The complaint

The case is Speedtop Globe Technology Limited v. Michael H. Domesick, No. 2:26-cv-04142 (W.D. Wash.), an 8-page complaint for declaratory judgment of noninfringement filed October 27, 2026, Document 1. The plaintiff is Speedtop Globe Technology Limited, a Hong Kong company doing business as Hontay and operating Amazon seller ID ASQVJDT7ZIEPA. The defendant is Michael H. Domesick, individually and doing business as AB MILL. The complaint demands a jury.

Jurisdiction and venue

The complaint seeks relief under the Declaratory Judgment Act, 28 U.S.C. 2201 and 2202, and pleads subject-matter jurisdiction under 28 U.S.C. 1331 and 1338(a). It alleges an actual controversy because an Amazon patent complaint led Amazon to remove Hontay offers for the accused products. For personal jurisdiction it relies on Washington's long-arm statute, alleging that Domesick directed his patent enforcement at Amazon, which is headquartered in Seattle, and it pleads venue under 28 U.S.C. 1391(b)(2).

The patent and claims

The complaint identifies U.S. Patent 11,491,364, Plank Support Exercise Apparatus and Related Methods, which issued November 8, 2022. It alleges, upon information and belief, that Domesick owns the patent. The patent has seventeen claims; independent claims are 1, 4, 8, 10, and 11. Count I seeks a declaration of noninfringement of any claim of the patent.

U.S. Patent 11,491,364 claims apparatuses for helping a user achieve a plank position. Claim 1 covers such an apparatus with a frame member extending front to back, a tubular portion attaching the arm support pad, a hand grip at a first end and arm support pad at a second end proximate the back, and a contact surface configured to engage a ground surface. Claim 4 covers left and right arm support pad portions on first and second frame legs connected by a hinge or pivot member that allows variation in spacing of the pads. Claim 8 covers a frame member with a hand grip and an arm support pad that couples moveably to the frame so the pad is movable to a plurality of positions, plus a ground-contact surface. Claim 10 covers a frame with a pad support member secured by a fastener holding an arm support pad that extends laterally beyond part of the frame, with a hand grip and ground-contact surface. Claim 11 covers an apparatus in which a position of the hand grip or the arm support pad is adjustable, with a ground-contact surface under the arm support pad.

What the lawsuit is about

The complaint says Domesick submitted or authorized Amazon Complaint ID 22372084231, asserting the '364 patent against Hontay's roller-type abdominal trainers. It says Amazon notified Hontay on October 8, 2026, that it had removed the offer under ASIN B0CH3LQK1W, and on October 11, 2026, that it had removed the offers under ASINs B0CH3LWY8F and B0CH3HPL2F, in response to the same report, and that the notices name "D/B/A AB MILL" as the reporting rights owner. It alleges the accused products lack the hinge or pivot member allowing variation in arm-pad spacing required by claim 4, the arm support pad movably coupled to the frame and movable to a plurality of positions required by claim 8, and the adjustable position of the hand grip or arm support pad required by claim 11, and instead have rigid frame connections and fixed pad and grip positions. It incorporates a noninfringement claim chart as Exhibit D, which it says also addresses the ground-contact limitations of claims 1 and 10, and alleges customers' intended use also does not infringe, so sale and instructions do not induce or contribute to infringement.

The relief sought

The prayer asks for judgment for plaintiff; a declaration of noninfringement of any claim of the '364 patent, directly or indirectly, literally or under the doctrine of equivalents; a permanent injunction barring Domesick from submitting, maintaining, or renewing Amazon complaints alleging that the adjudicated noninfringing form of the accused products infringes the patent; an order requiring withdrawal of outstanding Amazon complaints of that kind; taxable costs and, if the case is exceptional, attorneys' fees under 35 U.S.C. 285; and other relief.

What to watch next

Watch for service of process, Domesick's answer or Rule 12 motion, and any early relief tied to the Amazon listings.