DCT

4:25-cv-01205

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

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01205, E.D. Tex., 11/04/2025
  • Venue Allegations: Plaintiff alleges venue is proper because the Defendant is a foreign entity not residing in the United States and may therefore be sued in any judicial district.
  • Core Dispute: In this Declaratory Judgment action, Plaintiff seeks a judicial declaration that its "Lisen A608" phone holder product does not infringe Defendant's patent related to suction-cup mounting brackets, and/or that the patent is invalid.
  • Technical Context: The dispute concerns the mechanical design of suction-cup-based mounting brackets, a widely used accessory for securing mobile phones and other electronic devices in vehicles and other settings.
  • Key Procedural History: The action was precipitated by a September 2025 email communication from Defendant Zhenwei Xin to Plaintiff Xiangdangwen, which alleged infringement of the patent-in-suit and threatened legal action. The complaint also identifies several Chinese patents and publicly available products as prior art alleged to invalidate the patent's claims.

Case Timeline

Date Event
2020 Earliest alleged public availability of invalidating prior art products on Amazon.
2024-09-01 Earliest Priority Date for U.S. Patent No. 12,388,922.
2025-08-12 U.S. Patent No. 12,388,922 Issues.
2025-09-27 Defendant allegedly sends email to Plaintiff accusing it of infringement.
2025-11-04 Complaint for Declaratory Judgment filed.

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 some existing suction cup brackets can be accidentally released if a protruding piece on the suction cup, designed for removal, is inadvertently touched during use, causing the suction to fail (US 12,388,922 B1, col. 1:33-41).
  • The Patented Solution: The invention proposes a mechanical bracket where rotational motion is converted into linear motion to control the suction cup. A user manipulates a "swing rod" that rotates an internal "rotating member" (’922 Patent, col. 6:60-65). This rotation causes a pin on a connecting rod to move along a "climbing track," which lifts the connecting rod and the center of the attached suction cup to create a strong vacuum seal (’922 Patent, col. 6:15-22). Reversing the rotation lowers the rod, releasing the vacuum. This design internalizes the release mechanism, aiming to prevent the accidental release noted in the prior art.
  • Technical Importance: The claimed solution seeks to provide a more reliable and robust suction mechanism for device mounts by replacing a simple pull-tab release with a more deliberate, mechanically-driven actuation system.

Key Claims at a Glance

  • The complaint asserts non-infringement and invalidity of claims 1-18, focusing its non-infringement argument on independent claim 1 (Compl. ¶22, Compl. ¶24, Compl. ¶32).
  • Essential Elements of Independent Claim 1:
    • A base comprising a base body, a suction cup, and a connecting rod.
    • The connecting rod is axially movable between a first (raised) position to create a vacuum and a second (lowered) position to release the vacuum.
    • The base body has a rotatable "rotating member."
    • The base body is covered with a "first cover body."
    • A "swing groove" is horizontally defined in the first cover body.
    • The rotating member is connected to a "swing rod," which passes through the swing groove and extends out of the first cover body.
    • The rotation of the rotating member is limited by the end walls of the swing groove.
  • The complaint notes that claims 2-18 are dependent on claim 1 (Compl. ¶12).

III. The Accused Instrumentality

Product Identification

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

Functionality and Market Context

  • The Accused Product is a mobile phone peripheral designed to mount a phone to a surface using a vacuum suction cup mechanism (Compl. ¶1, Compl. ¶3). The complaint alleges that Plaintiff Xiangdangwen is the developer and designer of the Accused Product and other "Lisen" branded peripherals sold on platforms like Amazon.com (Compl. ¶3, Compl. ¶15-Compl. ¶16). The specific operating mechanism of the Accused Product is not detailed, but the complaint's core non-infringement theory is that the product lacks specific structural elements recited in claim 1 of the ’922 Patent (Compl. ¶24).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement, centering on the argument that the Accused Product lacks, at a minimum, the "first cover body" and "swing groove" limitations of claim 1 (Compl. ¶24). The complaint includes a visual comparison to support this position, showing a patent figure next to a photograph of the Accused Product (Compl. p. 8).

’922 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A bracket, comprising: a base, wherein the base comprises: a base body; a suction cup provided at a bottom portion of the base body; and a connecting rod provided on the base body and connected to the suction cup; The complaint implicitly acknowledges the Accused Product is a bracket with a base, suction cup, and connecting rod. ¶1, 22, 24 col. 13:5-12
wherein the connecting rod is movable between a first position and a second position along its axial direction... to rise to form a vacuum... or... to descend to release vacuum... The complaint does not contest that the Accused Product utilizes an axially movable rod to actuate the suction cup. ¶22, 29 col. 13:13-23
wherein the base body is provided with a rotating member, the rotating member is rotatable relative to the base body; The complaint does not contest that the Accused Product utilizes a rotatable member to drive its mechanism. ¶22, 29 col. 13:24-26
the base body is covered with a first cover body; and a swing groove is horizontally defined in the first cover body; the swing groove is parallel to a bottom surface of the suction cup; Plaintiff alleges the Accused Product does not have a "first cover body" or a "swing groove" as claimed. The complaint's visual evidence contrasts the patent's distinct dome-like cover with the Accused Product's integrated body. ¶24 col. 13:27-31
the rotating member is connected with a swing rod; an end portion of the swing rod passes through the swing groove and extends out of the first cover body; As Plaintiff alleges no "first cover body" or "swing groove," it follows that the Accused Product is alleged to lack a swing rod that passes through such a structure. ¶24 col. 13:32-34
wherein a rotation angle of the rotating member is limited by two end groove walls of the swing groove. As Plaintiff alleges no "swing groove," it follows that the Accused Product is alleged to lack limitation by the walls of such a groove. ¶24 col. 13:35-37

Identified Points of Contention

  • Scope Questions: The central dispute appears to be whether the housing of the Accused Product constitutes a "first cover body" as that term is used in the patent. This raises the question of whether the claim requires a distinct, separate component serving as the cover, or if an integrated housing can satisfy the limitation.
  • Technical Questions: Does the mechanism of the Accused Product operate via a "swing rod" that passes "through" a "swing groove" located in a cover or housing? The complaint suggests a fundamental structural difference, raising the question of what evidence will show about how the Accused Product's components interact to actuate the suction mechanism (Compl. ¶24; Compl. p. 8).

V. Key Claim Terms for Construction

  • The Term: "first cover body"
  • Context and Importance: This term is the explicit basis for the Plaintiff's non-infringement argument (Compl. ¶24). The outcome of the infringement analysis may depend entirely on how this term is construed by the court. Practitioners may focus on this term because the complaint's sole exemplary non-infringement argument rests upon it.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent holder (Defendant) may argue the term should be read broadly to encompass any external housing that covers the internal mechanism. The specification states, "A first cover body 500 is provided on the base body 100" and that a "cavity is formed between the first cover body 500 and the base body 100," language that could describe a general housing (’922 Patent, col. 5:65-col. 6:1).
    • Evidence for a Narrower Interpretation: The accused infringer (Plaintiff) may argue that the claim language itself imposes structural limits. Claim 1 requires that the "swing groove is horizontally defined in the first cover body" and that the "swing rod passes through the swing groove and extends out of the first cover body” (’922 Patent, col. 13:28-34). This language, combined with the embodiment shown in Figure 1, suggests the "first cover body" must be a structure with a defined aperture for the actuating rod to pass through, potentially limiting the term to a configuration similar to the one depicted in the patent's figures.

VI. Other Allegations

  • Invalidity: The complaint includes a second count for a declaratory judgment of invalidity of the ’922 Patent under 35 U.S.C. §§ 102 and/or 103 (Compl. ¶¶26-32). It alleges that claims 1-18 are anticipated or rendered obvious by three specified Chinese patents as well as commercially available products sold on Amazon prior to the patent's priority date (Compl. ¶¶29-30). This indicates that validity will be a significant parallel issue to infringement.

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

This declaratory judgment action appears poised to center on two fundamental and distinct questions for the court:

  1. A core issue will be one of claim construction and structural equivalence: How narrowly will the court define the "first cover body" and its required "swing groove"? The case may turn on whether the accused product's integrated housing is structurally and functionally equivalent to the patent's claimed multi-component design where an actuator must pass through a groove in a distinct cover.
  2. A parallel dispositive question will be one of patent validity: Does the combination of cited Chinese patents and prior commercial products disclose every element of the asserted claims, as the complaint alleges? This raises a significant evidentiary challenge for the patent holder to defend the novelty and non-obviousness of its invention against a field of allegedly similar prior art.