Lojek v. Henan Ocean Power Housewares Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Steven Lojek (New Jersey)
  • Defendant: Henan Ocean Power Housewares Co., Ltd.; Henan Dongzhi Value Trading Co., Ltd.; et al. (People's Republic of China)
  • Plaintiff’s Counsel: Steven Lojek, Pro Se
• Case Identification: 2:25-cv-02449, W.D. Wash., 12/03/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendants transact business in the district through Amazon's facilities and infrastructure, fulfill Amazon FBA orders to U.S. addresses, and advertise infringing products on Amazon.com.
• Core Dispute: Plaintiff alleges that Defendants’ hinge-style weight-stack selector pins infringe a patent related to an automatically ejecting selector pin for exercise equipment.
• Technical Context: The technology concerns selector pins for "selectorized" weight stack exercise machines, enabling users to perform "drop sets" by automatically reducing resistance during an exercise without manual intervention.
• Key Procedural History: The complaint alleges that Defendant Henan Dongzhi Value Trading Co., Ltd. previously participated in an Amazon Patent Evaluation (APEX) proceeding where it was provided with the patent-in-suit and Plaintiff's infringement contentions, a fact central to the willfulness allegations.

Case Timeline

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

U.S. Patent No. 9,468,791 - "Selectorized Weight Stack Ejecting Pin"

The Invention Explained

• Problem Addressed: The patent addresses the challenge in resistance training where a user reaches momentary muscular failure but could continue exercising if the weight were quickly reduced. Manually stopping to change a standard selector pin is described as disruptive and "counterproductive" to the training session (’791 Patent, col. 1:47-59).
• The Patented Solution: The invention is a portable, mechanical selector pin that automatically ejects from the weight stack when the weights are returned to a resting position. This is achieved through a "biasing means" (e.g., a spring) held in a compressed, "loaded" state by a "trigger latch." A portion of the latch engages a lower, unoccupied weight plate slot. When the user lifts and then lowers the selected weight, the movement disengages the latch. Once the stack is at rest and friction is relieved, the stored energy in the spring ejects the pin, allowing the user to seamlessly continue with a pre-selected lower weight (’791 Patent, Abstract; col. 4:50-68).
• Technical Importance: The invention provides a portable device that enables users to perform descending resistance "drop sets" on conventional selectorized equipment without requiring an assistant or permanent equipment modifications (’791 Patent, col. 3:7-14).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶2, ¶16).
• The essential elements of Claim 1 include:
  • A pin shaft with a proximal end and a distal end.
  • A body slidably positioned on the pin shaft between a loaded and a released position.
  • A biasing means (e.g., a spring) that is compressed when the body is in the loaded position.
  • A trigger latch coupled to the pin shaft, comprising:
    • A first extension that selectively contacts the body to maintain the loaded position.
    • A second extension configured for insertion into a second (lower) selector slot.

III. The Accused Instrumentality

Product Identification

The accused products are "hinge-style weight-stack selector pin" devices (Compl. ¶7).

Functionality and Market Context

The complaint alleges that the accused devices are "substantially identical in size, structure, function, and operation to Plaintiff's patented design" and that they embody every element of Claim 1 (’791 Patent, col. 6:36-68; Compl. ¶16). The products are allegedly manufactured by a coordinated group of entities in China and sold into the United States through e-commerce platforms like Amazon.com and Alibaba.com (Compl. ¶¶4-7, ¶17). The complaint provides visual side-by-side comparisons of the accused device and Plaintiff's product to demonstrate the alleged structural similarities (Compl. Ex. H).

IV. Analysis of Infringement Allegations

’791 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether the term "trigger latch," as described in the patent with distinct "first" and "second" extensions, can be construed to read on the accused product's "hinge-style" mechanism. The complaint presents side-by-side cutaways to argue for structural identity (Compl. Ex. G).
• Technical Questions: What evidence does the complaint provide that the accused product's release is caused by the "removal of the first extension from contact with the body" in the specific manner claimed? The analysis will likely focus on whether the accused mechanism operates in the same way as the patented invention, or in a substantially different way.

V. Key Claim Terms for Construction

• The Term: "trigger latch"

  • Context and Importance: This term is the central novel component of the invention, responsible for holding and releasing the stored energy of the biasing means. The infringement analysis will depend entirely on whether the accused product's "hinge-style" mechanism falls within the scope of this term.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discloses several different embodiments for the trigger latch, including a wire-form latch (Fig. 8), a latch that fits into a groove on the pin shaft (Fig. 10), and a pivoting latch within a fully enclosed body (Fig. 13) (’791 Patent, col. 5:4-35). Plaintiff may argue this disclosure supports a broad functional definition covering any mechanical means that performs the claimed latching and releasing functions.
    • Evidence for a Narrower Interpretation: Defendants may argue that the term requires the specific structural relationship described in Claim 1, namely a "first extension that selectively contacts the body" and a separate "second extension that is configured to be inserted within a second selector slot" (’791 Patent, col. 6:57-62). They could contend that their single-piece hinge does not have these distinct, separately functioning extensions.

• The Term: "selectively contacts the body to maintain the loaded position"

  • Context and Importance: This phrase describes the function of the "first extension" of the trigger latch. Proving that the accused product performs this exact function in the same way is critical for showing literal infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional. Plaintiff may argue that any part of the accused hinge mechanism that holds the slidable body in place against the force of the spring meets this limitation, regardless of its specific shape or form of contact.
    • Evidence for a Narrower Interpretation: The patent’s preferred embodiment shows a latch extension engaging a specific opening (8) in the body to hold it in place (’791 Patent, Fig. 13, Fig. 15). A defendant could argue this functional language is implicitly limited to the specific type of direct contact and engagement shown in the patent's figures.

VI. Other Allegations

Willful Infringement

The complaint includes a separate count for willful infringement (Compl. ¶¶32-33). The primary basis for this allegation is Defendants' alleged "actual knowledge" of the ’791 Patent, which they obtained during their participation in an Amazon Patent Evaluation Express (APEX) proceeding in 2025 where Plaintiff's patent and infringement contentions were provided to them (Compl. ¶33). The complaint alleges that Defendants continued their infringing activities despite this notice.

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

• A core issue will be one of claim construction: does the term "trigger latch," which is defined in the patent as having distinct first and second extensions performing specific functions, read on the accused product's integrated "hinge-style" mechanism? The outcome may depend on whether the court adopts a broader functional interpretation based on the specification's multiple embodiments or a narrower structural one.
• A key evidentiary question will be one of operational equivalence: beyond visual similarity, does the accused product's mechanism function in the precise manner required by Claim 1? Specifically, is its spring-loaded body held and released by a component that "selectively contacts the body" and is subsequently removed from contact to trigger ejection, or is there a fundamental difference in its mechanical operation?