DCT
1:25-cv-00880
Changtingxiantinghaoshengshangmaoyouxiangongsi v. Jiang
Key Events
Complaint
I. Executive Summary and Procedural Information
Parties & Counsel:
- Plaintiff: Changtingxiantinghaoshengshangmaoyouxiangongsi d/b/a Eany-KK & minhoufuoush angm aoyou xiangongsi d/b/a Rai-Mee (China)
- Defendant: Zhongyi Jiang (China)
- Plaintiff’s Counsel: Aronberg Goldgehn Davis & Garmisa
Case Identification: 1:25-cv-00880, E.D. Va., 05/21/2025
Venue Allegations: Plaintiffs assert that venue is proper under 35 U.S.C. § 293 because Defendant is a foreign national, owns the U.S. patent-in-suit, and has not designated a U.S. agent for service of process.
Core Dispute: Plaintiffs seek a declaratory judgment that their headwear organizer products do not infringe Defendant’s patent for a baseball cap rack, and that the patent is invalid.
Technical Context: The lawsuit concerns the mechanical design of consumer products for organizing and storing baseball caps.
Key Procedural History: The action was precipitated by Defendant filing one or more complaints with Amazon, alleging that Plaintiffs' products infringe the patent-in-suit. Plaintiffs seek a finding that this case is "exceptional," which could entitle them to attorneys' fees, based on allegations that Defendant's infringement assertions were baseless.
Case Timeline
| Date | Event |
|---|---|
| 2024-08-05 | U.S. Patent App. No. 18/794,524 Filed |
| 2025-02-11 | ’071 Patent Issued |
| 2025-05-21 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,220,071 - "Hat Rack For Baseball Cap"
The Invention Explained
- Problem Addressed: The patent's background section identifies issues with common methods of storing baseball caps, noting that hanging them individually is space-inefficient and not secure, while stacking them makes it difficult to retrieve a single cap from the middle of the stack ('071 Patent, col. 1:21-28).
- The Patented Solution: The invention is a vertical rack with a series of "connection ports" designed to hold individual caps. A user folds a cap and inserts its rear edge into a port, where a "limiting portion" engages the cap's top buckle, preventing it from falling out. This configuration allows for the standardized and secure storage of multiple caps while keeping each one easily accessible ('071 Patent, Abstract; col. 3:31-52).
- Technical Importance: The design purports to offer a "simple and reliable" structure for storing a large number of caps in an organized, space-efficient manner where caps are easy to place and remove ('071 Patent, col. 2:44-49).
Key Claims at a Glance
- The complaint identifies Claim 1 as the only independent claim (Compl. ¶32).
- Claim 1 recites, among other things:
- A hat rack comprising a main body with a vertical support surface and a plurality of connection ports.
- "two of said main bodies disposed back to back".
- An upper end of each main body provided with a coaxially aligned "first through hole".
- "top ends of the main bodies are provided with a hook, a lower end of the hook is provided with a U-shaped opening".
- "the upper ends of the two main bodies are fitted into the U-shaped opening".
- The lower end of the hook is provided with a "bolt which cross both ends of the U-shaped opening, the bolt being connected through the first through hole on the main bodies".
- The complaint notes that Claims 2-9 depend on Claim 1 (Compl. ¶48).
III. The Accused Instrumentality
Product Identification
The accused products are "headwear organizers and displays" sold by Plaintiffs on Amazon.com under various ASINs, including B0DLFCX667 and B0DLG2ST5F (Compl. ¶12, ¶22).
Functionality and Market Context
- The complaint alleges the accused product is a "one body component" and does not contain "two main bodies," a "separate hook component," or "any separable parts" (Compl. ¶43-46). The complaint provides an image showing the accused product as a single molded plastic strip with multiple integrated cap-holding structures, displayed both empty and holding a stack of baseball caps (Compl. p. 6).
- Plaintiffs allege the products were "popular on Amazon" and that access to the U.S. market via Amazon is critical to their business (Compl. ¶23-25).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiffs' non-infringement arguments by comparing the elements of Claim 1 to the alleged structure of the accused products.
’071 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein there are two of said main bodies disposed back to back | The product is a "one body component" and does not contain two main bodies. | ¶43, ¶45 | col. 6:40-42 |
| top ends of the main bodies are provided with a hook, a lower end of the hook is provided with a U-shaped opening | The product "does not contain a separate hook component." | ¶44 | col. 6:45-46 |
| wherein the upper ends of the two main bodies are fitted into the U-shaped opening, and the lower end of the hook is provided with a bolt which cross both ends of the U-shaped opening, the bolt being connected through the first through hole on the main bodies | The product does not contain any separable parts, such as a bolt, and is not assembled by fitting two main bodies into a hook's U-shaped opening. | ¶46 | col. 6:48-53 |
Identified Points of Contention
- Scope Questions: The central dispute appears to be one of claim scope. Does the claim language requiring "two... main bodies," a "hook," and a "bolt" necessitate a multi-component assembly, or can it be construed to cover a single, integrally molded device that performs a similar function?
- Technical Questions: The complaint raises a direct question of structural mismatch. What evidence will show whether the accused product, described as a "one body component" (Compl. ¶43), possesses the distinct, mechanically interconnected components recited in Claim 1?
V. Key Claim Terms for Construction
"two of said main bodies disposed back to back"
- Context and Importance: This term is critical because Plaintiffs' core non-infringement argument is that their product is a single component, not an assembly of two bodies (Compl. ¶43, ¶45). The interpretation of whether "two... bodies" requires two physically separate and distinct structures will likely be dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent discloses a general embodiment with "two support surfaces disposed back to back," which a defendant could argue supports an interpretation not strictly limited to separate physical parts ('071 Patent, col. 2:36-38).
- Evidence for a Narrower Interpretation: The claim language recites "two of said main bodies" and further requires that they are "fitted into the U-shaped opening" of a hook and connected by a "bolt" ('071 Patent, col. 6:48-53). Embodiment Three and its associated Figure 11 explicitly depict two separate bodies (1) being joined together with a hook (7) and bolt (72), strongly suggesting the term requires separate components ('071 Patent, col. 5:37-48, Fig. 11).
"a hook"
- Context and Importance: Practitioners may focus on this term because Plaintiffs allege their product "does not contain a separate hook component" (Compl. ¶44). The dispute will concern whether an integrated hanging feature meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant could argue that "a hook" is a functional term referring to any structure that allows the rack to be hung, regardless of whether it is integral or separate.
- Evidence for a Narrower Interpretation: Claim 1 describes the hook in great detail, specifying it has a "U-shaped opening" for receiving the main bodies and is secured with a "bolt" ('071 Patent, col. 6:48-53). This description of mechanical interaction with other claimed components implies a distinct, separate part, as illustrated in Figure 11 ('071 Patent, Fig. 11).
VI. Other Allegations
- Indirect Infringement: Not applicable in this declaratory judgment action.
- Willful Infringement: While there is no allegation of willful infringement against the Plaintiffs, the complaint does allege that the Defendant's conduct in asserting the ’071 Patent in complaints to Amazon was done with "malice and an intent to harm Plaintiffs' business" (Compl. ¶50). Plaintiffs contend these assertions were "baseless" and "frivolous," and seek a finding that the case is "exceptional" under 35 U.S.C. § 285, which would permit an award of attorneys' fees (Compl. ¶54-55, ¶57).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: Does the language of Claim 1, which recites "two... main bodies," a "hook," and a "bolt," require a multi-component assembly of physically separate parts as depicted in the patent's preferred embodiments, or can the claim be interpreted more broadly to cover a single, integrally-molded product?
- A key evidentiary question will be one of structural comparison: Assuming the claim is construed to require a multi-component assembly, the case will turn on the straightforward factual question of whether the accused product is, as alleged, a "one body component" that lacks the claimed separable and interconnected parts.
- A procedural question will be whether Defendant's pre-suit enforcement activities through Amazon's complaint process were "baseless" and taken in bad faith, potentially rendering this an "exceptional case" and exposing the Defendant to liability for Plaintiffs' attorneys' fees.