DEHOYI and Mudygelay Seek Declaratory Judgment Against Ernst Manufacturing on a Tool Organizer Patent.

The complaint

The case is Shenzhenshi Xixihaina Maoyi Youxiangongsi d/b/a DEHOYI and Shenzhenshi Yunqishidai Dianzishangwu Youxiangongsi d/b/a Mudygelay Direct v. Ernst Manufacturing, Inc., No. 4:26-cv-09440 (S.D. Tex.), a 13-page complaint filed October 27, 2026, Document 1. The plaintiffs are companies organized under the laws of the People's Republic of China, based in Shenzhen, that operate the Amazon storefronts DEHOYI (Seller ID AKF85JW3NY5UG) and Mudygelay Direct (Seller ID A3Q4XHXWVUKG9I). The defendant is Ernst Manufacturing, Inc., an Oregon corporation the complaint places in Sandy, Oregon, and identifies as the assignee of the '813 patent. The complaint demands a jury.

Jurisdiction and venue

The complaint pleads subject matter jurisdiction under 28 U.S.C. 1338(a) and 1331. It alleges specific personal jurisdiction from Ernst's Amazon complaints against listings for products held at Amazon fulfillment facilities in the district, and from Ernst's sales channels open to Texas buyers. It pleads venue under 28 U.S.C. 1391(b)(2), based on the effect of that enforcement on inventory held and fulfilled in the district.

The patent and claims

The complaint identifies U.S. Patent 12,629,813, Tool Organizer, which issued May 19, 2026, from an application filed April 18, 2024, claiming benefit of a provisional filed April 19, 2023. It says the patent has thirteen claims, with claim 1 the sole independent claim and claims 2 through 13 dependent. Count I seeks a declaration of noninfringement of the patent; Count II seeks a declaration that claim 1 is invalid.

U.S. Patent 12,629,813 covers a tool organizer system for holding tools. Claim 1 covers a system in which first and second tool organizers couple together, each with a base member having a tool receiver channel, a front-side vertical tab, and a rear-proximal tab receiving slot with ridges at left and right edges, the channel having a first wall along a rear face of the tab and a second wall spaced from the first wall with a multi-sloped profile for providing a surface for abutting a portion of a face of a tool when the tool is placed in the channel, so that insertion of one organizer's tab into another's slot joins base members in series into a composite organizer with a combined set of tool receiver channels. The complaint focuses its noninfringement theory on the second-wall multi-sloped-profile limitation and raises additional product-specific grounds for certain dependent claims, including claim 5 (base cleats), claims 8 and 9 (multiple tool-receiver channels in a base member), and claim 12 (an installed magnet, for accused models sold without magnets).

What the lawsuit is about

The complaint alleges Ernst submitted Amazon patent complaints asserting the '813 patent against both storefronts; Amazon deactivated Mudygelay's accused listings, and Amazon's automated stranded-inventory system later issued orders disposing of 2,230 units; and DEHOYI's listings entered Amazon's patent-evaluation and takedown procedures. Plaintiffs allege the accused products' second wall has two planar facets joined at a crease, and that in the relied-on tool-placement configuration the tool rests against the upper facet while the lower facet does not contact it, so the products do not satisfy claim 1 literally or under the doctrine of equivalents. Count II alleges claim 1 is anticipated under 35 U.S.C. 102(a)(1) by earlier third-party modular tool organizers it says were publicly available before April 19, 2023, and cites U.S. Patent 11,110,589 as additional prior-art evidence. The complaint says the plaintiffs first sued Ernst in the Northern District of Illinois, No. 1:26-cv-10163, on August 26, 2026, and that the action was dismissed.

The relief sought

The prayer asks for a declaration of noninfringement of the '813 patent, directly or indirectly, literally or under the doctrine of equivalents; a declaration that claim 1 is invalid; further relief under 28 U.S.C. 2202; attorneys' fees under 35 U.S.C. 285 if the case is exceptional; taxable costs under Rule 54(d)(1) and 28 U.S.C. 1920; and other relief.

What to watch next

Watch for Ernst's answer or Rule 12 motion. The case can end at any time, including by settlement or voluntary dismissal.