2:25-cv-09316
Denys Orlov v. Adrian Rivera Maynez Enterprises Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Denys Orlov (California)
- Defendant: Adrian Rivera Maynez Enterprises, Inc. (Nevada)
- Plaintiff’s Counsel: Law Office of Michael P. Eddy; Dan B Law PLLC
- Case Identification: 2:25-cv-09316, C.D. Cal., 12/15/2025
- Venue Allegations: Venue is alleged to be proper as the Defendant is domiciled in the Central District of California.
- Core Dispute: Plaintiff seeks a declaratory judgment that its reusable coffee filter products are not infringed by and that patents owned by the Defendant are invalid, following Defendant’s infringement accusations made via Amazon.com complaints and formal legal counterclaims.
- Technical Context: The technology concerns reusable filters and pods designed for single-serve coffee brewing systems, a highly competitive segment of the consumer appliance market.
- Key Procedural History: The complaint notes a history of intellectual property disputes involving the Defendant and its CEO, including a prior patent being found invalid by the International Trade Commission and a finding of willful trademark infringement in a separate matter. The current action was precipitated by Defendant filing complaints on Amazon.com, resulting in the deactivation of Plaintiff’s product listings. After Plaintiff initiated this declaratory judgment action, Defendant filed counterclaims asserting infringement of U.S. Patent Nos. 10,865,039 and 11,805,934, prompting this First Amended Complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-03-28 | Earliest Priority Date Asserted for ’039 Patent (via Certificate of Correction) |
| 2009-10-30 | Earliest Priority Date for ’597 Patent |
| 2016-01-01 | Plaintiff begins selling GOODCUPS brand coffee filters (approximate) |
| 2020-09-01 | Keurig® My K-Cup (5-hole version) offered for sale (alleged prior art) |
| 2020-10-21 | Earliest Priority Date for ’934 Patent |
| 2020-12-15 | ’039 Patent Issued |
| 2021-10-29 | Earliest Priority Date for ’588 Patent |
| 2022-12-28 | Certificate of Correction filed for ’039 Patent to add priority claim |
| 2023-07-21 | USPTO grants petition to add late priority claim to ’039 Patent |
| 2023-08-29 | ’597 Patent Issued |
| 2023-11-07 | ’934 Patent Issued |
| 2025-08-12 | Defendant files Amazon complaint alleging infringement of ’597 Patent |
| 2025-08-13 | Defendant sends correspondence letter alleging infringement of multiple patents |
| 2025-08-26 | ’588 Patent Issued |
| 2025-09-09 | Defendant files Amazon complaint alleging infringement of ’588 Patent |
| 2025-11-24 | Defendant files counterclaims alleging infringement of ’039 and ’934 Patents |
| 2025-12-15 | Plaintiff files First Amended Complaint for Declaratory Judgment |
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 describes that when hot water passes too freely through loosely packed ground coffee in typical brewers, it fails to extract the full flavor (ʼ597 Patent, col. 1:26-34).
- The Patented Solution: The invention is a reusable coffee holder with a specific lid design that aims to solve this problem. The lid features a "recessed portion" that extends down into the coffee holder's body when closed, which compacts or "tamps" the loose coffee grounds inside (ʼ597 Patent, Abstract; col. 18:15-22). This tamping action is intended to create a more densely packed puck of coffee, slowing the water flow and improving flavor extraction (ʼ597 Patent, col. 2:10-14). Figure 29C of the patent illustrates this recessed portion (32') extending into the holder (30f) (ʼ597 Patent, Fig. 29C).
- Technical Importance: The technology seeks to replicate the coffee-tamping technique used by baristas within the convenient format of a reusable single-serve pod, aiming for enhanced flavor compared to brewing with loose grounds (ʼ597 Patent, col. 2:10-14).
Key Claims at a Glance
- The complaint asserts non-infringement of claims 1-14, 15-28, and 29-38 (Compl. ¶¶ 41, 44). Independent claims 1, 15, 29, and 32 are within these ranges.
- The essential elements of independent Claim 1 include:
- A coffee holder comprising a holder body and a holder lid.
- The holder body includes a base, a sidewall extending from the base to define an interior for receiving loose coffee, and an open receiving end.
- The holder lid is configured to engage the holder body to cover the open receiving end.
- The holder lid includes a "recessed portion that extends into the holder body interior when the holder lid engages the holder body."
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement as to all "asserted claims" (Compl. p. 20).
U.S. Patent No. 12,396,588 - *"Brewing Material Container for a Beverage Brewer"*
The Invention Explained
- Problem Addressed: The background discusses the waste generated by disposable single-use coffee cartridges and the incompatibility of certain reusable pods with different brewer models, particularly those with different numbers or arrangements of injection nozzles (ʼ588 Patent, col. 1:50-2:4).
- The Patented Solution: The patent describes a reusable brewing container with a lid that has multiple openings ("a plurality of lid openings") designed to align with the water injection nozzles of a brewer. The invention also includes a "selective obstruction" feature, which allows a user to block one or more of the lid openings that are not needed for a particular brewer model (ʼ588 Patent, Abstract). The complaint also notes the claims purport to cover a "keying element" for alignment (Compl. ¶ 54).
- Technical Importance: This design provides a universal reusable pod that can be adapted for use in different brewer models, including those with single or multiple water injectors, by selectively blocking unused openings (ʼ588 Patent, col. 2:5-10).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of invalidity and non-infringement of the "claims of U.S. Patent No. 12,396,588" (Compl. ¶ 53).
- The essential elements of independent Claim 1 include:
- A brewing material container comprising a receptacle, a lid, and a selective obstruction.
- The lid is configured to cover the receptacle and includes a "plurality of lid openings."
- The "selective obstruction is configured to selectively block one or more of the lid openings."
- The complaint does not explicitly reserve rights as to dependent claims but seeks a broad declaration (Compl. p. 20).
U.S. Patent No. 10,865,039 - *"Single Serving Brewing Material Holder"*
- Technology Synopsis: The patent describes a disposable "filter paper cup" for creating a beverage pod. The invention focuses on the cup's construction, which uses pleats in the walls and rim that are adhered (e.g., by heat) to provide structure and help the cup retain its shape, distinguishing it from unstructured, pillow-like coffee pods (ʼ039 Patent, Abstract; col. 1:35-41).
- Asserted Claims: Defendant’s counterclaim asserts infringement of Claim 1 (Compl. ¶ 73).
- Accused Features: Plaintiff's "Paper Filter Products" are accused of infringing the ’039 Patent (Compl. ¶ 73).
U.S. Patent No. 11,805,934 - *"Brewing Material Lid and Container for a Beverage Brewer"*
- Technology Synopsis: The technology relates to a reusable container for a beverage brewer, specifically one with a lid that features multiple openings to accommodate brewers with a corresponding number of injection nozzles. The patent also describes a "recess on an exterior of the receptacle" and an undefined "protrusion" (ʼ934 Patent, Abstract; Compl. ¶¶ 118-119).
- Asserted Claims: Defendant’s counterclaim asserts infringement of Claim 1 (Compl. ¶ 103).
- Accused Features: Plaintiff's "Five Hole Products" are accused of infringing the ’934 Patent (Compl. ¶ 103).
III. The Accused Instrumentality
Product Identification
- The accused products are Plaintiff's reusable and disposable coffee filters, sold on Amazon.com and elsewhere under brands including GOODCUPS (Compl. ¶¶ 8, 13). They are categorized in the complaint as "One Hole Products," "Five Hole Products," and "Paper Filter Products" (Compl. ¶¶ 9, 11, 13).
Functionality and Market Context
- These products function as containers for loose coffee grounds for use in single-serve brewers, such as those made by Keurig® (Compl. ¶ 8). The complaint alleges that the "One Hole" and "Five Hole" reusable products feature a "planar top surface" or "flat upper surface" (Compl. ¶¶ 43, 119). It also alleges that these products utilize a "hingedly attached lid" and incorporate "mesh screening in the perimeter" (Compl. ¶¶ 45-46). The complaint alleges these products were commercially successful enough to be targeted by Defendant for removal from Amazon.com (Compl. ¶¶ 17-18, 22).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,737,597 Infringement Allegations
Since this is a declaratory judgment action, the following table summarizes the Plaintiff's asserted non-infringement positions.
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a holder lid includes: a recessed portion that extends into the holder body interior when the holder lid engages the holder body | Plaintiff’s products are alleged to have a "planar top surface" that lacks the claimed recessed portion for tamping coffee. | ¶43 | col. 18:15-22 |
| a sidewall extending from the base and defining an interior configured to receive loose coffee | Plaintiff alleges its products include mesh screening in the perimeter, which would not contain loose coffee during the tamping process described in the patent. | ¶45 | col. 8:1-3 |
| a lid... to cover the open receiving end | Plaintiff alleges its products' lids do not completely cover the open end, which would be required to prevent coffee from escaping during tamping. | ¶45 | col. 1:51-54 |
U.S. Patent No. 12,396,588 Infringement Allegations
The complaint does not provide a feature-by-feature non-infringement analysis for the ’588 Patent. Instead, it asserts non-infringement on the basis that the accused products are "materially similar to the prior art" that allegedly invalidates the patent, citing the legal principle that a device which practices the prior art cannot infringe (Compl. ¶¶ 66-67). The complaint includes a side-by-side photographic comparison showing the top of the prior art Keurig® My K-Cup and the same device installed in a brewer, illustrating both the claimed "plurality of lid through-holes" and the "keying element" (Compl. p. 10).
V. Key Claim Terms for Construction
For U.S. Patent No. 11,737,597:
The Term: "recessed portion that extends into the holder body interior"
Context and Importance: This term describes the core tamping feature of the invention. Plaintiff's primary non-infringement argument is that its products have a "planar top surface" and lack this feature (Compl. ¶ 43). The outcome of the case for this patent may hinge on whether any part of the accused product's lid can be construed as meeting this definition.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term "portion," which could be argued to not require a specific size or shape.
- Evidence for a Narrower Interpretation: The specification describes this feature as a "cushion 32' [that] tamps the coffee" and is preferably a "solid resilient material" (ʼ597 Patent, col. 18:19-22). The figures, such as Fig. 29B, depict a distinct structural element descending into the coffee holder, suggesting a specific physical structure rather than merely the underside of a flat lid.
The Term: "sidewall... defining an interior configured to receive loose coffee"
Context and Importance: Plaintiff argues that its products, which have mesh in the sidewall, do not meet this limitation because the patent's described tamping function requires a solid wall to contain the coffee (Compl. ¶ 45). Practitioners may focus on whether "configured to receive" must be interpreted in the context of the entire claimed process, including tamping.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that a mesh basket is still "configured to receive loose coffee" for the primary purpose of brewing, regardless of its suitability for tamping.
- Evidence for a Narrower Interpretation: The complaint cites prosecution history and specification language allegedly stating that a solid, continuous sidewall is needed to prevent loose coffee from escaping during tamping (Compl. ¶¶ 41, 45). This suggests that to be "configured to receive loose coffee" for the purposes of the claimed invention, the sidewall must be capable of withstanding the tamping process described.
VI. Other Allegations
The complaint, being a request for declaratory judgment of non-infringement and invalidity, does not contain allegations of indirect or willful infringement against the Defendant. It does not provide sufficient detail for analysis of any such allegations made by the Defendant in its counterclaims.
VII. Analyst’s Conclusion: Key Questions for the Case
A central issue will be one of definitional scope: can the term "recessed portion," which the ’597 Patent describes as a structure for tamping coffee, be construed to cover the allegedly "planar" lids of the Plaintiff's reusable filters? The court's interpretation will likely determine infringement of this key patent.
A key question will be validity in light of commercial prior art: did commercially available products, such as the 5-hole Keurig® My K-Cup, disclose the claimed features of the ’588 and ’934 patents (e.g., "plurality of lid through-holes," "keying element") before their effective filing dates, potentially rendering those patents invalid as anticipated or obvious?
The case will raise a question of procedural and substantive priority: for the ’039 Patent, was the post-issuance Certificate of Correction effective in claiming an earlier priority date to overcome anticipating prior art? This presents a threshold legal question regarding the proper mechanism for correcting priority claims that may determine the patent's validity.