Shenzhen Dongjian Fangzhou Technology Co Ltd v. FeltRight LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Dongjian Fangzhou Technology Co., Ltd. (People's Republic of China)
  • Defendant: FeltRight, LLC (Utah)
  • Plaintiff's Counsel: Perkins Coie LLP
• Case Identification: Shenzhen Dongjian Fangzhou Technology Co., Ltd. v. FeltRight, LLC, 2:26-cv-00476, D. Utah, 05/22/2026
• Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant FeltRight is a Utah company with its principal place of business in the district, and because its enforcement activities directed at the Plaintiff originated from Utah.
• Core Dispute: Plaintiff seeks a declaratory judgment that its decorative felt tile products do not infringe Defendant's patent covering felt tiles with specific structural features.
• Technical Context: The technology relates to the field of modular, decorative wall coverings, specifically using felt tiles with unique edge profiles to create customizable aesthetic designs.
• Key Procedural History: This declaratory judgment action was filed after Defendant FeltRight initiated patent enforcement actions against Plaintiff Dongjian through the Amazon.com marketplace, alleging that Dongjian's products infringed the patent-in-suit. These actions led to the delisting of more than two hundred of Dongjian's product listings.

Case Timeline

Date	Event
2021-05-05	'674 Patent Priority Date (Application Filing)
2025-12-02	'674 Patent Issue Date
2026-05-15	Amazon Support Communication regarding delisted products
2026-05-22	Complaint Filing Date

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

U.S. Patent No. 12,486,674 - "Felt Tiles and Tile Kits"

• Patent Identification: U.S. Patent No. 12,486,674, "Felt Tiles and Tile Kits," issued December 2, 2025.

The Invention Explained

• Problem Addressed: The patent's background section describes traditional decorative wall tiles as being difficult to install, not easily customizable, and requiring significant work, skill, and tools, which can be a barrier for many consumers '674 Patent, col. 1:7-24
• The Patented Solution: The invention is a system of lightweight, rigid tiles made of felt that are easy to install and customize '674 Patent, abstract The patent describes specific edge designs, such as "chamfered edges," which are intended to give the tiles an improved aesthetic appeal and mitigate minor manufacturing imperfections that might otherwise be noticeable when tiles are placed together '674 Patent, col. 1:63-65 '674 Patent, col. 4:10-16
• Technical Importance: The patented approach provides a user-friendly and customizable wall décor solution that aims to simplify the process of creating decorative wall features compared to traditional tiling methods '674 Patent, col. 1:7-14

Key Claims at a Glance

• The complaint focuses on seeking a declaration of non-infringement of Claim 1, the sole independent claim Compl. ¶15 Compl. ¶26
• The essential elements of independent Claim 1 include:
  • A tile with a rigid body made of felt.
  • The body has parallel top and bottom surfaces, with the top surface area being smaller than the bottom surface area.
  • The tile thickness is no greater than 1 inch.
  • The rigid body comprises a "plurality of side surfaces" which consist of:
    • A first set of side surfaces connected to the top surface that are not perpendicular to it.
    • A second set of side surfaces connected to the bottom surface that are perpendicular to the top surface.
    • The first and second sets of side surfaces connect to form "chamfered edges."
• The complaint notes that because all other claims of the patent are dependent on Claim 1, its arguments for non-infringement apply to all claims Compl. ¶31

III. The Accused Instrumentality

Product Identification

The accused products are decorative felt products sold by Plaintiff Dongjian under brands including "Fluxynara" on the Amazon.com Marketplace Compl. ¶3 The complaint identifies an "Exemplary Product" sold under Amazon Standard Identification Number (ASIN) B0F52S62BD Compl. ¶22

Functionality and Market Context

• The accused products are decorative felt tiles intended for consumers to mount on walls Compl. ¶3 Compl. ¶16 The complaint alleges these products are one of Dongjian's primary sales channels into the United States Compl. ¶16
• The complaint provides a close-up photograph of the exemplary product's edge, depicting a single, continuous beveled surface from the top to the bottom of the tile Compl. p. 15
• The complaint alleges that FeltRight's enforcement actions have resulted in the delisting of approximately 225 of Dongjian's product links from Amazon, suggesting the products have a significant commercial presence Compl. ¶20 Compl. ¶23

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The table below summarizes Dongjian's non-infringement arguments for Claim 1 as presented in the complaint.

'674 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
the rigid body of the tile comprises a plurality of side surfaces extending from the top surface to the bottom surface, the plurality of side surfaces consisting of: a first set of side surfaces...being not perpendicular to the top surface...	Dongjian alleges that its products, as illustrated by a photo of the Exemplary Product, do not have this two-part side surface structure and instead feature a single continuous bevel Compl. ¶29	¶29	col. 8:36-49
...and a second set of side surfaces...being perpendicular to the top surface...	Dongjian alleges its products do not have a set of side surfaces that are perpendicular to the top surface as part of the edge structure Compl. ¶29	¶29	col. 8:50-54
...each side surface of the second set of side surfaces being directly connected to a corresponding side surface of the first set of side surfaces to form chamfered edges.	Because the accused products allegedly lack the first and second sets of side surfaces, Dongjian argues they cannot have the claimed connection between them to form the specified "chamfered edges" Compl. ¶29	¶29	col. 8:54-57

• Identified Points of Contention:
  • Structural Mismatch: The central dispute is whether the accused products' edge profile, which Dongjian portrays as a simple, single-angled bevel Compl. p. 15, can be found to infringe a claim that requires a composite edge structure "consisting of" two distinct sets of surfaces with different angular properties (one non-perpendicular, one perpendicular).
  • Geometric Interpretation: The case raises the question of how literally the geometric limitations "not perpendicular" and "perpendicular" will be interpreted and whether the physical structure of the accused products meets these precise definitions.

V. Key Claim Terms for Construction

• The Term: "a plurality of side surfaces consisting of: a first set of side surfaces... and a second set of side surfaces"

• Context and Importance: This phrase is critical because "consisting of" is a closed-ended term in patent law, meaning the "plurality of side surfaces" must be composed of only the listed first and second sets of surfaces and nothing more. Dongjian's non-infringement case hinges on the argument that its products' side surfaces do not consist of these two distinct, required parts Compl. ¶29

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party seeking a broader reading might argue that as long as regions corresponding to the two sets can be identified within a single continuous surface, the limitation is met. However, the claim language and specification provide limited support for such a reading.
  • Evidence for a Narrower Interpretation: The patent specification appears to support a narrow, literal interpretation. Figure 3A and its description explicitly depict the "first side surface" (330A) and "second side surface" (340A) as two distinct, adjoining surfaces that together form the chamfered edge '674 Patent, FIG. 3A '674 Patent, col. 4:65-67 This suggests two separately identifiable surfaces must be present.

• The Term: "perpendicular to the top surface"

• Context and Importance: This term defines a specific geometric requirement for the "second set of side surfaces." Dongjian explicitly alleges its products do not have a side surface that is perpendicular to the top surface Compl. ¶29 The presence or absence of this feature in the accused products will be a key factual determination.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue for a "substantially perpendicular" construction, allowing for minor deviations from a perfect 90-degree angle due to manufacturing tolerances.
  • Evidence for a Narrower Interpretation: The term's plain meaning is a 90-degree angle. The patent specification reinforces this literal meaning, stating in one embodiment that the "second side surface 340A is perpendicular to the bottom surface 320A" '674 Patent, col. 5:3-4, which is parallel to the top surface.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaration of non-infringement for indirect infringement, based on the predicate argument that no direct infringement exists Compl. ¶32
• Willful Infringement: While this is a declaratory judgment action by the accused infringer, the complaint alleges that FeltRight's enforcement actions on Amazon were "objectively baseless and made in subjective bad faith" Compl. ¶40 On this basis, Dongjian requests a finding that the case is "exceptional" under 35 U.S.C. § 285, which would entitle it to an award of attorneys' fees Compl. Prayer D This allegation serves as the inverse of a typical willfulness claim.

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

• A core issue will be one of claim construction: can the accused product's edge, which appears to be a single continuous bevel, be construed as "consisting of" the two distinct surfaces required by Claim 1-one "not perpendicular" and one "perpendicular" to the tile's top surface? The restrictive term "consisting of" will likely be a focal point of legal argument.
• The case will also depend on a question of factual comparison: does a geometric analysis of the accused "Fluxynara" tiles reveal the specific two-part edge structure mandated by the patent's claim language, or does it confirm Dongjian's assertion of a structurally different, and therefore non-infringing, design? The visual evidence submitted with the complaint frames this as the central technical dispute Compl. p. 15