Yiwu Jieya E Commerce Co Ltd v. Xu

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Yiwu Jieya E-Commerce Co. Ltd. (People's Republic of China)
  • Defendant: Liang Xu and Judybridal (People's Republic of China)
  • Plaintiff’s Counsel: Alight Law P.C.
• Case Identification: 2:25-cv-01595, W.D. Wash., 09/09/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendants submitted patent infringement complaints through Amazon, which is headquartered in Seattle, and this action caused harm to Plaintiff within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that U.S. Patent No. 12,274,337 is invalid and not infringed by Plaintiff's rotating desk organizers, and further alleges that Defendants' enforcement of the patent constitutes tortious interference, violations of state and federal antitrust law, and bad-faith patent assertion.
• Technical Context: The dispute concerns the market for rotating desk organizers, a common consumer office supply product designed to provide easy access to stored items like pens and scissors.
• Key Procedural History: The complaint alleges that Defendants filed infringement complaints against Plaintiff through Amazon's intellectual property enforcement platform, resulting in the removal of Plaintiff's product listings. This lawsuit is a direct response, seeking not only to invalidate the patent but also to establish liability for what Plaintiff characterizes as bad-faith enforcement and fraudulent patent procurement.

Case Timeline

Date	Event
2023-05-16	Earliest alleged public sale date of an Accused Product on Amazon.
2024-09-19	Filing date and priority date for U.S. Patent No. 12,274,337.
2025-04-15	U.S. Patent No. 12,274,337 issues.
2025-08-06	Amazon allegedly notifies Plaintiff of infringement complaint.
2025-09-09	Complaint for Declaratory Judgment filed.

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

U.S. Patent No. 12,274,337 - "PEN HOLDER" (issued April 15, 2025)

The Invention Explained

• Problem Addressed: The patent's background section notes that conventional, one-piece pen holders make it inconvenient for users to find and access office supplies placed in different positions within the holder's storage chamber (Compl. Ex. 1, ’337 Patent, col. 1:15-23).
• The Patented Solution: The invention is a two-part pen holder consisting of a stationary base and a rotating upper frame containing storage compartments. To facilitate smooth rotation, a "resistance reducing device" is placed between the base and the frame (Compl. Ex. 1, ’337 Patent, Abstract). This device is described as a mechanism using balls contained within a bracket, which allows the upper frame to spin freely on the base, making all compartments easily accessible to the user (Compl. Ex. 1, ’337 Patent, col. 4:5-23; Fig. 4).
• Technical Importance: This design purports to improve the usability of a common desktop item by introducing a rotational mechanism, thereby reducing the need for the user to physically move the entire holder or reach around it to access contents.

Key Claims at a Glance

• The complaint seeks a declaratory judgment concerning the entire patent and does not single out specific claims. The primary independent claims are Claim 1 and Claim 16.
• Independent Claim 1:
  • A pen holder base and a pen holder frame, where the frame rotates on the base.
  • The frame has an "accommodating chamber" for office supplies.
  • A "resistance reducing device" is arranged between the frame and the base.
  • This device comprises a bracket and balls.
  • A "bracket groove" is provided at the top of the base, and the bracket is arranged in the groove.
  • The height of the bracket groove's side wall is less than the diameter of the balls, allowing the balls to protrude and contact the bottom of the pen holder frame.
• Independent Claim 16:
  • A pen holder base and a pen holder frame, where the frame rotates on the base.
  • The frame has an "accommodating chamber."
  • The holder includes a circular-ring-shaped "rotating bracket" and a circular-ring-shaped "guide rail."
  • The rotating bracket is arranged at the top of the base or bottom of the frame, with the guide rail on the corresponding opposing surface, allowing the bracket to rotate within the rail.

III. The Accused Instrumentality

Product Identification

The Accused Products are various models of "rotating desk organizers and pen holders" sold by Plaintiff on Amazon.com under specific Amazon Standard Identification Numbers (ASINs), including B0C5M4FXD3 and B0C8C6ZFXW (Compl. ¶4, ¶22).

Functionality and Market Context

The complaint describes the Accused Products as sharing the same underlying structure and features, namely a multi-compartment container that rotates on a stationary base (Compl. ¶22). The complaint provides visual evidence, including a side-by-side comparison of an Accused Product and a figure from the ’337 Patent, to illustrate their structural similarity (Compl. p. 6). Plaintiff alleges these products were sold on Amazon in the U.S. as early as May 2023, positioning them as a competing product in the online marketplace for office supplies (Compl. ¶6, ¶23).

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement and invalidity and therefore does not contain a traditional infringement claim chart. Instead, Plaintiff advances alternative arguments: either the Accused Products do not infringe, or, if they are found to infringe, the ’337 Patent's claims are invalid under the on-sale bar of 35 U.S.C. § 102 (Compl. ¶¶25-26). The complaint's primary focus is on the invalidity argument, alleging that the Accused Products, which embody the patented invention, were publicly sold more than one year prior to the patent's effective filing date (Compl. ¶36).

The complaint includes a visual comparison between an Amazon listing for an Accused Product (ASIN B0C58MCR4C) and figures from the ’337 Patent, which implicitly maps the product's features to the patented design to support the on-sale bar allegation (Compl. p. 6). Additional images from an Amazon customer review dated July 21, 2023, are provided as further evidence of the product's public availability and features, such as its "360° Rotating base" and compartment structure, prior to the patent's critical date (Compl. p. 7).

Identified Points of Contention

• Scope Questions: The central dispute is not over claim scope versus product functionality in a traditional infringement sense. Rather, it is whether the features of the products Plaintiff sold before the critical date of September 19, 2023, fall within the scope of the ’337 Patent's claims. An affirmative answer may lead to a judgment of invalidity, while a negative answer may lead to a judgment of non-infringement.
• Technical Questions: A key evidentiary question will be whether Plaintiff can provide clear and convincing evidence that the specific "rotating desk organizers" sold in the U.S. starting in May 2023 possessed all the structural elements required by the asserted independent claims, particularly the specific "resistance reducing device" (Claim 1) or "rotating bracket" and "guide rail" (Claim 16).

V. Key Claim Terms for Construction

The complaint does not propose constructions for any claim terms. However, based on the technology and the nature of the invalidity defense, the following terms may be central to the dispute.

• The Term: "resistance reducing device" (Claim 1)
• Context and Importance: The definition of this term is critical because it describes the core mechanism enabling the product's key feature—rotation. Plaintiff's on-sale bar defense will require proving that the products it sold prior to the critical date included a structure meeting this limitation. Practitioners may focus on whether this term should be limited to the specific ball-and-bracket embodiment described in the patent or if it can encompass other rotational mechanisms.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself, "resistance reducing device," is functional language, which could suggest a broader scope covering any component that reduces friction during rotation.
  • Evidence for a Narrower Interpretation: Claim 1 further defines the device structurally as comprising a "bracket (5) and balls (4)" arranged within a "bracket groove (11)" with specific height requirements. The specification heavily focuses on this ball bearing-like embodiment, showing it in detail in Figures 4, 7, and 9, which may support an interpretation limiting the term to this specific structure (Compl. Ex. 1, ’337 Patent, col. 4:24-44).

VI. Other Allegations

Willful Infringement

Not applicable, as this is a declaratory judgment action filed by the accused infringer. Instead, Plaintiff alleges Defendants engaged in "bad-faith enforcement" by submitting infringement complaints to Amazon, allegedly with knowledge that the ’337 Patent was invalid due to prior public sales of the invention (Compl. ¶¶27, 31).

Fraudulent Procurement and Sham Litigation

The complaint alleges that the ’337 Patent is unenforceable due to inequitable conduct and was procured by fraud on the USPTO (Compl. ¶40). Plaintiff asserts that Defendants knew the claimed invention was already on sale but intentionally failed to disclose this material prior art to the patent examiner, forming the basis for a Walker Process antitrust claim (Compl. ¶¶68-71). Plaintiff further alleges that Defendants' enforcement actions on Amazon constitute objectively baseless sham litigation intended to harm a competitor (Compl. ¶¶79, 82).

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

This case appears to be less about nuanced claim construction and more about the factual record of events preceding the patent application. The central questions for the court will likely be:

• A primary question of invalidity based on prior art: Can the Plaintiff establish with clear and convincing evidence that its rotating desk organizers—or other substantially similar products—were publicly sold in the United States before September 19, 2023, thereby creating an on-sale bar that invalidates the asserted claims of the ’337 Patent?
• A fundamental question of patentee conduct: Did the inventor and assignee of the ’337 Patent know of these prior public sales when prosecuting the patent application, and did they intentionally conceal this information from the USPTO? The resolution of this issue is central to the claims of inequitable conduct and fraudulent procurement.
• An issue of enforcement legitimacy: Were the Defendants’ infringement complaints to Amazon objectively baseless, as Plaintiff alleges? The answer will determine the viability of Plaintiff’s claims for anticompetitive conduct and sham enforcement, turning on whether a reasonable patent holder could have believed the ’337 Patent was valid and infringed.