DCT

2:26-cv-00313

Foshanshihuituolidianchi Co Ltd v. Shenzhen Zhanpusida Technology Co Ltd

Log In
Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00313, W.D. Pa., 02/20/2026
  • Venue Allegations: Venue is asserted in the Western District of Pennsylvania on the basis that the Defendant is not a resident of the United States and therefore may be sued in any judicial district.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their vehicle jump starter products do not infringe Defendant’s patent related to the internal mechanical structure of an emergency power supply.
  • Technical Context: The technology concerns the internal design and component layout of portable jump starters, a common automotive accessory used to start a vehicle with a depleted battery.
  • Key Procedural History: The complaint alleges this action arises from Defendant’s patent enforcement activities on the Amazon.com marketplace, where Defendant submitted infringement complaints targeting Plaintiffs’ products. The complaint also references several other pending lawsuits in the same district involving Defendant and other Amazon sellers concerning patents from the same family. During prosecution of the patent-in-suit’s parent application, the USPTO issued an obviousness-type double patenting rejection, which the Defendant overcame by filing a terminal disclaimer.

Case Timeline

Date Event
2023-11-16 '127 Patent Priority Date
2024-12-31 USPTO issues double patenting rejection during prosecution
2025-03-20 Defendant files terminal disclaimer to overcome rejection
2025-06-17 U.S. Patent No. 12,336,127 ('127 Patent) Issued
2025-11-24 Defendant files related infringement action (Concurrent 25-1826)
2025-12-31 Other entities file related non-infringement action (Concurrent 25-2027)
2026-02-02 Amazon notifies Plaintiffs of Defendant's infringement complaint
2026-02-20 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,336,127 - "Emergency Starting Power Supply for Vehicle"

  • Patent Identification: U.S. Patent No. 12,336,127, issued June 17, 2025 (the “’127 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies a technical problem in prior art vehicle jump starters related to the "mounting instability and poor reliability of the power source, circuit board, and output terminals within the shell" of the device, which leads to a "relatively low lifespan" (ʼ127 Patent, col. 1:31-37).
  • The Patented Solution: The invention proposes a specific mechanical and structural arrangement to improve stability. It comprises a shell with a main internal cavity (a "first accommodating space") to house the power source and circuit board, and a distinct "first mounting part" which itself contains a "second accommodating space" for housing the output terminal (ʼ127 Patent, abstract; ʼ127 Patent, col. 7:59-col. 8:8). This compartmentalized design, where the output terminal is physically separated and secured in its own dedicated housing structure, aims to enhance the device's durability and reliability (ʼ127 Patent, col. 8:22-26).
  • Technical Importance: The described solution addresses the mechanical-structural integrity of a portable electronic device, which is significant for products intended for rugged, real-world use where components are subject to shock and vibration (ʼ127 Patent, col. 5:25-32).

Key Claims at a Glance

The complaint states Defendant’s infringement assertion was premised on Claim 1 of the ’127 Patent (Compl. ¶34). The complaint does not assert any other claims.

  • Independent Claim 1:
    • An emergency starting power supply for vehicles, comprising a shell, a power source, a circuit board, and an output terminal;
    • wherein the shell is provided with a first accommodating space and a first mounting part;
    • the power source and the circuit board are housed in the first accommodating space;
    • the power source is electrically connected to the circuit board and the output terminal, respectively;
    • the output terminal is provided with a first coupling part, the first mounting part is provided with a second coupling part, and the first coupling part is detachably connected to the second coupling part;
    • the output terminal is configured to output a current for starting an engine of the vehicles; and
    • 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 various models of "jump starter devices for vehicles" sold by Plaintiffs on the Amazon.com platform under the store names "HiTop Jump Starter" and "Uncle Smith's Garage" (Compl. ¶4; Compl. ¶5; Compl. ¶15). The complaint identifies specific products by their Amazon Standard Identification Numbers (ASINs) (Compl. ¶31).

Functionality and Market Context

  • The complaint describes the accused products as jump starters used to provide emergency power to vehicles (Compl. ¶15). The complaint alleges that Plaintiffs are "leading sellers in the jump starter segment on Amazon.com" and have earned goodwill through the sale of these products (Compl. ¶24; Compl. ¶26). Limited technical detail about the internal construction or specific operation of the accused products is provided in the complaint itself.

IV. Analysis of Infringement Allegations

The complaint, being a declaratory judgment action for non-infringement, does not contain a claim chart or detailed infringement allegations. It states that the Defendant's infringement accusation submitted to Amazon was "cursory and contained no infringement analysis or patent claim chart" (Compl. ¶34). Therefore, a claim chart summary cannot be constructed from the provided documents. The core of the dispute will center on whether the internal structure of the Plaintiffs' products contains the elements recited in Claim 1 of the ’127 Patent.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Structural Questions: The central dispute will likely involve a factual comparison of the internal mechanical construction of the accused jump starters against the claimed structural limitations. A key question for the court will be whether the accused products contain a distinct "first mounting part" that houses the output terminal separately from the "first accommodating space" where the main power source and circuit board reside, as required by Claim 1.
    • Scope Questions: The analysis may turn on the interpretation of terms like "first mounting part," "first coupling part," and "second coupling part." A potential issue is whether these terms, as used in the patent, can be read to cover the more integrated or unitary internal shell designs that may be present in the accused products, or if they are limited to the specific multi-component, detachable structures depicted in the patent’s figures.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific claim terms. However, based on the structural nature of the asserted claim, the following terms may become central to the dispute.

  • The Term: "first mounting part"

  • Context and Importance: This term defines the key structural element that allegedly provides the invention's stability benefits by compartmentalizing the output terminal. The entire infringement analysis for Claim 1 may depend on whether the accused products contain a structure that meets the definition of this term. Practitioners may focus on this term because it appears to be the primary point of novelty over a generic housing for a power supply.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Parties seeking a broader construction may argue that the term should be defined functionally as any internal structure within the shell that serves to mount and hold the output terminal (ʼ127 Patent, col. 8:1-2).
    • Evidence for a Narrower Interpretation: Parties seeking a narrower construction may point to the detailed description and figures, which consistently depict the "first mounting part" (112) as a specific, molded piece with a dedicated "second accommodating space" (1121) and a "second coupling part" (1125) for a detachable connection (ʼ127 Patent, FIG. 1; ʼ127 Patent, col. 8:27-30). This could support an argument that the term is limited to a structure with these specific features, and does not read on a simple boss or integrated portion of the main shell.

  • The Term: "detachably connected"

  • Context and Importance: This term describes the relationship between the "first coupling part" on the output terminal and the "second coupling part" on the "first mounting part." Whether the connection in the accused products is "detachable" in the manner claimed will be a critical infringement question.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A broad interpretation could encompass any non-permanent connection, including a snap-fit or a component held in place by pressure from other parts. The claim language itself does not specify the mechanism of detachment (ʼ127 Patent, claim 1).
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the coupling parts are "slidingly connected," with a "third protrusion" (1411) sliding into a "receiving groove" (11251) (ʼ127 Patent, col. 10:1-8). Another embodiment discloses the parts are connected "by a screw" (ʼ127 Patent, col. 10:27-35). A defendant may argue that "detachably connected" should be limited to these disclosed mechanisms, which imply intentional user action for removal, rather than a simple friction fit.

VI. Other Allegations

  • Exceptional Case: The complaint requests that the case be found "exceptional" under 35 U.S.C. § 285, which would entitle Plaintiffs to an award of attorneys' fees (Compl. ¶47). This allegation is based on Defendant's alleged conduct of initiating a "patent assertion campaign" through Amazon's e-commerce enforcement platform with the purported intent to "disrupt and terminate" Plaintiffs' commercial activities (Compl. ¶21; Compl. ¶29).

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

This declaratory judgment action appears poised to address the boundaries of patent enforcement on e-commerce platforms and the interpretation of mechanical-structural patent claims. The central questions for the court will likely be:

  • A core issue will be one of structural mapping: Do the internal components of the accused jump starters physically correspond to the claimed arrangement of a "first accommodating space" for the power source and a distinct "first mounting part" with its own "second accommodating space" for the output terminal, or is there a fundamental mismatch in their mechanical design?
  • A second key issue will be one of definitional scope: Can terms rooted in the patent’s specific embodiments, such as a "first mounting part" with a "coupling part" for a "detachably connected" terminal, be construed broadly enough to read on the potentially more integrated and unitary internal structures of the accused products?
  • Finally, a significant procedural question will be whether Defendant’s alleged use of Amazon's infringement reporting system as part of a multi-faceted enforcement campaign against numerous sellers constitutes conduct that renders the case "exceptional" under 35 U.S.C. § 285, irrespective of the ultimate outcome on the infringement question.
Loading Complaint