DCT

2:25-cv-10236

Ecosafe Packaging LLC v. Intl Sourcing Mfg

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-10236, C.D. Cal., 10/24/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is a California company with its headquarters and sole physical location in the district, where it allegedly commits acts of infringement and maintains a regular and established place of business.
  • Core Dispute: Plaintiff alleges that Defendant’s child-resistant metal containers infringe three patents related to mechanisms for child-resistant packaging.
  • Technical Context: The technology at issue involves child-resistant caps for metal containers, a field significant for packaging products, such as in the cannabis industry, that are subject to regulations requiring child-safety features.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patents-in-suit. Specifically, it alleges that in early-to-mid 2023, personnel from a licensee informed Defendant’s agent, Michael Salemi, of the infringement at a conference, and that Mr. Salemi subsequently sent a message on July 6, 2023, expressing interest in licensing the patents. These allegations form the basis of the willfulness claims.

Case Timeline

Date Event
2018-04-12 Earliest Priority Date for ’375, ’808, and ’182 Patents
2019-12-24 U.S. Patent No. 10,513,375 Issues
2021-06-22 U.S. Patent No. 11,040,808 Issues
2022-11-08 U.S. Patent No. 11,492,182 Issues
2023-Early Defendant allegedly notified of patents at a conference
2023-07-06 Defendant allegedly sends message inquiring about a license
2025-10-24 Complaint Filed

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

U.S. Patent No. 10,513,375 - "Metal Child Resistant Container"

The Invention Explained

  • Problem Addressed: The patent describes shortcomings in existing child-resistant packaging, noting that many are single-use, not easily resealable, or are made of plastic, which can be difficult to recycle and may leach chemicals into the contents (’375 Patent, col. 1:32-50). Metal containers are presented as a more durable, recyclable, and protective alternative (’375 Patent, col. 2:7-17).
  • The Patented Solution: The invention is a child-resistant metal container with a cap assembly composed of an inner cap, an outer cap, and, in some embodiments, an intermediate plate (’375 Patent, Abstract; col. 2:51-54). The outer cap is designed to spin freely over the inner cap. To open the container, a user must apply pressure (e.g., push down), which causes couplers on the outer cap (or plate) to engage with corresponding couplers on the inner cap. This engagement locks the caps together, allowing the user to unscrew the assembly (’375 Patent, col. 5:46-60).
  • Technical Importance: The technology provides a resealable and fully recyclable metal packaging solution that meets child-resistance requirements, addressing a need for durable and sustainable packaging for sensitive products (’375 Patent, col. 2:11-17).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-3, 5-7, 9, 11-14, and 17-19 (Compl. ¶18).
  • Independent Claim 1 requires:
    • A container body.
    • A cap assembly with a metal inner cap and a metal outer cap.
    • A metal plate disposed between the inner and outer caps, which is "rotationally and axially fixed relative to the outer cap."
    • A first coupler on the inner cap comprising a groove.
    • A second coupler on the plate comprising a tongue configured to engage the groove.
    • An outer cap that can move between a first (disengaged) position and a second (engaged) position relative to the inner cap.

U.S. Patent No. 11,040,808 - "Metal Child Resistant Container"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical problems as the ’375 Patent, seeking a resealable, recyclable, and durable child-resistant metal container (’808 Patent, col. 1:21-53).
  • The Patented Solution: This patent also describes a container with a two-part cap assembly (inner and outer cap) that requires a specific user action, such as applying pressure, to operate (’808 Patent, Abstract). The claims focus on the use of "indentations" stamped into the tops of both the inner and outer caps. When pressure is applied, these indentations align and engage, allowing the rotational force from the outer cap to be transferred to the inner cap for unscrewing (’808 Patent, col. 10:49-67).
  • Technical Importance: The invention provides an alternative structural approach to achieving the same goal as the ’375 Patent, focusing on integrally formed features ("indentations") rather than a separate intermediate plate for the child-resistant engagement mechanism.

Key Claims at a Glance

  • The complaint asserts independent claim 20 and dependent claims 21, 23, 25, 29, 31, and 32 (Compl. ¶34).
  • Independent Claim 20 requires:
    • A container body with an exterior wall comprising a threaded neck.
    • A metal inner cap with threads to couple with the neck and "one or more indentations stamped into a top of the inner cap."
    • A metal outer cap coupled to the inner cap with "one or more indentations stamped into the top of the outer cap."
    • The outer cap's indentations are configured to engage the inner cap's indentations when pressure is applied toward the inner cap.

U.S. Patent No. 11,492,182 - "Child Resistant Container"

Multi-Patent Capsule

  • Technology Synopsis: This patent, part of the same family, further refines and claims variations of the child-resistant container technology. It describes the cap assembly in terms of female and male "couplers" that can be part of the inner cap, outer cap, or an intermediate plate, and which engage upon user action to allow opening (’182 Patent, col. 4:16-34). The claims cover various configurations and geometric arrangements of these couplers.
  • Asserted Claims: Independent claims 1 and 20, and various dependent claims (Compl. ¶50).
  • Accused Features: The complaint alleges that the Accused Products, including the "CR Round Tin Jars," incorporate the claimed cap assembly with its specific coupler engagement mechanism (Compl. ¶¶ 6, 51).

III. The Accused Instrumentality

Product Identification

  • The accused products are Defendant TPC’s "CR Round Tin Jars" and "any and all similar child resistant containers" (Compl. ¶6).

Functionality and Market Context

  • The complaint alleges these products are child-resistant containers that TPC develops, makes, distributes, and sells (Compl. ¶5). It further alleges that TPC provides these products to partners and distributors for resale and "instructs and encourages" them to package their own goods in the containers for sale to end consumers (Compl. ¶23). The complaint does not provide specific details on the technical operation of the accused products' child-resistant mechanism in its narrative sections.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

The complaint alleges infringement of all asserted patents but relies on references to external exhibits (Exhibits 4, 5, and 6) that were not provided with the pleading (Compl. ¶¶ 19, 35, 51). The complaint’s narrative body lacks specific factual allegations mapping features of the Accused Products to the elements of the asserted claims.

’375 Patent Infringement Allegations

The complaint conclusorily alleges that the Accused Products meet all limitations of the asserted claims of the ’375 Patent but provides no supporting factual detail in the body of the pleading (Compl. ¶19). A central question for the asserted independent claim 1 will be whether the accused "CR Round Tin Jars" contain a structure that meets the claim limitation of "a metal plate disposed between the inner cap and the outer cap, wherein the plate is rotationally and axially fixed relative to the outer cap." The infringement analysis will likely depend on whether the accused products have a distinct third component functioning as this plate, or whether they employ a two-component cap design.

’808 Patent Infringement Allegations

Similarly, the complaint alleges the Accused Products meet all limitations of the asserted claims of the ’808 Patent, again without providing specific factual support in the complaint itself (Compl. ¶35). For independent claim 20 of the ’808 Patent, the dispute may focus on the structural and functional characteristics of the "indentations stamped into" the respective caps. The analysis will require evidence of how the features on the accused product's caps are formed and how they interact when a user applies pressure.

Identified Points of Contention

  • Evidentiary Questions: The complaint’s reliance on un-provided exhibits raises the fundamental evidentiary question of what facts support the infringement allegations. Discovery will be required to determine the precise structure and operation of the accused "CR Round Tin Jars."
  • Structural Questions: A primary technical question is whether the accused products utilize a three-component cap assembly (inner cap, outer cap, and a distinct intermediate plate) as recited in claim 1 of the ’375 Patent, or a two-component assembly (inner and outer caps with integral features) as recited in claim 20 of the ’808 Patent.

V. Key Claim Terms for Construction

  • The Term: "a metal plate disposed between the inner cap and the outer cap" (from ’375 Patent, Claim 1)
  • Context and Importance: This term is a critical structural limitation of claim 1 of the ’375 Patent. The determination of whether this element is present in the accused product, either as a separate component or an integral feature, will likely be dispositive of infringement for this claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the "plate" can be a "disk, cap (e.g., middle cap) or other structure," and that it can be coupled to the outer cap in any manner, including by being "formed simultaneously" with rolled edges (’375 Patent, col. 13:3-5, 13:19-24). This language could support an argument that an integrally formed internal structure of the outer cap functions as the claimed "plate."
    • Evidence for a Narrower Interpretation: The claim language "disposed between" and the term "plate" itself suggest a distinct component. Figures in the patent depict the plate (110) as a separate element assembled between the outer cap (102) and inner cap (105), which may support an interpretation requiring a physically separate piece of material (’375 Patent, Fig. 6).
  • The Term: "indentations stamped into a top of the inner cap" (from ’808 Patent, Claim 20)
  • Context and Importance: The child-resistant functionality of the invention claimed in the ’808 Patent depends entirely on the engagement of these "indentations." Their shape, method of formation ("stamped into"), and interaction under pressure are central to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The common specification describes these features as capable of being "stamped, molded, debossed or otherwise formed" and shows various patterns, such as a cross shape or separate rectangles (’808 Patent, col. 9:39-42; Figs. 5A-5B). This may support construing the term to cover a variety of shapes and manufacturing methods beyond literal stamping.
    • Evidence for a Narrower Interpretation: The explicit use of the term "stamped into" could be argued to limit the claim to a specific manufacturing process involving pressing a die into the metal. Furthermore, the specification discloses specific wall angles for the indentations (e.g., 75 degrees for the "working edge" and 60 degrees for the "open edge"), which could be used to argue for a narrower functional scope related to preventing overtightening and enabling opening (’808 Patent, col. 5:40-50; Fig. 4).

VI. Other Allegations

Indirect Infringement

  • The complaint alleges inducement of infringement by asserting that TPC supplies the Accused Products to distributors and customers and "instructs and encourages" them to use the products in an infringing manner (i.e., packaging goods for sale) (Compl. ¶¶ 23, 39, 55). It alleges contributory infringement on the basis that the products are especially made for infringing use and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶ 26, 42, 58).

Willful Infringement

  • Willfulness is alleged based on pre-suit knowledge. The complaint asserts that TPC has been aware of the patents and its infringement since at least early-to-mid 2023, citing a conversation at a conference and a subsequent licensing inquiry sent by TPC’s agent on July 6, 2023 (Compl. ¶¶ 13, 29, 45, 61). Plaintiff alleges that despite this knowledge, TPC continued its infringing conduct (Compl. ¶13).

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

  • A core issue will be one of structural interpretation: do the accused "CR Round Tin Jars" embody the specific three-component cap assembly recited in the ’375 Patent, which requires a distinct "metal plate," or do they utilize a two-component design with integral features more aligned with the "indentations" claimed in the ’808 Patent? The answer will likely determine which, if any, patent is most relevant to the accused technology.
  • A key evidentiary question will be one of factual correspondence: as the complaint lacks specific technical allegations in its main body, the case will depend on evidence developed in discovery to demonstrate how, precisely, the mechanism of the accused products maps to the specific structural and functional limitations of the asserted claims.
  • A critical question for damages will be willfulness: can the plaintiff prove its allegations that the defendant had actual knowledge of the patents-in-suit as of mid-2023, based on an alleged conference discussion and licensing inquiry, and deliberately disregarded the plaintiff's patent rights?