DCT

1:26-cv-11174

Qindao Baizi Acoustic Technology Co Ltd v. Felt Right LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case: QINGDAO BAIZI ACOUSTIC TECHNOLOGY CO., LTD. v. Felt Right, LLC, Case No. 1:26-cv-11174, N.D. Ill., 09/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Felt Right conducts business in the district and has purposefully directed its patent-enforcement activities toward sellers in the district through Amazon's complaint process.
  • Core Dispute: Plaintiff seeks a declaratory judgment that Defendant’s patent for felt acoustic tiles is invalid, following Defendant’s use of Amazon’s intellectual-property complaint process to remove Plaintiff's products from the platform for alleged infringement.
  • Technical Context: The technology concerns decorative and sound-dampening wall tiles made from felt, with a focus on a specific multi-surface edge geometry intended to be aesthetic and easy to install.
  • Key Procedural History: The complaint notes that this action is not an isolated event. Defendant Felt Right has allegedly engaged in similar patent enforcement against other sellers on Amazon, leading to at least two other declaratory judgment actions concerning the same patent, which are also pending in the Northern District of Illinois.

Case Timeline

Date Event
2021-05-05 Priority Date for U.S. Patent No. 12,486,674
2025-12-02 U.S. Patent No. 12,486,674 Issued
2026-06-10 Amazon notifies Plaintiff of product removal
2026-09-14 Complaint for Declaratory Judgment Filed

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

  • Patent Identification: U.S. Patent No. 12,486,674, "Felt Tiles and Tile Kits," issued December 2, 2025 (the "'674 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section describes conventional wall décor, particularly decorative tiles, as difficult to install, requiring significant work, skill, and specialized tools (e.g., wet saws, trowels, tile adhesives) ʼ674 Patent, col. 1:7-22 It also notes that most wall décor is not easily customizable or child-friendly ʼ674 Patent, col. 1:10-12
  • The Patented Solution: The ʼ674 Patent discloses lightweight, rigid tiles made of fibers like felt, which can be easily installed without specialized tools ʼ674 Patent, abstract The core technical feature is a specific edge geometry, described as a "chamfered edge," which is formed by two distinct sets of side surfaces connecting the top and bottom faces of the tile ʼ674 Patent, col. 4:5-9 This design is intended to provide an aesthetic appeal and mitigate minor manufacturing imperfections in thickness or dimension ʼ674 Patent, col. 1:61-65 '674 Patent, col. 4:10-14 Figures 1A and 3A illustrate this two-part edge structure, comprising an angled or "non-perpendicular" surface (130, 330A) and a straight or "perpendicular" surface (140, 340A) ʼ674 Patent, Figs. 1A, 3A
  • Technical Importance: The invention aims to provide a modular, user-friendly, and customizable wall covering system that combines acoustic properties with decorative appeal, avoiding the complexity and permanence of traditional tiling ʼ674 Patent, col. 1:7-22 '674 Patent, col. 2:43-48

Key Claims at a Glance

  • The complaint focuses on independent Claim 1 as representative of the asserted claims Compl. ¶22
  • The essential elements of Claim 1 include:
    • A tile with a rigid body made of felt.
    • Parallel top and bottom surfaces, where the top surface area is smaller than the bottom surface area.
    • A thickness no greater than 1 inch.
    • The top and bottom surfaces are geometrically similar.
    • A plurality of side surfaces consisting of two distinct sets:
      • A first set of side surfaces directly connected to the top surface, where each surface is "not perpendicular to the top surface."
      • A second set of side surfaces directly connected to the bottom surface, where each surface is "perpendicular to the top surface."
    • The first and second sets of side surfaces are directly connected to each other to form "chamfered edges."
  • The complaint notes that dependent claims 2-7 add further limitations, and claims 8-15 concern tile kits Compl. ¶24

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are forty-seven listings of acoustic wall products sold by Plaintiff Baizi on Amazon.com under the storefront name "Mollywell Direct" Compl. ¶15 Compl. ¶18 Compl. ¶19

Functionality and Market Context

  • The complaint describes the Accused Products as "decorative polyester fiber acoustic panels" Compl. ¶18
  • These products are grouped into three categories based on their structure: "thirty-three plain hexagonal acoustic-panel listings, nine carved or patterned hexagonal acoustic-panel listings, and five 24-inch square acoustic-panel listings" Compl. ¶20 The complaint alleges that Felt Right's infringement accusations through Amazon have disrupted Baizi's ability to sell these products in the United States, creating "continuing legal and commercial uncertainty" Compl. ¶28 The complaint also points to prior art materials depicting "felt or acoustic-panel structures with beveled or multi-surface edges," suggesting the accused products may have similar geometric features Compl. ¶30 As part of its invalidity argument, the complaint references video evidence in Exhibit C showing how to cut felt panels into specific shapes Compl. ¶39

IV. Analysis of Infringement Allegations

This is a declaratory judgment action for patent invalidity, filed by the accused infringer (Baizi). The infringement allegations are those made by the patent holder (Felt Right) to Amazon, which prompted this lawsuit (Compl. ¶3). The table below summarizes the apparent mapping between the patent's claims and the accused products, as can be inferred from the complaint's description of the claims and the products.

'674 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A tile, having a rigid body made of felt... the rigid body has a top surface and a bottom surface that are parallel to each other Plaintiff's products are described as "decorative polyester fiber acoustic panels" sold as wall products Compl. ¶18, which Felt Right has accused of infringement (Compl. ¶3). ¶18 col. 8:19-23
an area of the top surface is smaller than an area of the bottom surface... the top surface and the bottom surface are geometrically similar The accused products include hexagonal and square acoustic panels Compl. ¶20, which Felt Right has accused of infringing the '674 patent, suggesting they embody this geometric relationship (Compl. ¶3). ¶20 col. 8:26-32
the plurality of side surfaces consisting of: a first set of side surfaces... being not perpendicular to the top surface... and a second set of side surfaces... being perpendicular to the top surface... each side surface of the second set... being directly connected to a corresponding side surface of the first set... to form chamfered edges The complaint does not detail the specific edge geometry of the Accused Products, but its invalidity argument relies on prior art with "beveled or multi-surface edges" Compl. ¶30 ¶30 col. 8:37-52
  • Identified Points of Contention:
    • Technical Questions: The central dispute is one of validity, not infringement. The complaint asserts that the claimed features were "disclosed in and/or rendered obvious by prior art" Compl. ¶29 A key question for the court will be whether the combination of a non-perpendicular and a perpendicular side surface to form a "chamfered edge" on a felt tile was novel and non-obvious as of the May 5, 2021 filing date Compl. ¶29
    • Evidentiary Questions: The case will likely depend on the strength of the prior art Baizi has identified. This includes pre-filing Amazon product listings Compl. ¶30, public disclosures of "geometrically structured felt panels" and "chamfered edges" Compl. ¶31, and techniques from the wall-covering arts for simulating multi-piece tiles Compl. ¶33 The probative value of the evidence referenced in Exhibits C, D, and E will be critical to Baizi’s invalidity contentions (Compl. ¶¶30-31; Compl. ¶39).

V. Key Claim Terms for Construction

  • The Term: "chamfered edges"

  • Context and Importance: This term is the structural heart of Claim 1. The claim itself defines it as being formed by the connection of a "not perpendicular" side surface and a "perpendicular" side surface ʼ674 Patent, col. 8:52 The validity of the patent hinges on whether this specific two-part edge structure was known or obvious. Practitioners may focus on this term because Baizi's invalidity case appears to rest on prior art allegedly disclosing "chamfered edges" generally Compl. ¶31 Compl. ¶37

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent repeatedly refers to the aesthetic benefits of "chamfered edges or other designed edges" in a general sense, suggesting the term could encompass various edge treatments that hide imperfections and improve appearance ʼ674 Patent, col. 1:61-65
    • Evidence for a Narrower Interpretation: Claim 1 explicitly defines "chamfered edges" as arising from the direct connection of a first set of non-perpendicular side surfaces and a second set of perpendicular side surfaces ʼ674 Patent, col. 8:49-52 Felt Right may argue this specific structural definition, illustrated in Figure 3A, limits the term's scope to only this two-part configuration, distinguishing it from general "beveled" or single-surface chamfered edges in the prior art.

  • The Term: "rigid body"

  • Context and Importance: The claim requires the tile to have a "rigid body made of felt" ʼ674 Patent, col. 8:19 The degree of "rigidity" required is not defined with a specific metric. Practitioners may focus on this term because the properties of "felt" can vary widely, and the distinction between a flexible felt pad and a "rigid" panel could become a point of contention when comparing the claims to both the accused products and prior art references.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests the tiles are "very light compared to ceramic felt tiles" and can be attached with simple adhesive tabs, implying a level of rigidity sufficient to hold shape but not necessarily comparable to wood or plastic ʼ674 Patent, col. 7:22-24
    • Evidence for a Narrower Interpretation: The patent contrasts its invention with non-customizable wall décor and complex tile installations, suggesting the "rigid body" must be firm enough to be handled as a discrete tile, maintain its geometric shape, and be assembled into larger designs without warping or distortion ʼ674 Patent, col. 1:10-15 '674 Patent, Fig. 7

VI. Other Allegations

This section is not applicable as the complaint is a declaratory judgment action for patent invalidity and does not contain allegations of indirect or willful infringement against the defendant.

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

  • A core issue will be one of validity over prior art: Does the prior art cited by the Plaintiff, including allegedly pre-existing products with "beveled or multi-surface edges" Compl. ¶30 and known techniques for structuring felt panels Compl. ¶31, anticipate or render obvious the specific two-part "chamfered edge" geometry recited in Claim 1 of the ’674 Patent?
  • A second key issue will be one of claim construction: The dispute will likely turn on the definition of "chamfered edges." The central question for the court will be whether this term is limited to the specific two-part structure (one non-perpendicular surface, one perpendicular surface) explicitly recited in the claim, or if it can be construed more broadly, potentially encompassing single-surface beveled edges that may be present in the prior art.
  • A final question will be evidentiary: Can the Plaintiff successfully establish that the prior art references, particularly commercial product listings and videos Compl. ¶30 Compl. ¶39, were publicly accessible before the patent's May 5, 2021 priority date and that they teach every element of the asserted claims?