1:26-cv-02076
Chengdu Huiyuzhongtai Technology Co Ltd v. Changshawanfengyingmaoyiyouxiangongsi
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Chengdu Huiyuzhongtai Technology Co., Ltd. (China)
- Defendant: Changshawanfengyingmaoyiyouxiangongsi (China)
- Plaintiff's Counsel: Venable LLP; Rice Technology Law Group
- Case Identification: 1:26-cv-02076, E.D. Va., 07/10/2026
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign entity not resident in any U.S. judicial district, and has therefore committed acts of infringement in the Eastern District of Virginia through its sales on Amazon.com.
- Core Dispute: Plaintiff alleges that Defendant's "Seinloes" brand adjustable pull-out cabinet organizers infringe a patent related to an adjustable drawer.
- Technical Context: The technology concerns home storage solutions, specifically drawers that can be adjusted in both width and length to fit within various cabinet sizes.
- Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2024-09-10 | '181 Patent Priority Date |
| 2025-11-25 | '181 Patent Issue Date |
| 2026-07-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,478,181 - Adjustable Drawer
- Patent Identification: U.S. Patent No. 12,478,181 ("the '181 Patent"), Adjustable Drawer, issued November 25, 2025.
The Invention Explained
- Problem Addressed: The patent's background section notes that because household cabinets are often custom-made with inconsistent dimensions, drawers must be specifically sized, which complicates manufacturing and installation ʼ181 Patent, col. 1:10-18
- The Patented Solution: The invention is a drawer constructed from a "plurality of connecting elements" that can be moved relative to each other and fastened in place ʼ181 Patent, col. 2:33-42 This design allows the drawer's overall length and width to be expanded or contracted, enabling a single product to fit a variety of cabinet spaces ʼ181 Patent, abstract ʼ181 Patent, col. 2:54-60 The elements are perforated with openings that are used with fasteners to lock the drawer into the desired dimensions ʼ181 Patent, col. 4:39-51
- Technical Importance: The patented design offers a modular, adjustable solution that aims to standardize drawer products for non-standard spaces, potentially reducing manufacturing costs and simplifying consumer choice Compl. ¶18
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 10 Compl. ¶31 Compl. ¶34
- The essential elements of independent claim 10 are:
- A drawer body comprising a plurality of connecting elements.
- The connecting elements join together to form a drawer configuration.
- At least one connecting element is movable along a width direction for adjustment, and at least one is movable along a length direction for adjustment, making the drawer body expandable or contractible.
- Each connecting element defines an array of openings on its bottom surface.
- The connecting elements are connected to each other by inserting fasteners into at least one of the openings.
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims of the '181 Patent" Compl. ¶34
III. The Accused Instrumentality
Product Identification
The accused products are "adjustable pull-out cabinet organizers" sold under the brand name "Seinloes" on Amazon.com Compl. ¶¶5, 26 The complaint identifies two groups of products, the "First Accused Products" and "Second Accused Products," distinguished by Amazon Standard Identification Numbers (ASINs) Compl. ¶27 Compl. ¶29
Functionality and Market Context
- The accused products are described as "4-Side Expandable" pull-out drawers designed for kitchen cabinets Compl. ¶28 Compl. ¶30 A representative product listing shows a drawer that is adjustable in both width and depth (e.g., from 13"-21" in width and 17"-24" in depth), which is the central functionality accused of infringement Compl. ¶28 The complaint includes a screenshot from an Amazon product page showing the adjustable nature of the "Seinloes" organizer Compl. ¶28
- The complaint alleges that Defendant advertises and sells the Accused Products at significantly lower prices than the Plaintiff's comparable products, using sponsored advertisements on Amazon to target Plaintiff's customers Compl. ¶44 Compl. ¶45
IV. Analysis of Infringement Allegations
The complaint alleges that the Accused Products infringe at least claim 10 of the '181 Patent but does not provide the referenced claim chart exhibits Compl. ¶34 The following chart summarizes the infringement theory based on the complaint's narrative allegations and product imagery.
'181 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a drawer body, comprising a plurality of connecting elements, wherein the plurality of connecting elements join together and form a drawer configuration... | The accused "Seinloes" product is constructed from multiple component pieces that assemble to form a drawer structure. | ¶28 | col. 2:34-38 |
| ...at least one of the plurality of connecting elements is movable along a width direction of the drawer body for adjustment, at least one of the plurality of connecting elements is movable along a length direction of the drawer body for adjustment, and the drawer body is expandable or contractible; | The product is marketed as "4-Side Expandable" and is adjustable in both width and depth to fit different cabinet sizes, such as "13"-21"W x 17"-24"D". | ¶28 | col. 2:38-42 |
| wherein each of the plurality of connecting elements defines an array of openings that are dis-communicated with each other at a bottom surface of each of the plurality of connecting elements; | Product images show that the bottom surfaces of the drawer's component panels are perforated with a grid of slot-like openings. | ¶28 | col. 10:18-22 |
| the plurality of connecting elements are connected to each other by inserting fasteners into at least one of the plurality of openings. | The complaint alleges that the product practices this limitation, which suggests that the adjustable components are locked into place using fasteners that engage with the openings on the bottom surface. | ¶31 | col. 10:30-34 |
- Identified Points of Contention:
- Technical Question: A primary factual question will be how the accused "Seinloes" product is assembled and adjusted. The complaint does not provide evidence (such as user manuals or physical inspection) detailing the connection mechanism. The infringement analysis will turn on whether the product's components are connected "by inserting fasteners into at least one of the plurality of openings," as claim 10 requires.
- Scope Question: Does the term "fasteners" as used in the patent read on the specific connection hardware, if any, used in the accused product? The evidence for how the accused product achieves its locked, adjusted state is not present in the complaint, suggesting this will be a central point of discovery and dispute.
V. Key Claim Terms for Construction
The Term: "connecting elements"
Context and Importance: This term defines the fundamental building blocks of the claimed invention. Its construction will determine whether the components of the accused product qualify as "connecting elements" and thus fall within the scope of the claims. Practitioners may focus on this term because the patent's specific embodiments could be used to argue for a narrower definition than the plain and ordinary meaning.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the drawer body as being "formed by joining the plurality of individual connecting elements 11" ʼ181 Patent, col. 2:47-48, which may support a broad definition covering any separate components that join to form a drawer.
- Evidence for a Narrower Interpretation: Claim 1, from which claim 10 does not depend, and several figures describe elements with specific interlocking features, such as a "first protruding edge" and a "sliding groove" ʼ181 Patent, col. 8:31-40 ʼ181 Patent, Fig. 6 A party could argue these specific structures inform and limit the meaning of "connecting elements" throughout the patent.
The Term: "fasteners"
Context and Importance: The "fasteners" are critical to achieving a key function of the invention: locking the adjustable drawer into a fixed size. The infringement case for claim 10 hinges on whether the accused product uses such "fasteners" in the claimed manner.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification gives an example that a "fastener 125 may be a bolt or other" ʼ181 Patent, col. 4:52-53 The use of "or other" suggests the patentee did not intend to limit the term to a specific type of hardware.
- Evidence for a Narrower Interpretation: The figures consistently depict the fastener as a distinct, bolt-like component ʼ181 Patent, Fig. 3, element 125 A party could argue this context limits the term to removable mechanical hardware and excludes other connection methods like integrated snap-fits, clips, or friction-based locking.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by directing or instructing customers on how "to use, install and/or operate" the accused adjustable organizers, which implies the existence of user manuals or instructions that teach the infringing use Compl. ¶35
- Willful Infringement: The complaint alleges willfulness based on Defendant having notice of infringement "since at least the filing of this action" Compl. ¶37 It also makes a conclusory allegation of pre-suit knowledge, stating Defendant "knew or should have known" of the risk of infringement Compl. ¶40
VII. Analyst's Conclusion: Key Questions for the Case
A central evidentiary question will be one of technical operation: What is the precise mechanism that the accused "Seinloes" product uses to allow for size adjustment and then lock its components into a fixed configuration? The viability of the infringement case under claim 10 will depend on whether this mechanism involves "inserting fasteners into... openings" as claimed.
A key legal question will be one of claim construction: Can the term "connecting elements" be broadly interpreted to cover any modular components that form a drawer, or will it be limited by the specification's more detailed embodiments that show specific interlocking features? The outcome of this construction could significantly narrow or broaden the patent's scope.
The case will likely feature a significant dispute over functional evidence: Does the array of "openings" on the accused product's surface serve the claimed purpose of connecting elements with fasteners, or do they primarily serve a different function, such as drainage or ventilation? Plaintiff will need to provide evidence that the openings are used for the claimed connection function.