Xinjiang Hanyuanhengfeng Xinxikeji Youxian Gongsi v. Syncoda LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Xinjiang Hanyuanhengfeng Xinxikeji Youxian Gongsi (People's Republic of China)
  • Defendant: Syncoda LLC (North Carolina)
  • Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 3:23-cv-02600, N.D. Tex., 11/22/2023
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Texas because Texas is its top market, and the delisting of its products from Amazon.com, which serves the district, has a substantial effect on the state.
• Core Dispute: Plaintiff seeks a declaratory judgment that its "Shoe Wash Bags" do not infringe Defendant’s patent related to an apparatus for washing irregularly shaped objects.
• Technical Context: The technology concerns devices designed to enable the automated washing of rigid, irregularly shaped items like shoes within a standard washing machine.
• Key Procedural History: The action was prompted by a notice Plaintiff received through the Amazon Patent Evaluation Express (APEX) Program, initiated by Defendant, alleging patent infringement and threatening to delist Plaintiff's products from the Amazon platform.

Case Timeline

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

U.S. Patent No. 10,086,410 - "Apparatus, method and system for washing objects with irregular shapes"

• Patent Identification: U.S. Patent No. 10,086,410, "Apparatus, method and system for washing objects with irregular shapes," issued October 2, 2018.

The Invention Explained

• Problem Addressed: The patent addresses the difficulty of automatically cleaning objects that have both irregular shapes and relatively rigid textures, such as shoes or medical utensils, which traditionally require manual washing with brushes ('410 Patent, col. 1:15-22).
• The Patented Solution: The invention is an apparatus, such as a container or flexible bag, that encloses an irregularly shaped object. This apparatus contains a plurality of brushes movably coupled to its inner wall. When the apparatus is placed in a washing machine, the flow of water, air, or gas drives the brushes to scrub the object automatically, while the container protects the object from damage and contains any washed-off residue ('410 Patent, Abstract; col. 3:1-15, 30-38).
• Technical Importance: The invention purports to allow for the automated machine washing of a category of items that previously could not be cleaned effectively or safely in conventional appliances ('410 Patent, col. 1:15-22).

Key Claims at a Glance

• The complaint identifies independent claims 1, 9, and 15 as being at issue (Compl. ¶19).
• Independent Claim 1 (Apparatus):
  • An outer portion configured to substantially enclose the object.
  • A plurality of brushes movably coupled to an inner wall of the outer portion.
  • The coupling is achieved with one or more couplers comprising at least one of a string, a rubber band, a spring, or a cord.
  • The apparatus is configured for placement in a washing machine where flow causes the brushes to scrub the object.
• Independent Claim 9 (System):
  • A washing machine or washing cabinet.
  • A washing apparatus configured to wash an object with an irregular shape, comprising an outer portion and a plurality of brushes movably coupled to an inner wall via one or more couplers (string, rubber band, spring, or cord).
• Independent Claim 15 (Method):
  • Disposing an irregular-shaped object inside a washing apparatus that comprises an outer portion and a plurality of brushes movably coupled to an inner wall via one or more couplers (string, rubber band, spring, or cord).
  • Driving the brushes to scrub the object with a flow of water, air, or gas.
• The complaint notes that since the independent claims are not infringed, their dependent claims are likewise not infringed (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

• The "Teletrogy" brand "Wash Bag" products, identified by Amazon Standard Identification Numbers (ASINs) B07JZQ4RLL, B0C4YKBLK5, and B09TKVVZW3 (Compl. ¶8).

Functionality and Market Context

• The complaint describes the accused Wash Bag as a "shoe enclosure" that features "3-centimeter microfibers" which are "attached directly into the inner wall lining" (Compl. ¶¶ 20-22).
• The Plaintiff sells these products on the Amazon Marketplace, which it identifies as its primary sales channel into the United States, with Texas being its largest single market (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiff's arguments for why its product does not meet the patent's claim limitations.

No probative visual evidence provided in complaint.

'410 Patent Infringement Allegations

• Identified Points of Contention:
  • Definitional Question (Brushes): The central dispute appears to be whether the accused product's "microfibers" constitute "brushes" as that term is used in the patent. Plaintiff's non-infringement argument relies on an extrinsic definition requiring a "handle," which may or may not be supported by the patent's intrinsic evidence.
  • Technical Question (Couplers): A key question is whether the "direct attachment" of the microfibers to the bag's lining falls outside the scope of the claimed "coupler" element. The analysis will depend on how broadly the term "coupler" is construed and whether direct attachment can be considered a form of coupling as envisioned by the patent.

V. Key Claim Terms for Construction

• The Term: "brush"

• Context and Importance: Plaintiff's entire non-infringement theory for this element hinges on a narrow definition of "brush" that requires a "handle" (Compl. ¶20). The case may turn on whether the accused product's "microfibers" meet the definition of "brushes" as used in the patent. Practitioners may focus on this term as its construction appears dispositive for the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes brushes as potentially being "made of common materials, for example including a plurality of plastic bristles" ('410 Patent, col. 3:42-43) and does not explicitly require a handle in its descriptions or figures. The patent also discloses an embodiment with "protrusions" made of rubber or plastic that are "directly formed on the inner wall" to perform a brushing function, which could suggest that a separate "brush" structure with a handle is not required ('410 Patent, col. 7:13-24).
  • Evidence for a Narrower Interpretation: The figures consistently depict brushes as distinct, gear-like or bristle-cluster structures (e.g., Fig. 1, "110a", "110b") that are attached to, rather than integral with, the outer portion. An argument could be made that the term "brush" implies a discrete component separate from the fabric of the bag itself.

• The Term: "coupler"

• Context and Importance: Plaintiff argues its product lacks a "coupler" because its microfibers are "attached directly" (Compl. ¶20). The presence or absence of this element is another core point of the non-infringement argument. The interpretation will determine whether a direct attachment method (e.g., sewing, weaving) can satisfy this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "coupler" itself implies a means of joining two things. A party could argue that sewing thread or the material used for direct attachment serves as the "coupler" joining the microfiber "brushes" to the inner wall, potentially falling under the "string" or "cord" examples.
  • Evidence for a Narrower Interpretation: The patent explicitly lists examples: "a short string, a rubber band, a spring, or a cord" ('410 Patent, col. 4:52-53). A party could argue that this list confines the meaning of "coupler" to discrete, flexible tethers that provide a "radial degree of freedom" ('410 Patent, col. 4:56-57). Critically, the specification also states that in some embodiments, "the brushes 110a can be directly fastened (for example, sewed) to the inner sidewall" ('410 Patent, col. 3:44-46). This creates a potential tension, as it describes direct fastening in an embodiment, while the independent claims explicitly require a "coupler." This may suggest that direct fastening is an alternative to, not an example of, the claimed "coupler."

VI. Other Allegations

The complaint is a declaratory judgment action and does not contain affirmative allegations of indirect or willful infringement.

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

This declaratory judgment action appears to center on fundamental questions of claim construction that will likely be dispositive.

• A core issue will be one of definitional scope: Can the term "brush," as defined by the patent's intrinsic evidence, be construed to read on the accused product's directly attached "microfibers," or does the term implicitly require a discrete structure separate from the bag lining, as the patent figures might suggest?
• A second key issue is one of claim element necessity: Does the independent claims' explicit recitation of a "coupler" (e.g., string, rubber band) mean that a product with cleaning elements "directly fastened" to the inner wall, a configuration also described in the patent's specification, necessarily falls outside the claims' scope? The court's resolution of the potential conflict between the claim language and the specification's disclosure will be critical.