Chen v. Ah Technology Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Peixia Chen (China)
  • Defendant: Ah Technology Ltd, Eternity Commerce, Dollarsign Ltd, YISUEN COMMERCE, and Pang Pang Trading (Hong Kong)
  • Plaintiff’s Counsel: YoungZeal LLP
• Case Identification: 4:25-cv-01168, E.D. Tex., 11/06/2025
• Venue Allegations: Venue is asserted on the basis that Defendants are foreign entities not residing in the United States and have sold the accused products to consumers within the judicial district via interactive Amazon storefronts.
• Core Dispute: Plaintiff alleges that Defendants’ magnetic building block toys infringe two patents related to the internal structure and magnetic assembly methods of such toys.
• Technical Context: The technology concerns magnetic construction toys, a significant segment of the educational toy market, focusing on internal magnet-retention mechanisms that allow for more versatile connection methods.
• Key Procedural History: The complaint notes that U.S. Patent No. 12,151,182 is a continuation-in-part of the application that issued as U.S. Patent No. 11,766,622, suggesting a shared specification and an evolving claims strategy.

Case Timeline

Date	Event
2022-12-28	Priority Date for ’622 and ’182 Patents (Chinese Application)
2023-09-26	’622 Patent Issued
2024-10-01	Alleged Start of Infringing Sales by Defendants (approx.)
2024-10-18	Alleged Date of Defendants’ Knowledge for Willfulness
2024-11-26	’182 Patent Issued
2025-11-06	Complaint Filing Date

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

U.S. Patent No. 11,766,622 - “MAGNETIC SUCTION BUILDING BLOCK” (Issued Sep. 26, 2023)

The Invention Explained

• Problem Addressed: The patent identifies a limitation in conventional magnetic building blocks, which typically have "single stacking angles" and can only connect along a single axis. This restricts creative building possibilities, such as creating "misplaced modeling," and can limit a child's interest. (’622 Patent, col. 1:19-28).
• The Patented Solution: The invention proposes a building block with magnets housed in compartments located at the "crossed corner" of the block's side walls. These magnets are "capable of rotating" within their compartments. This design allows the north and south poles of magnets in different blocks to self-align and attract, enabling stable connections at various angles beyond simple face-to-face stacking, thereby facilitating more complex, "misplaced" constructions. (’622 Patent, Abstract; col. 5:5-16).
• Technical Importance: This approach seeks to expand the constructional possibilities of magnetic tiles beyond planar or simple axial stacking, enabling more complex three-dimensional structures. (’622 Patent, col. 1:35-43).

Key Claims at a Glance

• Independent Claim Asserted: Claim 1
• Essential Elements of Claim 1:
  • A square building block main body with six side walls.
  • Four "internal wall groups" that define four "compartments" at the joints between the side walls.
  • An "installation bracket" comprising a central "connecting shaft" and four "stop columns."
  • The stop columns, along with the upper and lower side walls, define eight "compartment units."
  • Eight "magnet units" are disposed inside the eight compartment units.
  • Each magnet unit is "capable of rotating" and has a North and South pole.
• The complaint reserves the right to assert additional claims, including dependent claims. (Compl. ¶36).

U.S. Patent No. 12,151,182 - “MAGNETIC SUCTION BUILDING BLOCK” (Issued Nov. 26, 2024)

The Invention Explained

• Problem Addressed: As a continuation-in-part, the ’182 Patent addresses the same technical problem as its parent: the limited, single-axis connectivity of existing magnetic building blocks, which hinders the creation of "misplaced modeling." (’182 Patent, col. 1:21-36).
• The Patented Solution: The ’182 Patent refines the solution by describing a structure with "supporting poles" located within compartments at the block's corners. Each pole holds two magnet units, one at each end (one near the upper wall, one near the lower wall). This structure contains the rotatable magnets, allowing them to self-align for multi-angle connections at the block's corners. (’182 Patent, Abstract; Claim 1). Claim 7 further adds the functional requirement that these supporting poles can move vertically within the compartment. (’182 Patent, Claim 7).
• Technical Importance: The claimed structure offers a specific mechanical implementation for securing rotatable magnets at the corners of a building block to achieve versatile connectivity. (’182 Patent, col. 7:7-24).

Key Claims at a Glance

• Independent Claims Asserted: Claim 1 and Claim 7
• Essential Elements of Claim 1:
  • A square building block main body with six side walls.
  • Four "internal wall groups" defining four "compartments."
  • Four "supporting poles," one corresponding to each compartment.
  • Four groups of magnet units, where each group has two magnet units positioned at "opposite ends of a corresponding support pole."
  • Each magnet unit is "capable of rotating" and has a North and South pole.
• Essential Elements of Claim 7:
  • Incorporates the elements of Claim 1.
  • Adds the limitations that the supporting poles are "rod-shaped."
  • Adds the functional limitation that each supporting pole is "capable of moving upwards and downwards along the extending direction thereof."
• The complaint reserves the right to assert additional claims. (Compl. ¶48).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are various "magnetic building block toys" sold by the five Defendants through separate storefronts on Amazon.com. (Compl. ¶6, ¶¶22-26). The complaint lists dozens of specific Amazon Standard Identification Numbers (ASINs) corresponding to these products. (Compl. ¶¶22-26).

Functionality and Market Context

The complaint alleges that these products are "unauthorized imitations" that incorporate the "innovations pioneered and developed by CHEN." (Compl. ¶6, ¶11). The core accused functionality is the "distinctive internal configuration and magnetic assembly methods" that allegedly copy the structures claimed in the Asserted Patents, enabling versatile connections. (Compl. ¶9). The products are allegedly sold without trademarks or brand information and target U.S. consumers through e-commerce. (Compl. ¶12-13).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Ex. 6a-6e for the ’622 Patent and Ex. 7a-7e for the ’182 Patent) purporting to show how the Accused Products meet the limitations of the asserted claims. (Compl. ¶41, ¶53). The narrative theory is that Defendants make, use, sell, and import magnetic building blocks whose internal structures for retaining magnets read on the elements of the asserted claims. (Compl. ¶36, ¶48). No probative visual evidence provided in complaint.

Identified Points of Contention

• ’622 Patent (Claim 1):
  • Scope Question: A potential point of contention may be whether the internal structure of the accused products constitutes an "installation bracket" with the claimed "connecting shaft" and "four stop columns." The inquiry may focus on whether the accused products contain a single, integrated bracket structure or a different mechanism for holding the magnets.
  • Technical Question: The claim requires that the stop columns and side walls define eight distinct "compartment units" housing eight "magnet units." A key factual question will be whether the accused products have this specific eight-magnet, eight-compartment-unit configuration as defined by the claim language.
• ’182 Patent (Claims 1 & 7):
  • Scope Question: Infringement analysis will likely turn on the definition of a "supporting pole." The question may arise as to whether the internal magnet-holding features of the accused products are structurally equivalent to a "pole" that holds magnets at "opposite ends," or if they operate differently.
  • Technical Question (Claim 7): A central evidentiary question for Claim 7 will be whether the accused products' internal "supporting poles" are, in fact, "capable of moving upwards and downwards." This functional limitation suggests a degree of vertical travel or "play" that Plaintiff will need to demonstrate is present in the accused devices.

V. Key Claim Terms for Construction

• The Term: "installation bracket" (’622 Patent, Claim 1)

  • Context and Importance: This term defines the core internal structure of the claimed invention. Its construction will be critical, as a narrow definition limited to the exact embodiment shown in the patent could allow Defendants to design around it, while a broader definition could capture a wider range of magnet-retention mechanisms.
  • Intrinsic Evidence for a Broader Interpretation: The claim itself defines the bracket as comprising a "connecting shaft" and four "stop columns," suggesting that any structure with these components could qualify. (’622 Patent, col. 10:24-30).
  • Intrinsic Evidence for a Narrower Interpretation: The specification and figures describe a specific cross-shaped bracket with a central locating hole for assembly. A defendant may argue that the term should be limited to structures that include these features shown in the preferred embodiment. (’622 Patent, Fig. 2; col. 8:50-58).

• The Term: "supporting pole" (’182 Patent, Claims 1 & 7)

  • Context and Importance: This term replaces the "installation bracket" of the parent patent and is central to the infringement theory for the ’182 Patent. Whether the accused products' internal structures are "poles" will be a primary dispute. Practitioners may focus on this term because it is less structurally defined in the claim language than the "installation bracket."
  • Intrinsic Evidence for a Broader Interpretation: The term "pole" is not explicitly defined, which may support an interpretation covering any elongated member that serves the function of holding two magnets in alignment within a corner compartment.
  • Intrinsic Evidence for a Narrower Interpretation: The dependent claims specify the poles are "rod-shaped" and circular in cross-section, which could imply the independent claim's "pole" should be construed as a similarly slender, distinct structure, rather than, for example, an integrated part of the block's housing. (’182 Patent, Claims 2-3).

• The Term: "capable of moving upwards and downwards" (’182 Patent, Claim 7)

  • Context and Importance: This functional language is the key differentiator for Claim 7 and presents a significant proof requirement for the Plaintiff. The dispute will center on what degree and type of movement satisfies this limitation.
  • Intrinsic Evidence for a Broader Interpretation: The phrase does not specify the extent of movement required. Plaintiff may argue that any discernible vertical play or movement, even if slight, meets the limitation. The patent does not appear to describe the purpose or function of this movement, leaving its scope open to interpretation.
  • Intrinsic Evidence for a Narrower Interpretation: A defendant may argue that "capable of moving" implies more than incidental manufacturing tolerance or looseness, and requires a structure intentionally designed to permit vertical travel for a specific functional purpose, which is not described in the specification.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement, stating that Defendants knew of the patents (or were willfully blind) since at least October 18, 2024, because Plaintiff marked the patent numbers on its product manuals. (Compl. ¶42, ¶54). It is alleged that Defendants encourage manufacturers, shippers, and retailers to directly infringe by importing and selling the products. (Compl. ¶42, ¶54).
• Willful Infringement: The willfulness allegation is based on the same assertion of pre-suit knowledge from at least October 18, 2024, due to the alleged patent marking on Plaintiff's product manuals. (Compl. ¶44, ¶56).

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

1. A core issue will be one of structural correspondence: Do the internal magnet-holding mechanisms of the accused products embody the specific architecture of the ’622 Patent’s "installation bracket" with its "stop columns," and the ’182 Patent’s "supporting poles," or is there a fundamental structural difference that places them outside the scope of the claims?
2. A key evidentiary question will be one of functional proof: For Claim 7 of the ’182 Patent, what evidence can Plaintiff provide to demonstrate that the internal components of the accused toys are "capable of moving upwards and downwards," and can this alleged capability be distinguished from incidental looseness inherent in a mass-produced plastic toy?