0:26-cv-61592
Taizhou Shengwan Home Furnishing Co Ltd v. Nnovative Closet Accessories LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Taizhou Shengwan Home Furnishing Co., Ltd. (People's Republic of China)
- Defendant: Nnovative Closet Accessories LLC (Florida)
- Plaintiff's Counsel: Levine Kellogg Lehman Schneider + Grossman LLP
- Case Identification: 0:26-cv-61592, S.D. Fla., 06/01/2026
- Venue Allegations: Venue is alleged to be proper as the Defendant's principal place of business is located within the Southern District of Florida.
- Core Dispute: Plaintiff seeks a declaratory judgment that its hat storage container product does not infringe Defendant's patent related to a stackable storage device and that the patent is invalid.
- Technical Context: The dispute concerns the mechanical design of consumer storage products, specifically stackable containers for displaying and storing headwear.
- Key Procedural History: This declaratory judgment action was precipitated by Defendant's patent infringement complaint filed through Amazon.com's intellectual property enforcement system, which resulted in the removal of Plaintiff's product listing. The complaint notes that after Plaintiff filed a prior lawsuit in the Northern District of Illinois, Defendant withdrew its Amazon complaint, but subsequently refused to agree not to file future complaints, prompting the current action. The complaint also alleges Defendant has asserted the same patent against at least one other seller.
Case Timeline
| Date | Event |
|---|---|
| 2017-07-27 | U.S. Patent No. 10,273,075 Priority Date |
| 2019-04-30 | U.S. Patent No. 10,273,075 Issue Date |
| 2025-04-01 | Defendant allegedly filed a DJ action against another seller over the '075 patent |
| 2025-07-18 | Defendant submitted an infringement complaint to Amazon against Plaintiff |
| 2025-08-27 | Plaintiff filed a prior declaratory judgment suit in the N.D. Illinois |
| 2026-06-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,273,075 - Stackable Storage Device for Headwear
- Patent Identification: U.S. Patent No. 10,273,075, issued April 30, 2019 (the "'075 Patent").
The Invention Explained
- Problem Addressed: The patent's background section identifies a need for an improved storage device for headwear that can protect items from dust and dirt while also allowing for an organized display and convenient access, particularly when multiple units are stacked together Compl., Ex. A, '075 Patent, col. 1:47-54 '075 Patent, col. 2:1-7 Existing solutions like hanging racks or flexible bags are described as inadequate for display, protection, and stacking Compl., Ex. A, '075 Patent, col. 1:55-62
- The Patented Solution: The invention is a rigid, typically transparent container with a slidable drawer designed to hold headwear Compl., Ex. A, '075 Patent, abstract To solve the problem of drawer instability, the design incorporates a "horizontal flange" on the interior side surfaces of the container that interacts with the drawer's side walls to limit vertical movement and prevent tipping when the drawer is open Compl., Ex. A, '075 Patent, col. 2:57-64 The design also includes stops to prevent the drawer from being pulled out completely and features to facilitate stable stacking Compl., Ex. A, '075 Patent, abstract
- Technical Importance: The patented solution purports to offer a modular system that combines protection, display, and accessibility for collectors of headwear, an improvement over prior art that allegedly failed to provide all three functions in a stackable format Compl., Ex. A, '075 Patent, col. 2:7-12
Key Claims at a Glance
- The complaint identifies independent claims 1, 11, and 15 as being at issue Compl. ¶21
- Independent Claim 1 recites the core elements of the device:
- An elongated container with a top surface shorter than its bottom surface and sloped side surfaces.
- A slidable drawer located on the bottom surface of the container's interior.
- A horizontal flange located on each side surface in the interior of the container, positioned to contact the drawer's side walls when the drawer's back wall is raised.
- Independent Claim 11 adds a further limitation to the structure of Claim 1:
- At least one stop located in the interior of the container to engage with the drawer as it slides.
- Independent Claim 15 recites an assembly of at least two such containers and adds:
- A first magnet on the door and a second magnet on the bottom of the container.
III. The Accused Instrumentality
Product Identification
- The accused product is a hat storage container sold by Plaintiff on Amazon.com through the "Euct" storefront, identified by ASIN B0FB3229TJ (the "Non-Infringing Product") Compl. ¶5 Compl. ¶11
Functionality and Market Context
- The Non-Infringing Product is a stackable, transparent container with a sliding drawer for storing headwear Compl. ¶11 The complaint alleges that its design differs critically from the patented invention. Specifically, it is alleged to use a horizontal flange located on the bottom surface of the container, which engages a ridge on the bottom of the drawer, rather than having flanges on the interior side surfaces Compl. ¶24a The complaint further alleges the product lacks the "stop" required by claim 11 and the "magnets" required by claim 15 Compl. ¶26b Compl. ¶28a
- The complaint alleges that Plaintiff and Defendant are direct competitors in the Amazon marketplace for hat storage containers and that Plaintiff's product was a "top-selling ASIN" prior to its removal by Amazon following Defendant's infringement complaint Compl. ¶30 Compl. ¶33
IV. Analysis of Infringement Allegations
- '075 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongated container with a top surface, a bottom surface, two side surfaces, a back surface, an interior, an opening and a moveable door positioned to cover the opening when closed; wherein the top surface is shorter in length than the bottom surface; and an end of each of the side surfaces slopes down from the top surface to the bottom surface at an obtuse angle; | The complaint acknowledges the product has these general structural features. | ¶23 | col. 8:9-15 |
| a slidable drawer having a bottom, a front wall, a back wall and two side walls, the drawer being located in the interior of the container on the bottom surface of the container; | The complaint acknowledges the product has a slidable drawer. | ¶23 | col. 8:16-18 |
| a horizontal flange located on each side surface in the interior of the container and positioned to contact the side walls of the drawer when the back wall of the drawer is raised. | The complaint alleges the product does not have this feature. Instead, it states the product has a horizontal flange on the bottom surface of the container that engages a ridge on the bottom of the drawer. A visual comparison is provided to illustrate this alleged difference. Compl. p. 6 | ¶24 | col. 5:23-25 |
- Identified Points of Contention:
- Scope Questions: The primary point of contention for all asserted claims appears to be the construction and scope of the term "a horizontal flange located on each side surface in the interior of the container". Plaintiff alleges its product has a flange on the bottom surface, not the side surfaces Compl. ¶24a The case may turn on whether this distinction removes the product from the literal scope of the claims and whether the doctrine of equivalents could bridge this gap.
- Technical Questions: The complaint raises direct factual questions about the presence of other claimed elements. For Claim 11, the complaint alleges the product "contains no stops" Compl. ¶26b, which is disputed by a visual showing the accused product's structure Compl. p. 8 For Claim 15, the complaint alleges the product "does not include any magnets" Compl. ¶28a, illustrated by a side-by-side comparison of the patent's magnetic closure and the accused product Compl. p. 9 The court will need to determine if any features of the accused product perform the functions of these claimed elements.
V. Key Claim Terms for Construction
The Term: "a horizontal flange located on each side surface in the interior of the container" (from Claim 1).
Context and Importance: This term is central to Plaintiff's non-infringement argument across all asserted independent claims. Plaintiff contends its product's flange is on the container's bottom surface, not its side surfaces Compl. ¶24a The resolution of the infringement dispute will likely depend on how narrowly or broadly the court construes the locational requirement "on each side surface."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party seeking a broader reading might argue that the function of the flange is to "limit the movement of the drawer" and prevent tipping, and that any structure achieving this result should be considered an equivalent '075 Patent, col. 2:46-52 The claim language itself requires the flange to be "positioned to contact the side walls of the drawer," which could be argued as the key functional requirement, regardless of the flange's precise point of attachment.
- Evidence for a Narrower Interpretation: A party seeking a narrower reading will point to the plain language specifying the location as "on each side surface." This is reinforced by the patent's detailed description, which consistently states that the "container 101 features two flanges 117 on the side surfaces 104" '075 Patent, col. 5:23-24 Furthermore, all patent figures, such as Figure 1 and Figure 2, depict the flange (117) attached to the vertical side walls (104), not the bottom surface (103) Compl., Ex. A, '075 Patent, Fig. 1 '075 Patent, Fig. 2 This consistent disclosure may support a construction that limits the claim to the specific embodiment shown.
VI. Other Allegations
Indirect Infringement: As a declaratory judgment action for non-infringement, the complaint asserts that Plaintiff has not infringed "either directly, contributorily, or by inducement" Compl. ¶41 The focus of the factual allegations is on negating the elements of direct infringement, which would consequently negate any basis for indirect infringement.
Willful Infringement: This is not applicable, as the complaint is brought by the accused infringer seeking a declaratory judgment. The complaint does, however, allege that Defendant's assertion of the patent was in "bad faith" and with "actual malice" due to the alleged clear differences between the patent claims and the accused product Compl. ¶3 Compl. ¶50 These allegations pertain to Plaintiff's state-law tort claims rather than a claim for willful patent infringement.
VII. Analyst's Conclusion: Key Questions for the Case
A core issue will be one of definitional scope: Can the claim term "a horizontal flange located on each side surface," which is consistently described and depicted in the patent as being attached to the container's vertical walls, be construed to read on the accused product's structure, where a flange is allegedly located on the container's bottom surface? The outcome of the literal infringement analysis hinges on this construction.
A second key issue will be one of factual presence: The complaint presents a direct factual challenge, alleging the complete absence of two key limitations in the accused product: the "stop" recited in Claim 11 and the "magnets" recited in Claim 15. The resolution will depend on an evidentiary analysis of the accused product's structure and function.
A final critical question will be one of validity: Plaintiff has introduced three prior art patents that were allegedly not considered during the '075 Patent's prosecution Compl. ¶38 The court will need to determine whether these references, alone or in combination, disclose or render obvious the key features of the asserted claims, potentially invalidating the patent regardless of the infringement outcome.