DCT
2:25-cv-00363
Shenzhen HanYi Technology Co Ltd v. ShelterLogic Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen HanYi Technology Co., Ltd. (China)
- Defendants: ShelterLogic Corp. (United States) and PNC Bank, National Association (United States)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-00363, W.D. Wash., 02/26/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because a substantial part of the events, specifically an Amazon Patent Evaluation Express (APEX) proceeding initiated by Defendants, took place involving Amazon, whose headquarters are in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its AKSOUL Beach Chair does not infringe Defendants' patent related to folding chair mechanisms and that the patent is invalid.
- Technical Context: The technology concerns mechanical improvements to common collapsible folding chairs, specifically mechanisms intended to guide frame components during folding and unfolding.
- Key Procedural History: The complaint states that Defendants initiated an Amazon Patent Evaluation Express (APEX) proceeding against Plaintiff, accusing its product of infringement. This action by Defendants is cited as the basis for an actual and justiciable controversy, prompting Plaintiff to file this declaratory judgment action in federal court.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-15 | U.S. Patent No. 9,867,466 Priority Date |
| 2018-01-16 | U.S. Patent No. 9,867,466 Issued |
| 2025-02-26 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,867,466 - "Foldable Chair" (Issued Jan. 16, 2018)
The Invention Explained
- Problem Addressed: While the patent's background section notes a general need for improved chair designs, the detailed description identifies a specific problem: some guide mechanisms on folding chairs can create a "pinching hazard" for the user's hand when the chair is being opened or closed ('466 Patent, col. 3:1-3; col. 4:60-62).
- The Patented Solution: The invention is a folding chair with a "cradle" that includes a "guide member." This guide member is designed to steer a first frame element (e.g., the seat bottom) toward a second frame element (e.g., the seat base) as the chair is unfolded, ensuring the parts properly engage ('466 Patent, Abstract; col. 4:36-43). In certain embodiments, the guide member has curved end portions that create a clearance space between it and the frame, which may further mitigate the risk of pinching a user's hand ('466 Patent, col. 5:11-16).
- Technical Importance: The described solution aims to improve the safety and reliability of folding chairs by managing the interaction of moving frame parts during deployment, a common usability issue in such products ('466 Patent, col. 7:28-33).
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement and invalidity regarding the '466 patent generally, with specific invalidity arguments directed at claims 1-18 (Compl. ¶30, ¶51). Independent claim 1 is central to the non-infringement arguments.
- Independent Claim 1 requires:
- A first frame element
- A second frame element, where the first element moves relative to the second
- A cradle comprising a guide member that guides the first frame element into the cradle
- The guide member is pivotally connected to both the first frame element and the second frame element
III. The Accused Instrumentality
Product Identification
- The "AKSOUL Beach Chair" (ASIN: B0CS6TTLW8) sold by Plaintiff on Amazon (Compl. ¶3).
Functionality and Market Context
- The complaint describes the AKSOUL Beach Chair as a folding chair that employs a "passive structural support system" (Compl. ¶26).
- Plaintiff alleges the chair features a "link rod" that "passively moves with the frame elements and does not require manual intervention by the user" (Compl. ¶27). It further contends the chair's cradle is an "independent and structurally complete support component" that does not include or need the claimed guide member (Compl. ¶28).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The following table summarizes the Plaintiff's allegations for why its product does not meet the limitations of claim 1 of the '466 patent.
'466 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cradle comprising a guide member that guides the first frame element into the cradle | The AKSOUL chair employs a "passive structural support system" with a "link rod that passively moves" and lacks a "manually operated guide member." | ¶26-27 | col. 8:43-47 |
| wherein the guide member is pivotally connected to both the first frame element and the second frame element | The chair's cradle is alleged to be a "structurally complete support component that does not include or need a guide member pivotally connected to both the first and second frame elements." | ¶28 | col. 8:48-51 |
- Identified Points of Contention:
- Scope Questions: The primary dispute revolves around the term "guide member." The complaint suggests this term requires a "manually operated" or "actively guide[d]" component (Compl. ¶26, ¶14). A central question for the court will be whether the patent's claims, when read in light of the specification, are limited to such active or manual guidance, or if they can also read on the allegedly "passive link rod" of the accused product.
- Technical Questions: A key factual question will be whether the accused product's "link rod" is, in fact, "pivotally connected to both the first and second frame elements" as required by the final limitation of claim 1. The complaint's assertion that the cradle is an "independent" component suggests Plaintiff will argue its product lacks this pivotal connection (Compl. ¶28).
V. Key Claim Terms for Construction
- The Term: "guide member"
- Context and Importance: The entirety of the non-infringement case, as presented in the complaint, hinges on whether the "link rod" in Plaintiff's product constitutes a "guide member." Plaintiff characterizes the patented "guide member" as requiring active, manual operation, a feature it claims its product lacks (Compl. ¶27). The construction of this term will therefore be dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification states that the term "'guide' is used in accordance with its ordinary meaning and can include arrangements that may influence, restrain, restrict or limit movement of one element relative to another element" ('466 Patent, col. 4:45-49). This language could support a construction that includes passive structures that direct movement, not just those requiring manual interaction.
- Evidence for a Narrower Interpretation: The specification discusses the invention in the context of preventing a "pinching hazard" when a user moves the chair frame ('466 Patent, col. 4:60-65). A party could argue that this context implies the "guide member" is a feature designed to interact with or replace a user's manual guidance, thereby supporting a narrower construction that requires some level of active guidance or user-facing safety function not present in a simple passive linkage.
VI. Other Allegations
- Declaratory Judgment of Invalidity: Plaintiff alleges that claims 1-18 of the '466 Patent are invalid as anticipated under 35 U.S.C. § 102 or obvious under § 103 in view of prior art, including U.S. Patent Pub. No. 2009/0309394 (LiBin) and Chinese Patent No. CN 101254051 B (Chen) (Compl. ¶36). Plaintiff alleges these references teach a folding chair with a similar frame structure, cradle, and guide mechanism (Compl. ¶37, ¶39).
- Willful Infringement / Bad Faith Enforcement: The complaint does not allege willful infringement by Plaintiff. Instead, Plaintiff seeks an award of treble damages and attorney's fees against Defendants, alleging "willful assertion of an invalid and unenforceable patent" and "bad faith enforcement" (Compl., Prayer for Relief ¶G, H, J). The basis for this allegation appears to be Defendants' initiation of the APEX proceeding despite the existence of the cited prior art (Compl. ¶21, ¶36).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on two fundamental questions for the court:
A core issue will be one of definitional scope: Will the term "guide member" be construed broadly to cover any component that directs movement, potentially including the accused product's "passive link rod," or will it be limited to a component that requires some form of active or manual guidance as Plaintiff alleges?
A second issue will be structural and factual: Assuming the "link rod" is a "guide member," does it meet the claim's structural requirement of being "pivotally connected to both the first frame element and the second frame element," or is it part of an "independent" component as the complaint contends?