Products Achieving the Patented Result Does Not Warrant a Finding of Infringement under Doctrine of Equivalents

In a patent infringement lawsuit involving utility model patent M513550 (the ‘550 patent), the appellate panel of Taiwan’s Intellectual Property and Commercial Court (“IPC Court”) rejected patentee’s arguments based on doctrine of equivalents, and upheld the lower court’s finding of non-infringement (114-Ming-Zhuan-Shang-Zi No. 11).  

 

The ‘550 patent, entitled “Support plate”, is a utility model patent directed to a foldable frame that could provide better stability and convenience in fixing and supporting one’s electronic devices, such as smartphones or tablets.

 

The patentee of ‘550 patent, Senseage Co. Ltd. (“Senseage”) , sued Uniicreative Co. Ltd. (“Uniicreative”) before Taiwan’s Intellectual Property and Commercial Court (“IPC Court”), alleging that Uniicreative’s products “Kira Kobai” (magnetic mobile power bank with supporting panel), “Spunk” (magnetic mobile power bank with supporting panel), and “Apex Skinarma IML” (smartphone case with supporting panel) infringed at least Claim 1 of the ‘550 patent. At the first instance level, the IPC Court rejected Senseage’s claim, finding no infringement. Senseage then appealed. 

 

On November 6, 2025, the IPC Court entered its judgment in Uniicreative’s favor, upholding the lower court’s finding that the accused products did not infringe Claim 1.

 

Claim 1 of the ‘550 patent reads:

  ”A support plate (100) for supporting an electronic device includes a first plate (110), a foldable portion (160), and a second plate (200). 

The foldable portion (160) is connected to the first plate (110) and the second plate (200) respectively. 

The first plate (110) further includes a connecting portion (210) away from the foldable portion (160) and an abutting portion (220) adjacent to the foldable portion (160). 

The second plate (200) has at least one connected portion (120) and an anti-slip element (140) attached to one side of the second plate (200).

The connecting portion (210) is foldable and can be connected and positioned with the connected portion (120). 

The abutting portion (220) can support the second plate (200) and forms a downward angle with the second plate (200).”

 

On Appeal, the parties’ argument mainly focused on whether the accused products have “The second plate (200) has at least one connected portion (120) and an anti-slip element (140) attached to one side of the second plate (200).” The IPC Court determined that the accused products did not have “an anti-slip element attached to one side of the second plate.” 

More specifically, for Uniicreative’s “Kira Kobai” and “Spunk“ series, the IPC Court noted that when charging user’s device, e.g., the smartphone, the smartphone could be fixed by the underlying magnetic coil without an “additional anti-slip element that is attached to one side of the second plate”. As to Uniicreative’s “Apex Skinarma IML” series, the IPC Court found that it is a smartphone case with supporting panel, and that when in use, the smartphone would actually be covered and fixed within the smartphone case, without any additional ant-slip element.

The Senseage argued that Uniicreative shall nonetheless infringe under doctrine of equivalents, because the magnetic coil and the surrounding structure of the smartphone case achieve similar anti-slip result through substantially similar way and function. That is, when in use, the position of the device will be fixed. The IPC Court disagreed, reasoning that the function of the claimed anti-slip element is to prevent the device from dropping or slipping, while that of the magnetic coil of the “Kira Kobai” and “Spunk“ series is to provide stable transmission and connection when charging the device. As to the surrounding structure of the smartphone case, the IPC Court found the function of the surrounding of a smartphone case is to protect and cover the smartphone, which is substantially different from that of the claimed anti-slip element.

In view of the above, the IPC Court upheld the lower court’s finding of non-infringement, and denied the patentee’s appeal accordingly. 

Source: 

https://judgment.judicial.gov.tw/FJUD/data.aspx?ty=JD&id=IPCV,114%2c%e6%b0%91%e5%b0%88%e4%b8%8a%2c11%2c20251106%2c2