Dongguan Pineapple Protection Co Ltd v. Ez Glaz Global Store

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Pineapple Protection Co., Ltd. (China)
  • Defendant: EZ-GLAZ Global Store, IGluz, and Mohave protection (China)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 1:25-cv-01739, E.D. Va., 10/09/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants, though based abroad, sell and ship the accused products to consumers in the Eastern District of Virginia through interactive Amazon.com storefronts. The complaint also asserts that venue against non-U.S. defendants is proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendants’ screen protector products infringe a patent related to a film-sticking assembly that uses an electrostatically charged release layer to remove dust from a device's screen during application.
• Technical Context: The technology addresses the common problem of trapping dust under screen protectors for consumer electronics, a large and competitive market where ease and quality of application are significant factors.
• Key Procedural History: The complaint alleges that the patent-in-suit was assigned to the Plaintiff on August 3, 2022. It further alleges that the Defendants are selling "identical/nearly identical" copies of the Plaintiff's patented products, which began appearing on the market after the patent was granted. No prior litigation or administrative patent challenges are mentioned in the complaint.

Case Timeline

Date	Event
2022-05-16	’487 Patent Priority Date
2023-09-05	’487 Patent Issue Date
2024-08-01 (approx.)	Accused Products allegedly began to be sold on Amazon.com
2025-10-09	Complaint Filing Date

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

U.S. Patent No. 11,745,487 - Sticking Film, A Film-Sticking Tool and A Film-Sticking Assembly

Issued: September 5, 2023 (Compl. ¶1; ’487 Patent, front page).

The Invention Explained

• Problem Addressed: The patent’s background section describes the problem of fine dust particles on the screen of an electronic product prior to applying a protective film. Wiping the screen can cause friction that damages the screen, and the cleaning effect is often imperfect, leaving particles trapped under the applied film (’487 Patent, col. 1:19-29).
• The Patented Solution: The invention claims a film assembly where the removable release layer is an "electrostatic layer." When a user peels this layer away from the tempered film (the actual screen protector), the release layer generates a static charge. This charged layer can then be used to attract and lift dust particles off the device's screen immediately before the tempered film is applied, integrating the final cleaning step into the application process (’487 Patent, Abstract; col. 1:39-44).
• Technical Importance: This approach seeks to solve the persistent issue of re-contamination of a screen in the interval between cleaning it with a separate cloth and applying the protector film (Compl. ¶11).

Key Claims at a Glance

• The complaint asserts claims 1-14, with infringement analysis focused on independent claim 1 (Compl. ¶22, ¶23).
• The essential elements of independent claim 1 of the ’487 Patent are:
  • A sticking film comprising a tempered film and an attached release film layer.
  • The release film layer is an "electrostatic layer."
  • The release film layer and tempered film are separated during pasting.
  • The side of the release film that was attached to the tempered film generates static electricity to attract dust.
  • The film includes a "pulling portion."
  • When the pulling portion is pulled, the side of the release film that was attached to the sticking surface contacts the screen to attract dust.
• The complaint reserves the right to modify its infringement contentions (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as "sticking film products" sold by the Defendants through their respective seller stores on the Amazon.com platform (Compl. ¶3).

Functionality and Market Context

The Accused Products are screen protector assemblies for electronic devices, such as mobile phones (Compl. ¶11, ¶14). The complaint alleges that these products are "identical/nearly identical" copies of Plaintiff's own commercial products and that Defendants have "flooded the online market" with them, thereby undercutting Plaintiff's sales and causing irreparable harm (Compl. ¶13, ¶14).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an Exhibit F, which was not filed with the public complaint (Compl. ¶23). The narrative infringement theory alleges that the Accused Products meet every element of at least claim 1 of the ’487 Patent, either literally or under the doctrine of equivalents (Compl. ¶36). The core allegation is that the Accused Products are direct copies of Plaintiff's patented assembly and therefore function in the same way (Compl. ¶13, ¶37). Specifically, the complaint implies that when a user applies one of the Accused Products, separating its release layer from its tempered film generates static electricity, which in turn is used to remove dust from the target screen, thus infringing the asserted claims (Compl. ¶11). The complaint provides a copy of the patent’s Figure 8, which illustrates the separation of the release film layer (202) from the tempered film (201) via a pulling portion (130) (Compl. ¶20).

Identified Points of Contention

• Scope Questions: The case may turn on the definition of an "electrostatic layer." A central question is whether this term covers any standard polymer film that incidentally generates static electricity when peeled (a triboelectric effect), or if it requires a material specifically designed or treated for enhanced electrostatic properties.
• Technical Questions: A key evidentiary hurdle will be demonstrating that the release layers of the Accused Products actually perform the claimed function of "generating static electricity to attract dust on the screen." This functional limitation will likely require empirical testing and evidence beyond a mere structural comparison. The complaint does not detail what tests, if any, have been performed.

V. Key Claim Terms for Construction

Key Term: "electrostatic layer"

• Context and Importance: This term is central to the patent's point of novelty. Its construction will determine whether the claim scope is broad enough to read on products using conventional plastic release liners or is narrow enough to require a more specialized material.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests that a material "that is easy to generate static electricity by friction," such as PET, is a suitable "electrostatic layer" (’487 Patent, col. 4:32-38). This may support an argument that the term encompasses common materials known to exhibit such properties.
  • Evidence for a Narrower Interpretation: The claim’s explicit recitation of the layer as an "electrostatic layer" could suggest that this is its primary, defining characteristic, rather than an incidental property. A defendant might argue that this language limits the claim to layers specifically engineered or treated to optimize static generation beyond what is inherent in a standard release film.

Key Term: "contacting the screen to attract dust"

• Context and Importance: This phrase recites an affirmative step in the claimed method of use. Infringement will depend not just on the product's structure but also on whether its intended or actual use involves this specific action.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a scenario where "the side of the release film layer attached to the sticking surface contacts the screen to attract dust" as part of the pulling process (’487 Patent, col. 2:6-8). This could be interpreted to include any incidental contact that occurs as the film is peeled back over the screen.
  • Evidence for a Narrower Interpretation: The patent also describes the release layer being in "pressing contact with the screen" and having a structure similar to a "scraper" (’487 Patent, col. 2:10-11, col. 4:11-12). This language may support a narrower construction requiring a deliberate, wiping-like action, which might not be part of every user's application process.

VI. Other Allegations

Indirect Infringement

The complaint focuses on direct infringement under 35 U.S.C. § 271(a) (Compl. ¶22, ¶35). While no count for indirect infringement is pleaded, the prayer for relief seeks to enjoin Defendants from "assisting, aiding, or abetting" infringement (Prayer ¶B.ii).

Willful Infringement

Willfulness is alleged based on the assertion that the Accused Products are "copies of the Plaintiff’s patented sticking film assembly" and that Defendants continued to infringe after they "became aware of the patent" (Compl. ¶30, ¶37). The complaint notes that the accused Amazon listings began "well after the grant of the '487 Patent," suggesting Defendants had at least constructive notice (Compl. ¶13).

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

• A core issue will be one of definitional scope: can the term "electrostatic layer" be construed to cover conventional polymer films commonly used as release liners in screen protectors, or is it limited to materials specifically engineered for enhanced static-generating properties?
• A key evidentiary question will be one of functional proof: what evidence will the Plaintiff present to demonstrate that the Accused Products actually perform the claimed function of "generating static electricity to attract dust," and is this effect significant enough to meet the claim limitations?
• The allegation of willful infringement will likely depend on whether the evidence supports a finding of deliberate copying, as the complaint alleges, versus the independent development or use of a product configuration that is common in the industry.