DCT

4:25-cv-01170

Chen v. Eternity Commerce

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01170, E.D. Tex., 10/24/2025
  • Venue Allegations: Venue is alleged to be proper on the basis that the defendant is a foreign entity not residing in the United States and may therefore 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 structures that house and orient magnets within the blocks.
  • Technical Context: The dispute is in the field of magnetic construction toys, a market segment where innovation often centers on improving the strength, stability, and versatility of connections between blocks.
  • Key Procedural History: U.S. Patent No. 12,151,182 is a continuation-in-part of the application that resulted in U.S. Patent No. 11,766,622. The complaint alleges that Defendant had pre-suit knowledge of the patents, based on patent marking on the plaintiff's product manual, which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2021-09-01 Plaintiff begins selling magnetic block products under 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 Priority date for U.S. Patent No. 11,766,622 (based on Chinese application filing)
2023-01-18 Priority date for U.S. Patent No. 12,151,182 (based on U.S. application filing)
2023-08-14 U.S. application leading to '182 Patent filed
2023-09-26 U.S. Patent No. 11,766,622 issued
2024-10-01 Alleged start of Defendant's infringing activity
2024-10-18 Date from which Plaintiff alleges Defendant had knowledge of patents via marking
2024-11-26 U.S. Patent No. 12,151,182 issued
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's background section describes prior art magnetic building blocks as having "single stacking angles," which typically limits connections to being on the same axis. This simplicity restricts the complexity of models that can be built and may limit a child's interest. (’622 Patent, col. 1:19-26).
  • The Patented Solution: The invention is a magnetic block with an internal structure that places magnets inside compartments located at the "crossed corner" of adjacent side walls. (’622 Patent, Abstract). These magnets are "capable of rotating in the compartment," which allows their north and south poles to orient automatically to attract magnets in other blocks, regardless of the angle of approach. (’622 Patent, col. 1:51-53). This enables "misplaced modeling" where blocks can connect at various angles beyond a simple grid. (’622 Patent, col. 1:29-34). Figure 2 provides an exploded view showing the building block main body (1), the internal installation bracket (7), and the magnets (5) that are housed within compartments at the corners. (’622 Patent, Fig. 2).
  • Technical Importance: This design approach aims to greatly enrich the "building mode and playing method" of magnetic toys compared to conventional on-axis stacking systems. (’622 Patent, col. 6:62-64).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 4. (Compl. ¶31).
  • The essential elements of independent Claim 1 include:
    • A square building block main body with six side walls.
    • Four "internal wall groups" that form joints between adjacent side walls.
    • Four "compartments" defined by the internal wall groups and the side walls.
    • An "installation bracket" comprising a "connecting shaft," four "stop columns," and four "connection portions."
    • Eight "compartment units" defined by the sides of the stop columns and the upper and lower side walls.
    • Eight "magnet units" disposed inside the eight compartment units, where each magnet is "capable of rotating" and has a north and south pole. (’622 Patent, col. 10:2-44).

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

The Invention Explained

  • Problem Addressed: As with its parent patent, the ’182 Patent addresses the limitation of conventional magnetic blocks that can only be stacked "on a same axis," which restricts creative play. (’182 Patent, col. 1:23-29).
  • The Patented Solution: This continuation-in-part patent claims a similar concept of placing rotatable magnets in corner compartments but describes the internal structure differently. The claims recite "supporting poles" located within each compartment. A group of magnet units is received in each compartment, with "two magnet units at two opposite ends of a corresponding support pole." (’182 Patent, Claim 1). This pole structure serves to hold the magnets in place while still allowing them to rotate and attract other blocks from multiple angles.
  • Technical Importance: The invention seeks to enable "misplaced connection among the magnetic suction building blocks" to enhance the design and building possibilities for users. (’182 Patent, col. 7:20-24).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 7. (Compl. ¶43).
  • The essential elements of independent Claim 1 include:
    • A square building block main body with six side walls.
    • Four "internal wall groups" creating joints.
    • Four "compartments" defined by these internal walls.
    • Four "supporting poles" corresponding to and located within the four compartments.
    • Four "groups of magnet units," with each group comprising "two magnet units at two opposite ends of a corresponding support pole."
    • Each magnet unit is "capable of rotating" and has a north and south pole.
    • Each internal wall group extends from the lower side wall to the upper side wall. (’182 Patent, col. 18:22-62).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "magnetic building block toys" sold under various Amazon Standard Identification Numbers (ASINs) on an Amazon storefront operated by Defendant under the name "Cheffun Direct." (Compl. ¶6, ¶16).

Functionality and Market Context

  • The complaint alleges that the accused products are "unauthorized imitations" that incorporate the "distinctive internal configuration and magnetic assembly methods claimed in the Asserted Patents." (Compl. ¶8, ¶10). The products are allegedly marketed and sold to consumers throughout the United States, including in the Eastern District of Texas, via an interactive e-commerce storefront. (Compl. ¶7, ¶15).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories. (Compl. ¶31, ¶43). The infringement allegations are therefore based on the narrative descriptions in the complaint.

The complaint alleges that the Defendant's products directly infringe the asserted patents by incorporating the patented internal structures. (Compl. ¶8). For the ’622 Patent, this suggests an allegation that the accused products contain a main body with internal walls creating corner compartments, which house an "installation bracket" with "stop columns" that retain rotatable magnets. (Compl. ¶8, ¶31). For the ’182 Patent, the complaint's theory suggests the accused products contain a similar main body with corner compartments, but with internal "supporting poles" that hold rotatable magnets at their opposite ends. (Compl. ¶8, ¶43).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A primary question may be whether the internal magnet-retaining structures in the accused products meet the specific structural limitations of the claims. For the ’622 Patent, this raises the question of whether the accused structure constitutes an "installation bracket" with a "connecting shaft" and "stop columns." For the ’182 Patent, the dispute may center on whether the internal components can be properly characterized as "supporting poles" holding magnets at "two opposite ends."
    • Technical Questions: The complaint does not provide technical details or evidence, such as product teardowns, to demonstrate how the accused products are constructed. A key factual question will be what evidence demonstrates that the internal components of the accused products are arranged to define "eight compartment units" (as required by Claim 1 of the ’622 Patent) or that they utilize "supporting poles" in the manner claimed by the ’182 Patent.

V. Key Claim Terms for Construction

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

  • Context and Importance: This term recites a key structural element that comprises a "connecting shaft," "stop columns," and "connection portions." The infringement analysis for the ’622 Patent will likely depend on whether the internal magnet-retaining structure of the accused product is encompassed by the definition of this composite element.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the function of the bracket as being to "stop[] the magnet 5 in the compartment 4." (’622 Patent, col. 8:49-51). This functional language could be used to argue for a construction that covers any internal structure performing that stopping function.
    • Evidence for a Narrower Interpretation: Figure 2 depicts a specific embodiment of the "installation bracket" (7) as a single, spider-like component with a central hub and radiating arms. (’622 Patent, Fig. 2). A party could argue the term should be limited to this disclosed structure or a close equivalent, particularly as it is the primary embodiment shown.

  • The Term: "supporting poles" (’182 Patent, Claim 1)

  • Context and Importance: This term defines the central element that positions the magnets within the compartments. Infringement of the ’182 Patent will depend on whether the internal structure of the accused product can be fairly characterized as "supporting poles."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Claim 1 itself does not define the shape or composition of the "poles," only their supporting function and location. This lack of specificity in the independent claim may support a broader construction covering various forms of pillars or posts.
    • Evidence for a Narrower Interpretation: Dependent Claim 2 of the ’182 Patent further specifies that "each supporting pole is rod-shaped." (’182 Patent, col. 18:63-64). Under the doctrine of claim differentiation, this might suggest that the term "supporting poles" in Claim 1 is broader than just "rod-shaped" structures. However, a defendant might argue that the specification's overall context limits the term to distinct, pillar-like structures.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement of infringement against manufacturers, shippers, distributors, and retailers. (Compl. ¶32, ¶44). The basis for the required knowledge and intent is an allegation that Defendant knew of or was 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).
  • Willful Infringement: The complaint alleges that Defendant's infringement has been and continues to be willful and deliberate. (Compl. ¶34, ¶46). This allegation is predicated on the same alleged pre-suit knowledge from Plaintiff's patent marking activities. (Compl. ¶32, ¶44).

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

This dispute will likely focus on the specific internal mechanics of the accused magnetic blocks and the defendant's state of mind. The central questions for the court appear to be:

  • A core issue will be one of structural identity: do the internal magnet-retaining mechanisms of the accused toys correspond to the specific configurations claimed in the patents—namely, the unitary "installation bracket" of the ’622 Patent and the "supporting poles" of the ’182 Patent—or do they represent a structurally distinct, non-infringing design?
  • A key evidentiary question will be one of scienter: can the plaintiff substantiate its allegation that the defendant had pre-suit knowledge of the patents, based on patent marking on a product manual sold in the marketplace, to a degree sufficient to support claims for both willful and induced infringement?