Amazon Seller sztgr Seeks a Declaratory Judgment on a Doorbell Guard Patent After an APEX Complaint.

The case

Shenzhenshi Xuandahangpiju Youxiangongsi d/b/a sztgr v. Ryan Dwain Smith, No. 9:26-cv-81486 (S.D. Fla., West Palm Beach Division), is a 10-page complaint for declaratory judgment filed November 2, 2026, Document 1, with a jury demand. The plaintiff is a company organized under the laws of the People's Republic of China that sells doorbell-related products on Amazon through the sztgr storefront. The complaint alleges, on information and belief, that the defendant is an individual located in Loxahatchee, Florida. Jurisdiction is pleaded under 28 U.S.C. §§ 1331, 1338(a), 2201, and 2202, and venue under 28 U.S.C. §§ 1391(b)(1) and 1391(c)(1).

The APEX complaint

The complaint says that on October 12, 2026, Amazon notified sztgr that the defendant had reported two products, ASINs B0GWH4ZP5X and B0DS9BLJBK, as infringing the '182 patent, and that an APEX Agreement identified claim 1 as the asserted claim. It says Amazon gave sztgr three weeks to obtain a retraction, file suit in federal court, or join Amazon's neutral patent evaluation, and that otherwise Amazon would remove the listings. The plaintiff says it chose federal court because the neutral evaluation cannot resolve all disputes between the parties, including the validity of claim 1.

The patent

The complaint says U.S. Patent 12,738,182, titled Multipurpose reconfigurable doorbell guard apparatus, issued September 15, 2026 from Application No. 19/228,311, filed June 4, 2025, as a continuation of the application that issued as U.S. Patent 12,347,345. As quoted in the complaint, claim 1 covers a reconfigurable doorbell guard apparatus with a sign, a backing plate configured for attachment to a mounting surface relative to a doorbell, a fastening element on the rear of the backing plate allowing removal without modifying the mounting surface, and a hinge assembly that lets the sign move between a blocking position obstructing actuation of the doorbell button and a non-blocking position.

Counts and relief

The first cause of action seeks a declaratory judgment that sztgr does not directly or indirectly infringe claim 1, literally or under the doctrine of equivalents. The second seeks a declaratory judgment that claim 1 is invalid under 35 U.S.C. §§ 102, 103, and/or 112, alleging anticipation by German utility model DE202008008330U1 and obviousness over that reference in view of U.S. Patent 2,447,226 or Austrian Patent AT22381B.

The prayer asks for declarations of noninfringement of claim 1 by the accused products and of invalidity of claim 1; a permanent injunction barring the defendant and those acting with him from asserting claim 1 against sztgr or the accused products, including through Amazon's APEX process, to the extent inconsistent with the judgment; an order to withdraw any pending APEX complaint as needed to carry out the judgment; an exceptional case finding and attorneys' fees under 35 U.S.C. § 285; costs; post-judgment interest; and other relief.

Docket activity

Through November 4, 2026, the docket shows the complaint, the patent and trademark form, a clerk's notice of judge assignment on November 3, a notice, a proposed summons, and summons issued on November 4.

What to watch next

Watch for service on the defendant, his answer, any infringement counterclaim or motion to dismiss, and any filing about the status of the Amazon listings.