold production for new design
2022-12-28 Earliest Priority Date for ’622 and ’182 Patents (Chinese Application)
2023-01-18 U.S. patent application filed for what would become the ’622 Patent
2023-08-14 U.S. patent application filed for what would become the ’182 Patent
2023-09-26 U.S. Patent No. 11,766,622 issues
2024-10-01 Defendant allegedly begins infringing activities
2024-10-18 Alleged date of Defendant's knowledge of patents via product marking
2024-11-26 U.S. Patent No. 12,151,182 issues
2025-10-24 Complaint filed

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

U.S. Patent No. 11,766,622 - MAGNETIC SUCTION BUILDING BLOCK

The Invention Explained

  • Problem Addressed: The patent describes a limitation in the market for magnetic building blocks where toys possess "single stacking angles," typically allowing connection only along a single axis (e.g., face-to-face) ('622 Patent, col. 1:19-24). This simplicity is said to limit more complex "misplaced modeling" and can diminish a child's interest ('622 Patent, col. 1:24-28).
  • The Patented Solution: The invention is a magnetic block with magnets housed in compartments located at the "crossed corner" joints between adjacent side walls ('622 Patent, Abstract). This corner-based magnetic system allows blocks to connect at various angles, not just along a single axis. The design includes an internal "installation bracket" that holds rotating magnets, ensuring they can orient themselves for proper N-S pole attraction, which enables a stable connection for "misplaced" or off-axis building configurations ('622 Patent, col. 5:5-16; Fig. 2).
  • Technical Importance: This approach enriches the building modes and play methods available with magnetic blocks, moving beyond simple axial stacking to facilitate more creative and complex constructions ('622 Patent, col. 1:40-44).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 4 (Compl. ¶31).
  • Claim 1 includes the following essential elements:
    • A square building block main body with six side walls.
    • Four internal wall groups creating four compartments at the joints of the side walls.
    • An "installation bracket" comprising a connecting shaft, four stop columns corresponding to the four compartments, and four connection portions.
    • The installation bracket and side walls define eight "compartment units."
    • Eight "magnet units" are disposed inside the eight compartment units, respectively.
    • Each magnet unit is capable of rotating and is provided with a N pole and a S pole.

U.S. Patent No. 12,151,182 - MAGNETIC SUCTION BUILDING BLOCK

The Invention Explained

  • Problem Addressed: The '182 Patent addresses the same problem as its parent '622 Patent: the restrictive, single-axis nature of connections in conventional magnetic building toys, which limits creative play ('182 Patent, col. 1:20-36).
  • The Patented Solution: As a continuation-in-part, the '182 Patent refines the concept of corner-based magnetic connections. The claims describe an internal structure comprising "supporting poles" located within compartments at the block's corners. Each supporting pole holds two magnet units, one at each end, which are capable of rotating. This configuration provides a specific mechanical means to achieve the multi-angle connectivity envisioned in the parent patent ('182 Patent, col. 17:46-57).
  • Technical Importance: This patented solution offers a specific internal architecture for magnetic blocks that aims to provide stable, reliable connections at multiple angles, thereby expanding construction possibilities ('182 Patent, col. 1:30-36).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 7 (Compl. ¶43).
  • Claim 1 includes the following essential elements:
    • A square building block main body with six side walls.
    • Four internal wall groups defining four compartments.
    • Four "supporting poles" corresponding to the four compartments.
    • Four groups of magnet units, with each group comprising two magnet units received at opposite ends of a corresponding supporting pole.
    • Each magnet unit is capable of rotating and has a N pole and a S pole.
    • The internal wall groups extend from the lower to the upper side wall, and each supporting pole with its magnets is received in a compartment.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "magnetic building block products" sold by Defendant AH TECHNOLOGY LIMITED on Amazon.com under multiple product listings identified by their Amazon Standard Identification Numbers (ASINs) (Compl. ¶¶ 6, 16).

Functionality and Market Context

The complaint alleges the accused products are "unauthorized imitations" that incorporate the patented inventions and copy the "distinctive internal configuration and magnetic assembly methods claimed in the Asserted Patents" (Compl. ¶¶ 8, 10). The complaint does not provide a technical description of how the accused products operate, instead referencing claim charts in exhibits that were not included with the filing (Compl. ¶¶ 31, 43). The products are allegedly sold through an interactive Amazon storefront that targets and ships to consumers throughout the United States, including within the Eastern District of Texas (Compl. ¶¶ 7, 11, 15).

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant's products infringe, either literally or under the doctrine of equivalents, at least Claim 1 and Claim 4 of the ’622 Patent and Claim 1 and Claim 7 of the ’182 Patent (Compl. ¶¶ 31, 43). The complaint states that infringement is detailed in claim charts provided as Exhibits 6 and 7; however, these exhibits were not available for analysis (Compl. ¶¶ 31, 43). The narrative infringement theory is based on the allegation that the accused products are "blatant copying of the patented structures" and embody the "distinctive internal configuration and magnetic assembly methods" claimed in the patents (Compl. ¶8). Without the claim charts or a more detailed technical description of the accused products' internal structures, a direct comparison of claim elements to product features cannot be conducted from the complaint alone.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Questions: A primary point of contention will be establishing the actual internal mechanics of the accused products. The litigation will likely depend on evidence from product teardowns or other discovery to determine if the products contain the specific internal components required by the claims, such as the "installation bracket" of the ’622 Patent or the "supporting pole" assembly of the ’182 Patent.
    • Scope Questions: The dispute may turn on whether the internal structures of the accused products, once revealed, fall within the scope of the patent claims. For example, a question for the court could be whether an internal structure that holds magnets in the corners but is not arranged as a single, integrated "installation bracket" infringes Claim 1 of the ’622 Patent.

V. Key Claim Terms for Construction

  • ’622 Patent:

    • The Term: "installation bracket" (from Claim 1)
    • Context and Importance: This term is a central limitation defining the complex internal structure that positions the magnets and stop columns. The outcome of the infringement analysis for the ’622 Patent will heavily depend on the scope assigned to this term, as it distinguishes the claimed invention from a simple arrangement of magnets in corner pockets.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term is not explicitly defined in the specification, which may support an argument that it should be given its plain and ordinary meaning, potentially covering any internal structure that performs the claimed functions of connecting to a shaft and holding the stop columns.
      • Evidence for a Narrower Interpretation: The specification consistently depicts the "installation bracket" (7) as a specific, single, spider-like component with a central hub and radiating arms ('622 Patent, Fig. 2; col. 8:50-53). A party could argue that the term should be limited to this disclosed embodiment or structures substantially similar to it.

  • ’182 Patent:

    • The Term: "supporting pole" (from Claim 1)
    • Context and Importance: This term defines the element upon which pairs of magnets are mounted within each corner compartment. Proving infringement of the ’182 Patent requires showing the presence of this specific component. Its construction will be critical to determining whether the accused products' internal magnet-holding mechanisms meet this limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue that any internal axle, pin, or rod-like structure that holds two magnets at its ends within a compartment meets the definition of a "supporting pole."
      • Evidence for a Narrower Interpretation: Dependent claim 2 of the patent specifies that "each supporting pole is rod-shaped" ('182 Patent, col. 18:6-8). This language from a dependent claim could be used to argue for a narrower construction of the independent claim, limiting "supporting pole" to structures that are distinctly rod-like in form.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that the Defendant actively and knowingly encourages "manufacturers, shippers, distributors, and retailers to directly infringe" by importing and selling the products in the United States (Compl. ¶¶ 32, 44).
  • Willful Infringement: Willfulness is alleged based on Defendant having knowledge of, or being willfully blind to, the Asserted Patents "since at least October 18, 2024, as CHEN marked the patent number on the product's manual" (Compl. ¶¶ 32, 44). This allegation of pre-suit knowledge through patent marking on the patentee's own product forms the basis for seeking enhanced damages (Compl. ¶¶ 34, 46).

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

This case appears to center on specific, complex internal product structures that are not visible externally. The key questions for the court will therefore likely be:

  • A core evidentiary question of internal structure: What are the precise mechanical components and arrangements inside the accused magnetic blocks? The case will likely turn on factual evidence, such as product teardowns, to establish whether the accused products contain the specific "installation bracket" of the ’622 Patent or the "supporting pole" assembly of the ’182 Patent.
  • A central legal question of claim scope: How broadly will key structural terms like "installation bracket" and "supporting pole" be construed? The resolution of the case will depend on whether these terms are interpreted to cover a range of functional equivalents or are limited more narrowly to the specific physical embodiments disclosed in the patent specifications and drawings.