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legal briefs, and other written submissions in patent infringement cases. Its structured content focuses on case and patent details, disputed facts, claim-by-claim infringement comparisons, party positions, defense arguments, evidence references, and cited legal authorities. It supports domain-specific training, information retrieval, legal analysis tool development, and evaluation of legal document understanding systems.\u003C\u002Fp>","2026-10-15 18:07:53","2026-10-19 18:26:31","0.00",0,5000,"patent infringement dataset,patent litigation documents,legal document understanding,patent claim comparison,patent pleading analysis,legal information extraction,IP disputes,legal AI training","Structured patent infringement pleadings covering claim comparisons, disputed facts, party arguments, and legal evidence for training and evaluating legal AI.","JSON","0.2GB","patent infringement litigation, patent pleading analysis, intellectual property dispute analysis","legal document understanding, claim comparison analysis, defense argument identification","V1.0","rivo\u002Fsample-packages\u002F5f737b5a-d162-4b14-81b1-dfc627770858\u002F20261015.zip",[583,588,594,599,604,610,615,620,625,630,635,640,645],{"id":572,"name":584,"field":585,"intro":586,"type":587},"File Name","file_name","File name","string",{"id":589,"name":590,"field":591,"intro":592,"type":593},9212,"Legal Basis","legal_basis","Laws and judicial interpretations cited in the document, along with the legal propositions they support.","array",{"id":595,"name":596,"field":597,"intro":598,"type":587},9213,"Pleading Document Text","document_text","Full text of a pleading document in a patent infringement case.",{"id":600,"name":601,"field":602,"intro":603,"type":587},9214,"Document Type","document_type","Type of pleading document, such as a complaint, statement of defense, counterclaim, legal brief, or written opinion.",{"id":605,"name":606,"field":607,"intro":608,"type":609},9215,"Disputed Facts","disputed_facts","Disputed content concerning the accused product or method, alleged acts, and related technical facts.","object",{"id":611,"name":612,"field":613,"intro":614,"type":593},9216,"Defense Arguments","defense_reasons","Arguments raised by the defendant or other parties concerning infringement, patent validity, liability, or claimed damages.",{"id":616,"name":617,"field":618,"intro":619,"type":593},9217,"Party Arguments and Positions","party_positions","Facts, legal arguments, and requested relief raised by the plaintiff, defendant, or other participants, with relevant positions linked where available.",{"id":621,"name":622,"field":623,"intro":624,"type":609},9218,"Case Information","case_information","Basic case details and procedural information identified in the document.",{"id":626,"name":627,"field":628,"intro":629,"type":587},9219,"Summary of Document Disputes","document_summary","A concise synthesis of the case background, key disputes, party positions, and principal requests discussed in the document.",{"id":631,"name":632,"field":633,"intro":634,"type":593},9220,"Patent Claim Infringement Comparisons","claim_comparisons","Comparisons by claim and technical feature recording the parties' positions on whether the accused solution falls within the scope of protection.",{"id":636,"name":637,"field":638,"intro":639,"type":609},9221,"Patent Information","patent_information","Basic information about the patents and claims involved in the document.",{"id":641,"name":642,"field":643,"intro":644,"type":593},9222,"Evidence References","evidence_references","Evidence cited in the document to support disputed facts or legal arguments.",{"id":646,"name":647,"field":648,"intro":649,"type":609},9223,"Counterclaim Information","counterclaim_information","Counterclaim facts, requested relief, and legal grounds extracted from counterclaims or related pleadings.",[651,655,659,663],{"id":652,"question":653,"answer":654},6479,"Which types of patent litigation documents are included?","The dataset covers complaints, statements of defense, counterclaims, legal briefs, and related written submissions in patent infringement cases. It provides structured content on case details, patents, disputed facts, and litigation positions.",{"id":656,"question":657,"answer":658},6480,"Which training and evaluation tasks does it support?","Potential tasks include legal document understanding, pleading information extraction, party argument linking, defense reason identification, patent claim infringement comparison, and document summarization. Results depend on the model, data processing, and evaluation design.",{"id":660,"question":661,"answer":662},6481,"What fields are included in the dataset structure?","Fields cover document text and type, case information, patent information, disputed facts, claim comparisons, party positions, defense reasons, counterclaim information, evidence references, legal basis, and a summary of the document's disputes.",{"id":664,"question":665,"answer":666},6482,"How can the dataset be obtained, and what usage restrictions apply?","Check the product page or the provider's published channels for access options, delivery format, and update details. Legal documents may be subject to privacy, confidentiality, or intellectual property restrictions, so verify the applicable license and rules before use. The dataset is not legal advice.",[668,688,705],{"id":669,"relate_table":670,"relate_id":671,"file_size":572,"file_name":672,"path":8,"duration":572,"cate":483,"file_format":673,"audio_rate":8,"audio_channel":522,"audio_bit_depth":522,"quality":8,"annotation":674,"cate_name":675,"legal_basis":676,"document_text":677,"document_type":678,"disputed_facts":679,"defense_reasons":680,"party_positions":681,"case_information":682,"document_summary":683,"claim_comparisons":684,"patent_information":685,"evidence_references":686,"counterclaim_information":687},15171,"union_cubo",2120570089,"样例_3.json","json","{\"legal_basis\": \"[{\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 64\\\", \\\"legal_proposition\\\": \\\"The scope of protection of an invention patent shall be based on the content of the claims, and the description and drawings may be used to interpret the claims.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Argue that the H-20 lacks essential features such as a plate-type heat exchange core, integrally formed guide groove, and same-side interfaces\\\"}, {\\\"law_name\\\": \\\"Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes\\\", \\\"article\\\": \\\"Article 7\\\", \\\"legal_proposition\\\": \\\"When determining whether an accused technical solution falls within the scope of protection, all technical features recorded in the claims shall be examined.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Request confirmation that the H-20 does not infringe Claims 1 and 6\\\"}, {\\\"law_name\\\": \\\"Anti-Unfair Competition Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 11\\\", \\\"legal_proposition\\\": \\\"Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Argue that Hanyu Company issued improper infringement warnings to customers and the public and should bear damage liability\\\"}, {\\\"law_name\\\": \\\"Civil Code of the People's Republic of China\\\", \\\"article\\\": \\\"Article 1024\\\", \\\"legal_proposition\\\": \\\"Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Support the request for goodwill clarification and related damages\\\"}]\", \"document_text\": \"Counterclaim and Written Opinion\\nCase No.: (2025) Zhe 01 Zhi Min Chu No. 203\\nPlaintiff in the principal action, Defendant in the counterclaim: Hanyu Environmental Equipment Co., Ltd.\\nDefendant in the principal action, Plaintiff in the counterclaim: Qinglan Thermal Control Systems Co., Ltd.\\nCounterclaim Requests: 1. Confirm that the 'Qinglan Modular Heat Exchanger H-20' manufactured and sold by the Counterclaim Plaintiff does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6; 2. Order the Counterclaim Defendant to cease alleging infringement by the Counterclaim Plaintiff at industry exhibitions, in customer emails, and on websites, and to delete the relevant statements; 3. Order the Counterclaim Defendant to compensate the Counterclaim Plaintiff for investigation, notarization, and goodwill clarification expenses totaling RMB 250,000 caused by the erroneous infringement warning; 4. The costs of the principal action and the counterclaim shall be borne by the Counterclaim Defendant.\\nFacts and Reasons: Hanyu Company is the patentee of Invention Patent No. ZL202110135790.6, titled 'A detachable heat exchange module for industrial waste heat recovery,' and filed the principal action on the ground that the Counterclaim Plaintiff's production and sale of the H-20 infringes the patent. Qinglan Company does not accept the infringement allegation in the principal action and now files this counterclaim in accordance with law.\\nClaim 1 of the patent at issue requires the heat exchange module to have a plate-type heat exchange core, a sealing frame arranged along the edge of the core, and a guide groove integrally formed with the sealing frame; Claim 6 further requires that the inlet and outlet of the guide groove be located on the same side of the module and be connected to external piping through detachable joints. The H-20 uses a brazed tube-fin heat exchange core, its sealing component is an independently installed silicone sealing ring, its flow guide path is formed by an internal header, and its external interfaces are located on opposite sides of the module. It does not have a plate-type heat exchange core, a guide groove integrally formed with a sealing frame, or same-side inlet and outlet.\\nIn January 2025, the Plaintiff in the principal action sent a 'Patent Infringement Risk Notification Letter' to three customers of Qinglan Company, and marked the H-20 on a display board at the 'East China Energy-Saving Equipment Exhibition' as a 'product suspected of infringing Hanyu's patent,' causing two customers to suspend acceptance and require Qinglan Company to submit a non-infringement statement. Qinglan Company has entrusted a notarial institution to preserve evidence of the display board and webpage, and has paid testing, attorney, and goodwill clarification expenses. Hanyu Company issued targeted warnings to counterparties without conducting product disassembly and technical comparison, expanding the scope of dissemination, which has exceeded the necessary limits of legitimate rights protection.\\nQinglan Company requests that, while hearing the infringement dispute in the principal action, the court confirm that the H-20 does not fall within the scope of protection of Claims 1 and 6, and order Hanyu Company to cease improper infringement warnings and compensate for reasonable losses.\\nRespectfully submitted to\\nHangcheng City Intermediate People's Court\\nCounterclaim Plaintiff: Qinglan Thermal Control Systems Co., Ltd.\\nMay 9, 2025\", \"document_type\": \"Counterclaim\", \"disputed_facts\": \"{\\\"accused_product\\\": \\\"Qinglan Modular Heat Exchanger H-20\\\", \\\"accused_technical_solution\\\": \\\"The H-20 uses a brazed tube-fin heat exchange core, an independently installed silicone sealing ring on the outer periphery of the heat exchange core, fluid distributed by an internal header to the tube-fin channels, hot medium inlet and outlet respectively located on opposite sides of the module, and fixed flanges connecting external piping.\\\", \\\"relevant_technical_features\\\": [\\\"Whether the heat exchange core is plate-type or brazed tube-fin type\\\", \\\"Whether the sealing component is arranged along the edge of the heat exchange core and integrally formed with a sealing frame\\\", \\\"Whether a guide groove is formed in the sealing frame and performs a fluid guiding function\\\", \\\"Whether the inlet and outlet are located on the same side of the module\\\", \\\"Whether external piping connection uses detachable joints\\\"], \\\"infringement_act\\\": \\\"The Plaintiff in the principal action alleges that the Counterclaim Plaintiff's manufacture and sale of the H-20 constitute patent infringement; the Counterclaim Plaintiff also alleges that the Plaintiff in the principal action issued infringement warnings against the H-20 to customers and the exhibition public, causing goodwill and transaction losses.\\\", \\\"factual_disputes\\\": [\\\"Whether the brazed tube-fin heat exchange core of the H-20 can correspond to the plate-type heat exchange core of Claim 1.\\\", \\\"Whether the independent silicone sealing ring is a guide groove structure integrally formed with a sealing frame.\\\", \\\"Whether the inlet and outlet arranged on two sides of the H-20 satisfy the same-side limitation of Claim 6.\\\", \\\"Whether Hanyu Company's infringement allegations to customers and at the exhibition were based on sufficient technical comparison.\\\", \\\"Whether the customers' suspension of acceptance and the notarization, testing, and clarification expenses incurred by the Counterclaim Plaintiff were directly caused by the infringement warning.\\\"]}\", \"defense_reasons\": \"[{\\\"defense_type\\\": \\\"Non-infringement defense\\\", \\\"defense_content\\\": \\\"The Counterclaim Plaintiff argues that the H-20 differs from the patent at issue in heat exchange core, sealing frame guide groove, inlet\u002Foutlet positions, and piping joints, and does not fall within the scope of protection of Claims 1 and 6.\\\", \\\"factual_basis\\\": [\\\"The H-20 uses a brazed tube-fin heat exchange core rather than a plate-type heat exchange core.\\\", \\\"The independent silicone sealing ring does not have an integrally formed guide groove.\\\", \\\"The inlet and outlet are arranged on two sides of the module and fixed flanges are used.\\\"], \\\"legal_basis\\\": [\\\"Article 64 of the Patent Law of the People's Republic of China: The scope of patent protection is based on the content of the claims.\\\", \\\"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: If the accused technical solution lacks a technical feature in the claims, it generally does not fall within the scope of protection.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 6\\\"]}, {\\\"defense_type\\\": \\\"Defense of damages from improper infringement warning\\\", \\\"defense_content\\\": \\\"The Counterclaim Plaintiff argues that the Plaintiff in the principal action, lacking product disassembly, technical appraisal, and complete comparison, issued infringement allegations to specific customers and unspecified exhibition visitors, exceeding the scope of legitimate rights protection and causing actual damage.\\\", \\\"factual_basis\\\": [\\\"The infringement warning letter specifically targeted the H-20 and its customer transactions.\\\", \\\"The exhibition display board publicly displayed suspected infringement information.\\\", \\\"The customers' suspension of acceptance was close in time to the sending of the warning letters.\\\"], \\\"legal_basis\\\": [\\\"Article 1024 of the Civil Code of the People's Republic of China: Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\\\", \\\"Article 11 of the Anti-Unfair Competition Law of the People's Republic of China: Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 6\\\"]}]\", \"party_positions\": \"[{\\\"party\\\": \\\"Hanyu Environmental Equipment Co., Ltd.\\\", \\\"position_type\\\": \\\"Infringement assertion in principal action\\\", \\\"claim_content\\\": \\\"The heat exchange core, sealing member, and guide structure of the H-20 have equivalent functions to the patent at issue, and Qinglan Company's manufacture and sale infringe Claims 1 and 6.\\\", \\\"supporting_facts\\\": [\\\"The H-20 has a heat exchange core, sealing member, and fluid guiding structure.\\\", \\\"The H-20 can achieve industrial waste heat recovery and modular disassembly.\\\"], \\\"requested_relief\\\": \\\"Request an order that Qinglan Company cease manufacturing and selling the H-20 and compensate for losses in the principal action.\\\"}, {\\\"party\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"position_type\\\": \\\"Counterclaim confirmation assertion\\\", \\\"claim_content\\\": \\\"The H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side flange interfaces, lacks the essential technical features of Claims 1 and 6, and does not infringe the patent at issue.\\\", \\\"supporting_facts\\\": [\\\"The H-20 structure diagram and product prototype show the use of a tube-fin heat exchange core.\\\", \\\"The inlet and outlet are located on opposite sides of the module.\\\", \\\"The sealing ring does not have a guiding function, and guiding is accomplished by the internal header.\\\"], \\\"requested_relief\\\": \\\"Request confirmation that the H-20 does not infringe Claims 1 and 6.\\\"}, {\\\"party\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"position_type\\\": \\\"Counterclaim damages assertion\\\", \\\"claim_content\\\": \\\"Hanyu Company, without completing sufficient technical comparison, issued targeted infringement warnings to customers and the exhibition public, causing customers to suspend acceptance and incurring notarization, testing, and goodwill clarification expenses.\\\", \\\"supporting_facts\\\": [\\\"Hanyu Company sent patent infringement risk notification letters to three customers.\\\", \\\"The exhibition display board directly marked the H-20 as suspected of infringement.\\\", \\\"Two customers suspended acceptance because of the warnings, and Qinglan Company paid notarization and testing expenses.\\\"], \\\"requested_relief\\\": \\\"Request an order that Hanyu Company cease improper warnings and compensate RMB 250,000 in reasonable losses.\\\"}]\", \"case_information\": \"{\\\"case_number\\\": \\\"(2025) Zhe 01 Zhi Min Chu No. 203\\\", \\\"court_name\\\": \\\"Hangcheng City Intermediate People's Court\\\", \\\"plaintiff\\\": \\\"Hanyu Environmental Equipment Co., Ltd.\\\", \\\"defendant\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"document_date\\\": \\\"May 9, 2025\\\", \\\"procedural_stage\\\": \\\"Counterclaim stage during first-instance principal action\\\"}\", \"document_summary\": \"This case includes a patent infringement principal action filed by Hanyu Environmental Equipment Co., Ltd. and a counterclaim filed by Qinglan Thermal Control Systems Co., Ltd. for confirmation of non-infringement and damages for improper infringement warning. Qinglan Company argues that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges, and lacks the plate-type heat exchange core, integrally formed guide groove, same-side inlet and outlet, and detachable joints required by Claims 1 and 6. Qinglan Company also argues that Hanyu Company, without sufficient comparison, issued infringement warnings to customers and the exhibition public, causing suspension of acceptance and related expenses, and therefore requests confirmation of non-infringement, cessation of warnings, and compensation of RMB 250,000.\", \"claim_comparisons\": \"[{\\\"claim_number\\\": \\\"Claim 1\\\", \\\"claim_text\\\": \\\"A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"1-A\\\", \\\"element_text\\\": \\\"Plate-type heat exchange core\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 uses a multi-row brazed tube-fin heat exchange core, in which fluid flows inside tubes and exchanges heat through fins.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The brazed tube-fin core is composed of tube bundles and fins, not a plate-type heat exchange core formed by stacked plates, and the structural basis and fluid channels are different.\\\"}, {\\\"element_label\\\": \\\"1-B\\\", \\\"element_text\\\": \\\"A sealing frame arranged along the edge of the heat exchange core\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 has an independent silicone sealing ring installed on the outer periphery of the core, fixed by metal pressure plates.\\\", \\\"comparison_result\\\": \\\"Partially corresponding but different\\\", \\\"comparison_reason\\\": \\\"Although the accused product has a sealing member on the outer periphery of the core, it is an independent sealing ring rather than the sealing frame recited in the claim, and the specific structure and assembly relationship differ.\\\"}, {\\\"element_label\\\": \\\"1-C\\\", \\\"element_text\\\": \\\"The guide groove is integrally formed with the sealing frame\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 distributes fluid to the tube-fin channels through an internal header, and the silicone sealing ring does not perform a guide groove function.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The fluid guiding of the accused product is accomplished by the internal header, and the sealing ring has no integrally formed guide groove and does not perform the guiding function in the claim.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff in the principal action, Hanyu Company, argues that the combination of the sealing ring and internal header of the H-20 can achieve the same sealing and guiding functions as the patented sealing frame guide groove, and is an equivalent technical solution.\\\", \\\"defendant_position\\\": \\\"The Counterclaim Plaintiff, Qinglan Company, argues that the H-20 uses a completely different tube-fin heat exchange core and internal header, and the sealing ring is neither a sealing frame nor has a guide groove, so it at least lacks the key features of Claim 1.\\\", \\\"overall_conclusion\\\": \\\"The accused solution and Claim 1 have obvious differences in heat exchange core type, sealing structure, and guide component, and the Counterclaim Plaintiff accordingly argues that it does not fall within the scope of protection of Claim 1.\\\"}, {\\\"claim_number\\\": \\\"Claim 6\\\", \\\"claim_text\\\": \\\"The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"6-A\\\", \\\"element_text\\\": \\\"The inlet and outlet of the guide groove are located on the same side of the module\\\", \\\"accused_corresponding_feature\\\": \\\"The hot medium inlet of the H-20 is located on the left side and the outlet is located on the right side, respectively on opposite sides of the module.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The product piping diagram and physical photos show that the inlet and outlet are arranged on two sides, which does not satisfy the explicit spatial limitation of same-side arrangement.\\\"}, {\\\"element_label\\\": \\\"6-B\\\", \\\"element_text\\\": \\\"Connected to external piping through detachable joints\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 is connected to external piping through fixed flanges, and disassembly requires releasing bolts and replacing sealing gaskets.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The fixed flange connection is different from the detachable joint recited in the claim, and this connection structure serves the tube-fin core rather than the patented guide groove.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff in the principal action argues that the flange connection can also make the module detachable, and the difference in inlet and outlet positions does not affect the overall heat exchange function, so it at least constitutes equivalent infringement.\\\", \\\"defendant_position\\\": \\\"The Counterclaim Plaintiff argues that same-side inlet and outlet are an explicit spatial relationship of Claim 6, and the two-side interfaces and fixed flanges of the H-20 do not have this feature, and cannot be replaced by similar function.\\\", \\\"overall_conclusion\\\": \\\"The H-20 does not have the same-side inlet and outlet or detachable joint features of Claim 6, and the Counterclaim Plaintiff's non-infringement confirmation claim has a technical comparison basis.\\\"}]\", \"patent_information\": \"{\\\"patent_number\\\": \\\"ZL202110135790.6\\\", \\\"patent_title\\\": \\\"A detachable heat exchange module for industrial waste heat recovery\\\", \\\"patent_type\\\": \\\"Invention patent\\\", \\\"priority_date\\\": \\\"February 20, 2021\\\", \\\"claims_involved\\\": [\\\"Claim 1: A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\\\", \\\"Claim 6: The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\\\"]}\", \"evidence_references\": \"[{\\\"evidence_label\\\": \\\"Evidence 1: Published invention patent text and claims of the patent at issue\\\", \\\"evidence_type\\\": \\\"Patent documents\\\", \\\"evidence_description\\\": \\\"Records the plate-type heat exchange core and sealing frame integrally formed guide groove of Claim 1, and the same-side interfaces and detachable joints of Claim 6.\\\", \\\"proof_purpose\\\": \\\"To determine the essential technical features required for infringement comparison in the principal action.\\\", \\\"related_issue\\\": \\\"Scope of protection of Claims 1 and 6\\\"}, {\\\"evidence_label\\\": \\\"Evidence 2: H-20 product structure diagram, piping diagram, and prototype photos\\\", \\\"evidence_type\\\": \\\"Technical materials and physical evidence\\\", \\\"evidence_description\\\": \\\"Shows that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges.\\\", \\\"proof_purpose\\\": \\\"To prove that the technical solution of the accused product differs from the patent claims.\\\", \\\"related_issue\\\": \\\"Non-infringement comparison\\\"}, {\\\"evidence_label\\\": \\\"Evidence 3: Patent infringement risk notification letters and notarized exhibition display board\\\", \\\"evidence_type\\\": \\\"Notarized documents and written materials\\\", \\\"evidence_description\\\": \\\"Records the content of the notification letters sent by Hanyu Company to three customers and the statements on the exhibition display board regarding the H-20 being suspected of infringement.\\\", \\\"proof_purpose\\\": \\\"To prove the recipients, dissemination scope, and specific content of the infringement warnings.\\\", \\\"related_issue\\\": \\\"Improper infringement warning conduct in the counterclaim\\\"}, {\\\"evidence_label\\\": \\\"Evidence 4: Customer suspension of acceptance notices, notarization and testing expense vouchers\\\", \\\"evidence_type\\\": \\\"Business records and expense vouchers\\\", \\\"evidence_description\\\": \\\"Records the notices from two customers suspending acceptance of the H-20 and the amounts paid by Qinglan Company for notarization, testing, and goodwill clarification services.\\\", \\\"proof_purpose\\\": \\\"To prove the connection between the infringement warnings, the transaction impact, and the losses.\\\", \\\"related_issue\\\": \\\"Counterclaim damages request\\\"}]\", \"counterclaim_information\": \"{\\\"has_counterclaim\\\": true, \\\"counterclaim_type\\\": \\\"Counterclaim for confirmation of non-infringement and damages for improper infringement warning\\\", \\\"counterclaim_content\\\": \\\"Qinglan Company requests confirmation that the H-20 does not infringe Claims 1 and 6 of Hanyu Company, and alleges that Hanyu Company, without completing sufficient technical comparison, disseminated infringement allegations to customers and the exhibition public, causing suspension of transactions, investigation expenses, and goodwill clarification expenses.\\\", \\\"counterclaim_requests\\\": [\\\"Confirm that the Qinglan Modular Heat Exchanger H-20 does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to cease issuing improper infringement warnings against the H-20 to customers and the public, and to delete the relevant webpage and display board content.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to compensate notarization, testing, attorney, and goodwill clarification expenses totaling RMB 250,000.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to bear the litigation costs of the principal action and counterclaim.\\\"], \\\"counterclaim_facts\\\": [\\\"The heat exchange core, sealing structure, and interface arrangement of the H-20 have multiple clear differences from the claims at issue.\\\", \\\"Hanyu Company sent patent infringement risk notification letters to three customers and publicly marked the H-20 as suspected of infringement at an industry exhibition.\\\", \\\"After receiving the notifications, two customers suspended acceptance, and Qinglan Company spent notarization, testing, and clarification expenses to restore the transactions.\\\"]}\"}","文本","[{\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 64\", \"legal_proposition\": \"The scope of protection of an invention patent shall be based on the content of the claims, and the description and drawings may be used to interpret the claims.\", \"cited_by\": \"Counterclaim Plaintiff\", \"related_claim\": \"Argue that the H-20 lacks essential features such as a plate-type heat exchange core, integrally formed guide groove, and same-side interfaces\"}, {\"law_name\": \"Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes\", \"article\": \"Article 7\", \"legal_proposition\": \"When determining whether an accused technical solution falls within the scope of protection, all technical features recorded in the claims shall be examined.\", \"cited_by\": \"Counterclaim Plaintiff\", \"related_claim\": \"Request confirmation that the H-20 does not infringe Claims 1 and 6\"}, {\"law_name\": \"Anti-Unfair Competition Law of the People's Republic of China\", \"article\": \"Article 11\", \"legal_proposition\": \"Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\", \"cited_by\": \"Counterclaim Plaintiff\", \"related_claim\": \"Argue that Hanyu Company issued improper infringement warnings to customers and the public and should bear damage liability\"}, {\"law_name\": \"Civil Code of the People's Republic of China\", \"article\": \"Article 1024\", \"legal_proposition\": \"Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\", \"cited_by\": \"Counterclaim Plaintiff\", \"related_claim\": \"Support the request for goodwill clarification and related damages\"}]","Counterclaim and Written Opinion\nCase No.: (2025) Zhe 01 Zhi Min Chu No. 203\nPlaintiff in the principal action, Defendant in the counterclaim: Hanyu Environmental Equipment Co., Ltd.\nDefendant in the principal action, Plaintiff in the counterclaim: Qinglan Thermal Control Systems Co., Ltd.\nCounterclaim Requests: 1. Confirm that the 'Qinglan Modular Heat Exchanger H-20' manufactured and sold by the Counterclaim Plaintiff does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6; 2. Order the Counterclaim Defendant to cease alleging infringement by the Counterclaim Plaintiff at industry exhibitions, in customer emails, and on websites, and to delete the relevant statements; 3. Order the Counterclaim Defendant to compensate the Counterclaim Plaintiff for investigation, notarization, and goodwill clarification expenses totaling RMB 250,000 caused by the erroneous infringement warning; 4. The costs of the principal action and the counterclaim shall be borne by the Counterclaim Defendant.\nFacts and Reasons: Hanyu Company is the patentee of Invention Patent No. ZL202110135790.6, titled 'A detachable heat exchange module for industrial waste heat recovery,' and filed the principal action on the ground that the Counterclaim Plaintiff's production and sale of the H-20 infringes the patent. Qinglan Company does not accept the infringement allegation in the principal action and now files this counterclaim in accordance with law.\nClaim 1 of the patent at issue requires the heat exchange module to have a plate-type heat exchange core, a sealing frame arranged along the edge of the core, and a guide groove integrally formed with the sealing frame; Claim 6 further requires that the inlet and outlet of the guide groove be located on the same side of the module and be connected to external piping through detachable joints. The H-20 uses a brazed tube-fin heat exchange core, its sealing component is an independently installed silicone sealing ring, its flow guide path is formed by an internal header, and its external interfaces are located on opposite sides of the module. It does not have a plate-type heat exchange core, a guide groove integrally formed with a sealing frame, or same-side inlet and outlet.\nIn January 2025, the Plaintiff in the principal action sent a 'Patent Infringement Risk Notification Letter' to three customers of Qinglan Company, and marked the H-20 on a display board at the 'East China Energy-Saving Equipment Exhibition' as a 'product suspected of infringing Hanyu's patent,' causing two customers to suspend acceptance and require Qinglan Company to submit a non-infringement statement. Qinglan Company has entrusted a notarial institution to preserve evidence of the display board and webpage, and has paid testing, attorney, and goodwill clarification expenses. Hanyu Company issued targeted warnings to counterparties without conducting product disassembly and technical comparison, expanding the scope of dissemination, which has exceeded the necessary limits of legitimate rights protection.\nQinglan Company requests that, while hearing the infringement dispute in the principal action, the court confirm that the H-20 does not fall within the scope of protection of Claims 1 and 6, and order Hanyu Company to cease improper infringement warnings and compensate for reasonable losses.\nRespectfully submitted to\nHangcheng City Intermediate People's Court\nCounterclaim Plaintiff: Qinglan Thermal Control Systems Co., Ltd.\nMay 9, 2025","Counterclaim","{\"accused_product\": \"Qinglan Modular Heat Exchanger H-20\", \"accused_technical_solution\": \"The H-20 uses a brazed tube-fin heat exchange core, an independently installed silicone sealing ring on the outer periphery of the heat exchange core, fluid distributed by an internal header to the tube-fin channels, hot medium inlet and outlet respectively located on opposite sides of the module, and fixed flanges connecting external piping.\", \"relevant_technical_features\": [\"Whether the heat exchange core is plate-type or brazed tube-fin type\", \"Whether the sealing component is arranged along the edge of the heat exchange core and integrally formed with a sealing frame\", \"Whether a guide groove is formed in the sealing frame and performs a fluid guiding function\", \"Whether the inlet and outlet are located on the same side of the module\", \"Whether external piping connection uses detachable joints\"], \"infringement_act\": \"The Plaintiff in the principal action alleges that the Counterclaim Plaintiff's manufacture and sale of the H-20 constitute patent infringement; the Counterclaim Plaintiff also alleges that the Plaintiff in the principal action issued infringement warnings against the H-20 to customers and the exhibition public, causing goodwill and transaction losses.\", \"factual_disputes\": [\"Whether the brazed tube-fin heat exchange core of the H-20 can correspond to the plate-type heat exchange core of Claim 1.\", \"Whether the independent silicone sealing ring is a guide groove structure integrally formed with a sealing frame.\", \"Whether the inlet and outlet arranged on two sides of the H-20 satisfy the same-side limitation of Claim 6.\", \"Whether Hanyu Company's infringement allegations to customers and at the exhibition were based on sufficient technical comparison.\", \"Whether the customers' suspension of acceptance and the notarization, testing, and clarification expenses incurred by the Counterclaim Plaintiff were directly caused by the infringement warning.\"]}","[{\"defense_type\": \"Non-infringement defense\", \"defense_content\": \"The Counterclaim Plaintiff argues that the H-20 differs from the patent at issue in heat exchange core, sealing frame guide groove, inlet\u002Foutlet positions, and piping joints, and does not fall within the scope of protection of Claims 1 and 6.\", \"factual_basis\": [\"The H-20 uses a brazed tube-fin heat exchange core rather than a plate-type heat exchange core.\", \"The independent silicone sealing ring does not have an integrally formed guide groove.\", \"The inlet and outlet are arranged on two sides of the module and fixed flanges are used.\"], \"legal_basis\": [\"Article 64 of the Patent Law of the People's Republic of China: The scope of patent protection is based on the content of the claims.\", \"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: If the accused technical solution lacks a technical feature in the claims, it generally does not fall within the scope of protection.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 6\"]}, {\"defense_type\": \"Defense of damages from improper infringement warning\", \"defense_content\": \"The Counterclaim Plaintiff argues that the Plaintiff in the principal action, lacking product disassembly, technical appraisal, and complete comparison, issued infringement allegations to specific customers and unspecified exhibition visitors, exceeding the scope of legitimate rights protection and causing actual damage.\", \"factual_basis\": [\"The infringement warning letter specifically targeted the H-20 and its customer transactions.\", \"The exhibition display board publicly displayed suspected infringement information.\", \"The customers' suspension of acceptance was close in time to the sending of the warning letters.\"], \"legal_basis\": [\"Article 1024 of the Civil Code of the People's Republic of China: Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\", \"Article 11 of the Anti-Unfair Competition Law of the People's Republic of China: Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 6\"]}]","[{\"party\": \"Hanyu Environmental Equipment Co., Ltd.\", \"position_type\": \"Infringement assertion in principal action\", \"claim_content\": \"The heat exchange core, sealing member, and guide structure of the H-20 have equivalent functions to the patent at issue, and Qinglan Company's manufacture and sale infringe Claims 1 and 6.\", \"supporting_facts\": [\"The H-20 has a heat exchange core, sealing member, and fluid guiding structure.\", \"The H-20 can achieve industrial waste heat recovery and modular disassembly.\"], \"requested_relief\": \"Request an order that Qinglan Company cease manufacturing and selling the H-20 and compensate for losses in the principal action.\"}, {\"party\": \"Qinglan Thermal Control Systems Co., Ltd.\", \"position_type\": \"Counterclaim confirmation assertion\", \"claim_content\": \"The H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side flange interfaces, lacks the essential technical features of Claims 1 and 6, and does not infringe the patent at issue.\", \"supporting_facts\": [\"The H-20 structure diagram and product prototype show the use of a tube-fin heat exchange core.\", \"The inlet and outlet are located on opposite sides of the module.\", \"The sealing ring does not have a guiding function, and guiding is accomplished by the internal header.\"], \"requested_relief\": \"Request confirmation that the H-20 does not infringe Claims 1 and 6.\"}, {\"party\": \"Qinglan Thermal Control Systems Co., Ltd.\", \"position_type\": \"Counterclaim damages assertion\", \"claim_content\": \"Hanyu Company, without completing sufficient technical comparison, issued targeted infringement warnings to customers and the exhibition public, causing customers to suspend acceptance and incurring notarization, testing, and goodwill clarification expenses.\", \"supporting_facts\": [\"Hanyu Company sent patent infringement risk notification letters to three customers.\", \"The exhibition display board directly marked the H-20 as suspected of infringement.\", \"Two customers suspended acceptance because of the warnings, and Qinglan Company paid notarization and testing expenses.\"], \"requested_relief\": \"Request an order that Hanyu Company cease improper warnings and compensate RMB 250,000 in reasonable losses.\"}]","{\"case_number\": \"(2025) Zhe 01 Zhi Min Chu No. 203\", \"court_name\": \"Hangcheng City Intermediate People's Court\", \"plaintiff\": \"Hanyu Environmental Equipment Co., Ltd.\", \"defendant\": \"Qinglan Thermal Control Systems Co., Ltd.\", \"document_date\": \"May 9, 2025\", \"procedural_stage\": \"Counterclaim stage during first-instance principal action\"}","This case includes a patent infringement principal action filed by Hanyu Environmental Equipment Co., Ltd. and a counterclaim filed by Qinglan Thermal Control Systems Co., Ltd. for confirmation of non-infringement and damages for improper infringement warning. Qinglan Company argues that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges, and lacks the plate-type heat exchange core, integrally formed guide groove, same-side inlet and outlet, and detachable joints required by Claims 1 and 6. Qinglan Company also argues that Hanyu Company, without sufficient comparison, issued infringement warnings to customers and the exhibition public, causing suspension of acceptance and related expenses, and therefore requests confirmation of non-infringement, cessation of warnings, and compensation of RMB 250,000.","[{\"claim_number\": \"Claim 1\", \"claim_text\": \"A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\", \"claim_elements\": [{\"element_label\": \"1-A\", \"element_text\": \"Plate-type heat exchange core\", \"accused_corresponding_feature\": \"The H-20 uses a multi-row brazed tube-fin heat exchange core, in which fluid flows inside tubes and exchanges heat through fins.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The brazed tube-fin core is composed of tube bundles and fins, not a plate-type heat exchange core formed by stacked plates, and the structural basis and fluid channels are different.\"}, {\"element_label\": \"1-B\", \"element_text\": \"A sealing frame arranged along the edge of the heat exchange core\", \"accused_corresponding_feature\": \"The H-20 has an independent silicone sealing ring installed on the outer periphery of the core, fixed by metal pressure plates.\", \"comparison_result\": \"Partially corresponding but different\", \"comparison_reason\": \"Although the accused product has a sealing member on the outer periphery of the core, it is an independent sealing ring rather than the sealing frame recited in the claim, and the specific structure and assembly relationship differ.\"}, {\"element_label\": \"1-C\", \"element_text\": \"The guide groove is integrally formed with the sealing frame\", \"accused_corresponding_feature\": \"The H-20 distributes fluid to the tube-fin channels through an internal header, and the silicone sealing ring does not perform a guide groove function.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The fluid guiding of the accused product is accomplished by the internal header, and the sealing ring has no integrally formed guide groove and does not perform the guiding function in the claim.\"}], \"plaintiff_position\": \"The Plaintiff in the principal action, Hanyu Company, argues that the combination of the sealing ring and internal header of the H-20 can achieve the same sealing and guiding functions as the patented sealing frame guide groove, and is an equivalent technical solution.\", \"defendant_position\": \"The Counterclaim Plaintiff, Qinglan Company, argues that the H-20 uses a completely different tube-fin heat exchange core and internal header, and the sealing ring is neither a sealing frame nor has a guide groove, so it at least lacks the key features of Claim 1.\", \"overall_conclusion\": \"The accused solution and Claim 1 have obvious differences in heat exchange core type, sealing structure, and guide component, and the Counterclaim Plaintiff accordingly argues that it does not fall within the scope of protection of Claim 1.\"}, {\"claim_number\": \"Claim 6\", \"claim_text\": \"The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\", \"claim_elements\": [{\"element_label\": \"6-A\", \"element_text\": \"The inlet and outlet of the guide groove are located on the same side of the module\", \"accused_corresponding_feature\": \"The hot medium inlet of the H-20 is located on the left side and the outlet is located on the right side, respectively on opposite sides of the module.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The product piping diagram and physical photos show that the inlet and outlet are arranged on two sides, which does not satisfy the explicit spatial limitation of same-side arrangement.\"}, {\"element_label\": \"6-B\", \"element_text\": \"Connected to external piping through detachable joints\", \"accused_corresponding_feature\": \"The H-20 is connected to external piping through fixed flanges, and disassembly requires releasing bolts and replacing sealing gaskets.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The fixed flange connection is different from the detachable joint recited in the claim, and this connection structure serves the tube-fin core rather than the patented guide groove.\"}], \"plaintiff_position\": \"The Plaintiff in the principal action argues that the flange connection can also make the module detachable, and the difference in inlet and outlet positions does not affect the overall heat exchange function, so it at least constitutes equivalent infringement.\", \"defendant_position\": \"The Counterclaim Plaintiff argues that same-side inlet and outlet are an explicit spatial relationship of Claim 6, and the two-side interfaces and fixed flanges of the H-20 do not have this feature, and cannot be replaced by similar function.\", \"overall_conclusion\": \"The H-20 does not have the same-side inlet and outlet or detachable joint features of Claim 6, and the Counterclaim Plaintiff's non-infringement confirmation claim has a technical comparison basis.\"}]","{\"patent_number\": \"ZL202110135790.6\", \"patent_title\": \"A detachable heat exchange module for industrial waste heat recovery\", \"patent_type\": \"Invention patent\", \"priority_date\": \"February 20, 2021\", \"claims_involved\": [\"Claim 1: A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\", \"Claim 6: The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\"]}","[{\"evidence_label\": \"Evidence 1: Published invention patent text and claims of the patent at issue\", \"evidence_type\": \"Patent documents\", \"evidence_description\": \"Records the plate-type heat exchange core and sealing frame integrally formed guide groove of Claim 1, and the same-side interfaces and detachable joints of Claim 6.\", \"proof_purpose\": \"To determine the essential technical features required for infringement comparison in the principal action.\", \"related_issue\": \"Scope of protection of Claims 1 and 6\"}, {\"evidence_label\": \"Evidence 2: H-20 product structure diagram, piping diagram, and prototype photos\", \"evidence_type\": \"Technical materials and physical evidence\", \"evidence_description\": \"Shows that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges.\", \"proof_purpose\": \"To prove that the technical solution of the accused product differs from the patent claims.\", \"related_issue\": \"Non-infringement comparison\"}, {\"evidence_label\": \"Evidence 3: Patent infringement risk notification letters and notarized exhibition display board\", \"evidence_type\": \"Notarized documents and written materials\", \"evidence_description\": \"Records the content of the notification letters sent by Hanyu Company to three customers and the statements on the exhibition display board regarding the H-20 being suspected of infringement.\", \"proof_purpose\": \"To prove the recipients, dissemination scope, and specific content of the infringement warnings.\", \"related_issue\": \"Improper infringement warning conduct in the counterclaim\"}, {\"evidence_label\": \"Evidence 4: Customer suspension of acceptance notices, notarization and testing expense vouchers\", \"evidence_type\": \"Business records and expense vouchers\", \"evidence_description\": \"Records the notices from two customers suspending acceptance of the H-20 and the amounts paid by Qinglan Company for notarization, testing, and goodwill clarification services.\", \"proof_purpose\": \"To prove the connection between the infringement warnings, the transaction impact, and the losses.\", \"related_issue\": \"Counterclaim damages request\"}]","{\"has_counterclaim\": true, \"counterclaim_type\": \"Counterclaim for confirmation of non-infringement and damages for improper infringement warning\", \"counterclaim_content\": \"Qinglan Company requests confirmation that the H-20 does not infringe Claims 1 and 6 of Hanyu Company, and alleges that Hanyu Company, without completing sufficient technical comparison, disseminated infringement allegations to customers and the exhibition public, causing suspension of transactions, investigation expenses, and goodwill clarification expenses.\", \"counterclaim_requests\": [\"Confirm that the Qinglan Modular Heat Exchanger H-20 does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6.\", \"Order Hanyu Environmental Equipment Co., Ltd. to cease issuing improper infringement warnings against the H-20 to customers and the public, and to delete the relevant webpage and display board content.\", \"Order Hanyu Environmental Equipment Co., Ltd. to compensate notarization, testing, attorney, and goodwill clarification expenses totaling RMB 250,000.\", \"Order Hanyu Environmental Equipment Co., Ltd. to bear the litigation costs of the principal action and counterclaim.\"], \"counterclaim_facts\": [\"The heat exchange core, sealing structure, and interface arrangement of the H-20 have multiple clear differences from the claims at issue.\", \"Hanyu Company sent patent infringement risk notification letters to three customers and publicly marked the H-20 as suspected of infringement at an industry exhibition.\", \"After receiving the notifications, two customers suspended acceptance, and Qinglan Company spent notarization, testing, and clarification expenses to restore the transactions.\"]}",{"id":689,"relate_table":670,"relate_id":690,"file_size":572,"file_name":691,"path":8,"duration":572,"cate":483,"file_format":673,"audio_rate":8,"audio_channel":522,"audio_bit_depth":522,"quality":8,"annotation":692,"cate_name":675,"legal_basis":693,"document_text":694,"document_type":695,"disputed_facts":696,"defense_reasons":697,"party_positions":698,"case_information":699,"document_summary":700,"claim_comparisons":701,"patent_information":702,"evidence_references":703,"counterclaim_information":704},15170,1051740250,"样例_2.json","{\"legal_basis\": \"[{\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 64\\\", \\\"legal_proposition\\\": \\\"The scope of protection of a utility model patent shall be based on the content of the claims, and the description and drawings are used to interpret the claims.\\\", \\\"cited_by\\\": \\\"Plaintiff and Defendant\\\", \\\"related_claim\\\": \\\"Determine whether the annular light-shielding plate, transmission ring, and mechanical locking assembly are essential technical features\\\"}, {\\\"law_name\\\": \\\"Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes\\\", \\\"article\\\": \\\"Article 7\\\", \\\"legal_proposition\\\": \\\"When determining whether an accused infringing technical solution falls within the scope of patent protection, the people's court shall examine all technical features recorded in the claims.\\\", \\\"cited_by\\\": \\\"Defendant\\\", \\\"related_claim\\\": \\\"Argue that the P-3 lacks essential technical features and does not constitute infringement\\\"}, {\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 77\\\", \\\"legal_proposition\\\": \\\"A person who can prove a legitimate source of a product and did not know that it was manufactured and sold without permission may not bear compensation liability.\\\", \\\"cited_by\\\": \\\"Defendant\\\", \\\"related_claim\\\": \\\"Raise a legitimate source defense and request exemption from compensation liability\\\"}]\", \"document_text\": \"Civil Answer\\nCase No.: (2025) Su 05 Zhi Min Chu No. 76\\nRespondent (Defendant): Qiyun Optical Instrument Co., Ltd.\\nOpposing Party (Plaintiff): Yuancen Precision Measurement Co., Ltd.\\nAnswer Requests: 1. Dismiss all of the Plaintiff's claims for cessation of infringement, compensation for losses, and bearing costs in accordance with law; 2. The litigation costs of this case shall be borne by the Plaintiff.\\nFacts and Reasons: The Plaintiff relies on Utility Model Patent No. ZL202320987654.1, titled 'A portable spectral detector with adjustable light-shielding structure,' and alleges that the 'Qiyun Portable Spectrometer P-3' sold by the Respondent infringes its Claims 1 and 4. The Respondent does not accept this claim.\\nFirst, the accused product does not have the annular light-shielding plate or the radial synchronous adjustment structure defined by Claim 1. Claim 1 requires the annular light-shielding plate to open and close radially and synchronously through the same transmission ring to change the incident slit; the P-3 uses two rectangular light-shielding plates that translate relative to each other, driven separately by independent micro-motors, move in parallel directions, cannot form an annular structure, and do not have the same transmission ring.\\nSecond, the accused product does not have the locking feedback assembly described in Claim 4. The P-3 feeds back position through a motor encoder and does not have the pawl-and-toothed-disc mechanical locking structure required by Claim 4. Even if the Plaintiff interprets the encoder feedback as an equivalent technical feature, the two differ in structure, mode of operation, and fault-handling effect.\\nThird, the webpage screenshots submitted by the Plaintiff cannot prove that every batch actually sold by the Respondent adopts the same structure. The Respondent's sales records show that the model at issue is a product modified after October 2024, and the light-shielding module differs before and after the modification; the prototype purchased by the Plaintiff has not undergone disassembly appraisal, and all products cannot be found infringing on that basis.\\nFourth, the Respondent also raises a legitimate-source defense. Even if the court finds that some products fall within the scope of protection, the Respondent can submit the purchase contract, invoices, and payment vouchers signed with Lanxu Automation (Suzhou) Co., Ltd., proving that the relevant light-shielding module has a legitimate source, and the Respondent only engages in sales and did not know that it might infringe.\\nIn summary, the Plaintiff has failed to prove that the accused solution has all technical features of Claims 1 and 4, and its compensation claim lacks a basis in sales volume and profits. Please dismiss the claims in accordance with law.\\nRespectfully submitted to\\nDongzhou City Intermediate People's Court\\nRespondent: Qiyun Optical Instrument Co., Ltd.\\nApril 18, 2025\", \"document_type\": \"Answer\", \"disputed_facts\": \"{\\\"accused_product\\\": \\\"Qiyun Portable Spectrometer P-3\\\", \\\"accused_technical_solution\\\": \\\"The P-3 uses two rectangular light-shielding plates that translate relative to each other, each plate driven by an independent micro-motor and feeding back position through a motor encoder; the product is not provided with an annular light-shielding plate, a common transmission ring, or a pawl-and-toothed-disc mechanical locking assembly.\\\", \\\"relevant_technical_features\\\": [\\\"Shape and arrangement of the light-shielding plates\\\", \\\"Transmission mechanism driving movement of the light-shielding plates\\\", \\\"Whether the light-shielding plates open and close radially and synchronously\\\", \\\"Whether a pawl-and-toothed-disc mechanical locking assembly is provided\\\", \\\"Whether encoder position feedback is equivalent to mechanical locking\\\"], \\\"infringement_act\\\": \\\"The Plaintiff alleges that the Defendant's sale and offer for sale of the Qiyun Portable Spectrometer P-3 constitute infringement; the Defendant acknowledges the sales act but denies that the product falls within the scope of protection of the patent at issue.\\\", \\\"factual_disputes\\\": [\\\"Whether the two translation-type light-shielding plates of the P-3 belong to the annular light-shielding plate of Claim 1.\\\", \\\"Whether separate driving by independent motors is equivalent to driving the light-shielding plates to open and close radially and synchronously by the same transmission ring.\\\", \\\"Whether motor encoder feedback constitutes the pawl-and-toothed-disc mechanical locking described in Claim 4.\\\", \\\"Whether the structure of the prototype purchased by the Plaintiff can represent different batches and modified products of the Defendant.\\\", \\\"Whether the Defendant had reasonable grounds to know, when purchasing the light-shielding module, that it might infringe the patent.\\\"]}\", \"defense_reasons\": \"[{\\\"defense_type\\\": \\\"Non-infringement defense\\\", \\\"defense_content\\\": \\\"The Defendant argues that the P-3 lacks the annular light-shielding plate, common transmission ring, and radial synchronous opening\u002Fclosing structure defined by Claim 1, and also lacks the pawl-and-toothed-disc mechanical locking assembly defined by Claim 4.\\\", \\\"factual_basis\\\": [\\\"The P-3 uses two rectangular light-shielding plates and two independent micro-motors.\\\", \\\"The P-3 uses encoder position feedback and does not have a pawl and toothed disc.\\\", \\\"The light-shielding plates of the accused solution move in parallel directions.\\\"], \\\"legal_basis\\\": [\\\"Article 64 of the Patent Law of the People's Republic of China: The scope of protection is based on the content of the claims.\\\", \\\"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: If any technical feature recorded in the claims is lacking, the solution generally does not fall within the scope of protection.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 4\\\"]}, {\\\"defense_type\\\": \\\"Legitimate source defense\\\", \\\"defense_content\\\": \\\"The Defendant argues that even if the light-shielding module at issue is found to be a component of an infringing product, the Defendant can still prove that it was obtained through normal procurement channels and did not know that the module might infringe.\\\", \\\"factual_basis\\\": [\\\"The Defendant signed a written procurement contract with Lanxu Automation (Suzhou) Co., Ltd.\\\", \\\"The procurement invoice, payment records, and warehousing receipt corroborate each other.\\\", \\\"The supplier issued a product compliance statement at the time of transaction.\\\"], \\\"legal_basis\\\": [\\\"Article 77 of the Patent Law of the People's Republic of China: A person who, for production or business purposes, uses, offers for sale, or sells a patented infringing product without knowing that it was manufactured and sold without the patentee's permission, and can prove a legitimate source of the product, shall not bear compensation liability.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 4\\\"]}, {\\\"defense_type\\\": \\\"Defense against the amount of damages\\\", \\\"defense_content\\\": \\\"The Plaintiff has not proven the Defendant's actual sales volume, the profits of the infringing product, or its losses, and cannot directly infer the amount of compensation from the online listing price.\\\", \\\"factual_basis\\\": [\\\"The Plaintiff submits only one purchase order and webpage screenshots.\\\", \\\"The Defendant's sales records include multiple different versions before and after the modification.\\\"], \\\"legal_basis\\\": [\\\"Article 71 of the Patent Law of the People's Republic of China: The amount of patent infringement compensation shall be determined in light of factors such as the losses of the right holder and the profits of the infringer.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 4\\\"]}]\", \"party_positions\": \"[{\\\"party\\\": \\\"Yuancen Precision Measurement Co., Ltd.\\\", \\\"position_type\\\": \\\"Infringement assertion\\\", \\\"claim_content\\\": \\\"The P-3's dual light-shielding plate synchronous adjustment solution has the same function and effect as the patent at issue and is an equivalent technical solution to Claim 1; its encoder feedback is also equivalent to the locking feedback assembly of Claim 4.\\\", \\\"supporting_facts\\\": [\\\"The P-3 purchased by the Plaintiff can adjust the width of the incident slit.\\\", \\\"The two light-shielding plates can move synchronously under the control program.\\\", \\\"The product has a position feedback prompt.\\\"], \\\"requested_relief\\\": \\\"Request an order that the Defendant cease selling and offering for sale and compensate for losses.\\\"}, {\\\"party\\\": \\\"Qiyun Optical Instrument Co., Ltd.\\\", \\\"position_type\\\": \\\"Defense assertion\\\", \\\"claim_content\\\": \\\"The P-3 adopts a translation-type dual-plate and independent-motor structure and lacks an annular light-shielding plate, common transmission ring, pawl, and toothed disc, and does not fall within the scope of protection of Claims 1 and 4.\\\", \\\"supporting_facts\\\": [\\\"The product structure diagram shows two rectangular light-shielding plates and two independent motors.\\\", \\\"Prototype disassembly reveals no annular light-shielding plate or mechanical locking component.\\\", \\\"The modified product differs from the light-shielding module of the prototype purchased by the Plaintiff.\\\"], \\\"requested_relief\\\": \\\"Request dismissal of all of the Plaintiff's claims.\\\"}, {\\\"party\\\": \\\"Qiyun Optical Instrument Co., Ltd.\\\", \\\"position_type\\\": \\\"Legitimate source defense\\\", \\\"claim_content\\\": \\\"The light-shielding module at issue is supplied by Lanxu Automation (Suzhou) Co., Ltd., and the Defendant has complete procurement vouchers and no subjective fault of knowing infringement.\\\", \\\"supporting_facts\\\": [\\\"The Defendant submits the purchase contract, VAT invoice, and bank payment voucher.\\\", \\\"The Defendant engages in instrument sales and does not participate in the research, development, and manufacture of the light-shielding module.\\\"], \\\"requested_relief\\\": \\\"If the court finds infringement, please exempt or reduce the compensation liability in accordance with law.\\\"}]\", \"case_information\": \"{\\\"case_number\\\": \\\"(2025) Su 05 Zhi Min Chu No. 76\\\", \\\"court_name\\\": \\\"Dongzhou City Intermediate People's Court\\\", \\\"plaintiff\\\": \\\"Yuancen Precision Measurement Co., Ltd.\\\", \\\"defendant\\\": \\\"Qiyun Optical Instrument Co., Ltd.\\\", \\\"document_date\\\": \\\"April 18, 2025\\\", \\\"procedural_stage\\\": \\\"First-instance answer stage\\\"}\", \"document_summary\": \"This answer concerns the claim by Yuancen Precision Measurement Co., Ltd. that the P-3 portable spectrometer sold by Qiyun Optical Instrument Co., Ltd. infringes Claims 1 and 4. The Defendant acknowledges the sales act but argues that the P-3 uses two translation-type rectangular light-shielding plates, independent motors, and an electronic encoder, and lacks the annular light-shielding plate, common transmission ring, and pawl-and-toothed-disc mechanical locking assembly required by the patent, so no literal or equivalent infringement exists. The Defendant also raises legitimate source and damages amount defenses. The dispute focuses on whether the two light-shielding structures are equivalent, whether the prototype can represent all products, and whether the procurement vouchers are sufficient to prove a legitimate source.\", \"claim_comparisons\": \"[{\\\"claim_number\\\": \\\"Claim 1\\\", \\\"claim_text\\\": \\\"A portable spectral detector, comprising an annular light-shielding plate, a transmission ring, and an adjustment mechanism that drives the transmission ring to cause the annular light-shielding plate to open and close radially and synchronously.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"1-A\\\", \\\"element_text\\\": \\\"Provided with an annular light-shielding plate\\\", \\\"accused_corresponding_feature\\\": \\\"The P-3 is provided with two rectangular light-shielding plates that translate relative to each other.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The light-shielding plates of the accused product are two rectangular plates; they are neither annular components nor a combined structure forming an annular light-shielding plate.\\\"}, {\\\"element_label\\\": \\\"1-B\\\", \\\"element_text\\\": \\\"Provided with a transmission ring for driving the light-shielding plates\\\", \\\"accused_corresponding_feature\\\": \\\"The P-3 uses two independent micro-motors to drive the two light-shielding plates separately, and has no common transmission ring.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The product disassembly description and procurement drawings both show two independent motors and screw-rod transmission, and there is no common transmission ring as in the claim.\\\"}, {\\\"element_label\\\": \\\"1-C\\\", \\\"element_text\\\": \\\"The transmission ring causes the annular light-shielding plate to open and close radially and synchronously\\\", \\\"accused_corresponding_feature\\\": \\\"The two rectangular light-shielding plates move in relatively parallel directions, and the controller sends drive signals separately.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The movement trajectory, driving entity, and light-shielding manner are all different; relative movement of two plates is not equal to radial synchronous opening and closing of an annular light-shielding plate.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff argues that the two light-shielding plates of the P-3 combine to form a variable slit, and the two motors act synchronously under the same control program, and should be found to be an equivalent technical solution to the annular light-shielding plate and transmission ring.\\\", \\\"defendant_position\\\": \\\"The Defendant argues that the P-3 lacks the annular light-shielding plate and common transmission ring, adopts a translation-type dual-plate structure, and its technical means and movement mode differ from the claim, so no literal or equivalent infringement exists.\\\", \\\"overall_conclusion\\\": \\\"The existing answer materials support that the accused product at least lacks the two features of an annular light-shielding plate and a common transmission ring; the Plaintiff's equivalent infringement claim still needs to prove that the two structures have basically the same means, function, and effect.\\\"}, {\\\"claim_number\\\": \\\"Claim 4\\\", \\\"claim_text\\\": \\\"The spectral detector according to Claim 1, further comprising a mechanical locking and feedback assembly for the position of the light-shielding plate, formed by a pawl and a toothed disc.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"4-A\\\", \\\"element_text\\\": \\\"Provided with a mechanical locking assembly formed by a pawl and a toothed disc\\\", \\\"accused_corresponding_feature\\\": \\\"The P-3 has no pawl or toothed disc and uses only motor holding force and software limits.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The mechanical structure list and prototype disassembly reveal no pawl, toothed disc, or other engaging locking component.\\\"}, {\\\"element_label\\\": \\\"4-B\\\", \\\"element_text\\\": \\\"The mechanical locking assembly provides position feedback for the light-shielding plate\\\", \\\"accused_corresponding_feature\\\": \\\"The P-3 obtains the screw-rod position through a motor encoder and feeds it back to the controller.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"An encoder is electronic position detection and cannot be directly equated with the mechanical locking and feedback assembly implemented by a pawl and toothed disc; the two have different locking mechanisms.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff argues that the encoder can also determine the position of the light-shielding plate and prevent position errors, and therefore has an equivalent function to the pawl-and-toothed-disc assembly.\\\", \\\"defendant_position\\\": \\\"The Defendant argues that the encoder can only detect the rotational position of the motor and cannot mechanically lock the light-shielding plate upon power loss or external force, and its working principle and anti-vibration effect are different.\\\", \\\"overall_conclusion\\\": \\\"The accused product does not disclose the pawl-and-toothed-disc mechanical locking structure of Claim 4, and the correspondence of all features of Claim 4 cannot be established.\\\"}]\", \"patent_information\": \"{\\\"patent_number\\\": \\\"ZL202320987654.1\\\", \\\"patent_title\\\": \\\"A portable spectral detector with adjustable light-shielding structure\\\", \\\"patent_type\\\": \\\"Utility model patent\\\", \\\"priority_date\\\": \\\"March 6, 2023\\\", \\\"claims_involved\\\": [\\\"Claim 1: A portable spectral detector, comprising an annular light-shielding plate, a transmission ring, and an adjustment mechanism that drives the transmission ring to cause the annular light-shielding plate to open and close radially and synchronously.\\\", \\\"Claim 4: The spectral detector according to Claim 1, further comprising a mechanical locking and feedback assembly for the position of the light-shielding plate, formed by a pawl and a toothed disc.\\\"]}\", \"evidence_references\": \"[{\\\"evidence_label\\\": \\\"Evidence 1: Published patent text and claims of the patent at issue\\\", \\\"evidence_type\\\": \\\"Patent documents\\\", \\\"evidence_description\\\": \\\"Records the annular light-shielding plate, transmission ring, and radial synchronous opening\u002Fclosing structure of Claim 1, and the pawl-and-toothed-disc assembly of Claim 4.\\\", \\\"proof_purpose\\\": \\\"To clarify the technical features and scope of protection for infringement comparison.\\\", \\\"related_issue\\\": \\\"Scope of technical features of Claims 1 and 4\\\"}, {\\\"evidence_label\\\": \\\"Evidence 2: P-3 product structure diagram, disassembly photos, and modification statement\\\", \\\"evidence_type\\\": \\\"Technical materials\\\", \\\"evidence_description\\\": \\\"Shows that the P-3 uses two rectangular light-shielding plates, two independent motors, and an encoder, and has no pawl or toothed disc.\\\", \\\"proof_purpose\\\": \\\"To prove the actual technical structure of the accused product.\\\", \\\"related_issue\\\": \\\"Non-infringement defense and claim comparison\\\"}, {\\\"evidence_label\\\": \\\"Evidence 3: Light-shielding module procurement contract, invoice, and payment voucher\\\", \\\"evidence_type\\\": \\\"Contract and financial materials\\\", \\\"evidence_description\\\": \\\"Shows that the Defendant purchased the light-shielding module from Lanxu Automation (Suzhou) Co., Ltd. and paid the price.\\\", \\\"proof_purpose\\\": \\\"To prove the legitimate source of the accused product and the Defendant's good faith in the transaction.\\\", \\\"related_issue\\\": \\\"Legitimate source defense\\\"}]\", \"counterclaim_information\": \"{\\\"has_counterclaim\\\": false, \\\"counterclaim_type\\\": \\\"\\\", \\\"counterclaim_content\\\": \\\"\\\", \\\"counterclaim_requests\\\": [], \\\"counterclaim_facts\\\": []}\"}","[{\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 64\", \"legal_proposition\": \"The scope of protection of a utility model patent shall be based on the content of the claims, and the description and drawings are used to interpret the claims.\", \"cited_by\": \"Plaintiff and Defendant\", \"related_claim\": \"Determine whether the annular light-shielding plate, transmission ring, and mechanical locking assembly are essential technical features\"}, {\"law_name\": \"Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes\", \"article\": \"Article 7\", \"legal_proposition\": \"When determining whether an accused infringing technical solution falls within the scope of patent protection, the people's court shall examine all technical features recorded in the claims.\", \"cited_by\": \"Defendant\", \"related_claim\": \"Argue that the P-3 lacks essential technical features and does not constitute infringement\"}, {\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 77\", \"legal_proposition\": \"A person who can prove a legitimate source of a product and did not know that it was manufactured and sold without permission may not bear compensation liability.\", \"cited_by\": \"Defendant\", \"related_claim\": \"Raise a legitimate source defense and request exemption from compensation liability\"}]","Civil Answer\nCase No.: (2025) Su 05 Zhi Min Chu No. 76\nRespondent (Defendant): Qiyun Optical Instrument Co., Ltd.\nOpposing Party (Plaintiff): Yuancen Precision Measurement Co., Ltd.\nAnswer Requests: 1. Dismiss all of the Plaintiff's claims for cessation of infringement, compensation for losses, and bearing costs in accordance with law; 2. The litigation costs of this case shall be borne by the Plaintiff.\nFacts and Reasons: The Plaintiff relies on Utility Model Patent No. ZL202320987654.1, titled 'A portable spectral detector with adjustable light-shielding structure,' and alleges that the 'Qiyun Portable Spectrometer P-3' sold by the Respondent infringes its Claims 1 and 4. The Respondent does not accept this claim.\nFirst, the accused product does not have the annular light-shielding plate or the radial synchronous adjustment structure defined by Claim 1. Claim 1 requires the annular light-shielding plate to open and close radially and synchronously through the same transmission ring to change the incident slit; the P-3 uses two rectangular light-shielding plates that translate relative to each other, driven separately by independent micro-motors, move in parallel directions, cannot form an annular structure, and do not have the same transmission ring.\nSecond, the accused product does not have the locking feedback assembly described in Claim 4. The P-3 feeds back position through a motor encoder and does not have the pawl-and-toothed-disc mechanical locking structure required by Claim 4. Even if the Plaintiff interprets the encoder feedback as an equivalent technical feature, the two differ in structure, mode of operation, and fault-handling effect.\nThird, the webpage screenshots submitted by the Plaintiff cannot prove that every batch actually sold by the Respondent adopts the same structure. The Respondent's sales records show that the model at issue is a product modified after October 2024, and the light-shielding module differs before and after the modification; the prototype purchased by the Plaintiff has not undergone disassembly appraisal, and all products cannot be found infringing on that basis.\nFourth, the Respondent also raises a legitimate-source defense. Even if the court finds that some products fall within the scope of protection, the Respondent can submit the purchase contract, invoices, and payment vouchers signed with Lanxu Automation (Suzhou) Co., Ltd., proving that the relevant light-shielding module has a legitimate source, and the Respondent only engages in sales and did not know that it might infringe.\nIn summary, the Plaintiff has failed to prove that the accused solution has all technical features of Claims 1 and 4, and its compensation claim lacks a basis in sales volume and profits. Please dismiss the claims in accordance with law.\nRespectfully submitted to\nDongzhou City Intermediate People's Court\nRespondent: Qiyun Optical Instrument Co., Ltd.\nApril 18, 2025","Answer","{\"accused_product\": \"Qiyun Portable Spectrometer P-3\", \"accused_technical_solution\": \"The P-3 uses two rectangular light-shielding plates that translate relative to each other, each plate driven by an independent micro-motor and feeding back position through a motor encoder; the product is not provided with an annular light-shielding plate, a common transmission ring, or a pawl-and-toothed-disc mechanical locking assembly.\", \"relevant_technical_features\": [\"Shape and arrangement of the light-shielding plates\", \"Transmission mechanism driving movement of the light-shielding plates\", \"Whether the light-shielding plates open and close radially and synchronously\", \"Whether a pawl-and-toothed-disc mechanical locking assembly is provided\", \"Whether encoder position feedback is equivalent to mechanical locking\"], \"infringement_act\": \"The Plaintiff alleges that the Defendant's sale and offer for sale of the Qiyun Portable Spectrometer P-3 constitute infringement; the Defendant acknowledges the sales act but denies that the product falls within the scope of protection of the patent at issue.\", \"factual_disputes\": [\"Whether the two translation-type light-shielding plates of the P-3 belong to the annular light-shielding plate of Claim 1.\", \"Whether separate driving by independent motors is equivalent to driving the light-shielding plates to open and close radially and synchronously by the same transmission ring.\", \"Whether motor encoder feedback constitutes the pawl-and-toothed-disc mechanical locking described in Claim 4.\", \"Whether the structure of the prototype purchased by the Plaintiff can represent different batches and modified products of the Defendant.\", \"Whether the Defendant had reasonable grounds to know, when purchasing the light-shielding module, that it might infringe the patent.\"]}","[{\"defense_type\": \"Non-infringement defense\", \"defense_content\": \"The Defendant argues that the P-3 lacks the annular light-shielding plate, common transmission ring, and radial synchronous opening\u002Fclosing structure defined by Claim 1, and also lacks the pawl-and-toothed-disc mechanical locking assembly defined by Claim 4.\", \"factual_basis\": [\"The P-3 uses two rectangular light-shielding plates and two independent micro-motors.\", \"The P-3 uses encoder position feedback and does not have a pawl and toothed disc.\", \"The light-shielding plates of the accused solution move in parallel directions.\"], \"legal_basis\": [\"Article 64 of the Patent Law of the People's Republic of China: The scope of protection is based on the content of the claims.\", \"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: If any technical feature recorded in the claims is lacking, the solution generally does not fall within the scope of protection.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 4\"]}, {\"defense_type\": \"Legitimate source defense\", \"defense_content\": \"The Defendant argues that even if the light-shielding module at issue is found to be a component of an infringing product, the Defendant can still prove that it was obtained through normal procurement channels and did not know that the module might infringe.\", \"factual_basis\": [\"The Defendant signed a written procurement contract with Lanxu Automation (Suzhou) Co., Ltd.\", \"The procurement invoice, payment records, and warehousing receipt corroborate each other.\", \"The supplier issued a product compliance statement at the time of transaction.\"], \"legal_basis\": [\"Article 77 of the Patent Law of the People's Republic of China: A person who, for production or business purposes, uses, offers for sale, or sells a patented infringing product without knowing that it was manufactured and sold without the patentee's permission, and can prove a legitimate source of the product, shall not bear compensation liability.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 4\"]}, {\"defense_type\": \"Defense against the amount of damages\", \"defense_content\": \"The Plaintiff has not proven the Defendant's actual sales volume, the profits of the infringing product, or its losses, and cannot directly infer the amount of compensation from the online listing price.\", \"factual_basis\": [\"The Plaintiff submits only one purchase order and webpage screenshots.\", \"The Defendant's sales records include multiple different versions before and after the modification.\"], \"legal_basis\": [\"Article 71 of the Patent Law of the People's Republic of China: The amount of patent infringement compensation shall be determined in light of factors such as the losses of the right holder and the profits of the infringer.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 4\"]}]","[{\"party\": \"Yuancen Precision Measurement Co., Ltd.\", \"position_type\": \"Infringement assertion\", \"claim_content\": \"The P-3's dual light-shielding plate synchronous adjustment solution has the same function and effect as the patent at issue and is an equivalent technical solution to Claim 1; its encoder feedback is also equivalent to the locking feedback assembly of Claim 4.\", \"supporting_facts\": [\"The P-3 purchased by the Plaintiff can adjust the width of the incident slit.\", \"The two light-shielding plates can move synchronously under the control program.\", \"The product has a position feedback prompt.\"], \"requested_relief\": \"Request an order that the Defendant cease selling and offering for sale and compensate for losses.\"}, {\"party\": \"Qiyun Optical Instrument Co., Ltd.\", \"position_type\": \"Defense assertion\", \"claim_content\": \"The P-3 adopts a translation-type dual-plate and independent-motor structure and lacks an annular light-shielding plate, common transmission ring, pawl, and toothed disc, and does not fall within the scope of protection of Claims 1 and 4.\", \"supporting_facts\": [\"The product structure diagram shows two rectangular light-shielding plates and two independent motors.\", \"Prototype disassembly reveals no annular light-shielding plate or mechanical locking component.\", \"The modified product differs from the light-shielding module of the prototype purchased by the Plaintiff.\"], \"requested_relief\": \"Request dismissal of all of the Plaintiff's claims.\"}, {\"party\": \"Qiyun Optical Instrument Co., Ltd.\", \"position_type\": \"Legitimate source defense\", \"claim_content\": \"The light-shielding module at issue is supplied by Lanxu Automation (Suzhou) Co., Ltd., and the Defendant has complete procurement vouchers and no subjective fault of knowing infringement.\", \"supporting_facts\": [\"The Defendant submits the purchase contract, VAT invoice, and bank payment voucher.\", \"The Defendant engages in instrument sales and does not participate in the research, development, and manufacture of the light-shielding module.\"], \"requested_relief\": \"If the court finds infringement, please exempt or reduce the compensation liability in accordance with law.\"}]","{\"case_number\": \"(2025) Su 05 Zhi Min Chu No. 76\", \"court_name\": \"Dongzhou City Intermediate People's Court\", \"plaintiff\": \"Yuancen Precision Measurement Co., Ltd.\", \"defendant\": \"Qiyun Optical Instrument Co., Ltd.\", \"document_date\": \"April 18, 2025\", \"procedural_stage\": \"First-instance answer stage\"}","This answer concerns the claim by Yuancen Precision Measurement Co., Ltd. that the P-3 portable spectrometer sold by Qiyun Optical Instrument Co., Ltd. infringes Claims 1 and 4. The Defendant acknowledges the sales act but argues that the P-3 uses two translation-type rectangular light-shielding plates, independent motors, and an electronic encoder, and lacks the annular light-shielding plate, common transmission ring, and pawl-and-toothed-disc mechanical locking assembly required by the patent, so no literal or equivalent infringement exists. The Defendant also raises legitimate source and damages amount defenses. The dispute focuses on whether the two light-shielding structures are equivalent, whether the prototype can represent all products, and whether the procurement vouchers are sufficient to prove a legitimate source.","[{\"claim_number\": \"Claim 1\", \"claim_text\": \"A portable spectral detector, comprising an annular light-shielding plate, a transmission ring, and an adjustment mechanism that drives the transmission ring to cause the annular light-shielding plate to open and close radially and synchronously.\", \"claim_elements\": [{\"element_label\": \"1-A\", \"element_text\": \"Provided with an annular light-shielding plate\", \"accused_corresponding_feature\": \"The P-3 is provided with two rectangular light-shielding plates that translate relative to each other.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The light-shielding plates of the accused product are two rectangular plates; they are neither annular components nor a combined structure forming an annular light-shielding plate.\"}, {\"element_label\": \"1-B\", \"element_text\": \"Provided with a transmission ring for driving the light-shielding plates\", \"accused_corresponding_feature\": \"The P-3 uses two independent micro-motors to drive the two light-shielding plates separately, and has no common transmission ring.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The product disassembly description and procurement drawings both show two independent motors and screw-rod transmission, and there is no common transmission ring as in the claim.\"}, {\"element_label\": \"1-C\", \"element_text\": \"The transmission ring causes the annular light-shielding plate to open and close radially and synchronously\", \"accused_corresponding_feature\": \"The two rectangular light-shielding plates move in relatively parallel directions, and the controller sends drive signals separately.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The movement trajectory, driving entity, and light-shielding manner are all different; relative movement of two plates is not equal to radial synchronous opening and closing of an annular light-shielding plate.\"}], \"plaintiff_position\": \"The Plaintiff argues that the two light-shielding plates of the P-3 combine to form a variable slit, and the two motors act synchronously under the same control program, and should be found to be an equivalent technical solution to the annular light-shielding plate and transmission ring.\", \"defendant_position\": \"The Defendant argues that the P-3 lacks the annular light-shielding plate and common transmission ring, adopts a translation-type dual-plate structure, and its technical means and movement mode differ from the claim, so no literal or equivalent infringement exists.\", \"overall_conclusion\": \"The existing answer materials support that the accused product at least lacks the two features of an annular light-shielding plate and a common transmission ring; the Plaintiff's equivalent infringement claim still needs to prove that the two structures have basically the same means, function, and effect.\"}, {\"claim_number\": \"Claim 4\", \"claim_text\": \"The spectral detector according to Claim 1, further comprising a mechanical locking and feedback assembly for the position of the light-shielding plate, formed by a pawl and a toothed disc.\", \"claim_elements\": [{\"element_label\": \"4-A\", \"element_text\": \"Provided with a mechanical locking assembly formed by a pawl and a toothed disc\", \"accused_corresponding_feature\": \"The P-3 has no pawl or toothed disc and uses only motor holding force and software limits.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"The mechanical structure list and prototype disassembly reveal no pawl, toothed disc, or other engaging locking component.\"}, {\"element_label\": \"4-B\", \"element_text\": \"The mechanical locking assembly provides position feedback for the light-shielding plate\", \"accused_corresponding_feature\": \"The P-3 obtains the screw-rod position through a motor encoder and feeds it back to the controller.\", \"comparison_result\": \"Different\", \"comparison_reason\": \"An encoder is electronic position detection and cannot be directly equated with the mechanical locking and feedback assembly implemented by a pawl and toothed disc; the two have different locking mechanisms.\"}], \"plaintiff_position\": \"The Plaintiff argues that the encoder can also determine the position of the light-shielding plate and prevent position errors, and therefore has an equivalent function to the pawl-and-toothed-disc assembly.\", \"defendant_position\": \"The Defendant argues that the encoder can only detect the rotational position of the motor and cannot mechanically lock the light-shielding plate upon power loss or external force, and its working principle and anti-vibration effect are different.\", \"overall_conclusion\": \"The accused product does not disclose the pawl-and-toothed-disc mechanical locking structure of Claim 4, and the correspondence of all features of Claim 4 cannot be established.\"}]","{\"patent_number\": \"ZL202320987654.1\", \"patent_title\": \"A portable spectral detector with adjustable light-shielding structure\", \"patent_type\": \"Utility model patent\", \"priority_date\": \"March 6, 2023\", \"claims_involved\": [\"Claim 1: A portable spectral detector, comprising an annular light-shielding plate, a transmission ring, and an adjustment mechanism that drives the transmission ring to cause the annular light-shielding plate to open and close radially and synchronously.\", \"Claim 4: The spectral detector according to Claim 1, further comprising a mechanical locking and feedback assembly for the position of the light-shielding plate, formed by a pawl and a toothed disc.\"]}","[{\"evidence_label\": \"Evidence 1: Published patent text and claims of the patent at issue\", \"evidence_type\": \"Patent documents\", \"evidence_description\": \"Records the annular light-shielding plate, transmission ring, and radial synchronous opening\u002Fclosing structure of Claim 1, and the pawl-and-toothed-disc assembly of Claim 4.\", \"proof_purpose\": \"To clarify the technical features and scope of protection for infringement comparison.\", \"related_issue\": \"Scope of technical features of Claims 1 and 4\"}, {\"evidence_label\": \"Evidence 2: P-3 product structure diagram, disassembly photos, and modification statement\", \"evidence_type\": \"Technical materials\", \"evidence_description\": \"Shows that the P-3 uses two rectangular light-shielding plates, two independent motors, and an encoder, and has no pawl or toothed disc.\", \"proof_purpose\": \"To prove the actual technical structure of the accused product.\", \"related_issue\": \"Non-infringement defense and claim comparison\"}, {\"evidence_label\": \"Evidence 3: Light-shielding module procurement contract, invoice, and payment voucher\", \"evidence_type\": \"Contract and financial materials\", \"evidence_description\": \"Shows that the Defendant purchased the light-shielding module from Lanxu Automation (Suzhou) Co., Ltd. and paid the price.\", \"proof_purpose\": \"To prove the legitimate source of the accused product and the Defendant's good faith in the transaction.\", \"related_issue\": \"Legitimate source defense\"}]","{\"has_counterclaim\": false, \"counterclaim_type\": \"\", \"counterclaim_content\": \"\", \"counterclaim_requests\": [], \"counterclaim_facts\": []}",{"id":706,"relate_table":670,"relate_id":707,"file_size":572,"file_name":708,"path":8,"duration":572,"cate":483,"file_format":673,"audio_rate":8,"audio_channel":522,"audio_bit_depth":522,"quality":8,"annotation":709,"cate_name":675,"legal_basis":710,"document_text":711,"document_type":712,"disputed_facts":713,"defense_reasons":714,"party_positions":715,"case_information":716,"document_summary":717,"claim_comparisons":718,"patent_information":719,"evidence_references":720,"counterclaim_information":704},15169,2080285468,"样例_1.json","{\"legal_basis\": \"[{\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 11\\\", \\\"legal_proposition\\\": \\\"After an invention or utility model patent is granted, without the permission of the patentee, no one may manufacture, use, offer for sale, sell, or import the patented product for production or business purposes.\\\", \\\"cited_by\\\": \\\"Plaintiff\\\", \\\"related_claim\\\": \\\"The Defendant's manufacture, sale, and offer for sale of the accused energy storage cabinet constitute infringement\\\"}, {\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 64\\\", \\\"legal_proposition\\\": \\\"The scope of protection of an invention or utility model patent shall be based on the content of its claims, and the description and drawings may be used to interpret the claims.\\\", \\\"cited_by\\\": \\\"Plaintiff and Defendant\\\", \\\"related_claim\\\": \\\"Determine the scope of protection of Claims 1 and 8 and conduct technical feature comparison\\\"}, {\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 71\\\", \\\"legal_proposition\\\": \\\"The amount of compensation for patent infringement shall be determined based on factors such as the losses of the right holder, the profits of the infringer, or a reasonable royalty.\\\", \\\"cited_by\\\": \\\"Plaintiff\\\", \\\"related_claim\\\": \\\"Request compensation for economic losses and reasonable rights-protection expenses\\\"}]\", \"document_text\": \"Civil Complaint\\nCase No.: (2025) Yue 03 Zhi Min Chu No. 118\\nPlaintiff: Chengming Energy Storage Technology Co., Ltd.\\nDefendant: Obsidian Power Equipment Co., Ltd.\\nClaims: 1. Order the Defendant to immediately cease manufacturing, selling, and offering for sale the 'Obsidian Liquid-Cooled Energy Storage Cabinet S-600' that falls within the scope of protection of Claims 1 and 8 of Invention Patent No. ZL202210456789.3; 2. Order the Defendant to compensate the Plaintiff for economic losses and reasonable rights-protection expenses totaling RMB 1,800,000; 3. Order the Defendant to bear the litigation costs of this case.\\nFacts and Reasons: The Plaintiff is the patentee of Invention Patent No. ZL202210456789.3, titled 'An energy storage cabinet with zoned liquid cooling and fault bypass functions.' The patent application date is June 17, 2022, the priority date is April 8, 2022, and it is currently valid. Claim 1 requires the energy storage cabinet to include battery modules, zoned liquid-cooling circuits, temperature sensors corresponding to each zone, and a controller that, based on a temperature threshold, shuts down an abnormal zone and maintains operation of the remaining zones; Claim 8 further defines that after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\\nIn February 2025, the Plaintiff obtained the accused product from Obsidian Company's direct-sale online store and at an exhibition in Nanshan District, Shenzhen. The accused product uses six battery compartments, six cooling branches, a temperature sensor in each compartment, and a central controller; when the temperature of a battery compartment exceeds a set threshold, the controller shuts down that compartment's cooling branch and power output, while keeping other battery compartments running, and displays the faulty compartment number on the screen. The Plaintiff submits that the above structure and control logic correspond one by one to the technical features of Claims 1 and 8.\\nIn a pre-trial letter, the Defendant stated that its product uses an 'independent safety control strategy' and does not fall within the patented solution, and also stated that the Plaintiff has not proven actual sales volume. The Plaintiff submits that differences in control module names and circuit layout do not affect the fact that the product implements the same zoned bypass function; the Defendant's public display, sales, and offers for sale have already constituted infringement.\\nAccordingly, pursuant to the Patent Law of the People's Republic of China and relevant judicial interpretations, the Plaintiff files this lawsuit and requests that the court support all of the Plaintiff's claims in accordance with law.\\nRespectfully submitted to\\nNanshan City Intermediate People's Court\\nPlaintiff: Chengming Energy Storage Technology Co., Ltd.\\nMarch 12, 2025\", \"document_type\": \"Complaint\", \"disputed_facts\": \"{\\\"accused_product\\\": \\\"Obsidian Liquid-Cooled Energy Storage Cabinet S-600\\\", \\\"accused_technical_solution\\\": \\\"The accused energy storage cabinet is provided with six independent battery compartments, six cooling branches, and corresponding temperature sensors, and a central controller continuously collects the temperature of each compartment; when any battery compartment exceeds the threshold, the controller shuts down that compartment's cooling branch and power output, keeps other battery compartments running, and displays the faulty compartment number on the screen.\\\", \\\"relevant_technical_features\\\": [\\\"Multiple mutually zoned battery modules or battery compartments\\\", \\\"Liquid-cooling circuits and temperature sensors respectively corresponding to each zone\\\", \\\"Controller shuts down the abnormal zone and maintains operation of other zones based on a temperature threshold\\\", \\\"After bypassing the abnormal zone, generates a maintenance alarm and saves the faulty zone number\\\"], \\\"infringement_act\\\": \\\"The Defendant manufactured, sold, and offered for sale the Obsidian Liquid-Cooled Energy Storage Cabinet S-600 through its direct-sale online store and at exhibitions.\\\", \\\"factual_disputes\\\": [\\\"Whether the accused product has independent liquid-cooling branches corresponding to each battery compartment.\\\", \\\"Whether the accused controller performs abnormal-zone bypass based on zoned temperature thresholds.\\\", \\\"Whether the function of displaying the faulty compartment number on the accused product constitutes the maintenance alarm and number saving described in Claim 8.\\\", \\\"Whether the display in the Defendant's direct-sale online store and the exhibition prototype are sufficient to prove sales or offers for sale.\\\"]}\", \"defense_reasons\": \"[{\\\"defense_type\\\": \\\"Non-infringement defense\\\", \\\"defense_content\\\": \\\"The Defendant argues that the accused product does not operate according to the zoned liquid cooling and abnormal-zone bypass solution of the patent at issue, and at least lacks the corresponding technical features of Claim 1.\\\", \\\"factual_basis\\\": [\\\"The Defendant states that its temperature sensor detects the overall temperature of the battery compartment rather than the battery module temperature.\\\", \\\"The Defendant states that in an abnormal situation it only cuts off power output and does not shut down the corresponding liquid-cooling circuit.\\\"], \\\"legal_basis\\\": [\\\"Article 11 of the Patent Law of the People's Republic of China: After a patent is granted, no entity or individual may exploit the patent without permission; whether infringement exists should be judged on whether the accused solution falls within the scope of protection of the claims.\\\", \\\"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: The people's court shall determine the scope of patent protection based on all technical features recorded in the claims.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 8\\\"]}, {\\\"defense_type\\\": \\\"Defense against the amount of damages\\\", \\\"defense_content\\\": \\\"The Defendant argues that the Plaintiff has not proven the Defendant's actual sales volume, per-unit profit, or the Plaintiff's losses, and the claim for RMB 1,800,000 in damages lacks a calculation basis.\\\", \\\"factual_basis\\\": [\\\"The Plaintiff currently submits only one prototype purchase record and webpage screenshots.\\\", \\\"The Defendant argues that an exhibition prototype does not equal completed mass sales.\\\"], \\\"legal_basis\\\": [\\\"Article 71 of the Patent Law of the People's Republic of China: The amount of damages shall be determined based on factors such as the losses of the right holder, the profits of the infringer, or a multiple of a reasonable royalty.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 8\\\"]}]\", \"party_positions\": \"[{\\\"party\\\": \\\"Chengming Energy Storage Technology Co., Ltd.\\\", \\\"position_type\\\": \\\"Ownership factual assertion\\\", \\\"claim_content\\\": \\\"The Plaintiff is the patentee of the invention patent at issue, the patent is currently valid, and the Plaintiff has the right to file an infringement lawsuit in accordance with law.\\\", \\\"supporting_facts\\\": [\\\"The patent certificate and register at issue record the Plaintiff as patentee.\\\", \\\"The annual fee for the patent at issue has been paid, and there is no record of termination of rights.\\\"], \\\"requested_relief\\\": \\\"Confirm that the Plaintiff enjoys the patent right at issue and adjudicate tort liability on that basis.\\\"}, {\\\"party\\\": \\\"Chengming Energy Storage Technology Co., Ltd.\\\", \\\"position_type\\\": \\\"Infringement assertion\\\", \\\"claim_content\\\": \\\"The accused product fully covers the technical features of Claims 1 and 8, and the Defendant's manufacturing, selling, and offering for sale constitute patent infringement.\\\", \\\"supporting_facts\\\": [\\\"The accused product prototype has six zoned battery compartments and corresponding liquid-cooling branches.\\\", \\\"The accused controller can bypass an abnormal zone and record the faulty compartment number.\\\", \\\"The Defendant's direct-sale online store and exhibition publicly displayed and offered the product for sale with quotations.\\\"], \\\"requested_relief\\\": \\\"Order the Defendant to cease manufacturing, selling, and offering for sale the accused product.\\\"}, {\\\"party\\\": \\\"Obsidian Power Equipment Co., Ltd.\\\", \\\"position_type\\\": \\\"Defense assertion\\\", \\\"claim_content\\\": \\\"The control strategy and liquid-cooling circuit of the accused product differ from the claims at issue, and the Plaintiff has not proven that the accused product falls within the scope of patent protection.\\\", \\\"supporting_facts\\\": [\\\"The Defendant's letter states that it adopts an independent safety control strategy.\\\", \\\"The Defendant denies having disclosed the complete control program and sales volume.\\\"], \\\"requested_relief\\\": \\\"Dismiss the Plaintiff's infringement and compensation claims.\\\"}]\", \"case_information\": \"{\\\"case_number\\\": \\\"(2025) Yue 03 Zhi Min Chu No. 118\\\", \\\"court_name\\\": \\\"Nanshan City Intermediate People's Court\\\", \\\"plaintiff\\\": \\\"Chengming Energy Storage Technology Co., Ltd.\\\", \\\"defendant\\\": \\\"Obsidian Power Equipment Co., Ltd.\\\", \\\"document_date\\\": \\\"March 12, 2025\\\", \\\"procedural_stage\\\": \\\"First-instance complaint stage\\\"}\", \"document_summary\": \"This case is a first-instance invention patent infringement action brought by Chengming Energy Storage Technology Co., Ltd. against Obsidian Power Equipment Co., Ltd. The Plaintiff alleges that the accused S-600 liquid-cooled energy storage cabinet adopts the same zoned liquid cooling, temperature detection, abnormal-zone bypass, and fault number recording solution as Claims 1 and 8 of the patent at issue, and requests cessation of infringement and compensation of RMB 1,800,000. The Defendant raises non-infringement and damages amount defenses. The dispute focuses on whether the accused product has independent zoned liquid-cooling circuits, abnormal bypass control, and the alarm recording function described in Claim 8, as well as the Defendant's actual sales scale.\", \"claim_comparisons\": \"[{\\\"claim_number\\\": \\\"Claim 1\\\", \\\"claim_text\\\": \\\"An energy storage cabinet, comprising multiple battery modules, zoned liquid-cooling circuits that provide cooling to each battery module respectively, temperature sensors corresponding to each battery module, and a controller that, based on a temperature threshold, shuts down an abnormal zone and keeps other zones running.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"1-A\\\", \\\"element_text\\\": \\\"The energy storage cabinet comprises multiple battery modules\\\", \\\"accused_corresponding_feature\\\": \\\"The S-600 is provided with six independent battery compartments, and each battery compartment contains a battery module.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The product structure description and prototype photos both show that the accused energy storage cabinet is composed of multiple independent battery compartments, which corresponds to multiple battery modules.\\\"}, {\\\"element_label\\\": \\\"1-B\\\", \\\"element_text\\\": \\\"Zoned liquid-cooling circuits that provide cooling to each battery module respectively\\\", \\\"accused_corresponding_feature\\\": \\\"The S-600 is provided with six cooling branches, respectively connected to six battery compartments.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The six cooling branches of the accused solution correspond one-to-one to the six battery compartments, and functionally provide liquid cooling to each zone respectively.\\\"}, {\\\"element_label\\\": \\\"1-C\\\", \\\"element_text\\\": \\\"Temperature sensors corresponding to each battery module\\\", \\\"accused_corresponding_feature\\\": \\\"Each battery compartment is equipped with a temperature sensor and sends temperature data to the central controller.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The technical manual of the accused product lists one temperature collection point per compartment, satisfying the zoned temperature detection relationship.\\\"}, {\\\"element_label\\\": \\\"1-D\\\", \\\"element_text\\\": \\\"The controller shuts down an abnormal zone and keeps other zones running based on a temperature threshold\\\", \\\"accused_corresponding_feature\\\": \\\"When the central controller detects that the temperature of a compartment exceeds the threshold, it shuts down that compartment's cooling branch and power output, while maintaining operation of other battery compartments.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The accused control logic has the same technical means and function as the abnormal-zone bypass and continued operation of the remaining zones required by the claim.\\\"}], \\\"plaintiff_position\\\": \\\"All technical features of Claim 1 appear directly and completely in the accused product, and the accused product falls within the scope of protection of Claim 1.\\\", \\\"defendant_position\\\": \\\"The Defendant argues that it adopts an independent safety control strategy, that the temperature sensor collects the overall temperature of the battery compartment, and that what is shut down is power output rather than the liquid-cooling circuit, so it at least lacks the zoned bypass feature of Claim 1.\\\", \\\"overall_conclusion\\\": \\\"The Plaintiff claims that all features are the same and that literal infringement exists; the Defendant denies the correspondence of zoned liquid cooling and bypass control, and the infringement conclusion remains to be determined in light of the physical product, control program, and technical appraisal.\\\"}, {\\\"claim_number\\\": \\\"Claim 8\\\", \\\"claim_text\\\": \\\"The energy storage cabinet according to Claim 1, wherein after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"8-A\\\", \\\"element_text\\\": \\\"After an abnormal zone is bypassed, generates a maintenance alarm\\\", \\\"accused_corresponding_feature\\\": \\\"After an abnormal battery compartment stops running, the S-600 pops up a 'battery compartment maintenance' alarm on the display.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The maintenance alarm displayed on the accused product's interface occurs after the abnormal compartment stops running, and its timing and function are consistent with Claim 8.\\\"}, {\\\"element_label\\\": \\\"8-B\\\", \\\"element_text\\\": \\\"Saves the abnormal zone number\\\", \\\"accused_corresponding_feature\\\": \\\"The controller records the faulty compartment number, occurrence time, and reset status in the operation log.\\\", \\\"comparison_result\\\": \\\"Same\\\", \\\"comparison_reason\\\": \\\"The accused operation log contains the faulty compartment number and can be used for subsequent maintenance locating, satisfying the limitation of saving the abnormal zone number.\\\"}], \\\"plaintiff_position\\\": \\\"The additional features of Claim 8 have corresponding manifestations in the accused product's displayed alarm and operation log, so the accused product also falls within the scope of protection of Claim 8.\\\", \\\"defendant_position\\\": \\\"The Defendant states that the maintenance prompt on the display is merely a general fault prompt, and the log record is also a safety monitoring record, and does not have the post-bypass alarm function defined by the patent claim.\\\", \\\"overall_conclusion\\\": \\\"The existing documents support a correspondence with the additional features of Claim 8, but the Defendant raises substantive objections to the alarm trigger timing and log function.\\\"}]\", \"patent_information\": \"{\\\"patent_number\\\": \\\"ZL202210456789.3\\\", \\\"patent_title\\\": \\\"An energy storage cabinet with zoned liquid cooling and fault bypass functions\\\", \\\"patent_type\\\": \\\"Invention patent\\\", \\\"priority_date\\\": \\\"April 8, 2022\\\", \\\"claims_involved\\\": [\\\"Claim 1: An energy storage cabinet, comprising multiple battery modules, zoned liquid-cooling circuits that provide cooling to each battery module respectively, temperature sensors corresponding to each battery module, and a controller that, based on a temperature threshold, shuts down an abnormal zone and keeps other zones running.\\\", \\\"Claim 8: The energy storage cabinet according to Claim 1, wherein after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\\\"]}\", \"evidence_references\": \"[{\\\"evidence_label\\\": \\\"Evidence 1: Patent certificate and copy of patent register for the patent at issue\\\", \\\"evidence_type\\\": \\\"Patent documents\\\", \\\"evidence_description\\\": \\\"Records the patent number, invention title, patentee, and valid status of the patent.\\\", \\\"proof_purpose\\\": \\\"To prove the Plaintiff's standing as patentee and the status of the right.\\\", \\\"related_issue\\\": \\\"Patent ownership and validity\\\"}, {\\\"evidence_label\\\": \\\"Evidence 2: Purchase record and on-site photos of the S-600 prototype\\\", \\\"evidence_type\\\": \\\"Physical evidence and transaction materials\\\", \\\"evidence_description\\\": \\\"Shows the six battery compartments, zoned cooling interfaces, and display alarm interface of the accused energy storage cabinet.\\\", \\\"proof_purpose\\\": \\\"To prove the structure, control interface, and purchase source of the accused product.\\\", \\\"related_issue\\\": \\\"Infringement comparison for Claims 1 and 8\\\"}, {\\\"evidence_label\\\": \\\"Evidence 3: Defendant's direct-sale online store pages and exhibition brochure\\\", \\\"evidence_type\\\": \\\"Electronic data and promotional materials\\\", \\\"evidence_description\\\": \\\"Contains the S-600 product name, technical parameters, sales contact information, and introduction to the zoned fault isolation function.\\\", \\\"proof_purpose\\\": \\\"To prove that the Defendant engaged in selling and offering for sale.\\\", \\\"related_issue\\\": \\\"Accused infringing acts\\\"}]\", \"counterclaim_information\": \"{\\\"has_counterclaim\\\": false, \\\"counterclaim_type\\\": \\\"\\\", \\\"counterclaim_content\\\": \\\"\\\", \\\"counterclaim_requests\\\": [], \\\"counterclaim_facts\\\": []}\"}","[{\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 11\", \"legal_proposition\": \"After an invention or utility model patent is granted, without the permission of the patentee, no one may manufacture, use, offer for sale, sell, or import the patented product for production or business purposes.\", \"cited_by\": \"Plaintiff\", \"related_claim\": \"The Defendant's manufacture, sale, and offer for sale of the accused energy storage cabinet constitute infringement\"}, {\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 64\", \"legal_proposition\": \"The scope of protection of an invention or utility model patent shall be based on the content of its claims, and the description and drawings may be used to interpret the claims.\", \"cited_by\": \"Plaintiff and Defendant\", \"related_claim\": \"Determine the scope of protection of Claims 1 and 8 and conduct technical feature comparison\"}, {\"law_name\": \"Patent Law of the People's Republic of China\", \"article\": \"Article 71\", \"legal_proposition\": \"The amount of compensation for patent infringement shall be determined based on factors such as the losses of the right holder, the profits of the infringer, or a reasonable royalty.\", \"cited_by\": \"Plaintiff\", \"related_claim\": \"Request compensation for economic losses and reasonable rights-protection expenses\"}]","Civil Complaint\nCase No.: (2025) Yue 03 Zhi Min Chu No. 118\nPlaintiff: Chengming Energy Storage Technology Co., Ltd.\nDefendant: Obsidian Power Equipment Co., Ltd.\nClaims: 1. Order the Defendant to immediately cease manufacturing, selling, and offering for sale the 'Obsidian Liquid-Cooled Energy Storage Cabinet S-600' that falls within the scope of protection of Claims 1 and 8 of Invention Patent No. ZL202210456789.3; 2. Order the Defendant to compensate the Plaintiff for economic losses and reasonable rights-protection expenses totaling RMB 1,800,000; 3. Order the Defendant to bear the litigation costs of this case.\nFacts and Reasons: The Plaintiff is the patentee of Invention Patent No. ZL202210456789.3, titled 'An energy storage cabinet with zoned liquid cooling and fault bypass functions.' The patent application date is June 17, 2022, the priority date is April 8, 2022, and it is currently valid. Claim 1 requires the energy storage cabinet to include battery modules, zoned liquid-cooling circuits, temperature sensors corresponding to each zone, and a controller that, based on a temperature threshold, shuts down an abnormal zone and maintains operation of the remaining zones; Claim 8 further defines that after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\nIn February 2025, the Plaintiff obtained the accused product from Obsidian Company's direct-sale online store and at an exhibition in Nanshan District, Shenzhen. The accused product uses six battery compartments, six cooling branches, a temperature sensor in each compartment, and a central controller; when the temperature of a battery compartment exceeds a set threshold, the controller shuts down that compartment's cooling branch and power output, while keeping other battery compartments running, and displays the faulty compartment number on the screen. The Plaintiff submits that the above structure and control logic correspond one by one to the technical features of Claims 1 and 8.\nIn a pre-trial letter, the Defendant stated that its product uses an 'independent safety control strategy' and does not fall within the patented solution, and also stated that the Plaintiff has not proven actual sales volume. The Plaintiff submits that differences in control module names and circuit layout do not affect the fact that the product implements the same zoned bypass function; the Defendant's public display, sales, and offers for sale have already constituted infringement.\nAccordingly, pursuant to the Patent Law of the People's Republic of China and relevant judicial interpretations, the Plaintiff files this lawsuit and requests that the court support all of the Plaintiff's claims in accordance with law.\nRespectfully submitted to\nNanshan City Intermediate People's Court\nPlaintiff: Chengming Energy Storage Technology Co., Ltd.\nMarch 12, 2025","Complaint","{\"accused_product\": \"Obsidian Liquid-Cooled Energy Storage Cabinet S-600\", \"accused_technical_solution\": \"The accused energy storage cabinet is provided with six independent battery compartments, six cooling branches, and corresponding temperature sensors, and a central controller continuously collects the temperature of each compartment; when any battery compartment exceeds the threshold, the controller shuts down that compartment's cooling branch and power output, keeps other battery compartments running, and displays the faulty compartment number on the screen.\", \"relevant_technical_features\": [\"Multiple mutually zoned battery modules or battery compartments\", \"Liquid-cooling circuits and temperature sensors respectively corresponding to each zone\", \"Controller shuts down the abnormal zone and maintains operation of other zones based on a temperature threshold\", \"After bypassing the abnormal zone, generates a maintenance alarm and saves the faulty zone number\"], \"infringement_act\": \"The Defendant manufactured, sold, and offered for sale the Obsidian Liquid-Cooled Energy Storage Cabinet S-600 through its direct-sale online store and at exhibitions.\", \"factual_disputes\": [\"Whether the accused product has independent liquid-cooling branches corresponding to each battery compartment.\", \"Whether the accused controller performs abnormal-zone bypass based on zoned temperature thresholds.\", \"Whether the function of displaying the faulty compartment number on the accused product constitutes the maintenance alarm and number saving described in Claim 8.\", \"Whether the display in the Defendant's direct-sale online store and the exhibition prototype are sufficient to prove sales or offers for sale.\"]}","[{\"defense_type\": \"Non-infringement defense\", \"defense_content\": \"The Defendant argues that the accused product does not operate according to the zoned liquid cooling and abnormal-zone bypass solution of the patent at issue, and at least lacks the corresponding technical features of Claim 1.\", \"factual_basis\": [\"The Defendant states that its temperature sensor detects the overall temperature of the battery compartment rather than the battery module temperature.\", \"The Defendant states that in an abnormal situation it only cuts off power output and does not shut down the corresponding liquid-cooling circuit.\"], \"legal_basis\": [\"Article 11 of the Patent Law of the People's Republic of China: After a patent is granted, no entity or individual may exploit the patent without permission; whether infringement exists should be judged on whether the accused solution falls within the scope of protection of the claims.\", \"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: The people's court shall determine the scope of patent protection based on all technical features recorded in the claims.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 8\"]}, {\"defense_type\": \"Defense against the amount of damages\", \"defense_content\": \"The Defendant argues that the Plaintiff has not proven the Defendant's actual sales volume, per-unit profit, or the Plaintiff's losses, and the claim for RMB 1,800,000 in damages lacks a calculation basis.\", \"factual_basis\": [\"The Plaintiff currently submits only one prototype purchase record and webpage screenshots.\", \"The Defendant argues that an exhibition prototype does not equal completed mass sales.\"], \"legal_basis\": [\"Article 71 of the Patent Law of the People's Republic of China: The amount of damages shall be determined based on factors such as the losses of the right holder, the profits of the infringer, or a multiple of a reasonable royalty.\"], \"targeted_claims\": [\"Claim 1\", \"Claim 8\"]}]","[{\"party\": \"Chengming Energy Storage Technology Co., Ltd.\", \"position_type\": \"Ownership factual assertion\", \"claim_content\": \"The Plaintiff is the patentee of the invention patent at issue, the patent is currently valid, and the Plaintiff has the right to file an infringement lawsuit in accordance with law.\", \"supporting_facts\": [\"The patent certificate and register at issue record the Plaintiff as patentee.\", \"The annual fee for the patent at issue has been paid, and there is no record of termination of rights.\"], \"requested_relief\": \"Confirm that the Plaintiff enjoys the patent right at issue and adjudicate tort liability on that basis.\"}, {\"party\": \"Chengming Energy Storage Technology Co., Ltd.\", \"position_type\": \"Infringement assertion\", \"claim_content\": \"The accused product fully covers the technical features of Claims 1 and 8, and the Defendant's manufacturing, selling, and offering for sale constitute patent infringement.\", \"supporting_facts\": [\"The accused product prototype has six zoned battery compartments and corresponding liquid-cooling branches.\", \"The accused controller can bypass an abnormal zone and record the faulty compartment number.\", \"The Defendant's direct-sale online store and exhibition publicly displayed and offered the product for sale with quotations.\"], \"requested_relief\": \"Order the Defendant to cease manufacturing, selling, and offering for sale the accused product.\"}, {\"party\": \"Obsidian Power Equipment Co., Ltd.\", \"position_type\": \"Defense assertion\", \"claim_content\": \"The control strategy and liquid-cooling circuit of the accused product differ from the claims at issue, and the Plaintiff has not proven that the accused product falls within the scope of patent protection.\", \"supporting_facts\": [\"The Defendant's letter states that it adopts an independent safety control strategy.\", \"The Defendant denies having disclosed the complete control program and sales volume.\"], \"requested_relief\": \"Dismiss the Plaintiff's infringement and compensation claims.\"}]","{\"case_number\": \"(2025) Yue 03 Zhi Min Chu No. 118\", \"court_name\": \"Nanshan City Intermediate People's Court\", \"plaintiff\": \"Chengming Energy Storage Technology Co., Ltd.\", \"defendant\": \"Obsidian Power Equipment Co., Ltd.\", \"document_date\": \"March 12, 2025\", \"procedural_stage\": \"First-instance complaint stage\"}","This case is a first-instance invention patent infringement action brought by Chengming Energy Storage Technology Co., Ltd. against Obsidian Power Equipment Co., Ltd. The Plaintiff alleges that the accused S-600 liquid-cooled energy storage cabinet adopts the same zoned liquid cooling, temperature detection, abnormal-zone bypass, and fault number recording solution as Claims 1 and 8 of the patent at issue, and requests cessation of infringement and compensation of RMB 1,800,000. The Defendant raises non-infringement and damages amount defenses. The dispute focuses on whether the accused product has independent zoned liquid-cooling circuits, abnormal bypass control, and the alarm recording function described in Claim 8, as well as the Defendant's actual sales scale.","[{\"claim_number\": \"Claim 1\", \"claim_text\": \"An energy storage cabinet, comprising multiple battery modules, zoned liquid-cooling circuits that provide cooling to each battery module respectively, temperature sensors corresponding to each battery module, and a controller that, based on a temperature threshold, shuts down an abnormal zone and keeps other zones running.\", \"claim_elements\": [{\"element_label\": \"1-A\", \"element_text\": \"The energy storage cabinet comprises multiple battery modules\", \"accused_corresponding_feature\": \"The S-600 is provided with six independent battery compartments, and each battery compartment contains a battery module.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The product structure description and prototype photos both show that the accused energy storage cabinet is composed of multiple independent battery compartments, which corresponds to multiple battery modules.\"}, {\"element_label\": \"1-B\", \"element_text\": \"Zoned liquid-cooling circuits that provide cooling to each battery module respectively\", \"accused_corresponding_feature\": \"The S-600 is provided with six cooling branches, respectively connected to six battery compartments.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The six cooling branches of the accused solution correspond one-to-one to the six battery compartments, and functionally provide liquid cooling to each zone respectively.\"}, {\"element_label\": \"1-C\", \"element_text\": \"Temperature sensors corresponding to each battery module\", \"accused_corresponding_feature\": \"Each battery compartment is equipped with a temperature sensor and sends temperature data to the central controller.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The technical manual of the accused product lists one temperature collection point per compartment, satisfying the zoned temperature detection relationship.\"}, {\"element_label\": \"1-D\", \"element_text\": \"The controller shuts down an abnormal zone and keeps other zones running based on a temperature threshold\", \"accused_corresponding_feature\": \"When the central controller detects that the temperature of a compartment exceeds the threshold, it shuts down that compartment's cooling branch and power output, while maintaining operation of other battery compartments.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The accused control logic has the same technical means and function as the abnormal-zone bypass and continued operation of the remaining zones required by the claim.\"}], \"plaintiff_position\": \"All technical features of Claim 1 appear directly and completely in the accused product, and the accused product falls within the scope of protection of Claim 1.\", \"defendant_position\": \"The Defendant argues that it adopts an independent safety control strategy, that the temperature sensor collects the overall temperature of the battery compartment, and that what is shut down is power output rather than the liquid-cooling circuit, so it at least lacks the zoned bypass feature of Claim 1.\", \"overall_conclusion\": \"The Plaintiff claims that all features are the same and that literal infringement exists; the Defendant denies the correspondence of zoned liquid cooling and bypass control, and the infringement conclusion remains to be determined in light of the physical product, control program, and technical appraisal.\"}, {\"claim_number\": \"Claim 8\", \"claim_text\": \"The energy storage cabinet according to Claim 1, wherein after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\", \"claim_elements\": [{\"element_label\": \"8-A\", \"element_text\": \"After an abnormal zone is bypassed, generates a maintenance alarm\", \"accused_corresponding_feature\": \"After an abnormal battery compartment stops running, the S-600 pops up a 'battery compartment maintenance' alarm on the display.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The maintenance alarm displayed on the accused product's interface occurs after the abnormal compartment stops running, and its timing and function are consistent with Claim 8.\"}, {\"element_label\": \"8-B\", \"element_text\": \"Saves the abnormal zone number\", \"accused_corresponding_feature\": \"The controller records the faulty compartment number, occurrence time, and reset status in the operation log.\", \"comparison_result\": \"Same\", \"comparison_reason\": \"The accused operation log contains the faulty compartment number and can be used for subsequent maintenance locating, satisfying the limitation of saving the abnormal zone number.\"}], \"plaintiff_position\": \"The additional features of Claim 8 have corresponding manifestations in the accused product's displayed alarm and operation log, so the accused product also falls within the scope of protection of Claim 8.\", \"defendant_position\": \"The Defendant states that the maintenance prompt on the display is merely a general fault prompt, and the log record is also a safety monitoring record, and does not have the post-bypass alarm function defined by the patent claim.\", \"overall_conclusion\": \"The existing documents support a correspondence with the additional features of Claim 8, but the Defendant raises substantive objections to the alarm trigger timing and log function.\"}]","{\"patent_number\": \"ZL202210456789.3\", \"patent_title\": \"An energy storage cabinet with zoned liquid cooling and fault bypass functions\", \"patent_type\": \"Invention patent\", \"priority_date\": \"April 8, 2022\", \"claims_involved\": [\"Claim 1: An energy storage cabinet, comprising multiple battery modules, zoned liquid-cooling circuits that provide cooling to each battery module respectively, temperature sensors corresponding to each battery module, and a controller that, based on a temperature threshold, shuts down an abnormal zone and keeps other zones running.\", \"Claim 8: The energy storage cabinet according to Claim 1, wherein after an abnormal zone is bypassed, the controller generates a maintenance alarm and saves the abnormal zone number.\"]}","[{\"evidence_label\": \"Evidence 1: Patent certificate and copy of patent register for the patent at issue\", \"evidence_type\": \"Patent documents\", \"evidence_description\": \"Records the patent number, invention title, patentee, and valid status of the patent.\", \"proof_purpose\": \"To prove the Plaintiff's standing as patentee and the status of the right.\", \"related_issue\": \"Patent ownership and validity\"}, {\"evidence_label\": \"Evidence 2: Purchase record and on-site photos of the S-600 prototype\", \"evidence_type\": \"Physical evidence and transaction materials\", \"evidence_description\": \"Shows the six battery compartments, zoned cooling interfaces, and display alarm interface of the accused energy storage cabinet.\", \"proof_purpose\": \"To prove the structure, control interface, and purchase source of the accused product.\", \"related_issue\": \"Infringement comparison for Claims 1 and 8\"}, {\"evidence_label\": \"Evidence 3: Defendant's direct-sale online store pages and exhibition brochure\", \"evidence_type\": \"Electronic data and promotional materials\", \"evidence_description\": \"Contains the S-600 product name, technical parameters, sales contact information, and introduction to the zoned fault isolation function.\", \"proof_purpose\": \"To prove that the Defendant engaged in selling and offering for sale.\", \"related_issue\": \"Accused infringing acts\"}]","{\"legal_basis\":\"[{\\\"law_name\\\": \\\"Patent Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 64\\\", \\\"legal_proposition\\\": \\\"The scope of protection of an invention patent shall be based on the content of the claims, and the description and drawings may be used to interpret the claims.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Argue that the H-20 lacks essential features such as a plate-type heat exchange core, integrally formed guide groove, and same-side interfaces\\\"}, {\\\"law_name\\\": \\\"Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes\\\", \\\"article\\\": \\\"Article 7\\\", \\\"legal_proposition\\\": \\\"When determining whether an accused technical solution falls within the scope of protection, all technical features recorded in the claims shall be examined.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Request confirmation that the H-20 does not infringe Claims 1 and 6\\\"}, {\\\"law_name\\\": \\\"Anti-Unfair Competition Law of the People's Republic of China\\\", \\\"article\\\": \\\"Article 11\\\", \\\"legal_proposition\\\": \\\"Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Argue that Hanyu Company issued improper infringement warnings to customers and the public and should bear damage liability\\\"}, {\\\"law_name\\\": \\\"Civil Code of the People's Republic of China\\\", \\\"article\\\": \\\"Article 1024\\\", \\\"legal_proposition\\\": \\\"Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\\\", \\\"cited_by\\\": \\\"Counterclaim Plaintiff\\\", \\\"related_claim\\\": \\\"Support the request for goodwill clarification and related damages\\\"}]\",\"document_text\":\"Counterclaim and Written Opinion\\nCase No.: (2025) Zhe 01 Zhi Min Chu No. 203\\nPlaintiff in the principal action, Defendant in the counterclaim: Hanyu Environmental Equipment Co., Ltd.\\nDefendant in the principal action, Plaintiff in the counterclaim: Qinglan Thermal Control Systems Co., Ltd.\\nCounterclaim Requests: 1. Confirm that the 'Qinglan Modular Heat Exchanger H-20' manufactured and sold by the Counterclaim Plaintiff does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6; 2. Order the Counterclaim Defendant to cease alleging infringement by the Counterclaim Plaintiff at industry exhibitions, in customer emails, and on websites, and to delete the relevant statements; 3. Order the Counterclaim Defendant to compensate the Counterclaim Plaintiff for investigation, notarization, and goodwill clarification expenses totaling RMB 250,000 caused by the erroneous infringement warning; 4. The costs of the principal action and the counterclaim shall be borne by the Counterclaim Defendant.\\nFacts and Reasons: Hanyu Company is the patentee of Invention Patent No. ZL202110135790.6, titled 'A detachable heat exchange module for industrial waste heat recovery,' and filed the principal action on the ground that the Counterclaim Plaintiff's production and sale of the H-20 infringes the patent. Qinglan Company does not accept the infringement allegation in the principal action and now files this counterclaim in accordance with law.\\nClaim 1 of the patent at issue requires the heat exchange module to have a plate-type heat exchange core, a sealing frame arranged along the edge of the core, and a guide groove integrally formed with the sealing frame; Claim 6 further requires that the inlet and outlet of the guide groove be located on the same side of the module and be connected to external piping through detachable joints. The H-20 uses a brazed tube-fin heat exchange core, its sealing component is an independently installed silicone sealing ring, its flow guide path is formed by an internal header, and its external interfaces are located on opposite sides of the module. It does not have a plate-type heat exchange core, a guide groove integrally formed with a sealing frame, or same-side inlet and outlet.\\nIn January 2025, the Plaintiff in the principal action sent a 'Patent Infringement Risk Notification Letter' to three customers of Qinglan Company, and marked the H-20 on a display board at the 'East China Energy-Saving Equipment Exhibition' as a 'product suspected of infringing Hanyu's patent,' causing two customers to suspend acceptance and require Qinglan Company to submit a non-infringement statement. Qinglan Company has entrusted a notarial institution to preserve evidence of the display board and webpage, and has paid testing, attorney, and goodwill clarification expenses. Hanyu Company issued targeted warnings to counterparties without conducting product disassembly and technical comparison, expanding the scope of dissemination, which has exceeded the necessary limits of legitimate rights protection.\\nQinglan Company requests that, while hearing the infringement dispute in the principal action, the court confirm that the H-20 does not fall within the scope of protection of Claims 1 and 6, and order Hanyu Company to cease improper infringement warnings and compensate for reasonable losses.\\nRespectfully submitted to\\nHangcheng City Intermediate People's Court\\nCounterclaim Plaintiff: Qinglan Thermal Control Systems Co., Ltd.\\nMay 9, 2025\",\"document_type\":\"Counterclaim\",\"disputed_facts\":\"{\\\"accused_product\\\": \\\"Qinglan Modular Heat Exchanger H-20\\\", \\\"accused_technical_solution\\\": \\\"The H-20 uses a brazed tube-fin heat exchange core, an independently installed silicone sealing ring on the outer periphery of the heat exchange core, fluid distributed by an internal header to the tube-fin channels, hot medium inlet and outlet respectively located on opposite sides of the module, and fixed flanges connecting external piping.\\\", \\\"relevant_technical_features\\\": [\\\"Whether the heat exchange core is plate-type or brazed tube-fin type\\\", \\\"Whether the sealing component is arranged along the edge of the heat exchange core and integrally formed with a sealing frame\\\", \\\"Whether a guide groove is formed in the sealing frame and performs a fluid guiding function\\\", \\\"Whether the inlet and outlet are located on the same side of the module\\\", \\\"Whether external piping connection uses detachable joints\\\"], \\\"infringement_act\\\": \\\"The Plaintiff in the principal action alleges that the Counterclaim Plaintiff's manufacture and sale of the H-20 constitute patent infringement; the Counterclaim Plaintiff also alleges that the Plaintiff in the principal action issued infringement warnings against the H-20 to customers and the exhibition public, causing goodwill and transaction losses.\\\", \\\"factual_disputes\\\": [\\\"Whether the brazed tube-fin heat exchange core of the H-20 can correspond to the plate-type heat exchange core of Claim 1.\\\", \\\"Whether the independent silicone sealing ring is a guide groove structure integrally formed with a sealing frame.\\\", \\\"Whether the inlet and outlet arranged on two sides of the H-20 satisfy the same-side limitation of Claim 6.\\\", \\\"Whether Hanyu Company's infringement allegations to customers and at the exhibition were based on sufficient technical comparison.\\\", \\\"Whether the customers' suspension of acceptance and the notarization, testing, and clarification expenses incurred by the Counterclaim Plaintiff were directly caused by the infringement warning.\\\"]}\",\"defense_reasons\":\"[{\\\"defense_type\\\": \\\"Non-infringement defense\\\", \\\"defense_content\\\": \\\"The Counterclaim Plaintiff argues that the H-20 differs from the patent at issue in heat exchange core, sealing frame guide groove, inlet\\\u002Foutlet positions, and piping joints, and does not fall within the scope of protection of Claims 1 and 6.\\\", \\\"factual_basis\\\": [\\\"The H-20 uses a brazed tube-fin heat exchange core rather than a plate-type heat exchange core.\\\", \\\"The independent silicone sealing ring does not have an integrally formed guide groove.\\\", \\\"The inlet and outlet are arranged on two sides of the module and fixed flanges are used.\\\"], \\\"legal_basis\\\": [\\\"Article 64 of the Patent Law of the People's Republic of China: The scope of patent protection is based on the content of the claims.\\\", \\\"Article 7 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Application of Law in the Trial of Patent Infringement Disputes: If the accused technical solution lacks a technical feature in the claims, it generally does not fall within the scope of protection.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 6\\\"]}, {\\\"defense_type\\\": \\\"Defense of damages from improper infringement warning\\\", \\\"defense_content\\\": \\\"The Counterclaim Plaintiff argues that the Plaintiff in the principal action, lacking product disassembly, technical appraisal, and complete comparison, issued infringement allegations to specific customers and unspecified exhibition visitors, exceeding the scope of legitimate rights protection and causing actual damage.\\\", \\\"factual_basis\\\": [\\\"The infringement warning letter specifically targeted the H-20 and its customer transactions.\\\", \\\"The exhibition display board publicly displayed suspected infringement information.\\\", \\\"The customers' suspension of acceptance was close in time to the sending of the warning letters.\\\"], \\\"legal_basis\\\": [\\\"Article 1024 of the Civil Code of the People's Republic of China: Civil subjects enjoy the right of reputation, and no organization or individual may infringe upon another's right of reputation by insult, defamation, or other means.\\\", \\\"Article 11 of the Anti-Unfair Competition Law of the People's Republic of China: Business operators may not fabricate or disseminate false or misleading information to damage a competitor's business reputation or product reputation.\\\"], \\\"targeted_claims\\\": [\\\"Claim 1\\\", \\\"Claim 6\\\"]}]\",\"party_positions\":\"[{\\\"party\\\": \\\"Hanyu Environmental Equipment Co., Ltd.\\\", \\\"position_type\\\": \\\"Infringement assertion in principal action\\\", \\\"claim_content\\\": \\\"The heat exchange core, sealing member, and guide structure of the H-20 have equivalent functions to the patent at issue, and Qinglan Company's manufacture and sale infringe Claims 1 and 6.\\\", \\\"supporting_facts\\\": [\\\"The H-20 has a heat exchange core, sealing member, and fluid guiding structure.\\\", \\\"The H-20 can achieve industrial waste heat recovery and modular disassembly.\\\"], \\\"requested_relief\\\": \\\"Request an order that Qinglan Company cease manufacturing and selling the H-20 and compensate for losses in the principal action.\\\"}, {\\\"party\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"position_type\\\": \\\"Counterclaim confirmation assertion\\\", \\\"claim_content\\\": \\\"The H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side flange interfaces, lacks the essential technical features of Claims 1 and 6, and does not infringe the patent at issue.\\\", \\\"supporting_facts\\\": [\\\"The H-20 structure diagram and product prototype show the use of a tube-fin heat exchange core.\\\", \\\"The inlet and outlet are located on opposite sides of the module.\\\", \\\"The sealing ring does not have a guiding function, and guiding is accomplished by the internal header.\\\"], \\\"requested_relief\\\": \\\"Request confirmation that the H-20 does not infringe Claims 1 and 6.\\\"}, {\\\"party\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"position_type\\\": \\\"Counterclaim damages assertion\\\", \\\"claim_content\\\": \\\"Hanyu Company, without completing sufficient technical comparison, issued targeted infringement warnings to customers and the exhibition public, causing customers to suspend acceptance and incurring notarization, testing, and goodwill clarification expenses.\\\", \\\"supporting_facts\\\": [\\\"Hanyu Company sent patent infringement risk notification letters to three customers.\\\", \\\"The exhibition display board directly marked the H-20 as suspected of infringement.\\\", \\\"Two customers suspended acceptance because of the warnings, and Qinglan Company paid notarization and testing expenses.\\\"], \\\"requested_relief\\\": \\\"Request an order that Hanyu Company cease improper warnings and compensate RMB 250,000 in reasonable losses.\\\"}]\",\"case_information\":\"{\\\"case_number\\\": \\\"(2025) Zhe 01 Zhi Min Chu No. 203\\\", \\\"court_name\\\": \\\"Hangcheng City Intermediate People's Court\\\", \\\"plaintiff\\\": \\\"Hanyu Environmental Equipment Co., Ltd.\\\", \\\"defendant\\\": \\\"Qinglan Thermal Control Systems Co., Ltd.\\\", \\\"document_date\\\": \\\"May 9, 2025\\\", \\\"procedural_stage\\\": \\\"Counterclaim stage during first-instance principal action\\\"}\",\"document_summary\":\"This case includes a patent infringement principal action filed by Hanyu Environmental Equipment Co., Ltd. and a counterclaim filed by Qinglan Thermal Control Systems Co., Ltd. for confirmation of non-infringement and damages for improper infringement warning. Qinglan Company argues that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges, and lacks the plate-type heat exchange core, integrally formed guide groove, same-side inlet and outlet, and detachable joints required by Claims 1 and 6. Qinglan Company also argues that Hanyu Company, without sufficient comparison, issued infringement warnings to customers and the exhibition public, causing suspension of acceptance and related expenses, and therefore requests confirmation of non-infringement, cessation of warnings, and compensation of RMB 250,000.\",\"claim_comparisons\":\"[{\\\"claim_number\\\": \\\"Claim 1\\\", \\\"claim_text\\\": \\\"A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"1-A\\\", \\\"element_text\\\": \\\"Plate-type heat exchange core\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 uses a multi-row brazed tube-fin heat exchange core, in which fluid flows inside tubes and exchanges heat through fins.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The brazed tube-fin core is composed of tube bundles and fins, not a plate-type heat exchange core formed by stacked plates, and the structural basis and fluid channels are different.\\\"}, {\\\"element_label\\\": \\\"1-B\\\", \\\"element_text\\\": \\\"A sealing frame arranged along the edge of the heat exchange core\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 has an independent silicone sealing ring installed on the outer periphery of the core, fixed by metal pressure plates.\\\", \\\"comparison_result\\\": \\\"Partially corresponding but different\\\", \\\"comparison_reason\\\": \\\"Although the accused product has a sealing member on the outer periphery of the core, it is an independent sealing ring rather than the sealing frame recited in the claim, and the specific structure and assembly relationship differ.\\\"}, {\\\"element_label\\\": \\\"1-C\\\", \\\"element_text\\\": \\\"The guide groove is integrally formed with the sealing frame\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 distributes fluid to the tube-fin channels through an internal header, and the silicone sealing ring does not perform a guide groove function.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The fluid guiding of the accused product is accomplished by the internal header, and the sealing ring has no integrally formed guide groove and does not perform the guiding function in the claim.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff in the principal action, Hanyu Company, argues that the combination of the sealing ring and internal header of the H-20 can achieve the same sealing and guiding functions as the patented sealing frame guide groove, and is an equivalent technical solution.\\\", \\\"defendant_position\\\": \\\"The Counterclaim Plaintiff, Qinglan Company, argues that the H-20 uses a completely different tube-fin heat exchange core and internal header, and the sealing ring is neither a sealing frame nor has a guide groove, so it at least lacks the key features of Claim 1.\\\", \\\"overall_conclusion\\\": \\\"The accused solution and Claim 1 have obvious differences in heat exchange core type, sealing structure, and guide component, and the Counterclaim Plaintiff accordingly argues that it does not fall within the scope of protection of Claim 1.\\\"}, {\\\"claim_number\\\": \\\"Claim 6\\\", \\\"claim_text\\\": \\\"The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\\\", \\\"claim_elements\\\": [{\\\"element_label\\\": \\\"6-A\\\", \\\"element_text\\\": \\\"The inlet and outlet of the guide groove are located on the same side of the module\\\", \\\"accused_corresponding_feature\\\": \\\"The hot medium inlet of the H-20 is located on the left side and the outlet is located on the right side, respectively on opposite sides of the module.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The product piping diagram and physical photos show that the inlet and outlet are arranged on two sides, which does not satisfy the explicit spatial limitation of same-side arrangement.\\\"}, {\\\"element_label\\\": \\\"6-B\\\", \\\"element_text\\\": \\\"Connected to external piping through detachable joints\\\", \\\"accused_corresponding_feature\\\": \\\"The H-20 is connected to external piping through fixed flanges, and disassembly requires releasing bolts and replacing sealing gaskets.\\\", \\\"comparison_result\\\": \\\"Different\\\", \\\"comparison_reason\\\": \\\"The fixed flange connection is different from the detachable joint recited in the claim, and this connection structure serves the tube-fin core rather than the patented guide groove.\\\"}], \\\"plaintiff_position\\\": \\\"The Plaintiff in the principal action argues that the flange connection can also make the module detachable, and the difference in inlet and outlet positions does not affect the overall heat exchange function, so it at least constitutes equivalent infringement.\\\", \\\"defendant_position\\\": \\\"The Counterclaim Plaintiff argues that same-side inlet and outlet are an explicit spatial relationship of Claim 6, and the two-side interfaces and fixed flanges of the H-20 do not have this feature, and cannot be replaced by similar function.\\\", \\\"overall_conclusion\\\": \\\"The H-20 does not have the same-side inlet and outlet or detachable joint features of Claim 6, and the Counterclaim Plaintiff's non-infringement confirmation claim has a technical comparison basis.\\\"}]\",\"patent_information\":\"{\\\"patent_number\\\": \\\"ZL202110135790.6\\\", \\\"patent_title\\\": \\\"A detachable heat exchange module for industrial waste heat recovery\\\", \\\"patent_type\\\": \\\"Invention patent\\\", \\\"priority_date\\\": \\\"February 20, 2021\\\", \\\"claims_involved\\\": [\\\"Claim 1: A detachable heat exchange module, comprising a plate-type heat exchange core, a sealing frame arranged along the edge of the heat exchange core, and a guide groove integrally formed with the sealing frame.\\\", \\\"Claim 6: The heat exchange module according to Claim 1, wherein the inlet and outlet of the guide groove are located on the same side of the module and are connected to external piping through detachable joints.\\\"]}\",\"evidence_references\":\"[{\\\"evidence_label\\\": \\\"Evidence 1: Published invention patent text and claims of the patent at issue\\\", \\\"evidence_type\\\": \\\"Patent documents\\\", \\\"evidence_description\\\": \\\"Records the plate-type heat exchange core and sealing frame integrally formed guide groove of Claim 1, and the same-side interfaces and detachable joints of Claim 6.\\\", \\\"proof_purpose\\\": \\\"To determine the essential technical features required for infringement comparison in the principal action.\\\", \\\"related_issue\\\": \\\"Scope of protection of Claims 1 and 6\\\"}, {\\\"evidence_label\\\": \\\"Evidence 2: H-20 product structure diagram, piping diagram, and prototype photos\\\", \\\"evidence_type\\\": \\\"Technical materials and physical evidence\\\", \\\"evidence_description\\\": \\\"Shows that the H-20 uses a brazed tube-fin heat exchange core, independent silicone sealing ring, internal header, and two-side fixed flanges.\\\", \\\"proof_purpose\\\": \\\"To prove that the technical solution of the accused product differs from the patent claims.\\\", \\\"related_issue\\\": \\\"Non-infringement comparison\\\"}, {\\\"evidence_label\\\": \\\"Evidence 3: Patent infringement risk notification letters and notarized exhibition display board\\\", \\\"evidence_type\\\": \\\"Notarized documents and written materials\\\", \\\"evidence_description\\\": \\\"Records the content of the notification letters sent by Hanyu Company to three customers and the statements on the exhibition display board regarding the H-20 being suspected of infringement.\\\", \\\"proof_purpose\\\": \\\"To prove the recipients, dissemination scope, and specific content of the infringement warnings.\\\", \\\"related_issue\\\": \\\"Improper infringement warning conduct in the counterclaim\\\"}, {\\\"evidence_label\\\": \\\"Evidence 4: Customer suspension of acceptance notices, notarization and testing expense vouchers\\\", \\\"evidence_type\\\": \\\"Business records and expense vouchers\\\", \\\"evidence_description\\\": \\\"Records the notices from two customers suspending acceptance of the H-20 and the amounts paid by Qinglan Company for notarization, testing, and goodwill clarification services.\\\", \\\"proof_purpose\\\": \\\"To prove the connection between the infringement warnings, the transaction impact, and the losses.\\\", \\\"related_issue\\\": \\\"Counterclaim damages request\\\"}]\",\"counterclaim_information\":\"{\\\"has_counterclaim\\\": true, \\\"counterclaim_type\\\": \\\"Counterclaim for confirmation of non-infringement and damages for improper infringement warning\\\", \\\"counterclaim_content\\\": \\\"Qinglan Company requests confirmation that the H-20 does not infringe Claims 1 and 6 of Hanyu Company, and alleges that Hanyu Company, without completing sufficient technical comparison, disseminated infringement allegations to customers and the exhibition public, causing suspension of transactions, investigation expenses, and goodwill clarification expenses.\\\", \\\"counterclaim_requests\\\": [\\\"Confirm that the Qinglan Modular Heat Exchanger H-20 does not infringe Claims 1 and 6 of Invention Patent No. ZL202110135790.6.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to cease issuing improper infringement warnings against the H-20 to customers and the public, and to delete the relevant webpage and display board content.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to compensate notarization, testing, attorney, and goodwill clarification expenses totaling RMB 250,000.\\\", \\\"Order Hanyu Environmental Equipment Co., Ltd. to bear the litigation costs of the principal action and counterclaim.\\\"], \\\"counterclaim_facts\\\": [\\\"The heat exchange core, sealing structure, and interface arrangement of the H-20 have multiple clear differences from the claims at issue.\\\", \\\"Hanyu Company sent patent infringement risk notification letters to three customers and publicly marked the H-20 as suspected of infringement at an industry exhibition.\\\", \\\"After receiving the notifications, two customers suspended acceptance, and Qinglan Company spent notarization, testing, and clarification expenses to restore the transactions.\\\"]}\"}","MOBIUSI 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