Dong Guan Shi Dian Xiao Wu Technology Co Ltd v. Shenzhen Zhanpusida Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiffs: DONG GUAN SHI DIAN XIAO WU TECHNOLOGY CO., LTD.; CHANGSHASHIJIEMAOSHANGMAOYOUXIANGONGSI; SHENZHENSHIJIEZHAOKEJIYOUXIANGONGSI; SUZHOUYEHAIDEJINGWENHUACHUANBOYOUXIANGONGSI; SHENZHENSHIJIUXIAOTONGKEJIYOUXIANGONGSI; and NANJING BEIBAO IMPORT & EXPORT CO. (People's Republic of China)
  • Defendant: Shenzhen Zhanpusida Technology Co., Ltd. (People's Republic of China)
  • Plaintiff's Counsel: ShinyRise PLLC
• Case Identification: 2:26-cv-00312, W.D. Pa., 04/26/2026
• Venue Allegations: Plaintiffs allege that venue is proper in any judicial district because the Defendant is not a resident of the United States.
• Core Dispute: Plaintiffs seek a declaratory judgment that their vehicle jump starter products do not infringe Defendant's patent, following Defendant's infringement complaints submitted through the Amazon.com e-commerce platform.
• Technical Context: The technology at issue concerns the internal mechanical construction and component layout of portable emergency power supplies used to jump-start vehicles.
• Key Procedural History: The complaint arises from Defendant's alleged patent enforcement actions on Amazon.com, which Plaintiffs characterize as a "patent assertion campaign." These actions, including complaints filed via Amazon's Patent Evaluation Express (APEX) program, resulted in the delisting of Plaintiffs' products. The complaint also references several other pending declaratory judgment actions in the same district involving the Defendant and other patents from the same patent family, indicating a broader dispute between competitors on the platform.

Case Timeline

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

• Patent Identification: U.S. Patent No. 12,284,774, "Emergency Starting Power Supply for Vehicle," issued on April 22, 2025.

• The Invention Explained:

  • Problem Addressed: The patent's background section identifies issues in existing portable jump starters related to the "mounting instability and poor reliability of the power source, circuit board, and output terminals within the shell," which can lead to a "relatively low lifespan" for the device ʼ774 Patent, col. 1:30-36
  • The Patented Solution: The invention proposes a specific internal structural arrangement to improve durability. The solution is a shell comprising a "first accommodating space" to house the power source and circuit board, and a distinct "first mounting part" which in turn has a "second accommodating space" designed to securely house at least a portion of the output terminal '774 Patent, abstract '774 Patent, col. 1:44-59 This compartmentalized design is intended to enhance the mounting stability and reliability of the internal components '774 Patent, col. 8:14-27
  • Technical Importance: The patent addresses the need for improved mechanical robustness and longevity in a consumer electronics product class through specific choices in internal physical architecture.

• Key Claims at a Glance:
  The complaint states that Defendant's infringement assertion is premised on Claim 1 of the '774 Patent Compl. ¶37

  • Independent Claim 1:
    • An emergency starting power supply for vehicles comprising a shell, a power source, a circuit board, and an output terminal.
    • The shell is provided with a first accommodating space and a first mounting part.
    • The power source and circuit board are housed in the first accommodating space.
    • The power source is electrically connected to the circuit board and the output terminal.
    • The first mounting part is provided with a first through-hole and a second accommodating space.
    • At least a portion of the output terminal is housed in the second accommodating space.
    • The output terminal is configured to output current for starting a vehicle engine.
    • The first through-hole is configured for mounting the output terminal.
    • The first mounting part is provided with at least one first opening configured for mounting cables connected to the output terminal.

III. The Accused Instrumentality

• Product Identification: The accused instrumentalities are "jump starter devices for vehicles" sold by the six Plaintiffs on the Amazon.com platform Compl. ¶17 Compl. ¶26 The complaint identifies each specific product by its Amazon Standard Identification Number (ASIN) Compl. ¶34

• Functionality and Market Context:

  • The complaint describes the accused products as jump starters offered for sale on the Amazon marketplace Compl. ¶26 Compl. ¶27 The complaint includes a chart identifying each Plaintiff, their accused product's Amazon Standard Identification Number (ASIN), and the date they received notice of enforcement from Amazon Compl. p. 9
  • The complaint alleges that Plaintiffs are competitors of the Defendant in the jump starter market segment on Amazon Compl. ¶32 It further alleges that the Defendant's actions have caused Plaintiffs' products to be delisted, resulting in loss of sales, ranking, and market visibility Compl. ¶27 Compl. ¶41

IV. Analysis of Infringement Allegations

The complaint, a declaratory judgment action for non-infringement, does not contain a claim chart or a detailed infringement theory from the Defendant. In fact, it alleges that the Defendant's accusation was "cursory and contained no infringement analysis or patent claim chart" Compl. ¶37 The Plaintiffs' core allegation is a general denial that their products contain "each and every element and limitation of any valid claim of the '774 Patent" Compl. ¶45

• Identified Points of Contention:
  Given that Claim 1 of the '774 Patent recites a series of specific, physical structural features, the dispute will center on a factual comparison of the accused products' internal construction against these claimed elements.

  • Scope Questions: The analysis may raise questions about the scope of the claim terms. For example, does the internal chassis of an accused product contain a structure that qualifies as a "first mounting part" that is distinct from the main shell and contains its own "second accommodating space," as the claim requires?
  • Technical Questions: A primary technical question will be whether the accused products are constructed with the specific compartmentalization claimed. For instance, what evidence exists that the accused products' output terminals are housed within a "second accommodating space" that is part of a "first mounting part," rather than being mounted directly to the main shell or integrated in a different manner not covered by the claim?

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a full analysis of claim construction disputes. However, based on the nature of the patent, the following term is likely to be critical.

• The Term: "first mounting part"

• Context and Importance: This term is the central structural element that distinguishes the claimed invention from the prior art described in the patent. It is not just part of the shell; it is a feature of the shell that has its own features (e.g., a "second accommodating space" and a "first through-hole"). Infringement of Claim 1 will hinge on whether the accused products contain a structure that meets this definition. Practitioners may focus on this term because its definition will determine whether a wide range of internal product architectures fall within the scope of the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party seeking a broader interpretation might argue that "first mounting part" should encompass any internal feature or combination of molded features within the shell that serves to position and secure the output terminal. The specification describes it as being provided on the "first shell" ʼ774 Patent, col. 8:66-67, which could support an argument that it is an integral feature rather than a physically separate piece.
  • Evidence for a Narrower Interpretation: A party seeking a narrower interpretation may point to figures like FIG. 1 and FIG. 7, which depict element 112 as a specific, defined section of the housing with multiple complex features. Language stating the "first mounting part is injection-molded using a mold" '774 Patent, col. 8:60-61 and has specific features like a "second coupling part" ʼ774 Patent, col. 9:52-54 and a "receiving groove" ʼ774 Patent, col. 10:4-6 could be used to argue it must be a structure with these particular characteristics.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both direct and indirect infringement but does not provide specific facts related to an indirect infringement theory Compl. ¶46 The focus is on the accused products themselves.

• Willful Infringement: The complaint does not address willful infringement by the Plaintiffs. Instead, it makes allegations about the Defendant's conduct, requesting that the court find the case "exceptional" under 35 U.S.C. § 285, which would entitle Plaintiffs to attorneys' fees Compl. ¶51 Compl., prayer 3 The basis for this request is the allegation that Defendant engaged in a "wrongful assertion of patent infringement" and is "intentionally abusing Amazon's marketplace enforcement procedures" Compl. ¶50 Compl., p. 11

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

1. A central question will be one of structural identity: Does the internal physical architecture of the various accused jump starters, once subjected to discovery and inspection, contain each of the specific structural limitations recited in Claim 1, most notably a "first mounting part" that itself contains a "second accommodating space" for housing the output terminal?

2. A key legal and procedural question will be the propriety of enforcement: Did the Defendant's use of Amazon's APEX program, based on what Plaintiffs allege was a "cursory" infringement accusation without a detailed claim chart, constitute wrongful assertion or abuse of enforcement procedures sufficient to make this an "exceptional case" under 35 U.S.C. § 285?