DCT
2:25-cv-01562
Shenzhen Jianyuan Electronic Technology Co Ltd v. Hyper Ice Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Jianyuan Electronic Technology Co., Ltd. (China)
- Defendant: Hyperice IP Subco, LLC, and Hyper Ice, Inc. (Delaware, California)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-01562, W.D. Wash., 08/15/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants directed "extra-judicial patent enforcement" efforts into the district by submitting an infringement complaint to Amazon.com, Inc., which is headquartered in Seattle, Washington.
- Core Dispute: Plaintiff seeks a declaratory judgment that its massage guns do not infringe Defendant's patent related to the mechanical design of percussive massagers, and/or that the patent is invalid.
- Technical Context: The dispute involves the field of handheld electronic percussive massage devices, a consumer product category focused on muscle therapy and recovery.
- Key Procedural History: The action was precipitated by an intellectual property complaint filed by Hyperice with Amazon.com, alleging that Jianyuan's products infringe the patent-in-suit. The complaint also presents several prior art patents as the basis for its invalidity contentions.
Case Timeline
| Date | Event |
|---|---|
| 2013-07-01 | ’933 Patent - Earliest Priority Date |
| 2025-02-04 | ’933 Patent - Issue Date |
| 2025-08-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 12,213,933, "Massage device with a releasable connection for a massaging head," issued February 4, 2025. (’933 Patent)
The Invention Explained
- Problem Addressed: The patent's background section notes that prior art vibrating massage devices suffered from deficiencies, including being "bulky, get very hot, are noisy and/or are difficult to use for extended periods of time" (’933 Patent, col. 1:29-34).
- The Patented Solution: The invention is a handheld percussive massager with a specific mechanical architecture. The design features a motor and a handle positioned on opposite sides of the piston's longitudinal axis, a drive mechanism converting the motor's rotation into the piston's reciprocating motion, and a quick-connect system for attaching massage heads (’933 Patent, Abstract; col. 4:56-62). The specification also describes a cooling system where a fan draws air over a heat sink in a dedicated cavity, isolated from the motor, to dissipate heat (’933 Patent, col. 6:10-24).
- Technical Importance: The design purports to offer a more robust, durable, and user-friendly device by addressing common points of failure like noise, wear, and overheating in high-speed reciprocating mechanisms (’933 Patent, col. 5:19-25; col. 6:39-46).
Key Claims at a Glance
- The complaint focuses its non-infringement arguments on independent claim 1 (Compl. ¶20).
- The essential elements of independent claim 1 include:
- A housing
- A piston with a bore at its distal end
- A motor to cause the piston to reciprocate
- A drive mechanism that determines a predetermined stroke length of the piston
- A quick-connect system for a massaging head
- A requirement that the quick-connect system allows the head to be inserted or removed "while the piston reciprocates the predetermined stroke length at the first speed"
- A specific drive mechanism comprising a flywheel connected to the motor's output shaft and a crank pin extending from the flywheel to the piston
- The complaint notes that dependent claims 2-15 are also not infringed because they depend on claim 1 (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The accused products are "Massage Gun" devices sold by Plaintiff on Amazon and identified by ASINs B083L8RNJR, B0B2Z5JHN4, and B08XB3ZV7X (Compl. ¶23).
Functionality and Market Context
- Based on the complaint's description, the Accused Product is a percussive massager that utilizes interchangeable heads (Compl. ¶22).
- A key operational feature alleged by the Plaintiff is that the massage heads cannot be changed while the device is operating; it "must be powered off, with the piston at rest, before a head can be changed" via a "secure friction/interference and/or twist/press fit" (Compl. ¶22).
- The complaint also states that the Accused Product's stroke length is "fixed by its internal geometry at the time of manufacture" and cannot be adjusted by the user (Compl. ¶23).
- Plaintiff asserts that the Amazon marketplace is its "primary sales channel in the United States," making the infringement complaint from Hyperice a significant commercial threat (Compl. ¶14).
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment of non-infringement, the following chart summarizes the Plaintiff's primary arguments for why its product does not meet the limitations of the asserted patent claim. No probative visual evidence provided in complaint.
’933 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein the quick-connect system allows a proximal end of the first massaging head to be inserted into or removed from the bore while the piston reciprocates the predetermined stroke length at the first speed | The Accused Product requires the device to be powered off and the piston to be static before a head can be changed. The connection relies on a friction/interference fit that depends on static alignment. | ¶22 | col. 7:7-12 |
| a drive mechanism that determines a predetermined stroke length of the piston | The Accused Product's stroke length is immutable and fixed at the time of manufacture. Plaintiff argues the patent specification teaches a mechanism for user-selectable stroke lengths, which the Accused Product lacks. | ¶23 | col. 8:22-36 |
Identified Points of Contention
- Functional Questions: A central dispute concerns the functionality of the head attachment mechanism. The complaint raises the question of whether the Accused Product's "friction/interference" fit (Compl. ¶22) can be considered equivalent to a system that, according to the patent, is designed to allow head swapping "even while the piston... is moving" (’933 Patent, col. 7:11-12).
- Scope Questions: The case will involve interpreting the scope of two key phrases. First, what actions are encompassed by allowing removal "while the piston reciprocates." Second, what is meant by a "drive mechanism that determines a predetermined stroke length." Does this phrase read on a mechanism with a fixed, unchangeable stroke length, or does the patent's disclosure of an adjustable stroke mechanism limit the term to require user-adjustability? (Compl. ¶¶23, 25).
V. Key Claim Terms for Construction
The Term: "while the piston reciprocates the predetermined stroke length at the first speed"
Context and Importance: This term is critical because the Plaintiff's primary non-infringement argument is that its device must be powered off to change heads (Compl. ¶22). The definition will determine whether a "stop-to-change" system can infringe.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee may argue that the claim only requires the capability for such an exchange, not that it is the sole or recommended method. The use of a magnetic quick-connect system could be presented as inherently motion-tolerant, suggesting the phrase describes a characteristic of the connection rather than a required user action (’933 Patent, col. 6:57-7:4).
- Evidence for a Narrower Interpretation: The Plaintiff will likely point to specification language stating that the massaging head is tapered "to allow it to easily slip into the opening... even while the piston... is moving" as evidence that the claim requires functionality during active operation (’933 Patent, col. 7:10-12). This suggests an intended feature that a static-only system would lack.
The Term: "a drive mechanism that determines a predetermined stroke length"
Context and Importance: Plaintiff argues its fixed-stroke product does not meet this limitation because, it contends, the patent's specification implies an adjustable mechanism (Compl. ¶23). Practitioners may focus on this term as a potential point of distinction between a fixed-geometry design and a user-configurable one.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee could argue that any fixed-geometry crank mechanism "determines" the stroke length by its physical dimensions. The word "predetermined" may be interpreted to mean "determined in advance," which would include being fixed at the factory. The description of the basic drive mechanism (flywheel and crank pin) does not inherently require adjustability (’933 Patent, col. 4:41-51).
- Evidence for a Narrower Interpretation: The Plaintiff will likely argue that the patent teaches the concept of "determining" the stroke length through an adjustable "lost motion system" that allows a user to "choose different magnitudes of floating piston movement" (’933 Patent, col. 8:60-63; FIG. 7). This disclosure could be used to argue that the term implies an active selection or setting of the stroke length, not a passive, immutable one.
VI. Other Allegations
As this is a declaratory judgment action filed by the accused infringer, the complaint does not contain allegations of indirect or willful infringement against the Defendant. Instead, the Plaintiff seeks a finding that the case is "exceptional" under 35 U.S.C. § 285, which may entitle it to attorney's fees, and requests damages for what it characterizes as Hyperice's "improper acts" in filing the Amazon complaint (Compl., Prayer for Relief F, G).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action appears to hinge on two central questions of claim construction and scope:
- A core issue will be one of functional capability: does the claim limitation requiring the ability to change a massage head "while the piston reciprocates" require that function to be possible during full-speed operation, or can it be met by a system that is merely motion-tolerant? This will require a close analysis of whether the Accused Product's "stop-to-change" friction fit is fundamentally different from the claimed system.
- A key question will be one of definitional scope: can the term "determines a predetermined stroke length," when read in light of a specification that describes an adjustable stroke-setting mechanism, be construed to cover a device where the stroke length is immutably fixed at the time of manufacture?