HK Sanli Trading Co Ltd v. Wang

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: HK SANLI TRADING CO., LTD (China)
  • Defendant: Hongyan Wang (China)
  • Plaintiff's Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:26-cv-02292, N.D. Ill., 03/01/2026
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant purposefully directed patent enforcement activities toward Plaintiff's U.S. commerce through Amazon, which includes sales to consumers in Illinois, and the alleged commercial harm is suffered in the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its drawer product does not infringe Defendant's patent for an adjustable drawer, and that the patent is invalid, following an infringement complaint filed by the Defendant through Amazon's e-commerce enforcement program.
• Technical Context: The dispute concerns adjustable storage drawers for home furnishings, a field where modular and customizable solutions are valuable for fitting non-standard cabinet sizes.
• Key Procedural History: The action was precipitated by Defendant Hongyan Wang submitting a patent infringement complaint against Plaintiff HK SANLI TRADING CO., LTD to Amazon under its intellectual property enforcement program. This action created a justiciable controversy, prompting the plaintiff to file for declaratory judgment.

Case Timeline

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

U.S. Patent No. 12,478,181 - "ADJUSTABLE DRAWER"

(the "'181 Patent")

The Invention Explained

• Problem Addressed: The patent addresses the problem that household cabinets are often custom-made with inconsistent dimensions, requiring drawers to be specifically customized to fit, which can be inefficient '181 Patent, col. 1:9-15
• The Patented Solution: The invention is a modular drawer constructed from a "plurality of connecting elements" that join together to form the drawer body '181 Patent, abstract These elements can slide relative to one another along both the length and width axes, allowing the overall drawer dimensions to be expanded or contracted '181 Patent, col. 2:36-42 The desired size is then fixed in place by inserting fasteners through aligned openings on the overlapping elements '181 Patent, col. 4:38-51
• Technical Importance: This design allows a single drawer product to be adapted to fit various cabinet sizes, potentially reducing manufacturing complexity and inventory costs compared to producing numerous fixed-size drawers '181 Patent, col. 2:56-60

Key Claims at a Glance

The complaint seeks a declaratory judgment of non-infringement of "at least one claim" Compl. ¶27 and invalidity of "at least Claim 10" Compl., prayer 2 Claim 10 is an independent claim.

• Independent Claim 10:
  • A drawer body, comprising a plurality of connecting elements, wherein the plurality of connecting elements join together and form a drawer configuration,
  • at least one of the plurality of connecting elements is movable along a width direction of the drawer body for adjustment,
  • at least one of the plurality of connecting elements is movable along a length direction of the drawer body for adjustment,
  • and the drawer body is expandable or contractible;
  • wherein each of the plurality of connecting elements defines an array of openings that are dis-communicated with each other at a bottom surface of each of the plurality of connecting elements;
  • and the array comprises a plurality of rows and a plurality of columns...
  • the plurality of connecting elements are connected to each other by inserting fasteners into at least one of the plurality of openings.

The complaint does not specify any asserted dependent claims but seeks judgment on "any asserted claims" Compl., prayer 2

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as "Plaintiff's drawer product" sold on Amazon, referencing at least ASIN B0DT8FNLKR Compl. ¶3 Compl. ¶16 Compl. ¶28

Functionality and Market Context

The complaint is a declaratory judgment action and does not describe the technical functionality of the accused product in detail. It is identified as a "drawer product" offered for sale on Amazon's e-commerce platform, which accounts for a significant portion of the Plaintiff's business Compl. ¶3 Compl. ¶15 The complaint alleges that Defendant's enforcement action through Amazon threatens the removal of Plaintiff's product listings Compl. ¶5 Compl. ¶16

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment, does not contain a detailed breakdown of the defendant's infringement theory. It states only that the defendant "contended that Plaintiff's Accused Products infringe at least one claim of the '181 Patent" via a complaint to Amazon Compl. ¶27 The complaint avers that the Accused Products do not infringe any claim "literally or under the doctrine of equivalents" Compl. ¶29 As the complaint does not provide the defendant's infringement contentions or map features of the accused product to claim limitations, a claim chart summary cannot be constructed.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may arise over the meaning of "connecting elements." The question for the court could be whether this term is limited to the specific sheet-like structures with protruding side walls shown in the patent's figures or if it can be read more broadly to cover other modular drawer components.
• Technical Questions: A key evidentiary question will be whether the accused product's components are connected using "fasteners" inserted into "an array of openings that are dis-communicated with each other" as required by Claim 10. The complaint provides no facts to suggest how the accused product is constructed or adjusted.

V. Key Claim Terms for Construction

• The Term: "an array of openings that are dis-communicated with each other" (from Claim 10)
• Context and Importance: This term is critical as it defines the mechanism for adjusting and securing the drawer's components. The interpretation of "array" and the unusual term "dis-communicated" will be central to determining whether the accused product's adjustment features fall within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification mentions that openings can be "elongated oval hole[s] or...circular hole[s]" '181 Patent, col. 8:3-12, which may support an argument that the precise shape is not limiting. "Dis-communicated" could be argued to simply mean the openings are physically separate and distinct from one another.
  • Evidence for a Narrower Interpretation: Claim 10 itself requires the "array" to comprise "a plurality of rows and a plurality of columns," suggesting a structured, grid-like arrangement '181 Patent, col. 10:23-25 The patent figures consistently depict a regular pattern of discrete, elongated slots '181 Patent, Fig. 1 '181 Patent, Fig. 2 A party could argue "dis-communicated" is intended to distinguish these separate openings from a single, continuous slot, thereby narrowing the claim scope.

VI. Other Allegations

• Indirect Infringement: The complaint broadly denies indirect infringement but provides no specific facts regarding the defendant's allegations on this issue Compl. ¶29 The complaint does not provide sufficient detail for analysis of any potential induced or contributory infringement theory.

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

• Definitional Scope: A core issue will be one of claim construction, particularly for the terms "connecting elements" and the phrase "array of openings that are dis-communicated with each other." How the court defines these structural requirements will likely determine the outcome of the infringement analysis.
• Invalidity and Obviousness: The complaint seeks a declaration of invalidity based on prior art allegedly disclosing features like nested components and width adjustability '181 Patent, ¶36 A central question will be whether combining these known elements to create a drawer adjustable in both length and width, as claimed in the '181 Patent, would have been obvious to a person of ordinary skill in the art.
• Factual Comparison: Assuming the case proceeds, a key evidentiary question will be whether the plaintiff's accused drawer product, once fully examined, actually embodies the specific adjustment mechanism recited in the claims, particularly the use of fasteners passing through a grid-like array of separate openings on overlapping components.