Zhengzhouchengguankejiyouxiangongsi v. Cross Innovations LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Zhengzhouchengguankejiyouxiangongsi dba BigDolphin (China)
  • Defendant: Cross Innovations, LLC (Wyoming)
  • Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 4:26-cv-00115, E.D. Tex., 01/30/2026
• Venue Allegations: Plaintiff alleges venue is proper under 28 U.S.C. § 1391, based on Defendant's alleged substantial business activities within the Eastern District of Texas.
• Core Dispute: Plaintiff seeks a declaratory judgment that its bed assist rail products do not infringe Defendant’s patent on a bed rail system.
• Technical Context: The technology concerns bed assist rails, a home health and safety device used to help individuals get in and out of bed and to prevent falls, with specific patented improvements related to assembly and integrated lighting.
• Key Procedural History: This action was initiated after Defendant, Cross Innovations, LLC, filed a patent infringement complaint on the Amazon Marketplace against Plaintiff's products, resulting in their delisting. This lawsuit seeks a court order of non-infringement to resolve the dispute and potentially overturn the delisting.

Case Timeline

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

U.S. Patent No. 12,350,210 - "BED RAIL SYSTEM"

• Patent Identification: U.S. Patent No. 12,350,210, "BED RAIL SYSTEM," issued July 8, 2025 (the "'210 Patent").

The Invention Explained

• Problem Addressed: The patent's background section notes that while bed rails assist with bed entry/exit and prevent falls, "there are many desirable functions and features still not seen in the field" ('210 Patent, col. 1:22-24).
• The Patented Solution: The invention claims to provide improvements including easier assembly and integrated lighting features ('210 Patent, col. 2:28-32). An embodiment of the bed rail ships to a user in "four primary structural pieces, eliminating complicated user assembly," and incorporates a removable light bar within a cross member of the rail's frame ('210 Patent, col. 2:32-35; FIG. 9).
• Technical Importance: The described improvements aim to provide a "better user experience and increase the usability of the bed rail" by simplifying its setup and adding a functional, integrated lighting component ('210 Patent, col. 2:35-37).

Key Claims at a Glance

• The complaint focuses its non-infringement arguments on independent claim 1 ('210 Patent, col. 5:22-42; Compl. ¶¶ 29-32).
• The essential elements of independent claim 1 include:
  • A first pipe member.
  • A second pipe member disposed parallel to the first.
  • A removable cross member coupled between the first and second pipe members.
  • The removable cross member comprising a hollow cavity, a first finger cutout, and a second finger cutout.
  • A light bar comprising a light source.
  • The light bar is configured to be removably disposed within the hollow cavity of the removable cross member.
• The complaint seeks a declaration of non-infringement for "any claims of the Patent" Compl. ¶ 28

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are "bed assist rails" sold by Plaintiff on Amazon under the store name BigDolphin, identified by ASINs B0FJ1P5C39 and B0FHW97NB4 Compl. ¶¶ 13, 14

Functionality and Market Context

• The complaint alleges the Accused Products have a structure that differs from the claims of the ’210 Patent. Specifically, it is alleged to have a "non-removable tubular cross member without any hollow cavity" Compl. ¶ 30
• The lighting feature is described as a "motion sensing LED light" that "attaches to a removable storage pocket, which can be attached to and removed from the non-removable tubular cross member and the side bars by Velcro" Compl. ¶¶ 31, 7:1-3
• The complaint also alleges the Accused Products' frame includes "two additional pipe members between the first and second pipe members for stabilization effect," in contrast to the structure recited in claim 1 Compl. ¶ 32
• Plaintiff asserts that the Amazon marketplace is its "primary sales channel" and that delisting due to Defendant's infringement complaint causes significant harm, including lost sales, reviews, and product ranking Compl. ¶¶ 15, 16
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

’210 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute concerns the meaning of "removable cross member." The complaint's assertion that the accused cross member is "non-removable" Compl. ¶ 30 raises the question of what degree of permanence or what type of fastening defines "removable" under the patent. Another scope question is whether the presence of "two additional pipe members" Compl. ¶ 32 avoids infringement of a claim reciting "a first" and "a second" pipe member, especially given the claim's use of the open-ended transitional phrase "comprising."
• Technical Questions: A key factual question will be whether the accused product's LED light, which allegedly attaches to an external "storage pocket" via Velcro Compl. ¶¶ 31, 7:1-3, can be considered "disposed within the hollow cavity of the removable cross member" as required by the claim ('210 Patent, col. 5:40-42). Evidence will be needed to establish the precise location and method of attachment of the light in the Accused Products.

V. Key Claim Terms for Construction

The Term: "removable cross member"

• Context and Importance: This term is critical because Plaintiff's primary non-infringement argument is that its product has a "non-removable" cross member Compl. ¶ 30 The definition of "removable" will likely be a central point of contention.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the cross member can be removed by "removing the fastening members 306, 308," which appear to be screws ('210 Patent, col. 4:40-42). This may support an interpretation that "removable" includes components that are not necessarily designed for tool-less or frequent removal.
  • Evidence for a Narrower Interpretation: The patent's emphasis on "easier assembly" from "four primary structural parts" ('210 Patent, col. 2:30-32; col. 3:19-24) could suggest that "removable" implies a component intended for user manipulation as part of the normal assembly/disassembly process.

The Term: "disposed within the hollow cavity"

• Context and Importance: This term is pivotal as the complaint alleges the accused light attaches to an external pocket, not "within" a cavity in the cross member (Compl. ¶ 31).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The parties might dispute the boundaries of the "cross member" and "cavity." An argument could be made that any feature integrated with the cross member that houses the light is a "cavity."
  • Evidence for a Narrower Interpretation: The patent figures and description show a light bar (118) inserted into a "recess or space configured to receive the light bar" that is integral to the cross member (116) itself ('210 Patent, col. 4:35-37; FIG. 9). This evidence may support a narrower construction requiring the light to be housed inside the main body of the cross member, not in an external, fabric pocket.

VI. Other Allegations

Indirect Infringement

While the plaintiff seeks a declaratory judgment of non-infringement "either directly or indirectly" Compl. ¶ 28, the complaint's factual allegations focus exclusively on a direct non-infringement theory based on the physical structure of the Accused Products. The complaint does not provide sufficient detail for analysis of any indirect infringement theory.

Willful Infringement

Not applicable, as this is a declaratory judgment action for non-infringement filed by the accused infringer.

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

• A core issue will be one of structural correspondence: does the plaintiff's product, allegedly featuring a "non-removable tubular cross member" and an externally attached light, contain the "removable cross member" with an internal "hollow cavity" for the light as claimed in the '210 patent? The resolution will depend on both claim construction and a factual comparison of the accused device to the patent's claims.
• A secondary legal question will be one of claim scope: can the presence of additional, unrecited stabilizing pipes in the accused product's frame serve as a basis for non-infringement, or does the claim's "comprising" language mean that the addition of elements cannot avoid infringement so long as all claimed elements are present?