Shenzhen Xiangdangwen Technology Co Ltd v. Shenzhen Zhenwei Xin Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Xiangdangwen Technology Co., Ltd. (People's Republic of China)
  • Defendant: Shenzhen Zhenwei Xin Technology Co., Ltd. (People's Republic of China)
  • Plaintiff’s Counsel: YoungZeal LLP
• Case Identification: 4:25-cv-01205, E.D. Tex., 11/04/2025
• 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 seeks a declaratory judgment that its Lisen A608 vacuum magnetic phone holder does not infringe, and that the asserted patent is invalid, following infringement allegations from the Defendant.
• Technical Context: The dispute concerns the mechanical design of suction-cup-based mounting brackets, commonly used for securing mobile phones and other electronic devices in vehicles or on desks.
• Key Procedural History: This action was initiated by the accused infringer in response to a communication from the patent owner alleging infringement and threatening litigation. The complaint also asserts that the patent is invalid in light of several prior art Chinese patents and commercially available products sold on Amazon prior to the patent's priority date.

Case Timeline

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

U.S. Patent No. 12,388,922 - “Bracket”

• Patent Identification: U.S. Patent No. 12,388,922, titled “Bracket,” issued August 12, 2025 (the “’922 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section notes that existing suction cup brackets can suffer from accidental release if a protruding piece on the suction cup is inadvertently touched, causing the suction to fail (’922 Patent, col. 1:36-42).
• The Patented Solution: The invention discloses a bracket base where a user interacts with a component, such as a swing rod, that is mechanically linked to a rotating member. This rotational movement is translated into vertical (axial) movement of a connecting rod attached to the suction cup. Rotating the member in one direction lifts the center of the suction cup to create a vacuum cavity for adhesion, and rotating it in the opposite direction lowers the suction cup to release the vacuum (’922 Patent, col. 6:7-22; Fig. 2). This mechanism is contained within a housing, aiming to improve suction stability and prevent accidental release.
• Technical Importance: This design aims to provide a more robust and reliable method for engaging and disengaging a suction cup compared to simpler lever or tab mechanisms, potentially reducing accidental detachment of the mounted electronic device.

Key Claims at a Glance

• The complaint asserts non-infringement and invalidity of claims 1-18 of the ’922 Patent (Compl. ¶¶23, 32). Claim 1 is the sole independent claim from which claims 2-18 depend (Compl. ¶12).
• Essential elements of Independent Claim 1 include:
  • A base comprising a base body, a suction cup, and a connecting rod.
  • The connecting rod is movable axially to drive the suction cup up (to form a vacuum) or down (to release the vacuum).
  • A rotating member, rotatable relative to the base body.
  • The base body is covered with a first cover body.
  • A swing groove is horizontally defined in the first cover body.
  • A swing rod connected to the rotating member passes through the swing groove and extends out of the first cover body.
  • The rotation angle of the rotating member is limited by the end groove walls of the swing groove.
• The complaint reserves the right to assert additional grounds of invalidity (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

• The Lisen A608 vacuum magnetic phone holder (“Xiangdangwen Accused Product”) (Compl. ¶1).

Functionality and Market Context

• The complaint describes the Accused Product as an electronic peripheral marketed under the “Lisen” brand on platforms like Amazon.com (Compl. ¶¶1, 3).
• The complaint provides a side-by-side visual comparison between a figure from the ’922 Patent labeled "First Cover Body" and a photograph of the Xiangdangwen Accused Product, which is central to its non-infringement argument (Compl. p. 8).
• The complaint alleges that Plaintiff Xiangdangwen is the developer and designer of the Accused Product, which was independently designed and developed (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement, arguing that the Accused Product lacks key elements recited in claim 1 of the ’922 Patent. The core of this argument is that the Accused Product does not have a "first cover body" with a "swing groove" as claimed (Compl. ¶24).

’922 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The primary dispute appears to center on whether the external housing of the Accused Product constitutes a "first cover body" as that term is used in the patent. The complaint’s visual evidence suggests the Accused Product has a unitary housing, raising the question of whether a "cover body" must be a structurally distinct component from the "base body" it is claimed to cover.
• Technical Questions: A related question is whether the opening in the Accused Product's housing, through which its operating mechanism extends, meets the definition of a "swing groove horizontally defined in the first cover body." The analysis will depend on whether the opening is merely an aperture or if it functions as a "groove" that limits rotation in the manner described by the claim.

V. Key Claim Terms for Construction

• The Term: "first cover body"
• Context and Importance: This term is the lynchpin of the Plaintiff's non-infringement argument (Compl. ¶24). How the court defines "first cover body" — whether it can be an integral part of the base or must be a separate component that "covers" the base body — may be dispositive of the infringement question. Practitioners may focus on this term because the Plaintiff has staked its non-infringement position on the absence of this specific structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states, "The base body is covered with a first cover body" (’922 Patent, col. 13:28-29). A party might argue this language does not explicitly require two separate, distinct pieces and could describe a single, integrated housing where one portion can be conceptually understood as "covering" another.
  • Evidence for a Narrower Interpretation: The specification also states, "A first cover body 500 is provided on the base body 100... A cavity is formed between the first cover body 500 and the base body 100" (’922 Patent, col. 5:65-col. 6:2). This language, along with figures like Fig. 2 which depict the base body (100) and first cover body (500) as separate components in an exploded view, may support an interpretation that the "first cover body" must be a distinct element from the "base body."

VI. Other Allegations

The complaint is for declaratory judgment and therefore does not allege infringement. It only responds to Defendant's alleged accusations.

• Indirect Infringement: Not applicable, as the complaint does not allege infringement.
• Willful Infringement: Not applicable, as the complaint does not allege infringement.

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

This declaratory judgment action appears to present two central questions for the court:

1. A core issue will be one of claim construction: does the term “first cover body,” as used in the context of the ’922 Patent’s specification and figures, require a component structurally separate from the “base body,” or can it read on an integrated housing like that seemingly present in the accused product?
2. A second key issue will be one of invalidity: do the asserted prior art references—including Chinese patents and products previously sold on Amazon—disclose each element of the asserted claims, thereby rendering the ’922 Patent invalid as anticipated or obvious? The outcome of this question will determine whether the patent is enforceable at all, irrespective of infringement.