DCT

2:25-cv-09316

Denys Orlov v. Adrian Rivera Maynez Enterprises Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-09316, C.D. Cal., 09/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is domiciled in the Central District of California.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its reusable coffee filters do not infringe, and that Defendant's patents related to reusable coffee holders are invalid.
  • Technical Context: The technology concerns reusable coffee pods for single-serve beverage brewers, a large and competitive segment of the consumer appliance market.
  • Key Procedural History: The complaint alleges Defendant has a history of aggressive patent enforcement, citing a prior case where claims of a related patent owned by Defendant's CEO were invalidated by the International Trade Commission and affirmed by the Federal Circuit. Plaintiff initiated this action after Defendant filed complaints with Amazon.com, resulting in the deactivation of Plaintiff's product listings.

Case Timeline

Date Event
2009-10-30 U.S. Patent No. 11,737,597 Priority Date
2016-01-01 Plaintiff's Product Launch (approximate date)
2021-10-29 U.S. Patent No. 12,396,588 Priority Date
2023-08-29 U.S. Patent No. 11,737,597 Issue Date
2025-08-12 Defendant files Amazon complaint regarding '597 Patent
2025-08-26 U.S. Patent No. 12,396,588 Issue Date
2025-09-09 Defendant files Amazon complaint regarding '588 Patent
2025-09-29 Complaint Filing Date

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

U.S. Patent No. 11,737,597 - Coffee Holder

The Invention Explained

  • Problem Addressed: The patent's background section states that when hot water passes through loosely packed ground coffee in typical coffee makers, it fails to extract the full flavor that would otherwise be obtained. (’597 Patent, col. 1:25-30).
  • The Patented Solution: The invention is a coffee holder designed to facilitate the tamping, or compacting, of loose coffee grounds. The holder comprises a body and a lid, where the lid features a "recessed portion" that extends down into the coffee when the lid is engaged. (’597 Patent, Abstract). This recessed portion, which can function as a "cushion," is configured to tamp the coffee when downward pressure is applied, for instance by the closing mechanism of a coffee maker, thereby enabling a richer brew. (’597 Patent, col. 14:8-11; Fig. 29C).
  • Technical Importance: The technology seeks to achieve the enhanced flavor extraction associated with tamped coffee, common in espresso preparation, within the convenience-oriented format of single-serve pod brewers. (’597 Patent, col. 1:30-34).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of all claims of the '597 Patent. (Compl. ¶48). The analysis focuses on limitations found in independent claim 1.
  • Independent Claim 1, essential elements:
    • A coffee holder with a holder body and a holder lid.
    • The holder body includes a base, a sidewall defining an interior for loose coffee, and an open receiving end.
    • The holder lid is configured to engage the body to cover the open end.
    • The lid includes a "recessed portion that extends into the holder body interior" when engaged.
    • The recessed portion has a "passage" to allow fluid flow into the interior.
    • The recessed portion is configured to accommodate a coffee maker's nozzle.
    • The coffee holder is "removably arranged" in the brewer's chamber.

U.S. Patent No. 12,396,588 - Brewing Material Container for a Beverage Brewer

The Invention Explained

  • Problem Addressed: The patent describes the limitations of conventional pod brewers, which are often restricted to specific disposable cartridge types, leading to consumer waste and limited beverage selection. (’588 Patent, col. 2:15-24).
  • The Patented Solution: The invention discloses a reusable brewing container designed for compatibility with modern brewers that use multiple injection nozzles. The complaint identifies two key features: a lid with a "plurality of lid through-holes" to receive the nozzles, and a "keying element" to ensure proper alignment of these holes with the brewer's nozzles. (Compl. ¶54; ’588 Patent, Abstract). This design allows users to brew their own loose-ground beverages in machines originally designed for proprietary, multi-nozzle cartridges.
  • Technical Importance: The invention aims to provide a versatile, reusable alternative to disposable pods, expanding user choice and reducing environmental waste associated with single-serve brewers, particularly newer multi-nozzle models. (’588 Patent, col. 2:25-30).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of invalidity and non-infringement of all claims of the '588 Patent. (Compl. ¶¶60, 68). The analysis focuses on limitations found in independent claim 1.
  • Independent Claim 1, essential elements:
    • A brewing material container with a receptacle and a lid.
    • The receptacle has a base and a sidewall, with the base being in a "raised position" to accommodate an outflow nozzle below it.
    • The lid has a "plurality of lid through-holes" to receive a corresponding plurality of injection nozzles.
    • The container includes a "keying element" to mate with the brewing chamber and align the through-holes with the nozzles.

III. The Accused Instrumentality

Product Identification

  • Plaintiff’s “One Hole Products” and “Five Hole Products,” which are refillable and reusable coffee filters sold on Amazon.com and elsewhere under the GOODCUPS brand for use with Keurig® coffee makers. (Compl. ¶¶8-12).

Functionality and Market Context

  • The accused products are reusable pods that allow consumers to use their own ground coffee in single-serve brewers. (Compl. ¶8). The complaint alleges that the products feature a "planar top surface" or "flat upper surface," in contrast to the recessed structure claimed in the ’597 Patent. (Compl. ¶¶43-44). The complaint includes a photograph of Plaintiff’s “Five Hole Products,” which appear to have multiple openings in the lid. (Compl. p. 3, ¶12). It is also alleged that many of the products have a "hingedly attached lid" and utilize mesh screening in their perimeter. (Compl. ¶¶45-46).

IV. Analysis of Infringement Allegations

U.S. Patent No. 11,737,597 Declaratory Judgment (Non-Infringement) Allegations

The following table summarizes the Plaintiff's arguments for why its products do not infringe the asserted patent.

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
a recessed portion that extends into the holder body interior when the holder lid engages the holder body Plaintiff's products allegedly include a "planar top surface" or "flat upper surface," which does not have the claimed recessed portion. The complaint references a figure from the patent's prosecution history to support its interpretation of this limitation. (Compl. p. 8, ¶42). ¶43 col. 14:1-11
a holder sidewall extending from the base and defining an interior configured to receive loose coffee Plaintiff's products allegedly include "at least a portion of mesh screening in the perimeter," which Plaintiff argues cannot be the solid, continuous sidewall required to contain and enable tamping of loose coffee as described in the patent. ¶45 col. 24:14-16
the coffee holder is configured to be removably arranged in the brewing chamber "At least most" of Plaintiff's products are alleged to utilize a "hingedly attached lid," which Plaintiff contends does not satisfy the "removably arranged" limitation as that term was allegedly defined during prosecution to mean the lid is separate from the body. ¶46 col. 24:29-31

U.S. Patent No. 12,396,588 Declaratory Judgment (Non-Infringement) Allegations

The complaint does not provide a detailed, element-by-element non-infringement analysis for the ’588 Patent. Instead, it asserts a broader legal and factual theory: that the accused products are "materially similar to the prior art and thus cannot be infringing." (Compl. ¶67). This argument relies on the legal principle that a device which practices the prior art cannot infringe a later patent. (Compl. ¶67). The complaint specifically identifies the 5-hole Keurig® My K-Cup, allegedly offered for sale since September 2020, as invalidating prior art that discloses the allegedly patentable features. (Compl. ¶¶55-56). The complaint provides screenshots from a YouTube video as evidence of the prior art product's features. (Compl. p. 10, ¶56).

  • Identified Points of Contention:
    • Scope Questions (’597 Patent): The dispute may center on the definition of "recessed portion." The question for the court will be whether this term requires a specific structure for tamping, as Plaintiff alleges based on the patent's figures and prosecution history (Compl. p. 8, ¶42), or if it can be construed more broadly. A second scope question is whether "removably arranged" refers to the holder's relationship with the coffee maker or, more narrowly, the lid's relationship with the holder body.
    • Factual & Legal Questions (’588 Patent): A central question will be whether the prior art Keurig® My K-Cup, as depicted in the complaint's visual evidence from a YouTube video (Compl. p. 11, ¶58), actually discloses every element of the asserted claims and predates the patent's October 2021 priority date. The analysis will depend on factual evidence regarding the precise features and sale date of that prior art product.

V. Key Claim Terms for Construction

  • The Term: "recessed portion" (’597 Patent, Claim 1)
  • Context and Importance: This term is central to Plaintiff's primary non-infringement argument. Plaintiff contends its products have a "planar" lid and thus lack this feature. (Compl. ¶43). The construction of this term—whether it requires a specific tamping structure or can cover any non-planar top surface—may be dispositive of infringement for a key set of claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language of claim 1 requires only "a recessed portion that extends into the holder body interior when the holder lid engages the holder body." (’597 Patent, col. 24:20-22).
    • Evidence for a Narrower Interpretation: The specification repeatedly depicts the "recessed portion 32'" as a distinct structure, describing it as a "cushion 32" [that] tamps the coffee." (’597 Patent, col. 14:8-9; Fig. 29C). Plaintiff's complaint cites these specific figures and descriptions from the patent's file history to support a narrower construction tied to the tamping function. (Compl. ¶¶41-42).
  • The Term: "keying element" (’588 Patent, Claim 1)
  • Context and Importance: Plaintiff's invalidity argument against the ’588 Patent alleges that the prior art Keurig® My K-Cup discloses all patentable features. (Compl. ¶56). Whether that prior art product contains a "keying element" as claimed will be a critical issue. Practitioners may focus on this term because its definition will determine what features on the prior art product and the accused products meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim defines the term functionally as being "configured to mate with a corresponding element of the brewing chamber to align the lid through-holes with the injection nozzles." (’588 Patent, col. 21:33-37). Any physical feature on the container that ensures proper rotational alignment could arguably satisfy this broad functional language.
    • Evidence for a Narrower Interpretation: The specification discloses specific structures for this function, such as an "ear arranged on the lid" (element 840) that interfaces with the brewer. (’588 Patent, Figs. 44-48). A party could argue that the term should be limited to the types of distinct, structural alignment features shown in the patent's embodiments.

VI. Other Allegations

The complaint does not contain counts for indirect or willful infringement. However, it includes allegations regarding Defendant's litigation history and extra-judicial enforcement actions through Amazon.com, which form the basis for Plaintiff's request that the court find this to be an "exceptional" case and award attorney's fees under 35 U.S.C. § 285. (Compl. ¶¶16, 71; Prayer for Relief C).

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

  • A core issue will be one of claim scope and prosecution history estoppel: for the ’597 Patent, can the term "recessed portion," which the specification and cited prosecution history describe as a tamping feature, be construed broadly enough to cover the Plaintiff's allegedly "planar" product lids?
  • A second core issue will be one of anticipation by prior public use: for the ’588 Patent, does the prior art Keurig® My K-Cup, which the complaint alleges was on sale before the patent's priority date, contain every element of the asserted claims, including a "plurality of lid through-holes" and a "keying element"? The outcome may depend on evidence establishing the precise features and on-sale date of that product.
  • A key evidentiary question will be one of technical comparison: what is the actual structure and functionality of the Plaintiff's accused products, and how does that structure map to the specific language of the asserted claims of both patents? The complaint's assertions regarding "planar" surfaces, "mesh screening," and "hinged lids" will require factual development.