DCT

2:25-cv-02171

Hangzhou Yanhan Intelligent Technology Co Ltd v. Bryan Richards

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-02171, W.D. Wash., 11/01/2025
  • Venue Allegations: Plaintiffs allege venue is proper in the Western District of Washington because the Defendant purposefully directed patent enforcement communications to Amazon personnel located in Seattle, causing the removal of Plaintiffs' product listings and giving rise to the action within the district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their Christmas tree stand products do not infringe Defendant’s patent related to a foldable tree stand, and/or that the patent is invalid.
  • Technical Context: The technology concerns mechanical stands for artificial Christmas trees, specifically the design of foldable leg mechanisms that provide stability during use and allow for compact storage.
  • Key Procedural History: This action was precipitated by Defendant’s patent infringement complaint submitted to Amazon, which resulted in the removal of Plaintiffs' product listings. This enforcement activity forms the basis for the "actual case or controversy" required for a declaratory judgment action.

Case Timeline

Date Event
2022-10-11 ’392 Patent Filing (Priority) Date
2023-09-05 ’392 Patent Issue Date
2025-10-22 Amazon notifies Plaintiff of Defendant's infringement complaint
2025-11-01 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,744,392 - "Christmas Tree Stand for Artificial Trees"

The Invention Explained

  • Problem Addressed: The patent background identifies a need for a Christmas tree stand that can effectively secure an artificial tree, hold it safely in an upright position (including adjustments to compensate for an unlevel floor), and be easily reconfigured between a use configuration and a storage configuration. (’392 Patent, col. 1:12-23).
  • The Patented Solution: The invention is a foldable stand featuring a central hollow tube to receive the tree trunk and a "plurality of locking-folding mechanisms" for the legs. (’392 Patent, Abstract). The core of this mechanism, as described in the specification, involves two curved, parallel plates positioned on opposite sides of each leg. (’392 Patent, col. 4:18-21). These plates contain at least two distinct notches that engage with pins extending from the sides of the leg, allowing each leg to be securely locked in either a horizontal (use) position or a vertical (storage) position. (’392 Patent, col. 4:22-29; col. 5:5-10).
  • Technical Importance: The design purports to offer a robust and discrete locking system for foldable legs, intended to improve stability and provide a simple mechanical means for transitioning the stand between operative and storage states. (’392 Patent, col. 6:5-10).

Key Claims at a Glance

  • The complaint challenges claims 1-17, focusing on independent claims 1 and 17. (Compl. ¶28, ¶31).
  • Independent Claim 1 recites a Christmas tree stand comprising essential elements including:
    • A base.
    • A hollow tubular member extending from the base.
    • A plurality of movable elongated leg members.
    • A plurality of locking-folding mechanisms, wherein each mechanism comprises:
      • "two curved parallel plates positioned... on opposite sides of a respective movable elongated leg member".
      • "each plate comprises at least a first notch and a second notch".
      • Each leg member comprises a "pin extending from the movable elongated leg member on each side".
      • The pins are configured to engage "with the first notches or with the second notches".
  • The complaint notes that because dependent claims 2-16 and independent claim 17 incorporate the same two-plate, dual-notch geometry, they are likewise not infringed. (Compl. ¶31).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are Christmas tree stands manufactured by Plaintiff Yanhan and sold by Plaintiff NEZHEIZERY on Amazon, identified at least by ASINs B0FM3CNZBM and B0FM3CRDWR. (Compl. ¶1, ¶8, ¶12).

Functionality and Market Context

  • The complaint describes the Accused Products as having four foldable legs arranged around a central tube. (Compl. ¶19). Crucially, the complaint alleges that the leg retention mechanism is not the claimed two-plate system, but rather "a single hinged swivel-hasp plate on one side of the leg." (Compl. ¶19). This single plate is described as co-rotating with the leg to function as a hinged stop or retainer. (Compl. ¶20).
  • The complaint provides a side-by-side visual comparison in Figure 1, contrasting a figure from the ’392 Patent with a photograph of the Accused Product to highlight the alleged structural differences. (Compl. p. 5, Figure 1).
  • The complaint alleges that the Amazon marketplace is Plaintiffs' primary sales channel in the United States, and the delisting of the Accused Products has caused significant and irreparable harm. (Compl. ¶11, ¶16).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following chart summarizes Plaintiffs' non-infringement positions with respect to Claim 1.

’392 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
each locking-folding mechanism comprises two curved parallel plates positioned adjacent to the base and the hollow tubular member on opposite sides of a respective movable elongated leg member The Accused Products use a "single hinged swivel-hasp plate mounted to the base" on only one side of the leg; it lacks a second, opposing plate and does not have plates that straddle the leg. ¶29 col. 8:38-44
each plate comprises at least a first notch and a second notch each extending partly from the curved side into the plate The single plate on the accused product is alleged to have a smooth surface and lacks the claimed first and second notches for selective locking. ¶20, ¶29 col. 8:45-49
the pins of each movable elongated leg member are configured to engage respectively with the first notches or with the second notches of a respective locking-folding mechanism The Accused Product is alleged not to employ any "pin-in-notch engagement," instead relying on the single hasp plate acting as a physical stop. ¶20, ¶29 col. 8:53-57
  • The complaint includes a close-up photograph in Figure 2 contrasting the claimed locking mechanism with the accused single swivel hasp. (Compl. p. 6, Figure 2).
  • Identified Points of Contention:
    • Scope Questions: A central dispute will be whether the claim term "locking-folding mechanism," which is explicitly defined in the claim as having a two-plate structure, can be read to cover the accused product's single-plate hasp system. The complaint argues this would be improper, as it would "vitiate" an express claim limitation. (Compl. ¶30).
    • Technical Questions: The analysis will raise the question of whether the accused single-hasp stop mechanism operates in a "materially different way" and produces a "different result" compared to the claimed two-plate, pin-in-notch system, as Plaintiffs allege. (Compl. ¶30). This suggests a potential dispute under the doctrine of equivalents.

V. Key Claim Terms for Construction

  • The Term: "locking-folding mechanism"
  • Context and Importance: This term is the locus of the non-infringement dispute. Its construction will likely be dispositive. The Plaintiffs' case rests on the argument that their single-plate hasp falls outside the specific structural definition provided for this term within the claim itself.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party seeking a broader interpretation might argue that the term should be understood functionally to encompass any structure that locks a folding leg. However, the patent provides little support for a purely functional definition, as the claim language itself is highly structural.
    • Evidence for a Narrower Interpretation: The claim language provides its own lexicon by stating the mechanism "comprises two curved parallel plates positioned... on opposite sides of a respective movable elongated leg member." (’392 Patent, col. 8:38-44). The specification reinforces this narrow, structural definition. (’392 Patent, col. 4:18-29). Practitioners may focus on this explicit definition as strong evidence that the patentee defined the term to require the two-plate structure, thereby excluding single-plate designs.

VI. Other Allegations

  • Indirect Infringement: The complaint preemptively denies any basis for indirect infringement. It alleges that Plaintiffs have not instructed any infringing use and that the Accused Products are staple articles of commerce with substantial non-infringing uses, thereby negating claims for either induced or contributory infringement. (Compl. ¶32).

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

The resolution of this declaratory judgment action appears to hinge on two primary questions for the court:

  1. A core issue will be one of definitional scope: Is the claim term "locking-folding mechanism" strictly limited by the claim's explicit recitation of a "two curved parallel plates... on opposite sides" structure, or could it be construed more broadly to cover other mechanical arrangements that achieve a similar purpose?
  2. A key evidentiary question will be one of structural and functional difference: If not literally infringed, does the accused product's single-plate swivel hasp function in a substantially different way and achieve a different result than the claimed two-plate, pin-in-notch locking system, thereby precluding a finding of infringement under the doctrine of equivalents?