Shenzhen Ke Xiu Technology Co Ltd v. Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Ke Xiu Technology Co. Ltd. (China)
  • Defendant: The Unincorp Associations Identified in Schedule A (China)
  • Plaintiff’s Counsel: DNL Zito
• Case Identification: 1:25-cv-01915, E.D. Va., 10/31/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendants are non-U.S. entities that sell accused products to consumers in the United States, including Virginia, through interactive Amazon storefronts, thereby committing the tort of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendants’ magnetic USB connectors sold on Amazon.com infringe a patent related to the internal mechanical structure of a detachable electronic connector.
• Technical Context: The technology concerns detachable magnetic connectors, which allow a cable to easily connect to a tip left in a device port, aiming to simplify manufacturing and improve durability over traditional connectors.
• Key Procedural History: The complaint notes Plaintiff has engaged in intellectual property enforcement against "knock-off and infringing products" in China. It also alleges Plaintiff has marked its own products with the patent-in-suit.

Case Timeline

Date	Event
2020-08-26	’602 Patent Earliest Priority Date
2023-08-15	’602 Patent Issue Date
2025-10-31	Complaint Filing Date

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

U.S. Patent No. 11,728,602 - "Connector and Cable with Connector"

• Issued: August 15, 2023.

The Invention Explained

• Problem Addressed: The patent’s background section describes that in existing small data cable connectors, electrical pins typically must be soldered to a printed circuit board (PCB). This process is described as complicated, difficult due to small volumes, and limiting to the number of pins that can be set on the circuit board (’602 Patent, col. 1:20-26).
• The Patented Solution: The invention proposes a connector that secures its internal pins mechanically, without soldering. The core of the solution is a multi-part "fixing member" that clamps or holds the connector pins in a precise arrangement. As shown in the exploded view of Figure 2, an upper fixing element (111) and a lower fixing element (112) cooperate to hold a plurality of first pins (12) in place, which simplifies assembly and reduces manufacturing costs (’602 Patent, Abstract; col. 5:17-27).
• Technical Importance: This solderless construction method is presented as a way to reduce the cost and difficulty of manufacturing small, multi-pin electronic connectors (’602 Patent, col. 3:45-49).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-18 (Compl. ¶29).
• Essential elements of independent claim 1 include:
  • An electronic connector with a first and second terminal head that are detachably connected.
  • The first terminal head comprises a plurality of first pins and a "fixing member."
  • The fixing member itself comprises an "upper fixing element" and a "lower fixing element."
  • The first pins are fixed on the upper and lower fixing elements, with parts of the pins passing through each element.
  • The first terminal head also comprises a protective shell and an "integration part" connected to the shell, where the integration part defines "seating grooves" for the first pins.
  • The pins in the seating grooves are positioned to make electrical and mechanical contact with pins of the second terminal head.

III. The Accused Instrumentality

Product Identification

• The accused products are various "infringing USB products," described as magnetic USB connectors sold by Defendants on Amazon.com storefronts (Compl. ¶4, ¶6).

Functionality and Market Context

• The Accused Products are described as electronic connectors with a first terminal head and a second terminal head that are detachably connected (Compl. ¶28). The first terminal head is the part designed to fit into a USB-C slot in a computer or smartphone (Compl. ¶25).
• The complaint alleges that the Accused Products have gained market traction by copying Plaintiff's successful products, which offer the benefit of allowing a user to leave a USB tip in a device and connect a power or data cable via magnets (Compl. ¶13, ¶15). Plaintiff alleges that the influx of these products has damaged its sales and forced it to lower prices (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint references "exemplary claim charts" in an Exhibit B, which was not provided with the filing (Compl. ¶30). The infringement theory is therefore summarized in prose based on the complaint's narrative allegations.

The core of the infringement allegation is that the Accused Products contain the same internal components as recited in the claims of the ’602 Patent (Compl. ¶25, ¶28). The complaint alleges that each Accused Product includes a first terminal head and a second terminal head that are detachably connected, and that the first terminal head contains a "plurality of first pins and a fixing member... having an upper fixing element and a lower fixing element" (Compl. ¶28). To support this, the complaint uses figures from the ’602 Patent itself to illustrate the structure it accuses. Figure 1 from the patent is used to show the two detachable heads (Compl. ¶25). Figure 2, an exploded diagram from the patent, is referenced to illustrate the internal components, including the upper and lower fixing elements (111, 112) and first pins (12) (Compl. ¶26). Figure 3 is also referenced to provide a closer view of the claimed "fixing member" (Compl. ¶27).

Identified Points of Contention

• Technical Questions: The complaint's infringement theory appears to rely on the assertion that the internal structure of the Accused Products is identical to the patent's embodiments. A central question will be what evidence Plaintiff provides to demonstrate that the unseen internal mechanics of the mass-market Accused Products actually contain the specific multi-part "fixing member" and "integration part" structures required by the claims. The complaint does not include, for example, a teardown or internal imaging of an accused device.
• Scope Questions: The dispute may turn on whether the internal pin-holding mechanism in the Accused Products, whatever its structure, falls within the scope of the term "fixing member comprising an upper fixing element and a lower fixing element." The case will question if the defendants' products achieve a similar result (solderless pin retention) through a structurally different design that falls outside the literal scope of the claims.

V. Key Claim Terms for Construction

The Term: "fixing member"

• Context and Importance: This term is the central element of the asserted independent claim and represents the core of the purported invention—a solderless mechanical solution for securing connector pins. The outcome of the infringement analysis will likely depend entirely on how this term is construed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent summary states the fixing member's purpose is to "fix the first pins in the first terminal head, without soldering" (’602 Patent, col. 3:36-39). This functional description could support an interpretation that covers any mechanical structure achieving this result.
  • Evidence for a Narrower Interpretation: The specification consistently describes and illustrates the "fixing member" (11) as a specific two-part structure comprising an "upper fixing element" (111) and a "lower fixing element" (112) that cooperate to hold the pins (’602 Patent, col. 5:45-54; Fig. 2). A defendant may argue that the term should be limited to this disclosed two-piece, clamshell-like embodiment.

The Term: "integration part"

• Context and Importance: Claim 1 requires the first terminal head to "further" comprise this part, in addition to the fixing member and protective shell. Its presence as a distinct element is a requirement for literal infringement, and its definition will be critical to mapping the claim onto an accused device.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language defines it partly by its function and location: it is "connected to an end of the protective shell close to the fixing member" and "defin[es] a plurality of seating grooves" for the pins (’602 Patent, col. 13:64-col. 14:4).
  • Evidence for a Narrower Interpretation: The detailed description and Figure 2 depict the "integration part" (16) as a discrete physical component separate from the fixing member (11) and the housing (15) (’602 Patent, col. 8:6-9; Fig. 2). This could support an argument that the claim requires three distinct components (shell, fixing member, integration part), not a single component that performs multiple functions.

VI. Other Allegations

Indirect Infringement

• The complaint makes a conclusory allegation of indirect infringement by inducement (Compl. ¶29) but does not plead specific facts to support the required element of intent, such as identifying specific instructions or advertising materials that encourage infringement.

Willful Infringement

• Willfulness is alleged based on Defendants having become "aware of the patent" and the assertion that the Accused Products are "copies of the Plaintiff’s patented USB product" (Compl. ¶36, ¶43).

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

• A core issue will be one of structural proof: what evidentiary basis, such as product teardowns or expert analysis, will Plaintiff present to establish that the commodity Accused Products incorporate the specific, multi-component internal architecture—including a distinct two-part "fixing member" and a separate "integration part"—recited in Claim 1 of the ’602 patent?
• The case will also present a key question of claim scope: will the term "fixing member," which the patent presents as a novel solution to the problem of soldering pins, be construed narrowly to the specific two-piece mechanical clamp shown in the patent's figures, or will it be interpreted more broadly to cover other non-soldered pin retention methods that may be used in the accused devices?