DCT

2:26-cv-01534

Suzhouyehaidejingwenhuachuanboyouxiangongsi v. Shenzhen Zhanpusida Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-01534, W.D. Pa., 07/27/2026
  • Venue Allegations: Plaintiffs allege venue is proper as the Defendant is not a U.S. resident and thus may be sued in any judicial district. The complaint also asserts a connection to other pending actions in the same court involving the same parties and related patents.
  • Core Dispute: Plaintiffs, sellers of vehicle jump starters, seek a declaratory judgment that their products do not infringe Defendant's patent related to the internal structure of an emergency starting power supply.
  • Technical Context: The technology concerns the mechanical design and internal component arrangement of portable power packs used to jump-start vehicles with dead batteries.
  • Key Procedural History: This action was filed after Defendant submitted patent infringement complaints against Plaintiffs to Amazon.com, prompting the potential delisting of Plaintiffs' products. The complaint notes that the patent-in-suit, a "child" patent, was subject to a terminal disclaimer during prosecution to overcome an obviousness-type double patenting rejection over a parent patent, which may suggest a narrower scope for its claims. The filing is part of a series of "Concurrent Actions" between Amazon sellers and the Defendant over a family of related patents.

Case Timeline

Date Event
2023-11-16 Priority Date for '126 Patent
2024-03-19 Filing Date of Parent '984 Application
2024-10-30 Filing Date of '038 Application (leading to '126 Patent)
2025-01-03 USPTO issues obviousness-type double patenting rejection
2025-03-20 Defendant files terminal disclaimer for '126 Patent claims
2025-06-17 '126 Patent Issues
Late Oct. 2025 Defendant allegedly begins lodging infringement complaints with Amazon
2026-02-03 Amazon notifies Plaintiff Carzip-us of infringement complaint
2026-06-26 Amazon notifies Plaintiffs PIRAIL Store and Szx Direct of infringement complaint
2026-07-27 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,336,126 - "Emergency Starting Power Supply for Vehicle"

  • Patent Identification: U.S. Patent No. 12,336,126, "Emergency Starting Power Supply for Vehicle," issued June 17, 2025 (the "'126 Patent").

The Invention Explained

  • Problem Addressed: The patent's background section identifies issues in existing portable jump starters, specifically the "mounting instability and poor reliability of the power source, circuit board, and output terminals within the shell," which leads to a "relatively low lifespan" for the devices '126 Patent, col. 1:30-35
  • The Patented Solution: The invention proposes a specific internal structural design to improve stability and reliability. The core of the solution is a shell containing a "first mounting part" which, in turn, has a "second accommodating space" designed to securely house the output terminal '126 Patent, col. 1:47-60 The design also features a detachable connection between a "first coupling part" on the output terminal and a "second coupling part" on the first mounting part, facilitating secure assembly and potentially easier maintenance '126 Patent, abstract '126 Patent, col. 9:55-63 The exploded view in Figure 1 illustrates this modular assembly of internal components within the shell.
  • Technical Importance: This approach aims to enhance the durability and longevity of portable jump starters by creating a more robust and stable internal assembly for critical electrical components '126 Patent, col. 5:27-35

Key Claims at a Glance

  • The complaint indicates that Defendant's infringement assertion is premised on Claim 1 of the '126 Patent Compl. ¶40
  • Independent Claim 1 of the '126 Patent requires:
    • An emergency starting power supply comprising a shell, a power source, a circuit board, and an output terminal.
    • The shell has a "first accommodating space" (housing the power source and circuit board) and a "first mounting part."
    • The output terminal has a "first coupling part," and the first mounting part has a "second coupling part," with the two parts being "detachably connected."
    • The shell itself comprises a "first shell" and a "second shell."
    • The "second shell" is provided with a "first translucent layer."
  • Plaintiffs seek a declaratory judgment of non-infringement for "any valid claim" of the '126 Patent Compl. ¶47

III. The Accused Instrumentality

Product Identification

The accused products are "jump starter devices for vehicles" sold by the three Plaintiffs on Amazon.com Compl. ¶18 The complaint provides a chart identifying the specific products by their Amazon Standard Identification Numbers (ASINs): B0FMY8ZQK5, B0FS19G784, and B0FM3HJZY2 Compl. ¶37

Functionality and Market Context

The complaint describes the products as jump starters sold on the Amazon marketplace Compl. ¶31 It does not provide specific technical details about their internal construction. The complaint emphasizes the commercial harm caused by Defendant's infringement notices to Amazon, which threaten to delist the products, thereby damaging their sales velocity, search ranking, and competitive positioning Compl. ¶44 The complaint includes a table identifying the plaintiffs and the specific Amazon Standard Identification Numbers (ASINs) of the accused jump starter products Compl. ¶37

IV. Analysis of Infringement Allegations

The declaratory judgment complaint does not contain a detailed infringement analysis or claim chart from the Defendant, stating the Defendant's allegations were "cursory" Compl. ¶40 The following table summarizes the infringement theory that can be inferred from the Defendant's assertion of Claim 1 against Plaintiffs' jump starter products.

'126 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An emergency starting power supply for vehicles, comprising a shell, a power source, a circuit board, and an output terminal The accused products are jump starter devices for vehicles that contain a shell, power source, circuit board, and output terminal Compl. ¶18 ¶18; ¶37 col. 7:56-61
wherein the shell is provided with a first accommodating space and a first mounting part The shell of the accused products allegedly contains an internal cavity and a structural component that serves as a mounting part for other components. ¶36; ¶49 col. 8:1-3
the power source and the circuit board are housed in the first accommodating space The power source and circuit board of the accused products are allegedly housed within the main internal cavity of the device's shell. ¶36; ¶49 col. 8:16-20
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 accused products allegedly feature a specific detachable connection mechanism between the output terminal and an internal mounting structure. ¶36; ¶49 col. 9:55-63
the shell comprises a first shell and a second shell, and the second shell is provided with a first translucent layer The housing of the accused products is allegedly made of two primary shell pieces, with one piece featuring a translucent layer or panel. ¶36; ¶49 col. 10:47-53; col. 11:15-17

Identified Points of Contention

  • Structural Equivalence: A central question will be factual: do the accused products contain the specific internal architecture described in Claim 1? The dispute may focus on whether the internal chassis of Plaintiffs' products constitutes a "first mounting part" with a "second coupling part" that is "detachably connected" to a "first coupling part" on the output terminal, as the patent requires.
  • Scope Questions: The interpretation of "first translucent layer" raises a potential point of contention. The parties may dispute whether this term covers any semi-transparent plastic on the device's housing or is limited to a distinct layer with specific properties or functions as described in the patent's embodiments (e.g., made of PVC, PC, or acrylic) '126 Patent, col. 11:24-25

V. Key Claim Terms for Construction

  • The Term: "first mounting part"

    • Context and Importance: This term is foundational to the patent's claimed structural invention. The entire claim revolves around how other components (the output terminal, the circuit board) are positioned and secured relative to this part. Its construction will determine whether the internal frame or chassis of a generic jump starter can be considered to meet this limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the "first mounting part" in functional terms, such as being provided with "at least one first protrusion ... for limiting the circuit board" '126 Patent, col. 8:30-33 and an "opening ... for mounting cables" '126 Patent, col. 8:49-51 A party could argue that any internal structure performing these general mounting and limiting functions qualifies.
      • Evidence for a Narrower Interpretation: The patent shows a specific structure for the "first mounting part" (112) in multiple figures (e.g., '126 Patent, Figs. 1, 2, 4). A party may argue the term should be limited to a structure having the features of the depicted embodiment, including the specific shape of the "second coupling part" (1125) and "receiving groove" (11251) '126 Patent, col. 10:6-12

  • The Term: "first translucent layer"

    • Context and Importance: This is a distinct and specific element of the claimed shell. Its presence, absence, or construction in the accused products could provide a straightforward path to determining infringement or non-infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states the layer "serves to transmit and diffuse light, making it easier for users to observe the button ... and/or the display device" '126 Patent, col. 11:18-22 This functional description could support an interpretation that covers any part of the housing that is not fully opaque and is located over an indicator or button.
      • Evidence for a Narrower Interpretation: The patent describes the layer (11025) as a distinct component arranged "on the second shell" '126 Patent, col. 11:15-17 '126 Patent, Fig. 16 It also provides a list of exemplary materials: "PVC, PC, or acrylic" '126 Patent, col. 11:24-25 A party could argue the term requires a separate layer made from these types of materials, rather than a section of the shell that is merely molded from thinner or different-colored plastic.

VI. Other Allegations

Indirect Infringement

The complaint states that Plaintiffs have not infringed "directly or indirectly" Compl. ¶48, but does not provide specific facts regarding any allegations of indirect infringement by the Defendant. The complaint does not provide sufficient detail for analysis of this element.

Willful Infringement

As a declaratory judgment action filed by the accused infringers, the complaint does not allege willful infringement. Instead, it seeks a judgment that the case is "exceptional under 35 U.S.C. § 285" based on Defendant's alleged "wrongful assertion of patent infringement" through Amazon's enforcement platform, which would entitle Plaintiffs to attorneys' fees Compl. ¶¶52-53

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

  • A core issue will be one of factual comparison: Do the internal structures of Plaintiffs' accused jump starters embody the specific, multi-element assembly claimed in the '126 patent? The case will likely require a detailed tear-down and analysis of whether the products contain a "first mounting part" and a detachable "coupling part" mechanism that maps onto the claim language and patent figures.
  • A second key question will be one of definitional scope and presence: Does the housing of the accused products include a "first translucent layer" as that term is properly construed? The resolution may depend on whether this limitation requires a distinct, separate layer or can read on an integrally molded, semi-transparent portion of the device's shell.
  • A third issue, with potential strategic importance, is the prosecution history: The terminal disclaimer filed to overcome an obviousness-type double patenting rejection Compl. ¶10 serves as an admission that the '126 patent's claims are not patentably distinct from its parent. This history may be leveraged by Plaintiffs to argue for a narrower construction of the claims, cabined by the scope of the parent patent.
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