Swift Paws Inc v. Zhende Tech

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Swift Paws, Inc. (Delaware, with principal place of business in Florida)
  • Defendant: ZHENDE TECH, et al. (Foreign entities of unknown makeup)
  • Plaintiff’s Counsel: Lowndes, Drosdick, Doster, Kantor & Reed, P.A.
• Case Identification: 6:26-cv-00259, M.D. Fla., 01/30/2026
• Venue Allegations: Plaintiff alleges that because Defendants do not reside in the United States, venue is proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendants’ pet lure chasing systems, sold through online marketplaces, infringe two U.S. patents related to the mechanical design and safety features of enclosed pulley systems.
• Technical Context: The technology concerns motorized, continuous-loop lure coursing systems designed to provide exercise for pets, a niche consumer product category.
• Key Procedural History: The complaint does not allege a history of prior litigation, licensing, or post-grant proceedings involving the Asserted Patents.

Case Timeline

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

U.S. Patent No. 10,609,904 - LURE CHASING SYSTEM

• Patent Identification: U.S. Patent No. 10,609,904, “LURE CHASING SYSTEM,” issued April 7, 2020 (’904 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies safety and operational risks in conventional lure chasing systems, such as injuries to animals from exposed pulleys and heavy lines, and line misalignment or failure during operation ʼ904 Patent, col. 1:28-43
• The Patented Solution: The invention proposes a lure chasing system using fully enclosed pulley units. A two-part housing, comprising a cover and a base, contains the drive and transfer pulleys, which are seated in corresponding annular recesses within the housing parts (’904 Patent, col. 2:55-63; Fig. 3). This enclosure is designed to prevent an animal from making contact with the moving pulley and to keep the lure line properly seated, while specific window and opening geometries allow the lure and line to pass through without binding (’904 Patent, col. 4:36-54). The system also contemplates using a plastic line that will soften and break from friction as a safety measure if the line becomes snagged (’904 Patent, col. 4:1-9).
• Technical Importance: The described approach sought to improve the safety and reliability of consumer-grade lure coursing equipment by enclosing all moving parts within protective housings. (’904 Patent, col. 2:55-59).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specification Compl. ¶2 Independent claim 1 is representative and includes the following essential elements:
  • A motorized pulley unit with a drive housing enclosing a motor and a drive pulley.
  • The drive housing comprises a cover and a base, each with an annular recess, which together at least partially enclose the drive pulley.
  • The drive pulley has portions that extend into both the cover's annular recess and the base's annular recess.
  • At least one transfer pulley unit with a housing enclosing a transfer pulley.
  • A lure line engaging both pulleys to form a loop, with an attached lure.
  • A "drive window" in the housing allowing the lure to pass through, and a smaller line "opening" formed by arcuate surfaces that guide the line.
• The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation against the patents.

U.S. Patent No. 12,156,508 - PULLEY SYSTEM ALLOWING FOR PASSAGE OF OBJECT ATTACHED TO LINE

• Patent Identification: U.S. Patent No. 12,156,508, “PULLEY SYSTEM ALLOWING FOR PASSAGE OF OBJECT ATTACHED TO LINE,” issued December 3, 2024 (’508 Patent).

The Invention Explained

• Problem Addressed: The patent identifies a drawback in prior art pulley systems where an object attached to the line (e.g., a lure) is impeded by the pulley housing or support structure as it passes, potentially causing the line to de-rail from the pulley groove or the system to fail (’508 Patent, col. 2:1-11).
• The Patented Solution: The invention describes a pulley system with a housing that incorporates an "inwardly beveled pulley shield." This shield, in combination with the pulley's circumferential groove, forms a "substantially solid inner surface." This surface creates a guided "object passthrough window" that both allows an attached object to move through the housing unimpeded and actively re-seats the line into the pulley groove if it becomes dislodged by turbulence (’508 Patent, Abstract; col. 8:1-10).
• Technical Importance: This design focuses on enhancing operational reliability by creating a continuous, fail-safe guide path for both the line and an attached object, preventing jams or derailments at the pulley mechanism. (’508 Patent, col. 2:16-25).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" without specification Compl. ¶2 Independent claim 1 is representative and includes the following essential elements:
  • A pulley attached to a housing structure via a rotatable attachment.
  • The pulley has a circumferential groove for retaining a line.
  • A structure forming an "object passthrough window" adjacent to the groove.
  • The housing structure encloses at least a portion of the pulley.
  • The circumferential groove opens into the object passthrough window.
  • The pulley housing includes an "inwardly beveled pulley shield."
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "cat" products, which it describes as "looping lure systems for use as lure chasing toy for pets" (Compl. ¶¶ 2, 32).

Functionality and Market Context

• The complaint alleges that the accused products are sold by numerous foreign entities under various aliases through online marketplaces such as Amazon, eBay, and Temu (Compl. ¶¶ 2, 8). It further alleges that the products "perform the same function in the same way, and achieve the same result, as is claimed in the Asserted Patents" Compl. ¶32 The complaint asserts that these products are "substantially identical to each other" and are believed to be made by the same foreign manufacturer (Compl. ¶¶ 33, 38). No specific technical details of the accused products' construction or operation are provided.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in its Exhibit 4 purporting to show where each element of the asserted claims is found in the accused products; however, this exhibit was not filed with the complaint Compl. ¶31 The complaint’s narrative infringement theory is summarized below.

The complaint alleges that the "Infringing Products" are "looping lure systems" that infringe claims of the ’904 and ’508 patents, both literally and under the doctrine of equivalents (Compl. ¶¶ 31-32, 53). The core of the infringement allegation rests on the assertion that the accused products "perform the same function in the same way, and achieve the same result" as the patented inventions Compl. ¶32 The complaint does not, however, contain factual allegations that describe the structure of the accused products or map their specific components to the claim limitations of either asserted patent, such as the annular recesses and window geometry of the ’904 Patent or the inwardly beveled pulley shield of the ’508 Patent.

• Identified Points of Contention:
  • Evidentiary Question: A primary question is what evidence the plaintiff will produce to demonstrate that the accused products, which are sold under various aliases and allegedly sourced from an unknown manufacturer, possess the specific structural elements required by the asserted claims (e.g., annular recesses, specific window and opening dimensions, inwardly beveled shields).
  • Scope Question: The analysis may raise the question of whether the term "enclosing," as used in the ’904 Patent, requires the specific two-part clamshell structure shown in the patent's figures or can be read more broadly on other housing configurations.
  • Technical Question: Does the housing of the accused products include a structure that functions as an "inwardly beveled pulley shield" (’508 Patent) to actively re-seat a dislodged line, or does it merely have a generic sloped surface that does not perform this claimed function?

V. Key Claim Terms for Construction

• The Term: "drive housing... wherein said drive pulley is at least partially enclosed by said drive housing cover annular recess and said drive housing base annular recess" (’904 Patent, Claim 1).
• Context and Importance: This term is critical because it defines the specific structural relationship between the housing and the pulley that is central to the patent's safety and operational claims. Practitioners may focus on this term because the infringement analysis will depend on whether the accused products' housings feature corresponding "annular recesses" that "partially enclose" the pulley in the manner claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states a general purpose "to safely rotate the motor unit pulley" and prevent injury, which could support a functional interpretation where any structure achieving that purpose meets the limitation (’904 Patent, col. 2:63-65).
  • Evidence for a Narrower Interpretation: Claim 1 and Figure 4 explicitly detail a two-part system (cover 42, base 44) with distinct annular recesses (52, 54). A party could argue that the term requires this specific clamshell-like geometry where portions of the pulley physically extend into recesses in both the top and bottom housing components.
• The Term: "inwardly beveled pulley shield" (’508 Patent, Claim 1).
• Context and Importance: This term describes the core novel feature of the ’508 Patent, which enables an attached object to pass through the housing while helping to retain the line. Infringement will likely turn on whether the accused products contain a structure that meets this definition.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The abstract describes the feature functionally as an "inward beveled edge of the housing structure" that acts to "guide the line into the pulley groove" (’508 Patent, Abstract). This could support construing the term to cover any inwardly angled housing surface that performs this guiding function.
  • Evidence for a Narrower Interpretation: The specification and figures depict the "drive pulley shield 44" as a distinct circular component affixed to the housing cover, with a substantial portion of its external surface (62) having an "inwardly beveled shape" (’508 Patent, col. 7:31-43; Fig. 7). This could support a narrower construction requiring a discrete shield-like element with a specific beveled geometry, rather than just any angled part of the main housing.

VI. Other Allegations

• Indirect Infringement: The complaint includes a general allegation of "indirect infringement" but does not plead specific facts to support the requisite knowledge and intent for either induced or contributory infringement Compl. ¶29
• Willful Infringement: Willfulness is alleged based on the assertion that Defendants acted "knowingly and intentionally or at least with reckless disregard or willful blindness to Plaintiff's rights" Compl. ¶15 The complaint alleges on "information and belief" that "Defendants are aware of Plaintiff and the Asserted Patent" Compl. ¶11j

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

• A core issue will be one of evidentiary sufficiency: As the complaint lacks specific factual allegations detailing the accused products' design, the case will likely depend on whether discovery can establish that products sold by disparate online sellers under various aliases actually incorporate the specific, detailed pulley and housing geometries required by the asserted claims.
• A key legal question will be one of structural definition: The dispute will likely turn on the construction of key claim terms. Can the "annular recess" structure of the ’904 Patent be read broadly on housings with different enclosure mechanisms, and can the "inwardly beveled pulley shield" of the ’508 Patent be found in a housing that lacks the discrete shield component depicted in the patent’s embodiments?