8:26-cv-01787
ETN Capital LLC v. Shenzen Shi Xiaolin Dasen Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ETN Capital, LLC (North Carolina)
- Defendant: SHENZHEN SHI XIAOLIN DASEN TECHNOLOGY CO., LTD. D/B/A SLINDAS, HOMTOK (Peoples Republic of China)
- Plaintiff's Counsel: Older Lundy Koch & Martino
- Case Identification: 8:26-cv-01787, M.D. Fla., 06/18/2026
- Venue Allegations: Venue is alleged to be proper because Defendant is an alien corporation that does business in the United States but is not a resident of any specific state, and therefore may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant's recreational vehicle (RV) leveling system, which utilizes a vehicle-mounted sensor and a smartphone application, infringes a patent related to vehicle leveling technology.
- Technical Context: The technology at issue addresses the market for RV accessories that simplify the process of leveling a parked vehicle, which is critical for the proper operation of appliances like refrigerators and plumbing systems.
- Key Procedural History: The patent-in-suit was issued on January 12, 2021, to Command Electronics, LLC. The rights were subsequently transferred to FBA Operating Co. on December 31, 2021, and then acquired by Plaintiff ETN CAPITAL, LLC on January 23, 2026. The complaint states Plaintiff sent a notice of infringement letter to the Defendant on May 11, 2026.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-05 | Priority Date for U.S. Patent No. 10,890,925 |
| 2021-01-12 | U.S. Patent No. 10,890,925 Issued |
| 2021-12-31 | '925 Patent assigned from Command Electronics to FBA Operating Co. |
| 2026-01-23 | '925 Patent assigned from FBA Operating Co. to ETN Capital, LLC |
| 2026-05-11 | Plaintiff allegedly sent Defendant a notice of infringement |
| 2026-06-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,890,925 - VEHICLE LEVELING SYSTEMS, DEVICES AND METHODS AND COMPUTER PROGRAM PRODUCTS FOR LEVELING VEHICLES USING SMART DEVICES
- Issued: January 12, 2021
The Invention Explained
Problem Addressed: The patent's background section describes the conventional method of leveling a recreational vehicle (RV) as a manual, imprecise, and iterative "trial and error" process involving bubble levels and jacks, which is prone to user error and can result in damage to the vehicle's onboard systems if not done correctly '925 Patent, col. 1:49 - col. 2:34 Compl. ¶¶25-26
The Patented Solution: The invention provides a system to automate and simplify this process '925 Patent, abstract It consists of a sensor device, containing a digital accelerometer, that is secured to the vehicle to measure its pitch and roll inclination '925 Patent, col. 6:29-34 This sensor wirelessly communicates with a user's smart device, which runs a software application '925 Patent, col. 6:34-40 The system calculates the specific height adjustments needed to level the vehicle and displays this information-often with a graphical representation of the RV-on the smart device, guiding the user on how much to raise each point of the vehicle '925 Patent, col. 10:25-40
Technical Importance: The patented technology aims to replace subjective user guesswork with precise, data-driven instructions, thereby increasing the accuracy, speed, and convenience of leveling an RV Compl. ¶27
Key Claims at a Glance
The complaint asserts infringement of independent claims 1, 10, and 15 (Compl. ¶¶15; Compl. ¶17; Compl. ¶19).
Independent Claim 1 (A system for leveling a vehicle):
- A sensor device with a digital accelerometer and processor to sense vehicle inclination (pitch and roll).
- A smart device with a display screen in wireless communication with the sensor.
- The system is configured to determine "adjustment pairs," each including a "height adjustment amount" and direction.
- The smart device is configured to "simultaneously display" a vehicle image along with the height adjustment amount and direction for each section.
- The display updates "substantially in real time."
Independent Claim 10 (A method for leveling a recreational vehicle): Describes the steps of sensing inclination, determining adjustment pairs, displaying the vehicle image with simultaneous height/direction data, and updating the display in "essentially in real time."
Independent Claim 15 (A non-transitory computer readable medium): Describes a software product whose instructions cause a smart device to perform steps largely parallel to the method of Claim 10, including receiving sensor data, calculating adjustment pairs, and displaying/updating the results.
III. The Accused Instrumentality
Product Identification
The accused products are the "Slin&Das Smart RV Leveling Navigator, model number RVS01" (the "RVS01") and the associated smartphone application, "XPARKLE App" Compl. ¶15
Functionality and Market Context
The complaint alleges that the RVS01 is a sensor device used with the XPARKLE App to provide RV leveling functionality Compl. ¶15 The complaint characterizes the accused system as a "virtually identical product" that "directly competes with Plaintiff's product" and is sold to U.S. consumers through online platforms such as Amazon.com Compl. ¶35 Compl. ¶4 The complaint alleges that the combination of the RVS01 and the XPARKLE App practices the patented invention Compl. ¶35
IV. Analysis of Infringement Allegations
The complaint alleges that the combination of the RVS01 sensor and the XPARKLE App infringes claims 1, 10, and 15 of the '925 Patent (Compl. ¶¶15; Compl. ¶17; Compl. ¶19). The infringement theory is based on the assertion that the accused system performs the same functions as the patented invention. No probative visual evidence provided in complaint.
'925 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sensor device secured to a vehicle to sense an inclination of the vehicle in both a pitch direction and a roll direction...the sensor device comprising a printed circuit board that includes: a digital accelerometer...and a processor... | The RVS01 device, which allegedly contains the necessary sensor components, is secured to a vehicle to sense pitch and roll. | ¶15 | col. 6:29-34 |
| a smart device in wireless communication with the sensor device, the smart device including a display screen | The XPARKLE App runs on a user's smartphone, which serves as the smart device and communicates wirelessly with the RVS01. | ¶15 | col. 6:34-40 |
| wherein, based on the inclination of the vehicle as sensed by the sensor device, at least one of the sensor device and smart device is configured to determine adjustment pairs, each adjustment pair including a height adjustment amount and a corresponding adjustment direction... | The combined RVS01 and XPARKLE App system allegedly calculates the necessary height adjustments and directions for leveling. | ¶15 | col. 13:21-27 |
| wherein the display device of the smart device is configured to display at least one image representative of the vehicle and showing the respective sections of the vehicle and to simultaneously display the height adjustment amount and corresponding adjustment direction... | The XPARKLE App allegedly displays a vehicle graphic along with the calculated height adjustments and directions for each relevant section of the vehicle. | ¶15 | col. 10:30-40 |
| wherein the smart device is further configured to update the display screen, substantially in real time, as one or more of the height adjustment amounts are changed. | The XPARKLE App display allegedly updates in near real-time as the vehicle's orientation changes. | ¶15 | col. 10:22 |
Identified Points of Contention
- Evidentiary Questions: The complaint makes conclusory allegations that the accused system is "virtually identical" and infringes, but it does not provide supporting evidence such as screenshots of the XPARKLE App or technical specifications for the RVS01 sensor Compl. ¶35 A central issue will be whether discovery reveals evidence that the accused system in fact performs each claimed function.
- Scope Questions: The case may raise questions about the scope of the claim term "substantially in real time." The parties may dispute whether the update frequency of the accused XPARKLE App meets the standard required by the claim, creating a potential battle of technical experts.
- Technical Questions: A key factual dispute may arise over whether the XPARKLE App's user interface functions in the manner required by the claims. The analysis will focus on what information is displayed, its format, and whether the vehicle image, height amounts, and directions are truly displayed "simultaneously" as a cohesive unit.
V. Key Claim Terms for Construction
The Term: "adjustment pairs"
Context and Importance: This term appears in all three independent claims and defines the core calculated output of the invention. Its construction is critical because it dictates what type of information the system must calculate and provide to the user to infringe.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 defines the term as including "a height adjustment amount and a corresponding adjustment direction." A party could argue this language is broad enough to cover any output that conveys both magnitude and location, not just a specific format.
- Evidence for a Narrower Interpretation: The patent's figures and detailed description show specific numerical height values (e.g., "2.25"") paired with directional arrows '925 Patent, FIG. 5A '925 Patent, col. 10:30-54 A party could argue that this context limits "height adjustment amount" to a calculated physical distance (e.g., in inches or millimeters), and that a system providing only angular data or qualitative guidance would not meet this limitation.
The Term: "simultaneously display"
Context and Importance: This term, also present in all independent claims, governs the user interface requirements. Infringement will hinge on whether the accused app's layout and operation meet this temporal and spatial constraint.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: This could be argued to mean simply "on the same screen at the same time," giving wide latitude to the specific arrangement of the visual elements.
- Evidence for a Narrower Interpretation: The patent claims require displaying the height and direction "adjacent to each respective section of the vehicle shown in the at least one image" '925 Patent, cl. 1 This language, combined with figures like FIG. 12 which show numerical values placed directly next to corresponding locations on a vehicle schematic, suggests a requirement for an integrated, spatially correlated display, not just a list of data on the same screen as an image.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant encourages infringement by "inducing its end-users to use the RVS01 and the XPARKLE App as intended" Compl. ¶46 The factual basis for this claim would likely rely on Defendant's product manuals, marketing materials, and in-app instructions.
- Willful Infringement: The complaint alleges willful infringement, asserting that Defendant had pre-suit knowledge of the '925 Patent Compl. ¶40 This allegation is based on a notice letter Plaintiff claims to have sent on May 11, 2026, as well as more general allegations of knowledge from competing in the same marketplace Compl. ¶32 Compl. ¶40 The complaint also notes that Defendant has continued its allegedly infringing activities post-notice Compl. ¶33
VII. Analyst's Conclusion: Key Questions for the Case
- Evidentiary Sufficiency: A threshold question for the court will be one of evidentiary proof: can the Plaintiff, through discovery, produce specific technical evidence to substantiate its currently conclusory allegations and demonstrate that the accused RVS01 and XPARKLE App system performs each specific function recited in the asserted claims?
- Claim Scope and Construction: The case will likely turn on a question of definitional scope: how will the court construe the term "height adjustment amount"? Will it be limited to a specific numerical distance as shown in the patent's embodiments, or can it be interpreted more broadly, a decision that will significantly impact the infringement analysis?
- Operational Equivalence: A central factual dispute will be a question of functional operation: does the accused XPARKLE App's user interface "simultaneously display" an integrated, spatially-aware set of instructions as required by the claims, or does its functionality rely on a sequence of displays or a layout that falls outside the patent's specific requirements?