DCT

4:25-cv-01172

Chen v. Yi Suen Commerce

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01172, E.D. Tex., 10/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper because 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 "Goodyking" brand of magnetic building block toys infringes two U.S. patents related to the internal structure and magnetic assembly methods of such toys.
  • Technical Context: The technology at issue resides in the popular and competitive market for three-dimensional magnetic construction toys, focusing on internal mechanisms that enable more versatile connections between blocks.
  • Key Procedural History: The complaint alleges 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. It further alleges that Defendant had knowledge of the asserted patents prior to the suit, based on Plaintiff's marking of the patent numbers on its own product manuals.

Case Timeline

Date Event
2022-05 Plaintiff begins new internal structure design
2022-08 Plaintiff completes prototype design and validation
2022-10 Plaintiff initiates mold production
2022-12-28 U.S. Patent No. 11,766,622 Priority Date
2023-01-18 U.S. Patent No. 12,151,182 Priority Date
2023-09-26 U.S. Patent No. 11,766,622 Issued
2024-10 Alleged commencement of infringement by Defendant
2024-10-18 Alleged date of Defendant's knowledge of the Asserted Patents
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"

  • Patent Identification: U.S. Patent No. 11,766,622, titled "MAGNETIC SUCTION BUILDING BLOCK," issued September 26, 2023 (’622 Patent). (Compl. ¶20).

The Invention Explained

  • Problem Addressed: The patent's background section identifies a limitation in existing magnetic building blocks, noting they often have "single stacking angles" and can only be stacked along the same axis, which restricts creative building possibilities and can diminish a child's interest. (’622 Patent, col. 1:19-29).
  • The Patented Solution: The invention is a magnetic building block containing magnets housed in compartments located at the "crossed corner" where adjacent side walls of the block meet. (’622 Patent, col. 1:47-52). These magnets are configured to rotate within their compartments, which is intended to allow the blocks to connect at various angles beyond simple face-to-face stacking, thereby enabling what the patent calls "misplaced modeling." (’622 Patent, Abstract; Fig. 2).
  • Technical Importance: This design sought to expand the versatility and play value of magnetic construction toys by enabling more complex, non-axial connections between individual blocks. (’622 Patent, col. 1:39-44).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 4. (Compl. ¶29).
  • Independent Claim 1 recites, in summary:
    • A square building block main body formed by six side walls.
    • Four "internal wall groups" that define four "compartments."
    • An "installation bracket" comprising a connecting shaft, four "stop columns," and four connection portions.
    • The stop columns and side walls define eight "compartment units."
    • Eight "magnet units" are disposed within the eight compartment units, respectively.
    • Each magnet unit is capable of rotating and is provided with a North and South pole. (’622 Patent, col. 10:1-44).

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

  • Patent Identification: U.S. Patent No. 12,151,182, titled "MAGNETIC SUCTION BUILDING BLOCK," issued November 26, 2024 (’182 Patent). (Compl. ¶21).

The Invention Explained

  • Problem Addressed: The patent addresses the same problem as its parent '622 Patent: the "single stacking angles" of conventional magnetic blocks limit the implementation of "misplaced modeling," thereby influencing a child's interest. (’182 Patent, col. 1:21-36).
  • The Patented Solution: The ’182 Patent discloses a building block with magnets in "first compartments" at the corners. A "stop column assembly" is disposed within the block's internal "mounting slot group." This assembly includes multiple "stop columns" that are used to stop the magnets, securing them within their respective compartments while allowing them to rotate. This structure is designed to facilitate magnetic attraction at the corners of the blocks. (’182 Patent, Abstract).
  • Technical Importance: The invention provides a specific mechanical configuration for securing rotatable magnets at the corners of building blocks, aimed at producing stable, multi-angle connections for more complex constructions. (’182 Patent, col. 7:7-24).

Key Claims at a Glance

  • The complaint asserts independent Claim 1 and dependent Claim 7. (Compl. ¶41).
  • Independent Claim 1 recites, in summary:
    • A square building block main body formed by 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 located at "two opposite ends of a corresponding support pole" and received in a corresponding compartment.
    • Each magnet unit is capable of rotating and has a North and South pole.
    • The internal wall groups extend from the lower side wall to the upper side wall. (’182 Patent, col. 17:23-62).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "magnetic building block" toys sold under the "Goodyking" brand through an interactive Amazon storefront. (Compl. ¶¶ 6, 15). A list of specific Amazon Standard Identification Numbers (ASINs) is provided. (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges the accused products are "unauthorized imitations" of Plaintiff's patented products and involve "blatant copying of the patented structures." (Compl. ¶¶ 8, 9). The complaint asserts these products are sold and shipped to consumers throughout the United States, including within the Eastern District of Texas. (Compl. ¶¶ 7, 10). The complaint does not provide specific technical details about the internal construction of the accused products, instead referencing external exhibits not attached to the filed complaint. (Compl. ¶¶ 29, 41).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the ’622 and ’182 patents but references claim chart exhibits that were not included with the publicly filed document. (Compl. ¶¶ 29, 41). In the absence of these exhibits, the infringement allegations must be analyzed based on the narrative assertions in the complaint.

The complaint’s infringement theory posits that the accused Goodyking magnetic building blocks incorporate the internal structures claimed in the asserted patents. (Compl. ¶¶ 8, 23, 35). For both the ’622 and ’182 patents, the core of the infringement allegation is that the accused products contain a system of rotatable magnets housed within compartments at the corners of the blocks, which is the central concept disclosed in the patents-in-suit. (Compl. ¶8).

  • Identified Points of Contention:
    • Factual Question: The primary issue for the court will be a factual one: do the accused Goodyking products, upon inspection and analysis, actually contain the internal structures recited in the asserted independent claims? The resolution of this question will likely require discovery and expert testimony regarding the internal construction of the accused products.
    • Scope Questions: The dispute may also center on claim scope. For the ’622 Patent, a key question could be whether the internal magnet-holding structure of the accused product meets the specific limitations of an "installation bracket" that comprises a "connecting shaft" and four "stop columns." For the ’182 Patent, a similar question arises as to whether the accused products contain "supporting poles" that each have two distinct "magnet units" at "opposite ends," as required by Claim 1.

V. Key Claim Terms for Construction

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

  • Context and Importance: This term describes the central component that secures the rotatable magnets. Whether the accused products infringe will depend heavily on whether their internal magnet-holding structure is found to be an "installation bracket" as claimed.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the bracket functionally as an element placed within a cavity to "stop the magnet in the compartment." (’622 Patent, col. 2:50-62). A party advocating for broader scope might argue that any internal structure performing this specific stopping function qualifies.
    • Evidence for a Narrower Interpretation: The patent figures consistently depict the "installation bracket" (7) as a single, multi-armed component with a distinct central "connecting shaft" (71) from which "stop columns" extend. (’622 Patent, Fig. 2). A party arguing for a narrower scope may contend that the term should be limited to structures with this specific disclosed configuration.

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

  • Context and Importance: Claim 1 requires four "supporting poles," each associated with two magnet units. The presence and configuration of any such "poles" in the accused products will be a critical infringement issue. Practitioners may focus on this term because its definition will determine whether a single, multi-functional internal component can be considered a collection of distinct "poles."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The abstract and summary of the ’182 Patent use the term "stop column assembly," which includes a "plurality of stop columns." (’182 Patent, col. 2:29-35). A party might argue that "supporting pole" should be construed as functionally equivalent to these "stop columns," encompassing any rod-like structure that supports magnets at its ends.
    • Evidence for a Narrower Interpretation: Dependent claims specify that a "supporting pole" can be "rod-shaped" (Claim 2) or "circular in cross-section" (Claim 3). (’182 Patent, col. 18:61-64). A party could argue that these further limitations imply that the term "supporting pole" in the independent claim must be a distinct, elongated structural element, not merely a feature of a more complex, integrated component.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced infringement (§ 271(b)) and contributory infringement (§ 271(c)) for both patents. (Compl. ¶¶ 26-27, 38-39). The factual basis alleged for inducement is that Defendant "intentionally causes, urges, or encourages manufacturers, shippers, distributors, and retailers to directly infringe... by importing into the United States." (Compl. ¶¶ 30, 42).
  • Willful Infringement: Willfulness is alleged for both patents based on pre-suit knowledge. The complaint asserts Defendant "had knowledge of, or was willfully blind to," the patents "since at least October 18, 2024, as CHEN marked the patent number on the product’s manual." (Compl. ¶¶ 30, 42).

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

This dispute will likely center on three key questions for the court:

  1. A core issue will be one of factual correspondence: Can the plaintiff demonstrate, through technical evidence obtained during discovery, that the internal mechanisms of the accused Goodyking products embody the specific, multi-component structural arrangements required by the independent claims of the ’622 and ’182 patents?
  2. The case may also turn on a question of definitional scope: How will the court construe key structural terms such as "installation bracket" (’622 Patent) and "supporting poles" (’182 Patent)? The interpretation of these terms will directly impact whether the physical components inside the accused products fall within the legal boundaries of the patent claims.
  3. A final key question will be one of culpability: Does the evidence support the plaintiff’s allegation that the defendant had pre-suit knowledge of the patents via product marking, a finding that would be necessary to sustain the claim for willful infringement and potential enhanced damages?