Chengdu Huiyuzhongtai Technology Co Ltd v. Changshawanfengyingmaoyiyouxiangongsi

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Chengdu Huiyuzhongtai Technology Co., Ltd. (China)
  • Defendant: Changshawanfengyingmaoyiyouxiangongsi (China)
  • Plaintiff's Counsel: Rice Technology Law Group
• Case Identification: 1:26-cv-06735, N.D. Ill., 06/09/2026
• Venue Allegations: Venue is asserted on the basis that the Defendant is not a U.S. resident, and there is no judicial district in which the action could otherwise be brought.
• Core Dispute: Plaintiff alleges that Defendant's adjustable pull-out cabinet organizers, sold in the U.S. via online marketplaces, infringe a patent related to adjustable drawer technology.
• Technical Context: The technology concerns modular, adjustable storage drawers for home and office cabinets, a market where the ability to customize a single product to fit various cabinet dimensions is a significant feature.
• Key Procedural History: The operative pleading is an Amended Complaint. The complaint does not reference any other significant procedural events such as prior litigation or administrative proceedings involving the patent-in-suit.

Case Timeline

Date	Event
2024-09-10	'181 Patent Priority Date
Fall 2025	Accused Product sales begin
2025-11-25	'181 Patent Issue Date
2026-06-09	Amended Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 12,478,181 ("the '181 Patent"), "Adjustable Drawer," issued November 25, 2025.

The Invention Explained

• Problem Addressed: The patent's background section notes that cabinets in households and offices come in different sizes and layouts, making the available space for storage drawers inconsistent. This requires drawers of different widths and lengths to be customized to match specific cabinets '181 Patent, col. 1:9-17
• The Patented Solution: The invention is an adjustable drawer constructed from a "plurality of connecting elements" that join together '181 Patent, abstract At least some of these elements are movable relative to each other along both the width and length directions, allowing the overall drawer body to be expanded or contracted to fit various cabinet sizes '181 Patent, col. 1:36-42 As shown in the patent's figures, this modularity allows for a customizable drawer configuration '181 Patent, Figs. 1, 4
• Technical Importance: This design offers a versatile, off-the-shelf storage solution that can adapt to different cabinet dimensions, potentially reducing the need for fully custom-built drawers '181 Patent, col. 1:56-60

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims of the '181 Patent, including at least claim 10" Compl. ¶42 Claim 10 is an independent claim.
• The essential elements of independent claim 10 include:
  • A drawer body comprising a plurality of connecting elements that join to form a drawer configuration.
  • At least one connecting element is movable along a width direction for adjustment, and at least one is movable along a length direction for adjustment, making the drawer body expandable or contractible.
  • Each connecting element defines an "array of openings that are dis-communicated with each other" on its bottom surface.
  • The array comprises a plurality of rows and columns of openings, where openings within a row are dis-communicated and openings within a column are dis-communicated.
  • The connecting elements are connected by inserting fasteners into at least one of the openings.

III. The Accused Instrumentality

Product Identification

The accused products are "adjustable pull-out cabinet organizer products" sold under the brand name "Seinloes" on Amazon.com Compl. ¶34 The complaint identifies two sets of products, the "First Accused Products" and "Second Accused Products," by their Amazon Standard Identification Numbers (ASINs) Compl. ¶35 Compl. ¶37

Functionality and Market Context

The accused products are marketed as storage solutions that can be adjusted to fit cabinets of various sizes Compl. ¶34 A product listing screenshot provided in the complaint describes the product as being "4-Side Expandable to Maximize Cabinet Space" and having an "adjustable length and width" Compl. p. 3 The complaint alleges these products are sold to U.S. consumers at prices denominated in U.S. dollars and have been sold in the U.S. since at least the fall of 2025 Compl. ¶13 Compl. ¶14 The complaint provides a screenshot of customer reviews from U.S. purchasers as evidence of sales within the United States Compl. p. 5

IV. Analysis of Infringement Allegations

The complaint states that claim charts comparing claim 10 of the '181 Patent to the accused products are attached as Exhibit B and Exhibit C Compl. ¶¶42-43 However, these exhibits were not included with the provided complaint. The complaint's narrative alleges that the accused products practice each limitation of at least claim 10 Compl. ¶39 The infringement theory centers on the allegation that the accused "Seinloes" organizers are composed of adjustable elements that allow for expansion and contraction in both length and width, mirroring the functionality claimed in the patent. A representative image of an accused product is included in the complaint Compl. p. 9

• Identified Points of Contention:
  • Scope Questions: A potential dispute may arise over the interpretation of "connecting elements" connected by "inserting fasteners." The analysis will question whether the specific components and assembly mechanism of the accused products fall within the scope of these terms as used in the patent.
  • Technical Questions: Claim 10 requires a very specific adjustment mechanism: an "array of openings that are dis-communicated with each other" arranged in rows and columns. A central factual question will be whether the accused product's adjustment system embodies this specific structure for receiving fasteners, or if it utilizes a different mechanism (e.g., a friction-based slide, continuous channels) that may not literally meet this claim limitation.

V. Key Claim Terms for Construction

• The Term: "connecting elements"

  • Context and Importance: This term defines the basic structural units of the claimed invention. Its scope will determine what types of modular components are covered by the claim. Practitioners may focus on this term to dispute whether the accused product is constructed from claimed "elements" or from a different structure.
  • Intrinsic Evidence for a Broader Interpretation: The patent specification describes the elements broadly as a "plurality of connecting elements [that] join together and form a drawer configuration" '181 Patent, col. 1:36-38, which could support an interpretation covering any modular pieces that assemble to form a drawer.
  • Intrinsic Evidence for a Narrower Interpretation: The embodiments depict the "connecting elements" as distinct plates with specific features like "a bottom portion 112" and "an outer edge 111" '181 Patent, col. 3:62-64 '181 Patent, Fig. 4 This could support an argument that the term is limited to the specific plate-like structures illustrated, not any generic modular component.

• The Term: "an array of openings that are dis-communicated with each other"

  • Context and Importance: This limitation is critical as it defines the claimed mechanism for adjusting and fastening the drawer components. The infringement analysis for claim 10 will depend heavily on whether the accused product's adjustment feature meets this specific structural requirement.
  • Intrinsic Evidence for a Broader Interpretation: The patent states that the openings may be "elongated oval hole[s] or a circular hole[s]" '181 Patent, col. 8:2-4, suggesting flexibility in the shape of the individual openings. This language may support an argument that the term covers various forms of discrete, non-continuous adjustment points arranged in a grid.
  • Intrinsic Evidence for a Narrower Interpretation: Claim 10 requires that the openings be "dis-communicated with each other in a row direction" and in a "column direction" '181 Patent, col. 10:20-27 This specific language could be used to argue for a narrow construction requiring a strict grid of physically separate and non-overlapping holes, potentially excluding systems with intersecting slots or other variations.

VI. Other Allegations

• Indirect Infringement: The complaint alleges active inducement of infringement, asserting that Defendant knowingly encourages infringement by "continuing to direct and/or instruct others to use, install and/or operate" the accused products Compl. ¶43
• Willful Infringement: The complaint alleges willful infringement based on Defendant's knowledge of its infringing acts since at least the filing of the complaint Compl. ¶45 Compl. ¶48 It seeks enhanced damages and asserts that Defendant acted despite an objectively high likelihood that its actions constitute infringement Compl. ¶47 Compl. ¶49

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

• A core issue will be one of definitional scope: Can the claim term "an array of openings that are dis-communicated with each other" be construed to read on the specific adjustment mechanism of the accused "Seinloes" organizers? The resolution of this claim construction issue will be pivotal to the infringement analysis.
• A key evidentiary question will be one of functional equivalence: If the accused product is found not to literally infringe, the case may turn on whether the differences between its adjustment mechanism and the claimed "array of openings" are insubstantial. The court will need to determine if the accused system performs substantially the same function, in substantially the same way, to achieve substantially the same result of adjustable fastening.
• A third question relates to damages and commercial activity: Given that both parties are non-U.S. entities and the sales channel is an online marketplace Compl. ¶2 Compl. ¶4 Compl. ¶19, establishing the full extent of U.S. sales, importation, and the resulting market impact on the Plaintiff will be a central focus for calculating any potential damages.