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Recently, the Guangdong Provincial Market Supervision Administration released the "Notice on Guangdong Province's 2023 Exemplary Cases of Intellectual Property Administrative Protection." One of the highlighted cases was a patent infringement dispute involving an invention patent for a "hinge mechanism and storage device," handled by the administration. This case was recognised as one of the Top 10 Exemplary Cases of Patent Administrative Protection in Guangdong Province for 2023.

Case Summary:
The petitioner, Sugatsune Kogyo Co., Ltd. (Japan), is the holder of the invention patent titled "Hinge Mechanism and Storage Device" (Patent No. ZL200980130836.0). The petitioner discovered that the respondent had been mass-producing and selling products suspected of infringing on this patent without authorisation. Additionally, the respondent carried out these infringing activities at two separate locations, causing the petitioner substantial financial losses. In response, the petitioner filed a patent infringement dispute request with the Municipal Market Supervision Administration. To support their claim, the petitioner submitted evidence, including notarised purchase records of the alleged infringing "hinge mechanism," its installation manual, and notarisation certificates. The petitioner asserted their right to protect Claim 1 of the patent involved in the case and made the following request:

1. That the respondent be ordered to cease the manufacturing and sale of products that infringe upon Claim 1 of the patent.

On July 11th, 2023, the Municipal Market Supervision Administration officially launched an investigation into the case. Enforcement officers determined that the patent in question, a granted invention patent over 10 years old, qualifies as a high-value patent. The respondent was suspected of conducting covert infringing activities at locations outside their registered business address. Some evidence could not be independently collected, with a risk of being destroyed or becoming inaccessible over time, and the likelihood of infringement was deemed high. To establish the facts, enforcement officers conducted investigations at both the respondent's actual business premises and the address registered on their business licence. They gathered evidence, took photographs, and prepared detailed written records. Additionally, relevant legal documents were formally served to the respondent at their registered business address.

After thorough review, the Municipal Market Supervision Administration concluded the following: According to Article 9 of the "Interpretation (II) of the Supreme People's Court on Several Issues Concerning the Application of Law in Patent Infringement Dispute Cases", if the alleged infringing product’s technical solution cannot be applied within the usage environment defined by the usage environment features in the patent claims, the court must determine that the accused product does not fall within the patent's scope of protection. In this case, Claim 1 of the patent specifies two connection structure features: "a connecting component installed on the housing" and "a door-side mounting component installed on the door." These features define the installation environment for the connecting component and the door-side mounting component. Based on the patent specification’s background and specific embodiments, these features qualify as usage environment features. The accused product includes a connecting component and a door-side mounting component. Referring to the installation instructions, which detail the installation process and required accessories, along with notarised evidence, it was established that the accused product’s connecting component can be installed on the housing, and the door-side mounting component can be installed on the door. Furthermore, industry-standard technical knowledge confirms that the accused product is suitable for use in the usage environment defined by Claim 1 of the patent. Upon comparison, it was determined that the accused product incorporates all the technical features outlined in Claim 1 of the patent. As a result, the accused product falls within the scope of protection granted by Claim 1 of the patent.

Significance of the Case
1. The case highlights the equal protection of domestic and international patent holders' legitimate rights, which plays a crucial role in boosting the confidence of both local and foreign investors while fostering a safe and business-friendly environment.
2. Enforcement officers employed strict enforcement measures and innovative case-handling techniques. By conducting on-site investigations and evidence collection at the respondent's registered address and the location of the alleged infringement, the administrative authorities demonstrated their proactive stance and zero-tolerance policy towards intellectual property violations.
3. This case involved the determination and handling of patent infringement related to usage environment features in an invention patent. It provides valuable guidance on recognising environmental technical features in patent claims and assessing whether accused products fall within the scope of patent protection. This serves as a precedent for judging whether accused products meet the usage environment technical features specified in patent claims in similar infringement cases.