Dongguan Sanqishi Technology Co Ltd v. Anker Innovations Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Sanqishi Technology Co., Ltd. (China)
  • Defendant: Anker Innovations Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 2:26-cv-00216, W.D. Wash., 02/17/2026
• Venue Allegations: Plaintiff asserts that venue is proper in the Western District of Washington because Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon patent-enforcement proceeding, which foreseeably caused enforcement actions by Amazon personnel located in Seattle.
• Core Dispute: Plaintiff seeks a declaratory judgment that its desktop charging station products do not infringe Defendant's U.S. Patent No. 12,316,149 and that the patent is invalid.
• Technical Context: The technology at issue involves multi-device consumer electronic charging stations designed to be compact and portable through the use of movable or retractable components.
• Key Procedural History: The complaint states that this declaratory judgment action was precipitated by Defendant's patent infringement report to Amazon, which resulted in the removal of Plaintiff’s product listings from the e-commerce platform on December 24, 2025, thereby creating an actual case or controversy between the parties.

Case Timeline

Date	Event
2022-03-10	Priority Date for U.S. Patent No. 12,316,149
2025-05-27	Issue Date for U.S. Patent No. 12,316,149
2025-12-24	Amazon removes Plaintiff's product listings based on report
2026-02-17	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 12,316,149 - "Charging device with movable board"

• Patent Identification: U.S. Patent No. 12,316,149 (the “`’149` Patent”), "Charging device with movable board," issued May 27, 2025.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem with then-current charging equipment for consumer electronics, noting that "unreasonable structural design" makes such devices "not compact enough," space-consuming, and "inconvenient for a user to carry around" ('149 Patent, col. 1:22-26).
• The Patented Solution: The invention claims to solve this problem by providing a charging device with a housing that contains an internal "accommodating chamber" ('149 Patent, col. 1:38-39). A "movable board" containing charging circuitry can extend from and retract into this chamber, reducing the device's overall volume for portability ('149 Patent, col. 3:1-12). The device also includes a "flip cover" that is "pivotably provided on the housing body" and can contain a second charging surface, allowing for multiple charging functions in a compact form factor ('149 Patent, abstract; '149 Patent, col. 1:40-44).
• Technical Importance: This design aims to integrate charging capabilities for multiple devices (e.g., a smartwatch, smartphone, and earphones) into a single, compact unit, addressing a key design objective in the consumer electronics accessory market ('149 Patent, col. 8:20-43).

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement and invalidity with respect to independent claims 1, 14, and 20 (Compl. ¶15; Compl. ¶¶19-33).
• Independent Claim 1 includes these essential elements:
  • A housing comprising a cavity, a body, and a flip cover
  • The flip cover is "pivotably connected to the body"
  • A movable board with charging circuitry, configured to "slide relative to the cavity"
  • A power interface
• Independent Claim 14 includes these essential elements:
  • A body with an exterior surface and interior space
  • A movable board with a "first charging circuitry"
  • A flip cover with a "second charging circuitry," where the flip cover is "pivotably connected to the body"
  • A "third charging circuitry located on the exterior surface of the body"
• Independent Claim 20 includes these essential elements:
  • A housing with a cavity, body, and flip cover
  • The flip cover is "pivotably coupled to the body via a rotating shaft"
  • An extendable/retractable movable board
  • First, second, and third charging circuitries located on the movable board, flip cover, and body, respectively
• The complaint alleges that because the independent claims are not infringed, no dependent claims are infringed either (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are Plaintiff's desktop charging station products, identified by Amazon Standard Identification Numbers (ASINs) B0DT1316TR and B0F5VQXY35 (Compl. ¶22; Compl. ¶24).

Functionality and Market Context

• The complaint alleges that the Accused Products feature a top charging module mounted on a "movable internal subassembly that translates relative to the body" (Compl. ¶20). It characterizes the deployment of this module as a "guided lifting/translation" mechanism, distinct from the rotational motion of a pivotable connection (Compl. ¶¶22, 28). The complaint provides a visual aid in Exhibit C, which purportedly illustrates the internal translating subassembly of the Accused Products that governs the movement of the top module (Compl. ¶17; Compl. ¶20).
• Plaintiff alleges that Amazon is its "primary sales channel in the United States" and that the removal of its product listings has caused "lost sales," "damage to goodwill," and "disruption to inventory and advertising planning" (Compl. ¶11; Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's primary arguments for why its products do not meet the limitations of the asserted claims, focusing on Claim 1 as representative.

• '149 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
a housing comprising ... a flip cover, wherein the flip cover is pivotably connected to the body	The Accused Products do not include a "flip cover" component that is pivotably connected to the main body.	¶19	col. 7:10-12
	The component that Defendant may contend is a "flip cover" is mounted on a movable internal subassembly that translates relative to the body during deployment.	¶20	col. 7:10-12
	Any angular change in the component's orientation occurs relative to the translating subassembly, not via rotation of a cover pivotably connected to the body itself.	¶21	col. 7:10-12

• Identified Points of Contention:
  • Scope Questions: The central dispute appears to be the proper construction of the phrase "flip cover... pivotably connected to the body." The case may turn on whether this phrase requires a direct, fixed-axis rotational coupling between the cover and the main housing, or if it can be construed more broadly to encompass a component that moves via a translating linkage mechanism.
  • Technical Questions: A key factual question will be the precise mechanical operation of the Accused Products. The complaint's characterization of the mechanism as a "guided lifting/translation architecture" (Compl. ¶22) raises the question of whether its function, way, and result are substantially different from the pivotable connection claimed in the patent.

V. Key Claim Terms for Construction

• The Term: "pivotably connected to the body" (from Claims 1 and 14) and "pivotably coupled to the body via a rotating shaft" (from Claim 20).
• Context and Importance: This limitation appears in all three asserted independent claims and is the cornerstone of the Plaintiff's non-infringement argument. The outcome of the case may depend heavily on whether the Accused Product's translating mechanism is found to fall within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification uses the general phrasing "a flip cover 15 rotatably (e.g., pivotably) provided on... the housing body 14," which a party might argue does not foreclose more complex linkages that achieve a rotational or pivoting effect relative to the body (Compl. ¶19; ’149 Patent, col. 7:10-12).
  • Evidence for a Narrower Interpretation: Claim 20 expressly recites that the coupling is "via a rotating shaft" ('149 Patent, col. 12:22-24). Furthermore, the detailed description discloses a specific embodiment with a "damping rotating shaft 16" directly coupling the flip cover to the housing body ('149 Patent, col. 7:17-23). This explicit disclosure of a direct, shaft-based connection may be used to argue for a narrower construction limited to such structures.

VI. Other Allegations

• Indirect Infringement: The complaint preemptively denies liability for induced infringement under 35 U.S.C. § 271(b) and contributory infringement under 35 U.S.C. § 271(c) (Compl. ¶34). The complaint does not provide sufficient detail for analysis of these elements beyond the general denial.
• 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

This declaratory judgment action appears to center on a classic patent dispute involving mechanical structures. The dispositive issues for the court will likely be:

1. A core issue will be one of definitional scope: How should the court construe the claim term "pivotably connected to the body"? Does the patent's intrinsic evidence, particularly the more specific language in Claim 20 and the disclosed embodiments, limit this term to a direct, fixed-axis rotational joint, or can it encompass the "guided lifting/translation" mechanism alleged to be used in the Accused Products?

2. A secondary issue will be one of technical equivalence: Assuming no literal infringement, does the Accused Product's translating subassembly perform substantially the same function, in substantially the same way, to achieve substantially the same result as the claimed pivotable connection? The Plaintiff's argument that finding equivalence would "effectively read the... limitation out of the claim" frames this question for the court (Compl. ¶¶1-2, p. 6).