DCT
2:26-cv-00216
Dongguan Sanqishi Technology Co Ltd v. Anker Innovations Technology Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Sanqishi Technology Co., Ltd. (China)
- Defendant: Anker Innovations Technology Co., Ltd. (China)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:26-cv-00216, W.D. Wash., 01/20/2026
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon patent-enforcement proceeding, which foreseeably caused actions by Amazon personnel located in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its desktop charging station products do not infringe Defendant’s patent related to charging devices with movable components.
- Technical Context: The technology concerns multi-device charging stations that incorporate movable or retractable elements to achieve a compact design for portability and use.
- Key Procedural History: The complaint states that this declaratory judgment action was precipitated by Defendant causing Amazon to remove Plaintiff's product listings on December 24, 2025, based on a patent-infringement report. This event is cited as the basis for an actual case or controversy between the parties.
Case Timeline
| Date | Event |
|---|---|
| 2022-03-10 | ’149 Patent Priority Date |
| 2024-08-26 | ’149 Patent Application Filing Date |
| 2025-05-27 | ’149 Patent Issue Date |
| 2025-12-24 | Amazon Takedown Notice Issued to Plaintiff |
| 2026-01-20 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,316,149 - *"Charging device with movable board"*
- Patent Identification: U.S. Patent No. 12,316,149, "Charging device with movable board," issued May 27, 2025 (the "’149 Patent").
The Invention Explained
- Problem Addressed: The patent’s background section identifies a problem with existing charging equipment being insufficiently compact, occupying a large space, and being inconvenient for users to carry (ʼ149 Patent, col. 1:24-28).
- The Patented Solution: The invention discloses a charging device with a housing that contains an internal "accommodating chamber" or cavity. A key feature is a "moving member" (e.g., a movable board) with charging circuitry, which can extend out from or retract into the housing. This allows the device to maintain a small overall volume for transport while providing an extendable surface for charging an electronic device when in use (’149 Patent, Abstract; col. 3:1-12). The design also contemplates a "flip cover" that can support charging another device (’149 Patent, col. 8:10-14).
- Technical Importance: This approach aims to combine multi-device charging functionality with a compact, portable form factor, addressing a consumer demand for versatile and space-saving electronic accessories.
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1, 14, and 20 (Compl. ¶¶ 19, 23, 26).
- Independent Claim 1 recites the following essential elements:
- A housing comprising a cavity, a body, and a flip cover, wherein the flip cover is pivotably connected to the body.
- A movable board comprising charging circuitry, configured to slide relative to the cavity.
- A power interface electrically connected to an external power supply to transmit power to the charging circuitry.
- The complaint notes that because the independent claims are not infringed, no dependent claims are infringed (Compl. ¶ 31).
III. The Accused Instrumentality
Product Identification
The "Accused Products" are Plaintiff's "desktop charging station products" sold on Amazon.com under ASINs B0DT1316TR and B0F5VQXY35 (Compl. ¶¶ 22, 24).
Functionality and Market Context
- The complaint alleges that the Accused Products feature a flip cover whose movement is "governed by an internal guided mechanism implemented on a movable internal subassembly that translates during use" (Compl. ¶ 20).
- It is specifically alleged that the cover is not coupled to the device body via a "body-anchored pivot axis" and that any angular change in the cover's orientation occurs relative to the translating subassembly, not the main body (Compl. ¶¶ 20-21).
- The complaint asserts that Amazon is Plaintiff's primary sales channel in the United States and that the removal of its product listings has caused significant commercial harm (Compl. ¶¶ 11-12).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's non-infringement theory for Claim 1.
’149 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing comprising a cavity, a body, and a flip cover, wherein the flip cover is pivotably connected to the body | The complaint alleges the Accused Products lack this feature because the flip cover is not coupled to the body through a body-anchored pivot axis. Instead, the cover's motion is allegedly governed by a translating internal subassembly. | ¶¶ 19-21 | col. 9:46-49 |
- Identified Points of Contention:
- Scope Questions: The primary dispute appears to center on the construction of the phrase "pivotably connected to the body." A central question will be whether this limitation requires a pivot axis that is fixed relative to the housing body, or if it can be read to cover a mechanism where the point of rotation itself translates relative to the body during operation.
- Technical Questions: A key factual question is the precise kinematic operation of the Accused Products' flip cover. The complaint alleges that the pivot axis of the cover "shifts position relative to the body during operation," a technical assertion that will require evidentiary support (Compl. ¶ 21). The complaint references "Exhibit C" to show the internal structure, but this exhibit was not included in the filing (Compl. ¶ 20). No probative visual evidence provided in complaint.
V. Key Claim Terms for Construction
- The Term: "pivotably connected to the body" (Claim 1)
- Context and Importance: This term is central to the non-infringement arguments for both Claim 1 and Claim 14 (Compl. ¶¶ 19, 23). Plaintiff contends its products employ a translating mechanism, not a "pivotably connected" one, defining "pivotably" to mean rotation about a fixed, body-anchored axis (Compl. ¶¶ 20-21). The outcome of the case may depend heavily on the court's construction of this phrase.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states the "flip cover is rotatably (e.g., pivotably) provided on... the housing body" (’149 Patent, col. 7:11-13). A party might argue that "pivotably" is merely an example of "rotatably" and does not strictly require a fixed-axis pivot, potentially encompassing more complex linkages that result in rotation.
- Evidence for a Narrower Interpretation: The specification discloses an embodiment where the flip cover is coupled to the body "through the damping rotating shaft" (’149 Patent, col. 9:43-44). Furthermore, independent Claim 20 recites a flip cover "pivotably coupled to the body via a rotating shaft" (’149 Patent, col. 12:22-24). A party may argue that these more specific disclosures limit the general term "pivotably connected" to a conventional, shaft-based rotational joint with a fixed axis relative to the body.
VI. Other Allegations
- Indirect Infringement: The complaint affirmatively pleads that Plaintiff does not indirectly infringe the ’149 Patent. It alleges a lack of intent for inducement and states that the Accused Products are "staple articles of commerce with substantial non-infringing uses," thereby negating contributory infringement (Compl. ¶ 32).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action will likely depend on the court’s determination of the following key questions:
A question of claim construction: What is the proper scope of the term "pivotably connected to the body" as used in Claims 1 and 14? The case appears to turn on whether this phrase mandates a rotational connection with a fixed pivot axis relative to the device's main body, as Plaintiff argues, or if it can be construed more broadly to encompass other kinematic arrangements that produce rotational motion.
A question of technical fact: What is the actual mechanism of operation of the Accused Products' flip cover? An evidentiary showing will be required to establish whether the cover's movement is based on the "translating internal subassembly" alleged in the complaint and whether that mechanism falls outside the properly construed scope of the asserted claims.