DCT
2:25-cv-02314
Youxiangongsi v. Torrx Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhenshi Daosishangmao Youxiangongsi d/b/a Shenzhen Daosi Trading Co., Ltd. (China)
- Defendant: TorrX, Inc. (Washington)
- Plaintiff’s Counsel: Corr Cronin LLP
- Case Identification: 2:25-cv-02314, W.D. Wash., 11/18/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides and has a physical address in the district, and because Defendant initiated patent enforcement actions through Amazon.com's complaint program, which is administered from its offices in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its electronic ball pump does not infringe Defendant’s patent related to automatic electronic air pumps.
- Technical Context: The technology concerns portable electronic air pumps that can automatically inflate or deflate objects like sports balls to a pre-set target pressure.
- Key Procedural History: The complaint states this action was precipitated by Defendant TorrX filing a patent infringement complaint against Plaintiff Daosi through the Amazon Patent Evaluation Express (APEX) program, which resulted in Amazon removing the listings for Plaintiff’s product.
Case Timeline
| Date | Event |
|---|---|
| 2014-11-25 | ’339 Patent Priority Date |
| 2021-08-10 | ’339 Patent Issue Date |
| Prior to 2025-09-26 | Defendant sends patent infringement complaint to Amazon.com |
| 2025-09-26 | Plaintiff receives notice of the complaint from Amazon.com |
| 2025-10-21 | Plaintiff receives notice that its product listings have been removed by Amazon.com |
| 2025-11-18 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,084,339 - "AUTOMATIC ELECTRONIC AIR PUMP", issued August 10, 2021
The Invention Explained
- Problem Addressed: The patent’s background section describes the shortcomings of conventional hand-held air pumps, noting that they are slow, make it difficult to achieve a correct pressure without a separate gauge, and can cause inflation needles to bend or break due to torsion. (’339 Patent, col. 1:25-32).
- The Patented Solution: The patent discloses a portable electronic air pump that operates in both a manual mode and an "automatic mode." In automatic mode, a user sets a target pressure, and a microcontroller then manages the inflation or deflation process to precisely match that target. (’339 Patent, Abstract). The system logic, shown in flowcharts like FIG. 5, involves measuring the current pressure, comparing it to the target, and then either actuating a pump motor to inflate or opening a solenoid valve to deflate the object. (’339 Patent, col. 4:7-25).
- Technical Importance: The invention provides a method for achieving precise, automated, and reliable inflation for objects like sports balls, intended to improve convenience and prevent damage to the equipment or unsatisfactory performance. (’339 Patent, col. 1:25-28).
Key Claims at a Glance
The complaint seeks a declaratory judgment of non-infringement for independent claims 1, 6, and 12. (Compl. ¶¶18, 21, 24).
- Independent Claim 1 (System):
- A processor and non-transitory medium with instructions to receive a target pressure, measure a current pressure, and determine if the current pressure is greater than the target.
- If the current pressure is greater, further instructions cause the processor to:
- automatically deflate the object for a predetermined time period;
- wait a specified period of time after closing a solenoid valve before measuring a second air pressure; and
- output an indication that the target pressure has been reached.
- Independent Claim 6 (System):
- A processor and non-transitory medium with instructions to receive a target pressure and measure a current pressure.
- The measurement step comprises averaging a plurality of air pressure sample measurements taken at specified intervals.
- If the current pressure is less than the target, further instructions cause the processor to:
- automatically inflate the object for a predetermined time period; and
- output an indication that the target pressure has been reached.
- Independent Claim 12 (Non-transitory medium):
- A non-transitory computer-readable medium with instructions that, when executed, cause a processor to perform steps similar to claim 6, including receiving a target pressure and measuring current pressure by averaging a plurality of samples.
- If the current pressure is less than the target, further instructions cause the processor to inflate the object by actuating a pump motor for a predetermined time and output an indication of completion.
The complaint also seeks a declaration of non-infringement for dependent claims corresponding to the asserted independent claims. (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
The accused product is an "electronic ball pump" sold by Plaintiff on Amazon.com under the identifier ASIN B0FJRMCZR5, referred to in the complaint as the "Product-at-Issue." (Compl. ¶10).
Functionality and Market Context
- The complaint does not provide a detailed technical description of how the Product-at-Issue operates. Instead, it makes negative assertions, stating that the product lacks specific features recited in the asserted claims of the ’339 Patent. (Compl. ¶¶19, 22, 25).
- The complaint alleges that sales of the Product-at-Issue on Amazon.com represent a substantial share of Plaintiff's business and that the removal of its listings threatens to cause substantial harm. (Compl. ¶15).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, and its allegations are framed as denials that the Product-at-Issue meets certain claim limitations.
No probative visual evidence provided in complaint.
’339 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| automatically deflate, by the electronic air pump, the object for a predetermined time period | The complaint alleges the Product-at-Issue does not perform this function. | ¶19 | col. 8:1-4 |
| wait a specified period of time after closing a solenoid valve before measuring a second air pressure of the object | The complaint alleges the Product-at-Issue does not perform this function. | ¶19 | col. 8:7-9 |
’339 Patent Infringement Allegations (Claims 6 & 12)
| Claim Element (from Independent Claims 6 & 12) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| measuring the current air pressure of the object comprises averaging a plurality of air pressure sample measurements taken at specified intervals | The complaint alleges the Product-at-Issue does not perform this function. | ¶¶22, 25 | col. 5:37-41 |
| automatically inflate, by the electronic air pump, the object for a predetermined time period | The complaint alleges the Product-at-Issue does not perform this function. | ¶¶22, 25 | col. 7:51-56 |
Identified Points of Contention
- Scope Questions: The dispute may turn on the construction of key phrases. For claim 1, a question is whether "wait a specified period of time" requires a discrete, programmed delay for pressure stabilization, as described in the specification, or if any inherent system latency between valve closure and measurement suffices. For claims 6 and 12, a question is whether "averaging a plurality of... measurements" requires the specific multi-sample process detailed in an embodiment, or if it could read on more general forms of digital sensor signal filtering.
- Technical Questions: The complaint provides no affirmative technical details about the Product-at-Issue. A central question for the court will be establishing the actual functionality of the accused device, specifically how its pressure measurement sensors operate and how its deflation process is controlled, in order to compare it to the claim limitations.
V. Key Claim Terms for Construction
The Term: "wait a specified period of time after closing a solenoid valve before measuring a second air pressure of the object" (Claim 1)
- Context and Importance: Plaintiff's non-infringement defense for claim 1 rests in part on this limitation. (Compl. ¶19). Its construction will be critical. Practitioners may focus on this term because the patent specification links this "wait" to a specific technical purpose—"pressure stabilization"—which may suggest a narrower meaning than the plain words alone.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not state the purpose or required duration of the "wait," which could support an argument that any non-zero delay between the two actions meets the limitation.
- Evidence for a Narrower Interpretation: The detailed description explicitly states that after closing the solenoid valve, the pump "waits a set period of time (e.g., 0.5 millisecond) for pressure stabilization prior to measuring the pressure." (’339 Patent, col. 8:7-9; see also col. 7:26-29). This language suggests the "wait" is a deliberate, functional step, not an incidental or inherent system lag.
The Term: "averaging a plurality of air pressure sample measurements taken at specified intervals" (Claims 6, 12)
- Context and Importance: Plaintiff denies that its product performs this specific type of measurement. (Compl. ¶¶22, 25). The viability of its non-infringement argument for claims 6 and 12 depends on whether the accused device's pressure sensing method falls outside the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue this language covers any form of digital signal processing or smoothing that inherently uses multiple data points over a time interval to derive a stable pressure reading.
- Evidence for a Narrower Interpretation: The specification discloses a specific implementation where the "pressure sensor 335 takes ten air pressure sample measurements at 0.5 milliseconds intervals then averages them together to generate a usable air pressure measurement." (’339 Patent, col. 5:37-41). This explicit example could be used to argue that the claim requires a discrete multi-sampling and mathematical averaging routine, rather than generic signal conditioning.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment that Plaintiff, its customers, distributors, and end-users have not induced infringement or contributorily infringed any claim of the ’339 Patent. (Compl. ¶¶28-29; Prayer for Relief ¶a).
- Willful Infringement: The complaint seeks a declaration that any infringement was not willful. (Compl., Prayer for Relief ¶b).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary proof: what is the precise software logic and hardware operation of the accused product? The complaint’s denials of infringement create a factual dispute that will require technical evidence, likely obtained through discovery, to resolve how the product actually measures pressure and controls deflation.
- The case will also likely involve a core question of claim construction: do the phrases "wait a specified period of time" and "averaging a plurality of... measurements" require the specific, purpose-driven implementations detailed in the patent’s specification, or can they be interpreted more broadly to encompass inherent system delays or generic digital signal filtering techniques?