Shenzhenshi Hebi Jiaju Yongpin Youxian Gongsi v. Zhang

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhenshi Hebi Jiaju Yongpin Youxian Gongsi, d/b/a HEBESPACE-US (People's Republic of China)
  • Defendant: Meng Zhang (People's Republic of China)
  • Plaintiff's Counsel: Tronfuture Law PLLC
• Case Identification: 1:26-cv-10406, N.D. Ill., 08/28/2026
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant, who does not reside in the United States, may be sued in any judicial district. It further asserts that a substantial part of the patent enforcement activity giving rise to the action-an assertion through Amazon's APEX program-was undertaken by Defendant's authorized counsel based in the Northern District of Illinois.
• Core Dispute: Plaintiff seeks a declaratory judgment that its puzzle-table products do not infringe Claim 13 of Defendant's patent and that Claim 13 is invalid, following Defendant's assertion of the patent against Plaintiff's products via Amazon's Patent Evaluation Express ("APEX") procedure.
• Technical Context: The lawsuit concerns the mechanical design of adjustable and rotating tables specifically adapted for assembling jigsaw puzzles.
• Key Procedural History: The action was precipitated by Defendant Meng Zhang's use of Amazon's APEX program to assert U.S. Patent No. 12,576,331 against several of Plaintiff's products. The complaint also notes a pending litigation in the same district involving co-inventors of the '331 patent and a related patent, suggesting a coordinated enforcement effort.

Case Timeline

Date	Event
2021-09-26	'331 Patent Priority Date
2026-03-17	'331 Patent Issue Date
2026-08-12	Defendant's APEX Assertion
2026-08-28	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,576,331 - "Rotating Assembly and Jigsaw Puzzle Table"

(Issued March 17, 2026; the "'331 Patent")

The Invention Explained

• Problem Addressed: The patent's background section notes that conventional jigsaw puzzle tables often have a fixed height and do not allow for easy access to the entire surface, especially for larger puzzles. This can result in a poor user experience, as the user may not be able to comfortably reach or view all areas of the puzzle without physically moving around the table. '331 Patent, col. 1:12-32
• The Patented Solution: The invention is a puzzle table featuring both a rotating assembly and a tilting mechanism. A rotating assembly (20) is situated between the puzzle board (10) and a supporting assembly (3), allowing the entire work surface to be spun around. '331 Patent, col. 6:41-47 Separately, an adjusting structure (50) connects the puzzle board's support structure to a lower frame, enabling the board to be tilted from a flat position to an angled one for better ergonomics. '331 Patent, col. 9:56-62 '331 Patent, FIG. 15 This combination aims to allow a user to conveniently access and view any part of the puzzle from a single position.
• Technical Importance: The claimed combination of rotation and tilting addresses distinct ergonomic problems associated with working on large, flat surfaces for extended periods.

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement and invalidity concerning independent Claim 13 Compl. ¶1 Compl. ¶34
• The essential elements of Claim 13 are:
  • A jigsaw puzzle table, comprising: a board portion configured to be selectively placed in either a flat position or a tilted position, the board portion comprising a bottom surface;
  • at least two puzzle drawers located below the bottom surface;
  • a first pivoting arm connected to the bottom surface of the board portion;
  • a main frame located below the board portion and separated from the first pivoting arm;
  • an adjusting structure connecting the main frame and the first pivoting arm for adjusting a tilt angle of the board portion;
  • wherein when the board portion is in the flat position, the adjusting structure is connected to both the main frame and the first pivoting arm;
  • wherein when the board portion is in the tilted position, the adjusting structure remains connected to the main frame and the first pivoting arm; and
  • wherein a distance between the first pivoting arm and the main frame increases when the board portion is tilted compared to when the board portion is flat.
• The complaint reserves the right to seek declaratory relief regarding other claims, including Claim 1, should the Defendant assert them Compl. ¶38

III. The Accused Instrumentality

Product Identification

Plaintiff's HEBESPACE-US brand puzzle-table products, identified by Amazon Standard Identification Numbers (ASINs) B0F3847VLR, B0F384YZKX, and B0F8NN9BWR Compl. ¶1 Compl. ¶29

Functionality and Market Context

• The complaint identifies the accused instrumentalities as "puzzle-table products" sold to consumers in the United States through Plaintiff's Amazon storefront Compl. ¶4 Compl. ¶23
• The complaint does not provide sufficient detail for analysis of the specific technical design or operation of the accused products. It makes the conclusory allegation that the products "do not satisfy one or more limitations of Claim 13" without specifying a non-infringement theory Compl. ¶35

IV. Analysis of Infringement Allegations

The complaint, being a declaratory judgment action filed by the accused infringer, alleges non-infringement rather than infringement. It asserts that the accused products "do not satisfy one or more limitations of Claim 13" but does not provide a limitation-by-limitation analysis or identify which specific claim elements are allegedly absent Compl. ¶35 Therefore, a comparative claim chart cannot be constructed based on the complaint's allegations. The primary focus of the complaint's substantive arguments is on the invalidity of Claim 13 Compl. ¶¶36-38

No probative visual evidence provided in complaint.

Identified Points of Contention

• Factual Question: The central factual dispute for infringement will be whether the Plaintiff's puzzle tables contain structures that meet every limitation of Claim 13. Given the lack of detail in the complaint, this will depend entirely on evidence regarding the accused products' design.
• Structural and Functional Questions: The infringement analysis will likely focus on the specific mechanical arrangement required by Claim 13. Key questions may include:
  • Do the accused products have a component that meets the definition of a "main frame" that is "separated from the first pivoting arm"?
  • Do the accused products utilize an "adjusting structure" that "connects" the main frame and the pivoting arm in the manner claimed?
  • Does the operation of the accused products' tilting mechanism result in an "increase" in the "distance between the first pivoting arm and the main frame" as functionally required by the final "wherein" clause of Claim 13?

V. Key Claim Terms for Construction

"a main frame located below the board portion and separated from the first pivoting arm"

• Context and Importance: This term is critical because it defines a specific spatial and structural relationship between two key components of the tilting mechanism. The infringement analysis will depend on whether the accused product's support structure is arranged in this "separated" manner. Practitioners may focus on this term to dispute whether components in the accused device that are integrated or closely coupled can be considered "separated" as required by the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself uses the general term "separated" without specifying a required distance or degree of separation, which could support a construction that does not require significant physical distance. The patent also refers to the main frame and pivoting arm being connected by the adjusting structure, suggesting they are not fully disconnected parts '331 Patent, col. 27:44-46
  • Evidence for a Narrower Interpretation: The patent figures, such as Figure 18, depict the "main frame" (part of structure 5) and the "first pivoting arm" (454) as physically distinct and non-contiguous components linked by the "adjusting structure" (52). The specification describes the main frame (322) as part of a lower support structure, distinct from the reinforcing arms (45) that include the pivoting arm, which may support an argument that the two must be discrete structural elements '331 Patent, col. 9:8-12 '331 Patent, col. 7:46-54

"an adjusting structure connecting the main frame and the first pivoting arm"

• Context and Importance: The definition of the "adjusting structure" and how it "connects" the other elements is central to the claim's scope. A dispute may arise over what types of mechanisms satisfy this limitation and whether the connection must be direct or can be indirect.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses the general term "adjusting structure" without reciting the specific sub-components detailed in the specification. This may support a construction covering any mechanism that achieves the claimed function of adjusting the tilt angle by connecting the two named components.
  • Evidence for a Narrower Interpretation: The specification provides a highly detailed description of a preferred "adjusting structure" (50), which includes a foldable two-section adjusting unit (51), a driving unit (52), and a control unit (53) '331 Patent, col. 9:62-66 '331 Patent, FIG. 22 A party could argue that the scope of "adjusting structure" should be informed by or limited to this detailed embodiment, particularly if it is presented as the key to the invention's operation.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement, as it is a declaratory judgment action filed by the accused infringer seeking a finding of non-infringement.

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

1. Validity over Prior Art: A primary issue will be one of validity. The complaint explicitly identifies three prior art references (Maynes, Malki, and Van Laarhoven) and alleges they anticipate or render obvious Claim 13 Compl. ¶¶36-37 The case will likely involve a detailed technical comparison between the features disclosed in this art-such as tiltable work surfaces and storage drawers-and the specific combination of elements recited in Claim 13.
2. Claim Scope and Infringement: The second core issue will be one of structural and functional correspondence. The infringement analysis will turn on whether the mechanical design of the HEBESPACE-US puzzle tables embodies the precise structural arrangement and operational characteristics defined in Claim 13, particularly the specific relationship and interaction between the "pivoting arm", "main frame", and "adjusting structure", including the functional requirement that the distance between the arm and frame increases upon tilting.
3. Personal Jurisdiction: A threshold procedural question will be whether the Defendant's act of hiring an Illinois-based lawyer to initiate an extra-judicial enforcement action through Amazon's APEX program constitutes sufficient "suit-related enforcement contacts" to subject the foreign-domiciled Defendant to personal jurisdiction in the Northern District of Illinois Compl. ¶¶8-11