DCT

2:26-cv-03525

Jinyun County Jinglian Shidai Trading Co Ltd v. Hyperice IP Subco LLC

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Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-03525, W.D. Wash., 09/20/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant has repeatedly used Amazon's patent enforcement procedures, which are allegedly governed by agreements that select Washington law and courts in King County, Washington, thereby creating a substantial connection between the controversy and the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its percussion massager product does not infringe Defendant's patent related to a quick-connect mechanism for attaching massaging heads and that the patent is invalid.
  • Technical Context: The technology at issue involves hand-held percussive massage devices, a consumer product category focused on muscle therapy and recovery.
  • Key Procedural History: This lawsuit was triggered by Defendant's accusation of infringement against Plaintiff through Amazon's Patent Evaluation Express (APEX) program. The complaint notes that the key claim limitation at issue has already been construed in a separate Post-Grant Review (PGR) proceeding before the Patent Trial and Appeal Board (PTAB), and that the PTAB's decision is currently on appeal at the U.S. Court of Appeals for the Federal Circuit. The complaint also notes that claim 17 of the patent-in-suit has been statutorily disclaimed.

Case Timeline

Date Event
2013-07-01 '082 Patent Priority Date
2024-03-26 '082 Patent Issue Date
2026-05-11 PTAB Final Written Decision issued in PGR2025-00013
2026-06-17 Appeal of PTAB decision filed at the Federal Circuit
2026-09-09 Defendant executed APEX Agreement against Plaintiff's product
2026-09-10 Amazon notified Plaintiff of APEX accusation
2026-09-20 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,938,082 - "Massage Device Having Variable Stroke Length"

  • Patent Identification: U.S. Patent No. 11,938,082, “Massage Device Having Variable Stroke Length,” issued March 26, 2024 Compl. ¶13

The Invention Explained

  • Problem Addressed: The patent’s background section states that prior art massaging devices can be “bulky, get very hot, are noisy and/or are difficult to use for extended periods of time” (’082 Patent, col. 1:29-34).
  • The Patented Solution: The patent describes a hand-held percussive massager with a system for quickly connecting and disconnecting massaging heads from the device's reciprocating piston ’082 Patent, abstract One embodiment describes a magnetic system where magnets in both the piston bore and the massaging head shaft attract each other to hold the head in place ’082 Patent, col. 6:58-68 The patent also describes features intended to facilitate this, such as a "rounded, pointed or tapered" head end that can "easily slip into the opening... even while the piston... is moving" ’082 Patent, col. 7:8-12
  • Technical Importance: A system for rapidly swapping massaging heads without stopping the device could enhance user experience by allowing for uninterrupted and more varied massage sessions, addressing the prior art problem of being "difficult to use."

Key Claims at a Glance

  • The complaint focuses on claim 7, which was asserted in the APEX proceeding Compl. ¶7 Claim 7 depends from independent claim 1 Compl. ¶14
  • The essential elements of Independent Claim 1 include:
    • A housing and a piston with a bore at its distal end.
    • A motor configured to cause the piston to reciprocate.
    • A drive mechanism controlling the piston's stroke length.
    • A "quick-connect system" comprising the piston's distal end and a massaging head, where the system is "configured to have a proximal end of the first massaging head inserted into or removed from the bore while the piston reciprocates." ’082 Patent, col. 10:4-14
  • The complaint notes that claims 1-16 and 18 are also at issue and that it reserves all non-infringement positions Compl. ¶¶26-28

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentality as a "percussion massager" sold on Amazon.com under ASIN B0GYWF96VS Compl. ¶1

Functionality and Market Context

  • The complaint describes the relevant feature of the Accused Product as its massaging-head retention interface Compl. ¶20 It alleges this interface is a "mechanical interference-fit connection" that uses an "elastic fit ring on the massaging-head shaft" which is retained in the piston's bore through "radial interference and friction" Compl. ¶3 The complaint alleges that this design requires "deliberate axial force to engage or disengage the massaging head" Compl. ¶3 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The table below summarizes the Plaintiff's primary non-infringement argument as presented in the complaint.

’082 Patent Infringement Allegations

Claim Element (from Independent Claim 1, incorporated into Claim 7) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a quick-connect system... wherein the quick-connect system is configured to have a proximal end of the first massaging head inserted into or removed from the bore while the piston reciprocates the predetermined stroke length at the first speed The Accused Product allegedly uses a conventional friction-based interference-fit interface with an elastic ring. The complaint asserts this interface is not specially designed or adapted for insertion or removal during piston reciprocation and relies on radial friction, which does not facilitate quick connection or disconnection while the piston is moving. ¶3; ¶22; ¶23 col. 6:52-68; col. 7:8-12
a flywheel operatively connected to the output shaft of the motor... and a crank pin extending from the flywheel... operatively connected to the piston. The complaint's non-infringement theory focuses entirely on the "Quick-Connect Limitation" and does not substantively address other claim elements, expressly reserving all non-infringement positions as to such other limitations. ¶28 col. 4:41-51
  • Identified Points of Contention:
    • Scope Question: The central dispute is one of claim scope. Does the claim term "configured to have a... head inserted into or removed from the bore while the piston reciprocates" require a mechanism specifically designed for that purpose (as Plaintiff argues and the PTAB previously found), or can it be read more broadly to include any mechanism where such an action is merely physically possible, even if difficult (which may be the patentee's position)? Compl. ¶19 Compl. ¶44
    • Technical Question: Factually, is the Accused Product's friction-fit interface "specially designed or adapted" for removal during reciprocation? The complaint makes a legal conclusion that it is not, but the case may require a technical analysis of the forces involved and the specific design of the elastic ring and bore. Compl. ¶22

V. Key Claim Terms for Construction

  • The Term: "a quick-connect system... configured to have a proximal end of the first massaging head inserted into or removed from the bore while the piston reciprocates" (referred to in the complaint as the "Quick-Connect Limitation") Compl. ¶16
  • Context and Importance: The definition of this term is dispositive of the infringement question, as it is the sole basis for the non-infringement argument presented in the complaint Compl. ¶24 Practitioners may focus on this term because the PTAB has already issued a construction in a related proceeding, which is now on appeal, creating a complex legal landscape for the District Court Compl. ¶19
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for a broader construction might point to the general phrase "quick-connect system" in the summary of the invention and claim language, contending that "configured to" means merely having the physical properties that allow for the function, not that it must be optimized for it '082 Patent, col. 2:9-12
    • Evidence for a Narrower Interpretation: A party arguing for a narrower construction will likely cite the specific embodiment describing a magnetic connection designed for easy attachment/detachment ’082 Patent, col. 6:58-68 They would also point to language describing the head being "rounded, pointed or tapered to allow it to easily slip into the opening... even while the piston... is moving," suggesting a specific adaptation is taught and required ’082 Patent, col. 7:8-12 This position is bolstered by the PTAB's prior construction, which required the system be "specially designed and adapted... not merely capable of doing so" Compl. ¶19

VI. Other Allegations

  • Indirect Infringement: The complaint preemptively addresses indirect infringement of method claim 18. It argues that because the Accused Product allegedly lacks the configuration for removal during reciprocation, there can be no direct infringement by any user, and therefore no basis for an indirect infringement claim against the Plaintiff Compl. ¶27

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

This declaratory judgment action appears to center on a small number of critical, interconnected issues. The key questions for the court will likely be:

  • A question of claim construction deference: How will the District Court construe the "Quick-Connect Limitation," and to what extent will it be influenced by the PTAB's narrow construction in a parallel proceeding that is now under appeal at the Federal Circuit?
  • A "squeeze" on validity and infringement: If Defendant convinces the court to adopt a broader construction of the "Quick-Connect Limitation" that reads on Plaintiff's friction-fit device, does that broader scope render the claim obvious in light of prior art that allegedly discloses interchangeable, press-fit heads on massagers?
  • A factual question of design: Assuming the court adopts the narrower "specially designed and adapted" construction, is Plaintiff's friction-fit mechanism, as a matter of technical fact, merely capable of removal during reciprocation, or does its specific design constitute a special adaptation for that purpose?