Seven Shenzhen Sellers Seek Declaratory Judgment on Andelian Solar Mosquito-Killer Patents.

The complaint

The case is Shenzhenshi Kuakuabao E-Commerce Co., Ltd. et al. v. Shenzhen Andelian Technology Co., Ltd., Zhongshan Yongqi Electronic Technology Co. Ltd., and Shaoqu Ji, No. 1:26-cv-02927 (E.D. Va., Alexandria Division), a verified complaint filed September 3, 2026, ECF No. 1. The plaintiffs are Shenzhenshi Kuakuabao E-Commerce Co., Ltd., Shenzhen Tongyuan E-Commerce Co., Ltd., Shenzhenshi Beizhilang E-Commerce Co., Ltd., Shenzhenshi Baoshu Keji Co., Ltd., Shenzhen Baohong Consulting Co., Ltd., Shenzhenshi Shijibaobing Keji Co., Ltd., and Shenzhen Xiebaochuhai Keji Co., Ltd., each organized under the laws of the People's Republic of China, which the complaint says run stores on Temu, Shein, and Walmart.com. The complaint describes Shenzhen Andelian Technology Co., Ltd. and Zhongshan Yongqi Electronic Technology Co. Ltd. as Chinese companies and Shaoqu Ji as an individual resident of China, and it alleges that they co-own the three patents in different combinations.

For personal jurisdiction the complaint relies on 35 U.S.C. 293, which gives the Eastern District of Virginia jurisdiction over a patentee not residing in the United States that has not designated a U.S. agent for service. It also alleges that the plaintiffs sell into Virginia and that the defendants' conduct stopped their sales there.

The patents and the Amazon complaints

The complaint names U.S. Patent 12,667,093 and U.S. Design Patents D1,094,828 and D1,144,726. The USPTO record shows the D1,094,828 patent, titled Lamp, issued September 23, 2025, from an application filed May 13, 2024. The D1,144,726 patent, titled Power Grid for Mosquito Killer, issued August 25, 2026, from an August 26, 2025 application that the USPTO record describes as a continuation-in-part of the D1,094,828 application. The '093 patent, titled Solar Mosquito Killer, issued June 30, 2026, from an application filed September 4, 2025, which the complaint describes as a continuation-in-part of the D1,094,828 application. The complaint alleges that the defendants asserted the D1,144,726 patent to lock down the plaintiffs' Amazon listings, each identified by an Amazon Standard Identification Number, and stop their sales of solar mosquito killers on Amazon, and it calls the defendants' platform complaints fraudulent and in bad faith.

The complaint does not identify particular claims of the '093 patent. Independent claim 14, for example, recites a solar mosquito killer with a solar module; a mosquito-killing module with a frame component, an electric grid in the frame, a control component connected to the grid, and a button on the frame; a detachable supporting module; and at least one mosquito trap lamp, among other elements.

The complaint alleges that the plaintiffs built their products following earlier public disclosures, including an Amazon listing with an April 10, 2023 customer review, social media posts from 2023, and Chinese design registrations from 2022 and 2023, all before the defendants' earliest priority date of May 13, 2024. It also alleges that the USPTO ordered reexamination of the D1,094,828 patent on August 3, 2026, based on substantial questions of patentability over prior art.

The counts and relief

Counts I and II seek declaratory judgments that the D1,094,828 and D1,144,726 patents are invalid as anticipated by, or obvious over, the April 2023 Amazon listing. Counts III through V seek declaratory judgments that the plaintiffs' mosquito killers do not infringe the D1,094,828 patent, the D1,144,726 patent, or the '093 patent, on the theory that the claims cannot read on products made according to the prior art without also reading on that prior art. Count VI alleges tortious interference with the plaintiffs' business relationships with Amazon, Temu, Shein, and Walmart.com.

The prayer asks for those declarations; an injunction barring the defendants from asserting the three patents against the plaintiffs; an order directing the defendants to instruct the platforms to reinstate the plaintiffs' stores and locked listings; an order barring new platform complaints against the plaintiffs while the case is pending; damages for tortious interference; and attorney fees and costs.

What to watch next

The docket shows only the complaint so far. Watch for service on the defendants (the complaint relies on 35 U.S.C. 293 for jurisdiction), any motion for preliminary relief on the platform listings, and the course of the reexamination of the D1,094,828 patent. The case can end at any time, including by settlement or voluntary dismissal.