Shenzhen Jing Cheng Dianzi Keji Yanfa Co Ltd v. Spectrum Products LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Jing Cheng DianZi Keji YanFa Co. Ltd. (China)
  • Defendant: Spectrum Products LLC d/b/a Eureka Air (Arizona)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 2:26-cv-00445, D. Ariz., 01/22/2026
• Venue Allegations: Venue is alleged to be proper in the District of Arizona because the Defendant, Spectrum Products LLC, is a resident of and maintains its principal place of business within the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its air deflector products do not infringe Defendant’s patent and, in the alternative, that the patent is invalid as anticipated by prior art.
• Technical Context: The dispute concerns magnetically attachable air deflectors, which are accessories placed over HVAC vents to redirect airflow.
• Key Procedural History: The complaint states this action was precipitated by Defendant filing intellectual property complaints with Amazon.com, which resulted in the removal of Plaintiff's products from the e-commerce platform, creating the basis for an actual controversy required for a declaratory judgment action.

Case Timeline

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

U.S. Patent No. 12,000,616 - "Air deflector system"

• Issued: June 4, 2024

The Invention Explained

• Problem Addressed: The patent addresses the general need for vent deflectors to redirect airflow from HVAC vents to improve heating and cooling efficiency (’616 Patent, col. 1:23-29). The implicit technical challenge is to provide a secure and robust method for attaching these deflectors to various metal vent grilles.
• The Patented Solution: The invention is a system for securing an air deflector using a specific magnet retainer structure. This retainer, extending from the deflector's sidewall, includes walls and ledges designed to hold a magnet in a specific orientation ('616 Patent, col. 3:31-37). The specification highlights the benefit of orienting the magnet so that its "largest surface" is parallel to the vent grille, thereby increasing the surface area contact and creating a stronger magnetic bond ('616 Patent, col. 8:25-34).
• Technical Importance: By specifying a retainer structure that orients the magnet for maximum surface area contact with the vent, the invention purports to provide a more secure attachment than might be achieved with other magnet configurations ('616 Patent, col. 8:25-34).

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement with respect to all claims, focusing on independent claims 1, 10, and 15 Compl. ¶¶18, 20, 21
• Independent Claim 1 recites the following essential elements:
  • An air deflector with a first and second sidewall.
  • A magnet retainer extending from the first sidewall, comprising a first and second retainer wall.
  • A magnet positioned between the retainer walls, where the magnet has a "largest planar surface" and an "exposed surface opposite the largest planar surface."
  • The retainer walls each have a ledge to directly couple to the magnet.
  • The "exposed surface" is configured to form a magnetic bond with and face an external surface (e.g., a vent grille).
• The complaint notes that if the independent claims are not infringed, no dependent claims can be infringed Compl. ¶19, ¶22

III. The Accused Instrumentality

Product Identification

The complaint identifies Plaintiff’s "airflow deflection devices" sold on Amazon.com under ASINs B0B5RJPMCS, B0C7QXCLTY, and B0B28YP22V Compl. ¶¶11-12

Functionality and Market Context

The products are described as devices used by placing them over an air vent to redirect the flow of air Compl. ¶11 The complaint states that Defendant’s actions asserting the ’616 Patent against these products led to their removal from Amazon, tarnishing Plaintiff's reputation and causing lost profit Compl. ¶¶13, 16

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiff's arguments for why its products do not meet the limitations of the asserted claims.

Claim Chart Summary

Identified Points of Contention

• Scope Questions: The central non-infringement argument turns on the geometric relationship between the magnet's "largest planar surface" and its "exposed surface." A primary question for the court will be whether the claim term "opposite" requires the two surfaces to be in a parallel configuration (like the top and bottom of a rectangular magnet), or if it can be construed more broadly to cover the perpendicular arrangement present in the accused products. The complaint's visual evidence highlights this alleged mismatch in orientation Compl. p.5
• Invalidity Questions: The complaint raises a contingent invalidity argument. It posits that if the claim term "opposite" is interpreted broadly enough to cover the Plaintiff's perpendicular magnet orientation, then the claim would also be anticipated by prior art products, such as the "Home Intuition Heat and Air Vent Deflector" and the "Frost King Unbreakable Heat and Air Deflector" Compl. ¶¶23-24, 28 The complaint alleges these products were publicly available before the '616 Patent's priority date and also employ magnets with a similar perpendicular orientation Compl. ¶26 An image from the "Home Intuition" product listing is provided to illustrate its structure Compl. p.7

V. Key Claim Terms for Construction

• The Term: "an exposed surface opposite the largest planar surface"
• Context and Importance: This phrase appears in all three independent claims Compl. ¶¶19-21 and is the focal point of the non-infringement argument. The construction of "opposite" will be dispositive; a narrow, parallel-only construction may support a finding of non-infringement, while a broader construction could bring the accused products within the claim's scope but may implicate the cited prior art.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patentee (Defendant) may argue that the plain and ordinary meaning of "opposite" does not strictly require a parallel orientation, but can simply mean on the other side of the magnet's center of mass. The claim language itself does not contain an explicit "parallel" limitation.
  • Evidence for a Narrower Interpretation: The declaratory judgment plaintiff will likely point to the specification, which states that orienting the "largest surface of the magnet ... parallel to the surface the air deflector is to be coupled to" results in "increased strength due to the increased surface area" ('616 Patent, col. 8:28-34). This passage suggests that the patent teaches a parallel orientation to achieve its technical objective, which could support construing "opposite" to mean parallel.

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

This declaratory judgment action appears to center on two critical, interrelated questions for the court:

• A core issue will be one of definitional scope: Does the claim phrase "exposed surface opposite the largest planar surface" require a parallel geometric orientation, as suggested by the patent’s stated purpose of maximizing magnetic strength, or can it be construed more broadly to encompass the perpendicular orientation found in the Plaintiff's products?
• A second issue presents a strategic dilemma for the patentee: If the patentee successfully argues for a broad construction of "opposite" that covers the accused products, will that same construction render the patent invalid as anticipated by prior art products that allegedly feature the same magnet orientation and predate the patent's priority date?