2:26-cv-03685
Yongkang Tiange Technology Co Ltd v. Hyperice IP Subco LLC
I. Executive Summary and Procedural Information
Parties & Counsel:
- Plaintiff: Yongkang Tiange Technology Co., Ltd. (People's Republic of China)
- Defendant: Hyperice IP Subco, LLC (Delaware)
- Plaintiff’s Counsel: Glacier Law LLP
Case Identification: Yongkang Tiange Technology Co., Ltd. v. Hyperice IP Subco, LLC, 2:26-cv-03685, W.D. Wash., 09/30/2026
Venue Allegations: Plaintiff asserts that venue is proper in the Western District of Washington because Defendant purposefully utilized Amazon's patent enforcement mechanisms, which include agreements that select Washington law and courts, creating a substantial connection between the controversy and the district.
Core Dispute: Plaintiff seeks a declaratory judgment that its percussion massagers do not infringe Defendant’s patent related to a quick-connect mechanism for massage heads, and further that the asserted patent claims are invalid.
Technical Context: The technology concerns handheld percussion massagers, focusing on the mechanical interface used to attach and detach interchangeable massage heads from the device's reciprocating piston.
Key Procedural History: The lawsuit was precipitated by Defendant's assertion of the patent against Plaintiff's products through Amazon's Patent Evaluation Express (APEX) process. The complaint notes that the patent's key "Quick-Connect Limitation" was previously construed in a Post-Grant Review (PGR) proceeding before the Patent Trial and Appeal Board (PTAB), which adopted a narrow construction. That PTAB decision is currently on appeal to the U.S. Court of Appeals for the Federal Circuit. The patent owner has also filed a statutory disclaimer for claim 17.
Case Timeline
| Date | Event |
|---|---|
| 2013-07-01 | U.S. Patent No. 11,938,082 Priority Date |
| 2024-03-26 | U.S. Patent No. 11,938,082 Issue Date |
| 2026-05-11 | PTAB issues Final Written Decision in PGR2025-00013 |
| 2026-06-17 | Appeal of PTAB decision filed at the Federal Circuit |
| 2026-09-10 | Hyperice asserts '082 Patent against Plaintiff via Amazon APEX |
| 2026-09-30 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,938,082, Massage Device Having Variable Stroke Length, issued on March 26, 2024 (the "'082 Patent").
The Invention Explained
- Problem Addressed: The background of the '082 Patent describes prior art massaging devices as being potentially bulky, noisy, prone to overheating, and difficult to use for extended periods (ʼ082 Patent, col. 1:29-33).
- The Patented Solution: The invention is a percussive massager that includes, among other features, a "quick-connect system" for attaching a massage head to a reciprocating piston. This system is described as being "configured to have a proximal end of the first massaging head inserted into or removed from the bore while the piston reciprocates" (ʼ082 Patent, claim 1). The detailed description illustrates this functionality with a magnetic coupling system that allows a user to swap massage heads without turning the device off (ʼ082 Patent, col. 6:47-68; ʼ082 Patent, col. 7:4-12).
- Technical Importance: A system allowing for the "hot-swapping" of massage heads could enhance user convenience by allowing for uninterrupted therapy sessions when switching between different head types.
Key Claims at a Glance
The complaint focuses on claim 7, which depends on independent claim 1.
Independent Claim 1:
- A percussive massager comprising a housing, a piston with a bore, a motor, and a drive mechanism.
- The central feature is a "quick-connect system" comprising the piston's distal end and a massage head.
- This 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."
Dependent Claim 7:
- This claim further specifies the drive mechanism as comprising a "flywheel" connected to the motor's output shaft and a "crank pin" extending from the flywheel to the piston.
The complaint notes that it is challenging claims 1-16 and 18, and that claim 17 has been statutorily disclaimed Compl. ¶26 Compl. ¶31
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Accused Products" as hand-held percussion massagers sold by Plaintiff on Amazon.com under ASINs B09P1DV7D8 and B0BG4HY4PX Compl. ¶1 Compl. ¶20
Functionality and Market Context
- The complaint alleges the Accused Products utilize a massage-head interface that is fundamentally different from the one claimed in the '082 Patent Compl. ¶3
- Instead of a system configured for removal during reciprocation, the Accused Products allegedly use a "mechanical interference-fit connection" Compl. ¶3 This connection consists of an "elastic fit ring" on the massage head's shaft that engages the piston bore via "radial interference and friction" Compl. ¶20
- Plaintiff alleges this design requires "deliberate axial force" for attachment and removal and is intended for use when the motor is stopped, not while the piston is moving Compl. ¶3 Compl. ¶23
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's arguments as to why its products do not meet the limitations of the '082 Patent claims.
'082 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 the predetermined stroke length at the first speed. | The Accused Products use a conventional friction-based interference fit. This interface requires deliberate force to engage and is designed for attachment changes to be performed with the motor stopped. It is allegedly not specially designed, adapted, or configured for insertion or removal while the piston is reciprocating. | ¶3; ¶23; ¶24 | col. 10:9-15 |
| a flywheel operatively connected to the output shaft of the motor to rotate about a flywheel axis... and a crank pin extending from the flywheel ... operatively connected to the piston. (from claim 7) | Plaintiff's non-infringement argument for claim 7 relies on its incorporation of the "Quick-Connect Limitation" from claim 1. The complaint does not separately contest the drive mechanism limitations for the purpose of its non-infringement argument. | ¶25; ¶31 | col. 10:30-44 |
- Identified Points of Contention:
- Scope Question: A central dispute will be the interpretation of the phrase "configured to" be removed "while the piston reciprocates." The case may turn on whether this requires the system to be specifically designed and adapted for this purpose (as Plaintiff argues and as the PTAB previously found), or if it is broad enough to cover any system that is merely physically capable of having the head removed during operation, regardless of design intent or practicality.
- Technical Question: What evidence will be required to demonstrate that the Accused Product's interference-fit connection is, or is not, "configured" for removal during reciprocation? The analysis may involve comparing the forces required for removal in the accused device versus the magnetic embodiment described in the '082 Patent's specification.
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..." (from claim 1).
Context and Importance: This term, referred to in the complaint as the "Quick-Connect Limitation" Compl. ¶16, is the dispositive element for Plaintiff's non-infringement theory. Its construction will determine whether a conventional friction-fit mechanism falls within the scope of the claims. Practitioners may focus on this term because its construction was the subject of a PTAB Final Written Decision, which is now on appeal, indicating its centrality and contentious nature Compl. ¶19
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not explicitly limit the "quick-connect system" to a magnetic type, nor do they expressly disclaim friction-fit systems. A party could argue that "quick-connect" is a general term and that the "configured to" language does not impose a strict "specially designed for" requirement.
- Evidence for a Narrower Interpretation: The specification describes the system's utility as allowing a user to "quickly switch massaging heads" "without turning off the massaging device" ('082 Patent, col. 6:52-55). It further describes the massage head being "rounded, pointed or tapered... to allow it to easily slip into the opening... even while the piston... is moving" ('082 Patent, col. 7:9-12). This language, combined with the magnetic embodiment being the primary example, suggests the system is intended to be a low-force mechanism specifically adapted for hot-swapping. The complaint also cites the PTAB's construction, which found the claims require a structure "specially designed and adapted" for this function, "not merely capable of doing so" Compl. ¶19
VI. Other Allegations
Indirect Infringement: The complaint preemptively argues against indirect infringement by stating that because the Accused Products do not possess the recited "during-reciprocation configuration," there can be no underlying direct infringement upon which a claim for indirect infringement could be based Compl. ¶28
Willful Infringement: The complaint does not contain allegations related to willful infringement, as it is a declaratory judgment action filed by the accused infringer.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to be a direct response to a patent enforcement action in a commercial marketplace. The case will likely turn on the resolution of three key questions:
A question of Claim Construction Precedent: How will the district court treat the PTAB's existing narrow construction of the "Quick-Connect Limitation," especially with that construction currently under appeal at the Federal Circuit? The outcome of that appeal could be highly influential, if not dispositive, on the issue of claim scope.
A question of Functional Configuration: Assuming the court adopts a construction, a core factual issue will be whether the Accused Product's friction-fit mechanism is technically "configured" for removal during piston reciprocation. This will require evidence comparing the design intent and practical functionality of the accused friction-fit interface against the requirements of the claim language.
An Alternative question of Validity: If the "Quick-Connect Limitation" is construed broadly enough to read on the Accused Products' conventional friction-fit interface, will that broad scope render the claim invalid as obvious over prior art that disclosed such well-known attachment methods? The complaint preserves this alternative argument, creating a classic "Ginsburg" scenario where the patentee may face a choice between a narrow construction for non-infringement or a broad construction that risks invalidity.