ETN Capital LLC v. Shenzhen Aomosur Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ETN Capital, LLC (North Carolina)
  • Defendant: Shenzhen AOMOSUR Technology Co., Ltd (China)
  • Plaintiff's Counsel: Older Lundy Koch & Martino
• Case Identification: ETN Capital, LLC v. Shenzhen AOMOSUR Technology Co., Ltd, 8:26-cv-02251, M.D. Fla., 08/04/2026
• Venue Allegations: Venue is asserted on the basis that the Defendant is a foreign company not resident in the United States and may therefore be sued in any judicial district. The complaint also alleges that Defendant does business in the district by offering to sell and selling products through online storefronts accessible to customers in Florida.
• Core Dispute: Plaintiff alleges that Defendant's RV leveling systems infringe a patent related to using a sensor device and a smart device to calculate and display vehicle leveling adjustments.
• Technical Context: The technology addresses the need to precisely level recreational vehicles (RVs) to ensure the proper and safe operation of onboard systems, replacing imprecise traditional methods with a sensor-based digital solution.
• Key Procedural History: The asserted patent was issued to Command Electronics, LLC, subsequently assigned to FBA Operating Co., and then acquired by the Plaintiff, ETN Capital, LLC. The complaint also notes that Plaintiff sells a product under the brand name Beech Lane that practices the patent and is marked with the patent number.

Case Timeline

Date	Event
2014-12-05	'925 Patent Priority Date
2021-01-12	'925 Patent Issue Date
2021-12-31	Asset Purchase Agreement (Command to FBA)
2025-06-06	Patent Purchase (FBA to ETN Capital)
2026-08-04	Complaint Filing Date

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 Jan. 12, 2021)

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulties and inaccuracies of leveling a recreational vehicle (RV) using traditional methods like bubble levels and manual jacks Compl. ¶¶36-37 '925 Patent, col. 1:27-33 This process is described as a "trial and error system" that is imprecise, time-consuming, and prone to user error, which can lead to malfunctioning RV systems like refrigerators, plumbing, and doors '925 Patent, col. 2:1-34
• The Patented Solution: The invention provides a system comprising a sensor device affixed to the vehicle and a smart device, such as a smartphone, in wireless communication '925 Patent, abstract The sensor detects the vehicle's inclination in both pitch and roll directions and transmits this data to the smart device '925 Patent, col. 6:26-48 The smart device's software then calculates the specific height adjustments needed to level the vehicle and displays this information, often on a graphical representation of the vehicle, guiding the user to make precise corrections '925 Patent, col. 10:25-34
• Technical Importance: This technology replaces the guesswork of manual leveling with a data-driven process, aiming to provide a faster, more accurate, and user-friendly method for achieving a level vehicle position Compl. ¶38 '925 Patent, col. 2:35-40

Key Claims at a Glance

• The complaint asserts independent claims 1, 10, and 15 Compl. ¶¶65-67
• Independent Claim 1 (System Claim):
  • A sensor device secured to a vehicle to sense pitch and roll inclination, comprising a printed circuit board with a digital accelerometer and a processor.
  • A smart device with a display screen, in wireless communication with the sensor.
  • The system is configured to determine "adjustment pairs" (height adjustment amount and direction).
  • The smart device displays at least one image of the vehicle and simultaneously displays the adjustment pair information adjacent to the respective sections of the vehicle image.
  • The smart device updates the display "substantially in real time" as adjustments are made.
• Independent Claim 10 (Method Claim): A method for leveling a recreational vehicle comprising the steps of sensing inclination, determining adjustment pairs, displaying a representative vehicle image with the adjustment information on a smart device, and updating the display "essentially in real time."
• Independent Claim 15 (Computer Readable Medium Claim): A non-transitory computer readable medium with instructions for a smart device to perform steps including receiving pitch/roll data, calculating adjustment pairs, displaying a representative vehicle image with the adjustment information, and updating the display "essentially in real time."
• The complaint notes that the right to assert various dependent claims is reserved Compl. ¶23 Compl. ¶26 Compl. ¶29

III. The Accused Instrumentality

Product Identification

The complaint identifies six accused product models: the AM50-PRO, AM350, AM350PRO, AM350-X, AM700 PRO, and AM700D PRO RV Leveling Systems Compl. ¶46

Functionality and Market Context

The accused products are alleged to be RV leveling systems sold in the United States through online storefronts like Amazon.com and Aomosur.com Compl. ¶4 Compl. ¶45 The system is alleged to function by using a sensor device, referred to as a "Transmitter," which contains an accelerometer and a processor to measure a vehicle's inclination Compl. ¶44 Compl. ¶47 Compl. ¶49 This sensor device then wirelessly communicates with a "smart device," which can be a dedicated display or a user's smartphone running a downloadable application (the "AMS RV Leveler" app), to display the vehicle's inclination Compl. ¶50 Compl. ¶51 Compl. ¶52 The complaint includes an image of the packaging for the plaintiff's own product, which it alleges is directly competitive with the accused products Compl. p. 13 This image shows a smartphone app displaying a vehicle diagram with height adjustments.

IV. Analysis of Infringement Allegations

'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 accused products include a sensor device ("Transmitter") designed to be secured to an RV for sensing inclination in both pitch and roll directions.	¶47	col. 6:30-34
the sensor device comprising a printed circuit board that includes: a digital accelerometer that permits calculation in both the pitch direction and roll direction, and a processor to process data collected by the digital accelerator;	The sensor device allegedly comprises a "six-axis gyroscope" understood to contain a 3-axis accelerometer, and a processor to process the data.	¶48; ¶49	col. 6:60-62
a smart device in wireless communication with the sensor device, the smart device including a display screen;	The accused products include a "smart device" (a dedicated "display" or an external smartphone) in wireless communication with the sensor, which includes a screen.	¶50; ¶51	col. 6:35-37
...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 accused products are allegedly configured to determine adjustment amounts and corresponding directions needed to level the vehicle.	¶54	col. 7:1-6
...the display device of the smart device is configured to display at least one image representative of the vehicle...and to simultaneously display the height adjustment amount and corresponding adjustment direction...	The accused products allegedly display an image representing the vehicle and show the determined adjustment amounts and directions on the smart device's screen.	¶55	col. 10:27-34
...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 accused products allegedly update the display in real time based on updated measurements received.	¶56	col. 7:17-20

Identified Points of Contention

• Scope Question: A potential dispute may arise over the term "digital accelerometer". The complaint alleges the accused device uses a "six-axis gyroscope," which it states is "generally understood to refer to... a 3-axis gyroscope and a 3-axis accelerometer" Compl. ¶48 The court may need to determine if this component combination, often referred to as an Inertial Measurement Unit (IMU), meets the "digital accelerometer" limitation as claimed in the patent.
• Technical Question: A key factual question will be whether the accused system's software performs the specific functions required by the claim. The claim requires the system to determine and display "adjustment pairs" (both a "height adjustment amount" and a "corresponding adjustment direction") on a "representative image of the vehicle." The court will have to examine what information the accused "AMS RV Leveler" application actually calculates and how it is presented to the user.

V. Key Claim Terms for Construction

The Term: "adjustment pairs"

• Context and Importance: This term appears in all three independent claims and defines the specific output of the claimed invention. The infringement analysis will likely hinge on whether the accused system calculates and displays information that meets this two-part definition ("height adjustment amount" and "corresponding adjustment direction"). Practitioners may focus on this term because it distinguishes the invention from a simple level that only shows raw angle data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's abstract speaks more generally of determining "the amount of adjustments needed in height" '925 Patent, abstract, which a defendant might argue does not strictly require an explicit "direction" component in all displayed outputs.
  • Evidence for a Narrower Interpretation: Claim 1 itself explicitly defines the term: "each adjustment pair including a height adjustment amount and a corresponding adjustment direction" '925 Patent, col. 7:2-4 The specification further supports this by describing calculations of "height and location" '925 Patent, col. 13:33-35 and showing figures (e.g., Fig. 5A) that display both a numerical height ("2.25"") and a directional indicator (an up-arrow).

The Term: "substantially in real time"

• Context and Importance: This term in Claim 1 (and "essentially in real time" in Claims 10 and 15) defines the required responsiveness of the system. A dispute could arise over how much, if any, latency is permissible for the display updates while still meeting this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification also uses the phrase "near real time" '925 Patent, col. 10:28 '925 Patent, col. 13:22, which could suggest some flexibility and tolerance for minor processing or communication delays.
  • Evidence for a Narrower Interpretation: The claim language requires the display to update "as one or more of the height adjustment amounts are changed" '925 Patent, col. 7:17-20 This suggests a dynamic feedback loop where the user's actions of leveling are immediately reflected on the display, implying a low-latency connection is a key feature.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant actively induces its end-users to infringe the method claims Compl. ¶74 The specific factual basis provided is the user manual for the "AM350-X" model, which allegedly directs consumers to download and use the "AMS RV Leveler" application, thereby performing the patented method Compl. ¶52

Willful Infringement

The complaint alleges that Defendant's infringement has been intentional, deliberate, and willful Compl. ¶72 The basis for this allegation is Defendant's purported knowledge of the '925 patent, which Plaintiff claims exists because Plaintiff's own competing product is marked with the patent number and is sold in the same online "Merchant Stores" as Defendant's products Compl. ¶71

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

The resolution of this dispute will likely depend on the court's determination of two central issues:

• A core issue will be one of functional scope: Does the accused "AMS RV Leveler" application merely display raw inclination data, or does it calculate and present specific "adjustment pairs"-a discrete height value and a corresponding direction for each point of adjustment-on a representative vehicle image, as required by the patent claims?
• A second key question will be one of technical mapping: Does the "six-axis gyroscope" component alleged to be in the accused sensor device constitute a "digital accelerometer" as that term is used and defined within the context of the '925 patent?