DCT
2:25-cv-01707
Fujian Gutian Daxing Import & Export Co Ltd v. Xiamen Sunnypet Products Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fujian Gutian Daxing Import & Export Co., Ltd. d/b/a AIVITUVIN PETS (China)
- Defendant: Xiamen Sunnypet Products Co., Ltd. (China)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-01707, W.D. Wash., 09/04/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant submitted a patent infringement complaint to Amazon.com, Inc., which is headquartered in Seattle, thereby directing enforcement activities at the forum.
- Core Dispute: Plaintiff seeks a declaratory judgment that its pet house products do not infringe Defendant’s patent for a foldable box structure, following Defendant’s infringement report to Amazon which resulted in the removal of Plaintiff's product listings.
- Technical Context: The technology concerns collapsible furniture, specifically pet houses, designed with integrated connectors to simplify assembly and reduce volume for storage and transport.
- Key Procedural History: In August 2025, Plaintiff received a notice from Amazon that its product listings had been removed due to an infringement report filed by Defendant. This complaint for declaratory judgment was filed in direct response to that extra-judicial enforcement action.
Case Timeline
| Date | Event |
|---|---|
| 2017-11-21 | ’510 Patent Priority Date |
| 2020-06-23 | ’510 Patent Issue Date |
| August 2025 | Defendant files infringement report with Amazon.com |
| 2025-09-04 | Complaint for Declaratory Judgment of Non-Infringement Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,687,510 - "Easy-to-Fold and Easy-to-Assemble Box and Pet House Using the Box"
- Issued: June 23, 2020 (’510 Patent)
- Cited in Complaint: (Compl. ¶14, ¶15)
The Invention Explained
- Problem Addressed: The patent's background section describes conventional flat-pack furniture as having too many components, being difficult and time-consuming to assemble, and lacking structural stability once built. (’510 Patent, col. 1:19-32).
- The Patented Solution: The invention is a box structure with an integrated folding mechanism that does not require dismounting connectors. (’510 Patent, col. 3:9-11). The structure includes side panels made of multiple hinged "sideboards" that fold inward, a bottom panel that pivots up against an inner wall, and a top cover that pivots down against an outer wall, creating a compact, layered unit for transport. (’510 Patent, col. 2:65-col. 3:4, Figs. 1-7).
- Technical Importance: This integrated design aims to reduce the difficulty and time of assembly while also decreasing package and storage volume. (’510 Patent, col. 3:15-20).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1. (Compl. ¶18).
- Essential elements of independent claim 1 include:
- A box comprising a left panel, a right panel, a front frame, a rear frame, a bottom panel, and a top cover.
- The left and right panels are formed by connecting two or more sideboards through a rotatable connector.
- The bottom panel has a rotatable connection end and a movable end.
- The rotatable connection end is rotatably connected to a lower part of the front or rear frame.
- The bottom panel is turned upward to abut against an inner wall of the front or rear frame.
- The sideboards of the left and right panels are sequentially folded to make the frames move toward each other to fold the box.
- The complaint notes that because claim 1 is not infringed, dependent claims 2 and 3 are likewise not infringed. (Compl. ¶25).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Aivituvin AIR 100 pet hutch" and "Aivituvin AIR 100-XL-L pet hutch" as the Accused Products. (Compl. ¶22).
Functionality and Market Context
- The complaint alleges the Accused Products are pet houses sold on Amazon, which constitutes Plaintiff's primary U.S. sales channel. (Compl. ¶7, ¶13).
- Functionally, the complaint alleges the AIR 100 model uses "two independent, removable floor plates that are not rotatably connected to any frame" and "cannot be turned upward while attached." (Compl. ¶23).
- For the AIR 100-XL-L model, the complaint alleges it also uses removable floor plates and that its right panel is a "single integral board," not one made of "two or more sideboards." (Compl. ¶24). Plaintiff provides an image in Exhibit C to illustrate the alleged removable floor plates of the AIR 100 product. (Compl. ¶23).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiff's allegations as to why its products do not meet the limitations of claim 1 of the ’510 Patent.
’510 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| the bottom panel has a rotatable connection end and a movable end | Plaintiff alleges the Accused Products use "two independent, removable floor plates that are not rotatably connected to any frame" and thus lack a rotatable connection end. | ¶23 | col. 6:40-42 |
| the rotatable connection end is rotatably connected to a lower part of the front frame or a lower part of the rear frame through a second rotatable connector | Because the floor plates are allegedly removable and not rotatably connected to any frame, this limitation is not met. | ¶23 | col. 6:43-46 |
| the bottom panel is turned upward to abut against an inner wall of the front frame or the rear frame | Plaintiff alleges its floor plates "cannot be turned upward while attached," distinguishing them from the claimed pivoting bottom panel. | ¶23 | col. 6:63-65 |
| wherein the left panel and the right panel are formed by connecting two or more sideboards in a vertical direction through a first rotatable connector | For the AIR 100-XL-L model, Plaintiff alleges its "right panel is a single integral board, not 'two or more sideboards ... sequentially folded.'" | ¶24 | col. 6:37-40 |
Identified Points of Contention
- Scope Questions: A central question is whether the claim term "bottom panel" can be construed to read on the accused "two independent, removable floor plates." (Compl. ¶23). Similarly, for the AIR 100-XL-L model, the dispute will involve whether a "single integral board" falls outside the scope of a panel "formed by connecting two or more sideboards." (Compl. ¶24).
- Technical Questions: The case raises the factual question of whether the accused products' removable floor plates are structurally and functionally different from the claimed "rotatably connected" bottom panel. The complaint alleges that this structural difference results in a different way of assembly and precludes infringement under the doctrine of equivalents. (Compl. ¶23).
V. Key Claim Terms for Construction
Term: "bottom panel has a rotatable connection end"
- Context and Importance: This term is critical because Plaintiff’s primary non-infringement argument is that its products use removable floor plates that are not rotatably connected to the frame. (Compl. ¶23). The construction of "rotatable connection end" will determine whether a completely detachable component can satisfy this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not specify the type of rotatable connector, which could suggest that any means of allowing rotation might suffice. The specification also refers generally to "rotatable connectors." (’510 Patent, col. 4:39-41).
- Evidence for a Narrower Interpretation: The specification consistently describes an integrated structure where the bottom panel is permanently attached and "turned over" or "turned upward." (’510 Patent, col. 3:12-13, col. 4:65-67). Embodiments describe the panel being "rotatably connected... through the rotatable connectors," suggesting a permanent, hinged-type connection rather than a separable one. (’510 Patent, col. 4:38-41).
Term: "panel... formed by connecting two or more sideboards"
- Context and Importance: Plaintiff alleges its AIR 100-XL-L model uses a "single integral board" for its right panel, directly challenging this limitation. (Compl. ¶24). The definition of "formed by" will be key to determining if a single-piece panel can meet this claim element.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "formed by" could encompass a single board that is manufactured to look like multiple connected sideboards (e.g., with grooves), though this interpretation may be difficult to sustain.
- Evidence for a Narrower Interpretation: The patent repeatedly and explicitly describes the panels as being constructed from separate components joined by connectors like hinges. The abstract states the panels "are both formed by connecting two or more sideboards through rotatable connectors," and the summary and detailed description consistently repeat this structural requirement, suggesting it is a fundamental aspect of the invention. (’510 Patent, Abstract; col. 2:44-47; col. 4:26-29).
VI. Other Allegations
The complaint does not contain sufficient detail for analysis of indirect or willful infringement, as it is a declaratory judgment action seeking a finding of non-infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to center on fundamental questions of literal claim scope and structural differences between the patented invention and the accused products. The key questions for the court will likely be:
- A core issue will be one of structural definition: Can the claim term "bottom panel" with a "rotatable connection end" be construed to cover the accused products' two independent and removable floor plates, which allegedly lack any permanent rotatable attachment to the frame?
- A second key issue is one of component construction: For the AIR 100-XL-L product, does its alleged use of a "single integral board" as a side panel place it outside the literal scope of the claim limitation requiring a panel "formed by connecting two or more sideboards"?
- An underlying evidentiary question will be one of functional difference: If the accused products are found not to literally infringe, do the alleged structural differences—removable plates versus a hinged panel—also represent "substantial differences in function, way, and result" sufficient to defeat a claim of infringement under the doctrine of equivalents?