Shenzhen Funsnap Technology Co Ltd v. Guilin Zhishen Information Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Funsnap Technology Co. Ltd., et al. (China, Hong Kong)
  • Defendant: Guilin Zhishen Information Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 3:23-cv-02134, N.D. Tex., 09/25/2023
• Venue Allegations: Plaintiffs allege venue is proper in the Northern District of Texas because it is a significant market for their products, and Defendant's enforcement actions will cause them harm there. They also allege venue is proper based on Defendant's and its subsidiaries' sales into the district.
• Core Dispute: Plaintiffs seek a declaratory judgment that their "Gimbal Products" do not infringe Defendant's patent related to the construction of plastic motors for handheld stabilizers.
• Technical Context: The technology concerns the use of plastic components in the motors of handheld camera stabilizers, aiming to reduce manufacturing cost, complexity, and weight compared to traditional metal motors.
• Key Procedural History: The action was precipitated by an Amazon Patent Evaluation Express (APEX) Program notice sent to the Plaintiffs alleging infringement. The complaint notes that a Chinese counterpart to the patent-in-suit, CN106849453B, has been found invalid, a finding that is not binding on U.S. courts but may inform case strategy.

Case Timeline

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

U.S. Patent No. 11,218,047 - "Plastic Motor For Handheld Stabilizer," Issued January 4, 2022

The Invention Explained

• Problem Addressed: The patent identifies several drawbacks with conventional metal motors used in handheld stabilizers, including "long production cycle, high procurement price, large weight, poor appearance designability and difficulty in threading" ('047 Patent, col. 1:28-32). These issues make stabilizers expensive and hinder their popularization ('047 Patent, col. 1:32-34).
• The Patented Solution: The invention proposes a "plastic motor" where at least one key structural component—the iron core carrier, motor shell, or motor end cover—is made of plastic material ('047 Patent, Abstract). This construction, which includes a hollow metal motor shaft passing through bearings fixed on the iron core carrier, is intended to simplify manufacturing, reduce cost, and allow for easier wiring, thereby solving the problems of prior art metal motors ('047 Patent, col. 2:51-57; col. 3:26-34).
• Technical Importance: The use of plastic, specifically polyaryl amides, aims to achieve high strength and stability comparable to metal but with the benefits of lower cost, lighter weight, and improved production efficiency for consumer-grade camera equipment ('047 Patent, col. 7:20-32).

Key Claims at a Glance

• The complaint identifies independent claim 1 as the focus of the dispute (Compl. ¶1, 27). The patent contains one independent claim.
• Essential elements of independent claim 1 include:
  • A motor shell
  • A hollow metal motor shaft, with one end fixedly connected to the motor shell
  • A motor end cover
  • Motor iron cores
  • An iron core carrier, where "one end of the iron core carrier is detachably connected to the motor end cover" and the other end carries the motor iron cores
  • At least one of the iron core carrier, motor shell, or motor end cover is made of plastic
  • An upper and lower bearing fixed on the iron core carrier, through which the hollow metal motor shaft passes
  • A stopping component connected to the motor shell is provided on an outer side of the hollow metal motor shaft
• The complaint notes that if independent claim 1 is not infringed, then dependent claims 2-19 cannot be infringed (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "Gimbal Products" sold on Amazon by the various Plaintiffs under storefronts such as "FUNSNAP Official," "iSleeky," and "AOCHUANGimbal" (Compl. ¶13-17). The complaint identifies the products by their Amazon Standard Identification Numbers (ASINs) (Compl. ¶13-17).

Functionality and Market Context

The complaint does not provide a technical description of how the accused Gimbal Products are constructed or operate. Instead, it focuses on their commercial context, noting they are sold on the Amazon marketplace, which constitutes the Plaintiffs' "primary sales channel into the United States" and a "largest channel of trade" (Compl. ¶18-19). The complaint highlights the products' positive customer ratings (Compl. ¶13-15, 17).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint seeks a declaratory judgment of non-infringement. The central non-infringement argument is summarized in the table below.

'047 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The primary dispute articulated in the complaint centers on the claim term "detachably connected." The case may turn on whether the specific connection mechanism between the iron core carrier and motor end cover in the Plaintiffs' products falls within the legal construction of this term.
  • Technical Questions: A central evidentiary question will be establishing the actual physical construction of the accused Gimbal Products. The complaint asserts a legal conclusion of non-infringement for one limitation but does not provide factual details or diagrams showing how its products are assembled, creating an information gap that will be a focus of discovery.

V. Key Claim Terms for Construction

• The Term: "detachably connected"
• Context and Importance: This term is the only one for which the Plaintiffs provide a specific non-infringement argument (Compl. ¶28). The outcome of the non-infringement analysis, as framed by the complaint, hinges on the definition of this term and its application to the accused products. Practitioners may focus on this term because it appears to be the sole basis for the declaratory judgment action.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification discloses multiple ways to achieve a connection, stating the iron core carrier can be connected to the motor end cover "by the nuts 11" or, in other embodiments, "by a snap-fit structure or a binder" ('047 Patent, col. 7:56-59). This could support a construction that encompasses any non-permanent joining method that allows for separation.
  • Evidence for a Narrower Interpretation: The primary embodiment described in detail shows the iron core carrier connected to the motor end cover via nuts passing through holes and fastening into corresponding threaded holes ('047 Patent, col. 5:46-52). A party could argue that "detachably" implies a connection designed for service or disassembly without destruction, potentially excluding methods like certain snap-fits or binders that may be difficult to separate non-destructively.

VI. Other Allegations

• Indirect Infringement: Plaintiffs seek a declaration that they do not infringe "either directly or indirectly" (Compl. ¶30). However, the complaint pleads no specific facts regarding inducement or contributory infringement theories.
• Willful Infringement: As a declaratory judgment action filed by the accused infringers, the complaint does not allege willfulness. Instead, it characterizes Defendant's infringement assertions through the APEX program as "objectively baseless" and a "misuse" of the patent (Compl. ¶1, 20). This forms the basis for Plaintiffs' request for a finding that the case is exceptional and an award of attorneys' fees (Compl., Prayer for Relief ¶H).

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

1. A central issue will be one of claim construction: What is the scope of the term "detachably connected" as used in Claim 1 of the ’047 patent? Does it require a specific mechanism, such as threaded fasteners, or does it more broadly cover any form of non-permanent attachment?
2. The case will also present a key evidentiary question: What is the precise physical construction of the connection between the iron core carrier and motor end cover in the Plaintiffs' accused gimbal products? The resolution of the infringement dispute will depend on comparing this factual evidence against the court's construction of the claim term.
3. A final question concerns the basis of the dispute: Is the disagreement a good-faith dispute over claim scope, or, as Plaintiffs allege, are the Defendant's infringement accusations "baseless"? The answer will determine whether the case could be deemed "exceptional," potentially shifting the burden of attorney's fees.