Huanmao E Commerce Shenzhen Co Ltd v. Hyperice IP Subco LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Huanmao E-commerce (Shenzhen) Co., Ltd. (China)
  • Defendant: Hyperice IP Subco, LLC (Delaware)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 2:26-cv-03558, W.D. Wash., 09/22/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant purposefully invoked Amazon’s patent enforcement process, which includes agreements selecting Washington law and courts, creating a substantial connection between the dispute and the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its percussion massager does not infringe Defendant’s patent and/or that the patent is invalid, following an infringement accusation made by Defendant through Amazon’s private patent evaluation program.
• Technical Context: The lawsuit concerns hand-held percussive massage devices, a popular category of consumer electronics used for deep-muscle stimulation and pain relief.
• Key Procedural History: The action was precipitated by Defendant’s assertion of U.S. Patent No. 11,938,082 via Amazon’s Patent Evaluation Express (APEX) process. A key claim limitation at issue was previously construed by the Patent Trial and Appeal Board (PTAB) in a Post-Grant Review proceeding involving a third party; that decision is currently on appeal to the U.S. Court of Appeals for the Federal Circuit. The complaint notes that claim 17 of the patent 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 asserting claim 7
2026-09-10	Amazon notified Plaintiff of Defendant's APEX assertion
2026-09-22	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"

The patent-in-suit is U.S. Patent No. 11,938,082, issued March 26, 2024.

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. 1:31-34
• The Patented Solution: The patent describes a percussive massager designed to address these deficiencies. A central feature is a "quick-connect system" that allows a user to attach or detach different massaging heads from the device’s reciprocating piston ’082 Patent, abstract The system is described as being configured to allow this head-swapping to occur "while the piston reciprocates" ’082 Patent, col. 10:12-15 One embodiment discloses a magnetic system to achieve this functionality, where magnets in the piston and the head shaft attract one another to hold the head in place during use while permitting quick removal ’082 Patent, col. 6:49-68
• Technical Importance: A mechanism for easily swapping applicator heads without stopping the device enhances user convenience and allows for a more versatile and uninterrupted massage session.

Key Claims at a Glance

• The complaint focuses on claim 7, which was asserted in the APEX process, and its parent independent claim 1 Compl. ¶¶14-15
• Independent Claim 1 includes the following essential elements:
  • A housing and a piston with a bore at its distal end.
  • A motor to reciprocate the piston.
  • A drive mechanism controlling the piston’s stroke length.
  • A "quick-connect system" comprising the piston’s distal end and a massaging head.
  • 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 complaint expressly reserves all non-infringement positions as to other claim limitations Compl. ¶28

III. The Accused Instrumentality

Product Identification

A hand-held percussion massager sold by Plaintiff on Amazon.com under the ASIN B0BFF9N6QQ Compl. ¶1 Compl. ¶20

Functionality and Market Context

• The complaint describes the accused product’s head attachment mechanism as a "mechanical interference-fit connection" Compl. ¶3 This interface allegedly uses an "elastic fit ring on the massaging-head shaft that engages the piston bore through radial interference and friction" Compl. ¶20
• According to the complaint, attaching or detaching the massaging head requires "deliberate axial force sufficient to overcome that interference" and is not a system "specially designed or adapted for insertion or removal during reciprocation" Compl. ¶22 Compl. ¶23
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

This is a declaratory judgment action where the Plaintiff (Huanmao) alleges non-infringement. The following table summarizes Plaintiff's position on why its product does not meet a key limitation of the asserted patent claim.

’082 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
a quick-connect system comprising the distal end of the piston and a first massaging head, 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 with an elastic ring, which is not specially designed or adapted for connection or disconnection while the piston is reciprocating. It relies on radial interference and friction, requiring deliberate axial force for insertion and removal.	¶23	col. 10:8-15

• Identified Points of Contention:
  • Scope Questions: The central dispute concerns the meaning of the phrase "configured to" be inserted or removed "while the piston reciprocates." A key question for the court will be whether this requires the system to be specifically designed for this purpose, or if it is sufficient that the system is merely capable of it. The complaint cites a PTAB construction from a related case stating the system must be "specially designed and adapted to quickly and easily connect or disconnect... not merely capable of doing so" Compl. ¶19
  • Technical Questions: A factual question will be how the Accused Product's interference-fit mechanism actually operates. The litigation will likely examine whether the "deliberate axial force" required to change the head Compl. ¶22 is compatible with the "quick-connect" functionality claimed in the ’082 Patent, particularly if the piston is in motion.

V. Key Claim Terms for Construction

• The Term: "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 analysis. Plaintiff argues its friction-fit mechanism is not "configured" for removal during reciprocation, positioning this as the key difference from the patented invention Compl. ¶23 Practitioners may focus on this term because its construction was the subject of a PTAB ruling that is now on appeal, creating uncertainty that this litigation seeks to resolve Compl. ¶19
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the "quick-connect system" to a specific structure, such as magnets. A patentee could argue that any system "capable of" being operated in the claimed manner is "configured to" do so, potentially encompassing some friction-fit designs.
  • Evidence for a Narrower Interpretation: The specification’s primary embodiment describes a magnetic connection system that is inherently designed for easy attachment and removal ’082 Patent, col. 6:57-68 The specification also describes a "rounded, pointed, or tapered head end that can slip into the bore opening even while the piston is moving," which may suggest a special design is required ’082 Patent, col. 7:9-12 This evidence could support the PTAB's narrower construction that the system must be "specially designed and adapted" for this function, not just "merely capable" of it Compl. ¶19

VI. Other Allegations

• Indirect Infringement: The complaint addresses method claim 18, arguing that because the Accused Product allegedly lacks the configuration for insertion/removal during reciprocation, there can be no underlying direct infringement on which a claim for indirect infringement could be based Compl. ¶27
• Willful Infringement: This allegation is not present, as the complaint is a declaratory judgment action filed by the accused infringer.

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

1. Claim Construction Precedent: A central issue will be one of claim scope and judicial deference: to what extent will the court be influenced by the PTAB's prior construction of the "Quick-Connect Limitation" in a related case, especially with that construction pending appeal at the Federal Circuit? The outcome of that appeal could be highly persuasive or even controlling.

2. The Infringement Squeeze: The case presents a classic "squeeze" argument. A key question is one of definitional boundaries: if the term "configured to" is construed narrowly (i.e., "specially designed for"), does that exonerate the accused friction-fit product from infringement? Conversely, if the term is construed broadly enough to cover the accused product, does the claim then become obvious in light of prior art disclosing conventional press-fit or interference-fit attachment mechanisms, as the Plaintiff argues in the alternative? Compl. ¶¶44-46

3. Functional Operation vs. Intended Design: An evidentiary question will be one of functional capability: does the accused product's friction-fit mechanism, while not "specially designed" for it, nevertheless allow for safe and practical insertion or removal of the massaging head while the piston is reciprocating? The answer will depend on expert testimony and technical evidence regarding the forces involved and the physical operation of the device.