## Facts

- Shengzhen Triangle Science & Technology Industrial Company, Ltd. and Ma Xiguang owned a Chinese utility-model patent covering a notebook-computer structure.
- The patented design included two “seat grooves” into which replaceable battery packs and “expansion boards” (expansion cards that increase a computer’s capabilities) could be inserted.
- Shengzhen and Ma sued Compaq Computer Corporation of the United States in China, alleging that a Compaq notebook computer sold in China used the same groove-and-module design.
- The accused Compaq notebook’s left seat groove had space for both a battery pack and a disc drive.
- Consistent with China’s bifurcated patent-enforcement model, the patent’s validity was addressed separately from infringement.
- In a hearing before the Patent Reexamination Board, Shengzhen and Ma stated that, for the seat grooves and expansion boards, the word “replaceable” meant “interchangeable.”
- The Patent Reexamination Board affirmed the validity of the utility-model patent.
- After validity was affirmed, the dispute proceeded to the Beijing Higher People’s Court to decide the infringement question, including the meaning of “replaceable” and comparison to Compaq’s product configuration.

## Issues

1. Whether, in the infringement proceeding, the claim term “replaceable” should be construed consistently with the patentees’ reexamination statement that “replaceable” means “interchangeable” for the claimed seat grooves and expansion boards.
2. Whether Compaq’s notebook computer—whose left seat groove could house both a battery pack and a disc drive—fell within the scope of the asserted utility-model claims under the proper construction.
3. What effect the patentees’ statements to the Patent Reexamination Board during reexamination should have on the scope the patentees could assert in court.

## Decision

- The case proceeded in court on the premise that the Patent Reexamination Board had already affirmed the patent’s validity.
- In analyzing infringement, the court considered the patentees’ reexamination statement equating “replaceable” with “interchangeable” as part of the interpretive record bearing on claim meaning.
- Publicly accessible English-language summaries do not reliably report the final infringement outcome or procedural disposition; therefore, no definitive statement of liability, nonliability, affirmance, or reversal is made here.

## Legal Principles

- Under China’s bifurcated patent system, patent validity may be determined in an administrative reexamination proceeding before the infringement case is resolved in court.
- Statements made by patentees during reexamination about the meaning of claim terms can be treated as relevant to later claim construction in infringement litigation, especially when the patentee gives a clear, term-defining explanation.
- In utility-model patent disputes involving product structure, infringement analysis commonly focuses on element-by-element comparison of the claimed physical configuration (here, seat grooves and the nature of “replaceable/interchangeable” modules) against the accused product’s structure and function.

## Conclusion

Shengzhen Triangle Science & Technology Industrial Co., Ltd. and Ma Xiguang v. Compaq Computer Corp. of the United States (Beijing Higher People’s Court, 2002) is used to show how a patentee’s definitional statements to the Patent Reexamination Board—made while defending validity—may shape claim construction and the infringement analysis in the later court proceeding, particularly for structurally focused utility-model patents.


Shengzhen Triangle Science & Technology Industrial Co., Ltd. and Ma Xiguang v. Compaq Computer Corp. of the United States, (2002)