Densch Design Ltd v. Jtle Investments LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Densch Design Limited (Hong Kong)
  • Defendant: JTLE Investments LLC (Florida)
  • Plaintiff's Counsel: LOTT & FISCHER, PL
• Case Identification: 0:26-cv-61812, S.D. Fla., 06/26/2026
• Venue Allegations: Venue is alleged to be proper as the Defendant is a Florida limited liability company with its principal place of business in the judicial district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its TV mount products do not infringe Defendant's patent for a wall mounting device, and that the patent is invalid.
• Technical Context: The technology involves mechanical hardware for securely hanging objects, such as televisions, on walls, particularly drywall, without requiring the use of wall studs.
• Key Procedural History: The action was precipitated by an infringement notice Defendant sent to Amazon.com, which resulted in the removal of Plaintiff's product listing. The complaint also highlights the prosecution history of the asserted patent, noting that claims were amended to overcome a rejection based on prior art, and alleges that newly cited prior art renders the patent obvious.

Case Timeline

Date	Event
2015-06-24	Dorn Reference (GB2521483A) publication date
2020-06-16	D'255 Design Patent publication date
2022-10-20	'669 Patent priority date
2025-07-28	'669 Patent claims amended during prosecution
2025-11-04	'669 Patent issue date
2026-05-12	Defendant allegedly files infringement complaint with Amazon
2026-06-26	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 12,460,669 - "Mounting Device To Securely Hang A Wide Range of Objects To A Wall"

• Patent Identification: U.S. Patent No. 12,460,669, "Mounting Device To Securely Hang A Wide Range of Objects To A Wall," issued November 4, 2025.

The Invention Explained

• Problem Addressed: The patent's background describes conventional wall mounting apparatuses as complex, time-consuming to install, and often requiring professional expertise and the support of wall studs, which limits where objects can be hung '669 Patent, col. 1:36-54 The invention aims to address these challenges '669 Patent, col. 2:6-10
• The Patented Solution: The invention is a multi-part mounting device. A "support member" attaches to the wall using nails driven through angled "nipple members," which is designed to create a strong anchor in materials like drywall without needing a stud '669 Patent, col. 5:55-6:4 This support member includes a "hook portion." A separate "hang member" attaches to the object being hung and features a large opening that couples with the hook portion to securely mount the object '669 Patent, col. 6:50-6:3
• Technical Importance: The design purports to allow a user with minimal experience to securely hang heavy objects (up to 200 lbs) on various wall types, including drywall, without needing to locate wall studs '669 Patent, col. 4:6-15

Key Claims at a Glance

• The complaint seeks a declaration of non-infringement of all claims but focuses its arguments on structural features present in the independent device claims Compl. ¶15 Compl. ¶26 Independent claims 1 and 6 are representative device claims.
• The essential elements of independent claim 1 include:
  • A support member with a hook portion and a plurality of nipple members at an angled position.
  • Nails on a lower portion that have sufficient length to overlap after being driven through the nipple members.
  • A hang member comprising a head portion (with a large opening) and a handle portion (with smaller apertures).
  • A hook portion that includes a flat bottom surface and a "barb member."
• The complaint does not explicitly reserve the right to assert dependent claims, as it is a declaratory judgment action filed by the accused infringer.

III. The Accused Instrumentality

Product Identification

The "Montek TV Mount" sold by Densch Design Limited on Amazon.com Compl. ¶2 Compl. ¶19

Functionality and Market Context

• The product is a TV mount that the complaint alleges is a direct competitor to the Defendant's products Compl. ¶20
• The complaint provides a photograph showing the accused product, which appears to consist of a main triangular component and a separate "small, round wheel structure" Compl. ¶16 The plaintiff, Montek, alleges that this product "plainly and undeniably does not include multiple structural features recited by the asserted claims," such as the specific hang member, nipple members, and barb member structure Compl. ¶2 Compl. ¶15 As depicted in a photograph, the accused product is a wall mount component sold under the "MONTEK" brand name Compl. ¶16, p. 5

IV. Analysis of Infringement Allegations

The complaint is for declaratory judgment of non-infringement. The following table summarizes the plaintiff's (Montek's) primary non-infringement positions.

'669 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
a hang member comprising a head portion and a handle portion ... the head portion comprises a large opening ... the handle portion comprises smaller apertures	Plaintiff alleges the Montek TV Mount lacks this structure. Defendant allegedly argued that a "small, round wheel structure" on the Montek product is the hang member, a position Plaintiff disputes.	¶15; ¶16	col. 9:22-29
a plurality of nipple members provided in corners of an upper portion and a lower portion of the support member at an angled position	Plaintiff alleges the Montek TV Mount does not have these structures.	¶15	col. 8:51-53
a hook portion having an edge comprising a barb member	Plaintiff alleges the Montek TV Mount does not have this structure.	¶15	col. 9:36-39
the nail members on a lower portion of the support member have a sufficient length to overlap after being driven through	This limitation was added during prosecution to overcome prior art. The complaint alleges invalidity based on this feature being disclosed in other prior art not before the examiner, which implicitly supports a non-infringement argument if the accused device also lacks this feature.	¶30; ¶32	col. 9:14-21

Identified Points of Contention

• Scope Questions: A central dispute will be whether the "small, round wheel structure" of the Montek TV Mount Compl. ¶16 can be construed to meet the "hang member comprising a head portion and a handle portion" limitation. The complaint alleges a clear structural dissimilarity.
• Technical Questions: A factual question for the court will be whether the Montek TV Mount contains any structures that perform the functions of the claimed "nipple members" or "barb member." The complaint asserts these features are entirely absent Compl. ¶15 The complaint also includes a side-by-side comparison figure contrasting a prior art patent with a figure from the '669 Patent to highlight alleged similarities, which is part of its invalidity argument Compl. p. 7

V. Key Claim Terms for Construction

The Term: "hang member comprising a head portion and a handle portion"

• Context and Importance: This term is critical because the complaint alleges the accused product lacks this specific two-part structure Compl. ¶15 Defendant has allegedly equated this limitation with the product's "small, round wheel structure," making the construction of this term central to the infringement analysis Compl. ¶16
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue the terms should be defined functionally, focusing on the hang member's role in affixing to an object and coupling with the hook portion, regardless of its specific shape '669 Patent, col. 6:50-63
  • Evidence for a Narrower Interpretation: The patent specification repeatedly distinguishes between the "head portion" and the "handle portion," and FIG. 1 depicts a specific elongated structure (106) with a clear physical separation between these two parts '669 Patent, FIG. 1 '669 Patent, col. 6:55-65 This may support an interpretation requiring a structure with two distinct sections.

The Term: "nipple members"

• Context and Importance: The complaint alleges these structures are absent from the accused product Compl. ¶15 The term itself is not standard, and its meaning will define a key structural element for anchoring the device to a wall.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claims define these members by their function: being at an "angled position" to facilitate "angular penetration" of nails '669 Patent, claim 1 A party might argue any structure enabling this angled entry meets the definition.
  • Evidence for a Narrower Interpretation: The patent figures consistently show "nipple members" as distinct, raised, hollow protrusions extending from the surface of the support member (e.g., '669 Patent, FIG. 1, items 108A-D; '669 Patent, FIG. 3). The use of a non-standard term may suggest the patentee was acting as their own lexicographer, limiting the term to the structures shown.

VI. Other Allegations

Indirect Infringement

The complaint seeks a declaration of non-infringement "either directly or indirectly" but does not allege specific facts related to inducement or contributory infringement Compl. ¶26

Willful Infringement

As a declaratory judgment action, there is no claim for willful infringement against the plaintiff. However, the plaintiff alleges that the defendant's enforcement actions were "objectively baseless" and that it "submitted and maintained false infringement allegations to Amazon" despite knowing they "lacked any factual or legal basis" Compl. ¶2 Compl. ¶42 These allegations support the plaintiff's claim for tortious interference and its request for attorneys' fees under 35 U.S.C. §285 (Compl. ¶38; Compl. ¶39; Compl. ¶40; Compl. ¶41; Compl. ¶42; Compl. ¶43; Compl. ¶44; Compl. ¶45, Compl. ¶prayer F).

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

• A core issue will be one of definitional scope: Can the claim term "hang member comprising a head portion and a handle portion," which is depicted in the patent as an elongated, two-part structure, be construed to read on the "small, round wheel structure" of the accused product?
• A second key issue centers on invalidity due to obviousness: The complaint alleges that the very feature added during prosecution to secure the patent-nails with "sufficient length to overlap"-was already disclosed in a prior art reference (the Dorn Reference) not considered by the USPTO. The case may turn on whether a person of ordinary skill would have been motivated to combine the prior art to arrive at the claimed invention.
• A final question relates to improper enforcement: Did the defendant's infringement notice to Amazon constitute an "objectively baseless" claim, potentially giving rise to liability for tortious interference or an exceptional case finding, especially in light of the structural differences and prosecution history alleged in the complaint?