DCT

2:22-cv-08504

Yunda Health Technology Tianjin Co Ltd v. LG Electronic Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-08504, C.D. Cal., 11/21/2022
  • Venue Allegations: Plaintiffs allege venue is proper because Defendant is a foreign corporation subject to personal jurisdiction under 35 U.S.C. § 293 (as a patentee not residing in the U.S.) and may therefore be sued in any judicial district. Plaintiffs also allege Defendant previously acquiesced to jurisdiction in this district via a stipulated transfer of a related case.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their after-market refrigerator water filter cartridges do not infringe Defendant’s patent, and that Defendant’s extra-judicial enforcement activities constitute patent misuse.
  • Technical Context: The technology concerns the mechanical structure of replaceable water filter cartridges used in refrigerators, a significant consumer-facing market for both original and after-market components.
  • Key Procedural History: This declaratory judgment action follows Defendant's extra-judicial assertion of the patent-in-suit against Plaintiffs via Amazon.com's "APEX" enforcement program. The complaint notes that Defendant had previously sued Plaintiffs for infringement of other, related patents in district court and the U.S. International Trade Commission (USITC), but did not assert the patent-in-suit in those formal proceedings.

Case Timeline

Date Event
2016-03-22 ’987 Patent Priority Date
2021-02-02 ’987 Patent Issue Date
2021-05-15 Prior litigation filed by LG against Plaintiffs (N.D. Ill.)
2021-11-29 Venue transfer ordered for certain Plaintiffs in prior litigation
2021-12-15 ITC complaint filed by LG against Plaintiffs
2022-01-03 Remaining Plaintiffs in prior litigation transferred to C.D. Cal.
2022-01-14 ITC Investigation Instituted
2022-10-31 LG requests Amazon APEX proceedings against Plaintiffs for '987 patent infringement
2022-11-21 Complaint for Declaratory Judgment filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,905,987 - "Water Purifying Apparatus and Filter Structure," issued February 2, 2021

The Invention Explained

  • Problem Addressed: The patent describes conventional refrigerator water filter systems with bypass flow paths as having complicated structures, including separate plungers and elastic members, which can decrease manufacturing productivity, reduce assembly workability, and potentially deteriorate water flow performance (’987 Patent, col. 2:35-47).
  • The Patented Solution: The invention is a filter and head assembly where the act of rotating the filter to install or remove it also serves to switch the water flow between a filtering path (through the filter medium) and a bypass path (which allows water to flow when no filter is installed). This is accomplished via the mechanical interaction between an "upper supporter" within the filter cartridge and a corresponding rotatable shaft within the refrigerator's filter head unit, eliminating the need for separate valves (’987 Patent, Abstract; col. 2:50-65).
  • Technical Importance: The described approach seeks to simplify the filter replacement process for consumers while reducing the mechanical complexity and manufacturing cost of the filter head assembly (’987 Patent, col. 2:55-58).

Key Claims at a Glance

  • The complaint’s non-infringement analysis focuses on independent Claim 1 (Compl. ¶51).
  • Essential elements of Claim 1 include:
    • A filtering member.
    • A housing body with an opening and a space to accommodate the filtering member.
    • A housing cap coupled to the housing body's opening, itself having a lower hollow space and a smaller-diameter upper hollow space.
    • An upper supporter within the housing cap's upper hollow space, which defines separated inlet and outlet flow paths and an outlet port.
    • A supporter stepped portion at a lower part of the upper supporter, which defines a second filter inlet flow path.
    • A supporter accommodating portion that contacts the filtering member.
    • A first and a second seal on the outer surface of the supporter's extending portion.
    • Specific relative locations for the first seal, second seal, and filter outlet port.
    • A requirement that the second seal is in contact with the supporter extending portion but is spaced apart from a portion of the inner surface of the housing cap.
  • The complaint seeks a declaration of non-infringement of any valid claim of the ’987 Patent (Compl. ¶50, ¶68).

III. The Accused Instrumentality

Product Identification

  • The accused products are after-market replacement water filter cartridges, specifically models RWF4700AB and RFW4700A (Compl. ¶43).

Functionality and Market Context

  • The products are designed to be compatible with Defendant’s refrigerators and serve as replacements for LG's own LT1000P filter cartridge (Compl. ¶38). The complaint alleges that sales of these products on Amazon's e-commerce platform represent a substantial source of Plaintiffs' revenue and are critical to their business (Compl. ¶28-29). The complaint provides a photograph showing a cutaway view of the accused RWF4700AB product (Compl. ¶54, p. 9).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiffs' primary arguments for why their products do not meet the limitations of Claim 1 of the ’987 Patent, focusing on the RWF4700AB model.

’987 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality (Plaintiffs' Position) Complaint Citation Patent Citation
[b] a housing body comprising an opening portion and a first accommodating space to accommodate the filtering member; The accused filter’s lower element is merely a base for the filtering member and cannot be considered the "housing body" as claimed. ¶55 col. 8:31-36
[c] a housing cap coupled to the opening portion of the housing body... The accused filter's upper element encompasses nearly the entire filtering member and therefore cannot reasonably be considered a "cap." ¶55 col. 8:37-41
[d] an upper supporter comprising a supporter extending portion... and a filter outlet port to discharge water from the filter outlet flow path, The "upper supporter" of the accused RWF4700AB is alleged to lack the claimed "filter outlet port." A photograph purports to show the accused product's internal supporter component (Compl. ¶58, p. 11). ¶59 col. 12:44-61
[e] a supporter stepped portion disposed at a lower portion of the supporter extending portion and having a second filter inlet flow path... The "upper supporter" of the accused RWF4700AB is alleged to lack the claimed "supporter stepped portion" and the associated "second filter inlet flow path." ¶61, ¶63 col. 12:16-35
[k] the second seal is in contact with the supporter extending portion and spaced apart from a portion of the inner surface of the housing cap that faces the second seal. Though not explicitly argued in the complaint's examples, the specific spatial relationship required by this limitation presents a potential point of non-infringement. ¶51 col. 26:17-21
  • Identified Points of Contention:
    • Scope Questions: The dispute raises a primary claim construction question: What are the structural requirements for a component to be a "housing body" versus a "housing cap"? Plaintiffs' argument suggests that the relative proportions of the components are dispositive (Compl. ¶55), which the court will need to evaluate against the patent’s text and figures.
    • Technical Questions: A core factual dispute will be whether the internal components of the accused filters, particularly the RWF4700AB and RFW4700A "upper supporters," contain the specific structures (e.g., "filter outlet port," "supporter stepped portion," "second filter inlet flow path") required by the claims. The complaint asserts a complete absence of these features in the RWF4700AB (Compl. ¶59-63) and a structural difference in the RFW4700A (Compl. ¶67). A photograph of the RWF4700A's supporter is provided to illustrate its allegedly non-circular, multi-surfaced nature (Compl. ¶66, p. 12).

V. Key Claim Terms for Construction

  • The Term: "housing cap coupled to the opening portion of the housing body"

    • Context and Importance: This term is central because Plaintiffs' primary non-infringement argument is that their filter's two-piece construction does not meet this structural definition (Compl. ¶55). The entire infringement analysis for several elements hinges on how these basic structural components are defined.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is general, requiring only that a "cap" be "coupled" to a "body." One might argue this does not impose strict size or proportionality requirements.
      • Evidence for a Narrower Interpretation: The patent’s figures consistently depict the "housing cap" (43) as a component that is substantially smaller than the "housing body" (42) and sits atop it (e.g., ’987 Patent, FIG. 7). Plaintiffs argue this context limits the term "cap" to a structure that is proportionally smaller than the main body (Compl. ¶55).

  • The Term: "supporter stepped portion"

    • Context and Importance: Plaintiffs unequivocally deny that their RWF4700AB product includes this feature or its associated flow path (Compl. ¶61, ¶63). Its presence or absence is a dispositive factual question for infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent broadly describes it as a portion "integrally formed on an upper portion of the supporter accommodating portion" where a "second filter inlet flow path is formed" (’987 Patent, col. 3:12-17).
      • Evidence for a Narrower Interpretation: The specification details a specific structure, where the second filter inlet flow path has "an opening formed in a circumferential surface" and extends toward the center (’987 Patent, col. 12:21-25). A party could argue that a structure lacking this specific circumferential opening does not meet the limitation.

VI. Other Allegations

  • Patent Misuse: The complaint includes a separate count for patent misuse (Compl. ¶¶ 69-78). Plaintiffs allege that Defendant attempted to improperly expand the scope of the ’987 Patent by knowingly asserting it via Amazon's APEX program against products, like the RWF4700AB, that "could not possibly infringe claim 1" (Compl. ¶72). The claim is based on alleged bad faith enforcement, with Plaintiffs contending that Defendant acted with "full knowledge" or "reckless disregard" of the fact that the products were outside the patent's scope (Compl. ¶77).
  • Indirect Infringement: The complaint seeks a declaration that Plaintiffs have not infringed directly, contributorily, or by inducement (Compl. ¶68). No specific facts related to inducement are detailed beyond the general sale of the accused products.

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of structural identity: Can the components of Plaintiffs’ two-piece filter housing be mapped to the claimed “housing body” and “housing cap,” or do the claimed terms, in light of the specification, require a different proportional and functional relationship that the accused products lack?
  • A second central question will be factual and technical: Do the internal "supporter" components of the accused filters contain the specific flow paths and structures—namely the "supporter stepped portion" and "filter outlet port"—required by Claim 1? This will likely depend on expert analysis of the physical products versus the patent's drawings and descriptions.
  • The case also presents a significant question regarding enforcement conduct: Did Defendant’s use of Amazon’s quasi-judicial APEX program to assert the ’987 Patent against allegedly non-infringing products constitute patent misuse? This will require the court to examine not only the technical merits but also Defendant’s knowledge and intent in its enforcement activities.