DCT

1:26-cv-05413

Hong Kong Zhan Teng Jiada Technology Ltd v. Shenzhen Liqiu Sanhou Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-05413, N.D. Ill., 05/11/2026
  • Venue Allegations: Venue is alleged to be proper under 28 U.S.C. § 1391(c)(3) on the basis that the Defendants are foreign entities not resident in any U.S. judicial district, and that they have directed sales of accused products into the district through various online marketplaces.
  • Core Dispute: Plaintiff alleges that Defendants' rotating and tilting puzzle boards infringe three U.S. patents related to "Puzzle Platform" technology.
  • Technical Context: The technology pertains to accessories for jigsaw puzzle enthusiasts, designed to improve the ergonomics and convenience of working on large puzzles through features like rotation and tilting.
  • Key Procedural History: The complaint does not allege any significant prior litigation, inter partes review proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date Event
2021-09-26 Priority Date for '343, '914, and '430 Patents
2025-03-04 U.S. Patent No. 12,239,914 Issued
2025-08-05 U.S. Patent No. 12,377,343 Issued
2025-12-09 U.S. Patent No. 12,491,430 Issued
2026-05-11 Complaint Filed

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

U.S. Patent No. 12,377,343 - "Puzzle Platform"

  • Issued: August 5, 2025

The Invention Explained

  • Problem Addressed: The patent describes conventional puzzle platforms as having complicated structures that are difficult and costly to manufacture due to the need for multiple, separate assembly steps '343 Patent, col. 2:1-14
  • The Patented Solution: The invention proposes a puzzle platform where the main puzzle board and its underlying reinforcing assembly are formed as a single, integral "one-piece structure," for example through injection molding '343 Patent, col. 6:58-63 This integrated base is combined with a detachable upper part, simplifying the manufacturing process and reducing costs '343 Patent, abstract
  • Technical Importance: This approach targets manufacturing efficiency for consumer goods by creating a robust, monolithic base structure that reduces assembly complexity and cost.

Key Claims at a Glance

  • The complaint asserts at least independent claim 23 '343 Patent, col. 18:1-11
  • The essential elements of independent claim 23 include:
    • a puzzle board;
    • a reinforcing assembly supporting the puzzle board and integral with the puzzle board to form a one-piece structure;
    • a rotating assembly coupled with the reinforcing assembly;
    • a receiving space formed by the puzzle board in cooperation with the reinforcing assembly; and
    • at least two puzzle drawers retained in the receiving space.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,239,914 - "Puzzle Platform"

  • Issued: March 4, 2025

The Invention Explained

  • Problem Addressed: The patent identifies the ergonomic challenges of large-scale puzzles, where a player's arm length is insufficient to reach the entire board, and notes that while tilting a board can help, it often leads to instability '914 Patent, col. 2:1-25
  • The Patented Solution: The invention discloses a dual-mode puzzle platform featuring both a kickstand for stable, inclined support and a separate rotating device for rotation. A core aspect of the solution is that these two modes are mutually exclusive: when the kickstand is used for tilting, the rotating device is in a "non-working state," and when the board is laid flat for rotation, the kickstand is in a "non-working state" '914 Patent, abstract '914 Patent, col. 2:32-47
  • Technical Importance: The invention provides a single product that combines two distinct ergonomic solutions-tilting for better viewing angles and rotation for better reach-addressing key usability problems for puzzle hobbyists.

Key Claims at a Glance

  • The complaint asserts at least independent claims 1 and 24 '914 Patent, col. 16:11-44 '914 Patent, col. 18:13-34
  • The essential elements of independent claim 1 include:
    • a puzzle board with at least one puzzle drawer;
    • a kickstand for supporting the puzzle board;
    • a rotating device coupled to the board and spaced apart from the kickstand;
    • a functional state where, when the kickstand is in use, the board is inclined and the rotating device is in a "non-working state";
    • a functional state where, when the kickstand is not in use, the board can be rotated by the rotating device and the kickstand is in a "non-working state"; and
    • a geometric limitation that projections of the kickstand and rotating device on the plane of the puzzle plate do not overlap.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,491,430 - "Puzzle Platform"

  • Issued: December 9, 2025

Technology Synopsis

The patent addresses the same ergonomic challenges as the '914 patent, proposing a dual-mode puzzle platform with mutually exclusive tilting and rotating functions '430 Patent, col. 2:27-51 This patent places a specific focus on the structure of the kickstand, claiming a "pair of extending arms" with rotating and free ends, and describes the kickstand being "at least partially received in the receiving cavity" when folded onto the puzzle board '430 Patent, claim 1

Asserted Claims & Accused Features

  • Asserted Claims: The complaint asserts at least independent claim 1 '430 Patent, col. 17:15-49
  • Accused Features: The complaint alleges that the "Accused Rotating and Tilting Puzzle Board Products" embody the claimed combination of a kickstand with extending arms and a rotating device Compl. ¶¶56-57

III. The Accused Instrumentality

  • Product Identification: The complaint identifies two categories of products: "Accused Rotating Puzzle Board Products" and "Accused Rotating and Tilting Puzzle Board Products" Compl. ¶27 Compl. ¶30 These are sold under the brand names "Playboda" and "WELGEE" Compl. ¶¶24-25
  • Functionality and Market Context: The accused products are described as puzzle boards that provide users with both rotational and tilting capabilities Compl. ¶¶27-31 The complaint includes an image from a product listing that advertises an "Upgraded Large Lazy Susan" for "360° Rotation" Compl. ¶28 Another image depicts a "Tilting & Rotating 2-in-1" product, which includes a "Foldable Tilting Stand" to "Adjust the angle" Compl. ¶31 The complaint alleges these products are sold through major e-commerce platforms such as Amazon.com, Wayfair.com, and the TikTok Shop, suggesting they are positioned for a broad consumer market Compl. ¶9

IV. Analysis of Infringement Allegations

'343 Patent Infringement Allegations

Claim Element (from Independent Claim 23) Alleged Infringing Functionality Complaint Citation Patent Citation
a puzzle board The main board component of the accused products used for puzzle assembly. ¶27 col. 6:3-5
a reinforcing assembly supporting the puzzle board and integral with the puzzle board to form a one-piece structure The complaint does not provide sufficient detail for analysis of this element, as it does not contain allegations regarding the manufacturing process or integral nature of the accused product's components. ¶34 col. 6:55-63
a rotating assembly coupled with the reinforcing assembly The accused products are alleged to include a "Lazy Susan" mechanism that provides rotational functionality. ¶28 col. 11:57-60
a receiving space formed by the puzzle board in cooperation with the reinforcing assembly; and at least two puzzle drawers retained in the receiving space The accused products are depicted with multiple drawers for storing puzzle pieces, which are housed within the board's structure. ¶31 col. 6:5-7
  • Identified Points of Contention:
    • Technical Question: A central technical question for the '343 Patent will be whether the accused product's reinforcing assembly is "integral with the puzzle board to form a one-piece structure." Infringement of this element may depend on evidence of the product's manufacturing process (e.g., whether it is a single injection-molded part), which is not detailed in the complaint.

'914 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a puzzle board having a puzzle plate...and at least one puzzle drawer The accused products are alleged to be puzzle boards that include one or more drawers. ¶31 col. 6:6-11
a kickstand for supporting the puzzle board on the playing surface The accused products are alleged to include a "Foldable Tilting Stand" for supporting the board at an angle. ¶31 col. 6:6
a rotating device coupled to the puzzle board and spaced apart from the kickstand The accused products are alleged to possess both a tilting stand and a separate "Lazy Susan" rotating mechanism. ¶28; ¶31 col. 6:7
when the kickstand supports the puzzle board...the rotating device is in a non-working state The complaint's theory alleges that the accused products operate in a tilting mode, which implies the rotating function is not simultaneously in use. ¶31; ¶45 col. 2:40-44
when the kickstand does not support the puzzle board, the puzzle board is capable of being rotated on the playing place via the rotating device, and the kickstand is in a non-working state The complaint alleges the accused products have a rotational mode via a "Lazy Susan," which implies the kickstand is stowed or not in use during rotation. ¶28; ¶45 col. 2:44-47
a projection of the kickstand on the projection plane and a projection of the rotating device on the projection plane do not overlap The complaint alleges infringement of this claim, which contains a specific geometric arrangement of the kickstand and rotating device. ¶45 col. 9:16-21
  • Identified Points of Contention:
    • Scope Question: A key dispute may concern the interpretation of "non-working state." The question for the court will be whether this term requires a component to be physically inoperable (e.g., the rotating device is lifted off the table when the kickstand is used) or if it is met simply when a feature is not actively being used by the operator.

V. Key Claim Terms for Construction

  • The Term: "integral with the puzzle board to form a one-piece structure" '343 Patent, claim 23

  • Context and Importance: This term appears to be the central point of novelty for the '343 Patent, distinguishing it from platforms made of multiple assembled components. The infringement analysis for this patent will likely depend entirely on whether the accused product meets this "one-piece" limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term could be argued to cover components that are permanently and inseparably joined post-manufacturing to function as a single unit, even if not molded as one piece.
    • Evidence for a Narrower Interpretation: The specification suggests a narrower meaning, stating that the components "are manufactured by injection molding to create an integral unit, thereby enhancing the mechanical strength of the board assembly 2 and reducing assembly costs" '343 Patent, col. 6:58-63 This language may support an interpretation that requires the board and assembly to be created as a single, monolithic part from the outset.

  • The Term: "non-working state" '914 Patent, claims 1, 24

  • Context and Importance: This term is critical to the patent's core concept of mutually exclusive operating modes. Its definition will determine whether the accused products, which possess both tilting and rotating hardware, actually function in the claimed manner. Practitioners may focus on this term because the infringement case depends on demonstrating that the use of one feature (e.g., the kickstand) necessarily places the other (e.g., the rotator) in a "non-working state."

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term might be construed to mean simply "not in use" or "not the intended mode of operation at a given time," which could be easier for the plaintiff to prove.
    • Evidence for a Narrower Interpretation: The abstract states that when the kickstand is in use, the "rotating device... [is] respectively inclined relative to the playing place," and is in a "non-working state" '914 Patent, abstract This physical description suggests a state of being physically inoperable or unstable for its intended function, rather than merely being idle.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all three patents, asserting that Defendants actively induce customers to infringe by providing instructions on how to use the accused rotating and tilting features of the products Compl. ¶35 Compl. ¶46 Compl. ¶57
  • Willful Infringement: The complaint alleges willful infringement based on Defendants' knowledge of the patents and the alleged infringement "since at least the filing of this action" Compl. ¶37 Compl. ¶48 Compl. ¶59 It further alleges that Defendants have acted "despite an objectively high likelihood that their actions constitute infringement of a valid patent" Compl. ¶39 Compl. ¶50 Compl. ¶61

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

  1. A primary issue will be one of manufacturing evidence: Does discovery reveal that the accused products are built with a reinforcing assembly that is "integral with the puzzle board to form a one-piece structure," as required by the '343 patent, or are they constructed from separately manufactured parts that are assembled later?
  2. A second central issue will be a question of claim scope and function: Can the term "non-working state," as used in the '914 and '430 patents, be met if a feature is merely not in use, or does it require the feature to be physically inoperable? The resolution of this question will be critical to determining if the accused dual-function products operate in the specific, mutually exclusive manner claimed by the patents.
  3. A third question will be one of technical equivalency: Does the accused product's "Foldable Tilting Stand" function as the claimed "kickstand," and does the "Lazy Susan" meet all the limitations of the claimed "rotating device," particularly concerning their geometric and functional relationships as described in the asserted claims?
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