DCT
2:25-cv-01563
Shenzhen Jiaxin Electronic Technology Co Ltd v. Hyper Ice Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Jiaxin Electronic Technology Co., Ltd. (China)
- Defendant: Hyperice IP Subco, LLC (Delaware) and Hyper Ice, Inc. (California)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-01563, W.D. Wash., 08/15/2025
- Venue Allegations: Plaintiff asserts that venue is proper in the Western District of Washington because Defendants directed patent enforcement activities into the district by submitting an infringement complaint to Seattle-based Amazon.com, Inc., which constitutes a substantial part of the events giving rise to this action.
- Core Dispute: Plaintiff seeks a declaratory judgment that its massage gun product does not infringe U.S. Patent No. 12,213,933 B1, and/or that the patent is invalid.
- Technical Context: The dispute concerns the mechanical design and functionality of percussive massage devices, a category of popular consumer electronics used for deep muscle therapy.
- Key Procedural History: The complaint states that this declaratory judgment action was initiated after Defendant Hyperice submitted a patent infringement report to Amazon.com, alleging that Plaintiff's product infringes the patent-in-suit. This action placed Plaintiff's product at risk of being removed from the Amazon marketplace, creating the basis for an actual controversy between the parties.
Case Timeline
| Date | Event |
|---|---|
| 2013-07-01 | ’933 Patent Priority Date |
| 2025-02-04 | ’933 Patent Issue Date |
| 2025-08-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,213,933 - "Massage device with a releasable connection for a massaging head"
- Issued: February 4, 2025
The Invention Explained
- Problem Addressed: The patent’s background section identifies deficiencies in prior art massaging devices, noting that they were often bulky, generated excessive heat, were noisy, and were difficult to use for extended periods (’933 Patent, col. 1:28-34).
- The Patented Solution: The invention claims to solve these problems through a specific device architecture. The abstract describes an arrangement with a motor on one side of a piston's longitudinal axis and a handle on the other, which may improve balance and usability (’933 Patent, Abstract). The specification also details a drive mechanism for converting the motor's rotary motion into the piston's reciprocating motion and a cooling system where a fan draws air over a heat sink in a dedicated cavity, separate from the motor, to manage thermal output (’933 Patent, col. 1:36-42; col. 6:10-29).
- Technical Importance: This design approach suggests an effort to create a more ergonomic, durable, and user-friendly percussive massager by addressing common points of failure like overheating and poor handling dynamics (’933 Patent, col. 1:28-34).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1 and, by extension, dependent claims 2-15 (Compl. ¶¶ 20, 26).
- The essential elements of independent claim 1 include:
- A housing, a piston with a bore at its distal end, and a motor to reciprocate the piston.
- A drive mechanism that determines a predetermined stroke length of the piston.
- A quick-connect system for a massaging head.
- A feature wherein the quick-connect system allows a massaging head to be inserted into or removed from the bore while the piston reciprocates the predetermined stroke length.
- A drive mechanism comprising a flywheel and a crank pin operatively connected to the piston.
III. The Accused Instrumentality
Product Identification
- Plaintiff's massage gun, identified by Amazon Standard Identification Number (ASIN) B0BC1GS34Q (Compl. ¶21).
- No probative visual evidence provided in complaint.
Functionality and Market Context
- The complaint alleges two key operational characteristics of the Accused Product. First, it asserts that the massage head connection relies on a secure friction/interference fit that requires the device to be powered off and the piston to be at rest before a head can be changed (Compl. ¶22).
- Second, the complaint alleges that the Accused Product’s stroke length is immutable, being fixed by its internal geometry at the time of manufacture, and that users cannot select or change the stroke length (Compl. ¶¶ 23, 1-2).
- Plaintiff alleges that the Amazon marketplace is its primary sales channel in the United States, and Defendant’s infringement complaint to Amazon threatens its access to this channel (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The following table summarizes Plaintiff’s non-infringement contentions against claim 1 of the ’933 Patent.
’933 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a drive mechanism that determines a predetermined stroke length of the piston; | The Accused Product has a stroke length that is fixed at the time of manufacture and cannot be set or adjusted by a user. The complaint argues the patent’s intrinsic evidence describes a mechanism for setting/adjusting stroke length, which the Accused Product lacks. | ¶23 | col. 10:7-8 |
| 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 is not configured to allow insertion or removal of a massage head while the piston is reciprocating. It allegedly must be powered off for a head to be changed, as its connection relies on a static-alignment friction fit. | ¶22 | col. 10:12-16 |
Identified Points of Contention
- Scope Questions: The dispute raises a central claim construction question: what is the scope of a "drive mechanism that determines a predetermined stroke length"? Does this language require a mechanism that allows a user to select or adjust the stroke length, as Plaintiff contends (Compl. ¶23), or can it also read on a device with a single, fixed stroke length that is "determined" by its manufactured geometry?
- Technical Questions: A key factual question is whether the Accused Product’s head connection system "allows" removal "while the piston reciprocates." This may turn on whether the claim requires a system specifically designed for safe and intended interchange during operation, or whether mere physical possibility, however impractical or contrary to user instructions, is sufficient to meet the limitation.
V. Key Claim Terms for Construction
The Term: "determines a predetermined stroke length"
- Context and Importance: This term is pivotal to one of Plaintiff's primary non-infringement arguments. If the court construes "determines" to require user-adjustability, Plaintiff's argument that its fixed-stroke device does not infringe may be strengthened. Conversely, a construction that encompasses a fixed, factory-set stroke length would undermine this theory (Compl. ¶23).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 8 of the patent recites that "an offset between the flywheel axis and an axis of the crank pin determines the predetermined stroke length of the piston," which suggests that a fixed mechanical parameter can "determine" the stroke length without user input (’933 Patent, col. 10:46-49). This may support an interpretation covering fixed-stroke designs.
- Evidence for a Narrower Interpretation: The specification explicitly discloses a "lost motion system" for "varying the stroke of the piston" using a rotatable cam to adjust the travel of the piston (’933 Patent, FIG. 7; col. 7:22-34). Plaintiff may argue that this detailed disclosure of an adjustable-stroke mechanism informs the meaning of "determines" and limits it to devices with such selective functionality.
The Term: "allows a proximal end of the first massaging head to be inserted into or removed from the bore while the piston reciprocates"
- Context and Importance: This clause is the basis for Plaintiff's second main non-infringement argument (Compl. ¶22). The interpretation of "allows" will be critical. If it implies a system designed for convenient and safe on-the-fly swapping, Plaintiff's "stop-to-change" product may fall outside the claim scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "allows" only requires physical possibility, not that the action is recommended, easy, or safe. If the head is not permanently affixed, it can be argued that its removal is "allowed" at any time.
- Evidence for a Narrower Interpretation: The patent describes a "quick-connect system" using magnets to hold the massaging head "firmly in place" during normal use, while also allowing a user to "quickly remove and replace" it by applying sufficient force (’933 Patent, col. 6:51-col. 7:12). This specific embodiment of a system designed for easy connection and disconnection may support an interpretation that the term "allows" requires more than mere physical possibility and implies a system affirmatively configured for such an operation.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiff does not indirectly infringe the ’933 Patent, but it does not provide sufficient detail for analysis of any specific theory of indirect infringement that may be asserted against it (Compl. ¶24).
- Willful Infringement: Not applicable, as this is a declaratory judgment action brought by the accused infringer.
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to center on two fundamental disputes over claim scope, both of which will likely require judicial claim construction. The outcome may depend on the answers to the following questions:
- A core issue will be one of definitional scope: Does the claim phrase "a drive mechanism that determines a predetermined stroke length" require a mechanism for user selection or adjustment, as taught in one of the patent’s embodiments, or does it also encompass a device where the stroke length is simply fixed by its manufactured design?
- A key issue of functional capability will also be central: What does it mean for a connection system to "allow" a massage head to be swapped "while the piston reciprocates"? Does this require a system expressly designed for safe, on-the-fly interchange, as the patent’s magnetic quick-connect system suggests, or is the mere physical possibility of removal during operation sufficient to meet the claim limitation?