Hangzhou Sanuoge Trading Co Ltd v. Sportspower Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Hangzhou Sanuoge Trading Co. Ltd. aka Fashionsport-Outfitters (China)
  • Defendant: Sportspower Ltd. (Hong Kong)
  • Plaintiff's Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 3:26-cv-02604, N.D. Tex., 08/06/2026
• Venue Allegations: Venue is asserted on the basis that Defendant Sportspower is not believed to reside in the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its combination trampoline and swing set product does not infringe Defendant's patent, following Defendant's patent infringement notice that resulted in the product's delisting from the Walmart Marketplace.
• Technical Context: The technology relates to outdoor recreational equipment, specifically combination play sets that integrate a trampoline with a traditional A-frame swing set structure.
• Key Procedural History: The complaint alleges that during the prosecution of the patent-in-suit, the inventor filed an affidavit with the USPTO stating that the novel feature was a trampoline member "having an outside pair of legs and the inside legs being shared with the swing set." This statement may be used to argue for a narrower interpretation of the patent's claims.

Case Timeline

Date	Event
2008-04-11	'738 Patent Priority Date
2009-07-31	Inventor filed affidavit with USPTO during prosecution
2011-03-22	'738 Patent Issued
2026-07-06	Sportspower lodged Walmart patent infringement notice
2026-08-06	Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 7,909,738 - "Trampoline Swing"

• Patent Identification: U.S. Patent No. 7,909,738, "Trampoline Swing," issued March 22, 2011.

The Invention Explained

• Problem Addressed: The patent does not explicitly state a problem, but its context in the field of backyard play equipment suggests an effort to create a more integrated and feature-rich combination play set beyond a simple swing frame U.S. Patent 7,909,738, col. 2:16-21
• The Patented Solution: The invention describes a play set where a trampoline assembly is structurally integrated with a swing set assembly '738 Patent, abstract A key aspect of this integration is the connection of the trampoline frame to the main leg supports of the swing set, effectively sharing part of the support structure '738 Patent, Fig. 1 '738 Patent, col. 4:55-67 The swing assembly has a standard A-frame design with a top bar and four main leg supports, while the attached trampoline assembly is supported, at least in part, by those same leg supports '738 Patent, col. 5:40-67
• Technical Importance: This design provides a method for combining two popular pieces of backyard equipment into a single, cohesive unit, potentially saving space and cost compared to two separate structures.

Key Claims at a Glance

• The complaint identifies independent claims 1 and 10 as being at issue Compl. ¶35 Compl. ¶37
• Independent Claim 1 requires, in part:
  • A swing assembly with a top bar and four main body leg supports.
  • A pair of connectors "connected to two of the four main body leg supports."
  • A trampoline assembly connected to the pair of connectors, which includes:
    • A "horizontally oriented trampoline frame, supported by at least two of the four main body leg supports."
    • A trampoline bed suspended across the frame.
• Independent Claim 10 is structurally similar to claim 1, requiring a "trampoline to swing connection member" that connects the trampoline frame to the swing assembly, and a trampoline frame "supported by at least two of the four main body leg supports" '738 Patent, col. 6:23-41
• The complaint notes that if the independent claims are not infringed, the dependent claims 2-9 and 11-19 are likewise not infringed Compl. ¶38

III. The Accused Instrumentality

Product Identification

• The Accused Product is a combined "trampoline swing set" sold by Fashionsport-Outfitters, identified by Product ID: 19260766807 Compl. ¶5

Functionality and Market Context

• The Accused Product is an outdoor recreation unit that includes a swing set frame, swings, a slide, and a small trampoline Compl. ¶16
• Based on the complaint's allegations and accompanying images, the trampoline component of the Accused Product appears to be a self-contained unit with its own dedicated legs for support Compl. ¶17 Compl. ¶37 This trampoline unit is attached to the main swing set frame via connectors that fasten to the horizontal top bar of the swing set, not to its vertical or angled leg supports Compl. ¶35 The complaint includes an annotated image showing the trampoline member labeled 'H' with its own legs, distinct from the swing set support legs labeled 'D1-D4' Compl. ¶17, p. 5 Another image isolates the trampoline 'H' to emphasize that it has its own four supporting legs Compl. ¶37, p. 9

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the plaintiff's arguments for why its product does not meet the limitations of the asserted claims, based on the infringement notice lodged by the defendant.

'738 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality (per Plaintiff)	Complaint Citation	Patent Citation
a pair of connectors connected to two of the four main body leg supports...	The Accused Product's trampoline is connected to the swing set's top bar (B) through connectors (G); it is not connected to any of the four main body leg supports (D1-D4).	¶35	col. 4:55-62
a horizontally oriented trampoline frame, supported by at least two of the four main body leg supports	The Accused Product's trampoline frame (H) is not supported by any of the swing set's main body leg supports (D1-D4). Instead, the trampoline has its own distinct set of supporting legs.	¶36	col. 4:65-67

• Identified Points of Contention:
  • Structural Connection Point: A primary dispute will center on the location of the connection. The claims require connectors "connected to... main body leg supports" '738 Patent, col. 5:58-60 The plaintiff alleges its product connects to the "top bar" Compl. ¶35 The court will need to determine if a connection to the top bar, which is itself held up by the legs, satisfies the claim language.
  • Meaning of "Supported By": The claims require the trampoline frame to be "supported by" the swing set's leg supports '738 Patent, col. 5:65-66 The plaintiff argues its trampoline is entirely self-supported by its own legs Compl. ¶37 The case may turn on whether "supported by" requires direct, weight-bearing support, or if it can be read more broadly to include stabilization or positional support derived from the connection to the main frame.

V. Key Claim Terms for Construction

• The Term: "supported by at least two of the four main body leg supports"
• Context and Importance: This term is central to the non-infringement argument. The plaintiff's entire defense, as outlined in the complaint, rests on the assertion that its trampoline has its own legs and receives no structural support from the swing set's legs Compl. ¶36 Compl. ¶37 The construction of "supported by" will therefore be dispositive.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party arguing for a broader scope might contend that because the trampoline is physically attached to the swing frame, it is inherently "supported by" the overall structure, including the legs that hold up that structure. The term is not explicitly defined, which could leave room for an interpretation that does not require direct load-bearing contact.
  • Evidence for a Narrower Interpretation: The patent's specification describes a "socket connector" with a collar portion that "rests upon the main body leg support" '738 Patent, col. 4:65-67 This language, along with the visual representation in Figure 1 showing the trampoline frame (138) connecting near the base footing (132) of the leg support (130), suggests a direct, weight-bearing relationship is intended. Further, the inventor's alleged statement during prosecution that the invention involves "inside legs being shared with the swing set" strongly supports a narrow interpretation requiring structural integration, not just attachment Compl. ¶26

VI. Other Allegations

• Indirect Infringement: The complaint is for declaratory judgment of non-infringement and does not contain allegations of indirect infringement.
• Willful Infringement: The complaint does not allege willful infringement by the plaintiff. However, it does allege that the defendant, Sportspower, lodged its infringement claim on the Walmart platform in "bad faith," with knowledge that the Accused Product does not infringe, citing the inventor's "limiting statements to the USPTO during prosecution" Compl. ¶41 These allegations form the basis for a separate state law claim of tortious interference with contract Compl. ¶¶40-47

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

This declaratory judgment action will likely revolve around two central questions of claim interpretation and factual comparison:

1. A question of structural support: Does the term "supported by," in the context of the '738 patent and its prosecution history, require direct, load-bearing contact between the trampoline frame and the swing set's leg supports? Or can it encompass a more general attachment where the trampoline has its own independent support structure?

2. A question of connection point: Can the claim limitation requiring connectors "connected to... main body leg supports" be met by a product where the connectors attach to the horizontal top bar of the swing set, rather than directly to the leg structures themselves?

The resolution of these questions, heavily influenced by the patent's intrinsic evidence and the alleged prosecution history disclaimer, will determine whether the Accused Product falls within the scope of the patent's claims.