DCT
3:25-cv-00391
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: 3:25-cv-00391, E.D. Va., 05/21/2025
- Venue Allegations: Plaintiffs allege venue is proper in the Eastern District of Virginia under 35 U.S.C. § 293, which provides for jurisdiction and venue in this district for proceedings against a foreign patentee who has no designated agent for service in the United States.
- Core Dispute: Plaintiffs, sellers of headwear organizers, seek a declaratory judgment that their products do not infringe the Defendant’s patent and that the patent is invalid, following Defendant’s infringement complaints to Amazon against Plaintiffs’ products.
- Technical Context: The technology concerns display racks designed for the standardized storage and display of multiple baseball caps.
- Key Procedural History: The action arises from Defendant’s alleged complaints to Amazon.com, accusing Plaintiffs’ products of infringing the patent-in-suit. Plaintiffs frame these accusations as the basis for an actual case or controversy, permitting a declaratory judgment action. Plaintiffs also allege the accusations were baseless and made with malice, forming the basis for an exceptional case finding.
Case Timeline
| Date | Event |
|---|---|
| 2024-08-05 | U.S. Patent No. 12,220,071 Priority Date |
| 2025-02-11 | U.S. Patent No. 12,220,071 Issue Date |
| 2025-05-21 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,220,071 - "HAT RACK FOR BASEBALL CAP"
- Patent Identification: U.S. Patent No. 12,220,071, "HAT RACK FOR BASEBALL CAP", issued February 11, 2025.
The Invention Explained
- Problem Addressed: The patent's background section identifies shortcomings in prior art hat storage methods, such as individual hooks being unstable, stacking making caps hard to access, and existing display stands having an "overly complex structure" (’071 Patent, col. 1:22-32).
- The Patented Solution: The patent describes a hat rack with a vertical main body featuring a series of "connection ports." Each port is designed to engage the top button (buckle) of a baseball cap. A "limiting portion" on the upper part of each port interferes with the cap's button, using gravity to hold the cap securely in place while allowing for easy, individual removal (’071 Patent, Abstract; col. 3:31-52). The invention aims for a structure that is "simple and reliable" (’071 Patent, col. 2:48-49).
- Technical Importance: The design purports to offer a standardized, space-efficient, and secure method for storing a large number of baseball caps, addressing stability and accessibility issues found in other solutions (’071 Patent, col. 2:44-49).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of all claims, focusing on independent Claim 1 (Compl. ¶32, ¶48).
- Independent Claim 1 recites the following essential elements:
- A hat rack comprising a main body with a vertical support surface and a plurality of connection ports.
- Each connection port has a lower support platform and an upper positioning platform.
- The bottom surface of the upper platform forms a "limiting portion."
- The structure comprises "two of said main bodies disposed back to back."
- An upper end of each main body has a first through hole.
- "top ends of the main bodies are provided with a hook."
- The hook has a "U-shaped opening" into which the "upper ends of the two main bodies are fitted."
- A bolt connects the lower end of the hook through the first through holes on the main bodies.
- The complaint notes that claims 2-9 depend on Claim 1 and therefore cannot be infringed if Claim 1 is not infringed (Compl. ¶48).
III. The Accused Instrumentality
Product Identification
- The accused products are "headwear organizers and displays" designed for baseball caps, sold by Plaintiffs on Amazon.com under the store names "Eany - KK" and "Rai-Mee" (Compl. ¶12, ¶21-22). Specific Amazon Standard Identification Numbers (ASINs) are identified in the complaint (Compl. ¶12).
Functionality and Market Context
- The complaint describes the accused products as being constructed as a "one body component" without any "separable parts" (Compl. ¶43, ¶46). The plaintiffs assert their products do not contain "two main bodies" or a "separate hook component" (Compl. ¶44-45). The complaint includes a visual of the product, showing it as a single, molded plastic unit with an integrated hanging loop. This visual, depicting a hat rack with multiple caps mounted, illustrates the product's function and unitary construction (Compl., p. 6). The products are alleged to be "popular on Amazon" (Compl. ¶23).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' core arguments for why their product does not meet the limitations of Claim 1.
’071 Patent Non-Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-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. 6:41-42 |
| top ends of the main bodies are provided with a hook | The product "does not contain a separate hook component." The hanging feature is an integrated part of the single body. | ¶44 | col. 6:45 |
| a lower end of the hook is provided with a U-shaped opening | As the product allegedly lacks the claimed hook, it necessarily lacks the hook's U-shaped opening. | ¶47 | col. 6:45-46 |
| wherein the upper ends of the two main bodies are fitted into the U-shaped opening | The product allegedly lacks two main bodies and the U-shaped opening, and therefore cannot meet this limitation. | ¶47 | col. 6:48-49 |
- Identified Points of Contention:
- Structural Questions: The central dispute revolves around the physical construction of the rack. The primary question is whether the claim term "two of said main bodies disposed back to back" requires two physically distinct components that are assembled together, or if it can be read to cover a single, integrally molded piece with two functional faces. The complaint's visual evidence of a "one body component" directly challenges the claim's apparent multi-part structure (Compl., p. 6).
- Component Questions: A related question is whether the integrated hanging loop on the accused product constitutes a "hook" as required by the claim. The claim further requires this "hook" to have a "U-shaped opening" to receive the "two main bodies," suggesting a specific mechanical interface that may not be present in a single-piece design.
V. Key Claim Terms for Construction
The Term: "two of said main bodies disposed back to back"
Context and Importance: This term is at the heart of the non-infringement argument. Plaintiffs contend their product is a "one body component" (Compl. ¶43). The interpretation of whether "two...main bodies" necessitates two separate physical parts will likely be dispositive for infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the claim language does not explicitly use the word "separate" or "distinct," and that a single molding with two back-to-back functional surfaces could satisfy the limitation.
- Evidence for a Narrower Interpretation: The patent's specification repeatedly describes and depicts a two-part construction. Embodiment Three states, "there are two main bodies 1 disposed back to back," which are then fitted into a separate hook component (7) via a "U-shaped opening 71" and secured with a bolt (’071 Patent, col. 5:38-46). Figure 11 clearly illustrates two distinct main bodies (1) being assembled with a separate hook (7), strongly suggesting that "two...main bodies" refers to two separate components.
The Term: "hook"
Context and Importance: This term is critical because Claim 1 requires a specific relationship between the "hook," its "U-shaped opening," and the "two main bodies." Plaintiffs allege their product "does not contain a separate hook component" (Compl. ¶44). The definition of "hook" and its structural role is therefore a key point of dispute.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any feature that allows the device to be hung qualifies as a "hook" in its ordinary sense.
- Evidence for a Narrower Interpretation: The claim itself provides significant context, describing the hook not merely as a hanging implement but as a connecting piece with a "U-shaped opening" into which "the upper ends of the two main bodies are fitted" (’071 Patent, col. 6:48-49). This functional language, combined with the clear depiction of hook (7) as a separate assembly component in Figure 11, suggests a narrower construction that requires a distinct part performing a specific assembly function, not just an integrated loop.
VI. Other Allegations
- Exceptional Case & Baseless Accusation Allegations: The complaint alleges that the "clear and obvious lack of infringement" means the Defendant had "no reasonable basis to assert infringement" and that the complaints to Amazon were made with "malice and an intent to harm Plaintiffs' business" (Compl. ¶49-50). Plaintiffs assert these actions make this an "exceptional case" under 35 U.S.C. § 285, entitling them to attorneys' fees (Compl. ¶55, ¶57).
- Invalidity Allegations: In Count II, Plaintiffs allege that all claims of the ’071 patent are invalid under 35 U.S.C. §§ 102 and/or 103 in view of prior art, specifically citing U.S. Patent No. 5,240,123 to Hawk and U.S. Patent Publication 2012/0037671 to Lueth (Compl. ¶63-66).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural interpretation: can the claim language "two of said main bodies disposed back to back," especially when read in light of the patent's specification and figures depicting a multi-part assembly, be construed to cover the single-piece, integrally molded construction of the accused products?
- A second key issue will be one of component definition: does the term "hook," as limited by the claim's functional requirement that it receive the main bodies in a "U-shaped opening," read on the integrated hanging loop of the accused product, or does it require a separate, assemblable component as shown in the patent's embodiments?
- Beyond infringement, a central question will be whether the Defendant's pre-suit enforcement activity through Amazon's complaint system was "baseless" or conducted with "malice," which could lead the court to deem this an "exceptional case" and award attorneys' fees to the Plaintiffs.