DCT

2:25-cv-10240

Ecosafe Packaging LLC v. Gpa Global Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-10240, C.D. Cal., 10/24/2025
  • Venue Allegations: Venue is based on Defendant being a California company with a regular and established place of business in the Central District of California, including manufacturing, logistics, and service centers.
  • Core Dispute: Plaintiff alleges that Defendant’s "Linus" line of child-resistant metal containers infringes two patents related to mechanical locking systems for such containers.
  • Technical Context: The technology addresses the need for recyclable, resealable, and child-resistant packaging, particularly for products like those in the cannabis industry that may require enhanced preservation and material safety.
  • Key Procedural History: The complaint alleges significant pre-suit history, including business collaboration between Defendant and the patents’ inventor in early 2019 involving the exchange of product samples and technical specifications. It also alleges that Plaintiff’s counsel sent a cease-and-desist letter regarding the ’375 patent in December 2019, to which Defendant responded in March 2020 after analyzing the patent and its prosecution history. These allegations form the basis for claims of willful infringement.

Case Timeline

Date Event
2018-04-12 Earliest Patent Priority Date (’375 and ’182 Patents)
2019-01-01 Alleged business collaboration between Defendant and inventor begins
2019-12-23 Application for ’182 Patent filed
2019-12-24 ’375 Patent issues
2019-12-24 Cease-and-desist letter regarding ’375 Patent sent to Defendant
2020-03-01 Defendant responds to cease-and-desist letter
2022-11-08 ’182 Patent issues
2025-10-24 Complaint filed

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

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

  • Patent Identification: U.S. Patent No. 10,513,375, titled "Metal Child Resistant Container," issued December 24, 2019 (Compl. ¶9).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies shortcomings in existing child-resistant packaging. Some types, like blister packs, are not resealable, while others, like plastic bottles, are not easily recycled, may leach chemicals, and may not adequately preserve contents from UV light degradation (’375 Patent, col. 1:28-62).
  • The Patented Solution: The invention is a child-resistant container, typically made of metal, featuring a multi-part cap assembly. This assembly includes an inner cap that engages the container body and an outer cap that can spin freely over it. A user must apply downward pressure to the outer cap to cause a "second coupler" (e.g., a tongue) on an intermediate plate to engage a "first coupler" (e.g., a groove) on the inner cap. This engagement locks the caps together, allowing the user to twist the assembly to open or close the container (’375 Patent, col. 2:30-50; Abstract).
  • Technical Importance: This design makes a child-resistant mechanism available for metal containers, which are often preferred for their recyclability and ability to protect sensitive contents (’375 Patent, col. 1:51-57).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-3, 5-7, 12-13, 15, and 17 (Compl. ¶18).
  • The essential elements of independent claim 1 include:
    • A container body and a cap assembly.
    • The cap assembly comprises a metal inner cap and a metal outer cap.
    • A metal plate is disposed between the inner and outer caps and is "rotationally and axially fixed relative to the outer cap."
    • A first coupler (comprising a groove) is coupled to the inner cap.
    • A second coupler (comprising a tongue) is coupled to the plate and is configured to engage the first coupler.
    • The outer cap can move between a first (disengaged) position where it rotates freely and a second (engaged) position where the couplers engage to allow for rotation of the inner cap.
  • The complaint states that Plaintiff may assert additional claims (Compl. ¶17).

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

  • Patent Identification: U.S. Patent No. 11,492,182, titled "Child Resistant Container," issued November 8, 2022 (Compl. ¶10).

The Invention Explained

  • Problem Addressed: The ’182 Patent addresses the same technical problems as its parent, the ’375 Patent: the need for a recyclable, resealable, and effective child-resistant metal container (’182 Patent, col. 1:32-66).
  • The Patented Solution: The ’182 Patent claims the cap assembly itself rather than the entire container. The described solution is structurally similar, involving an inner cap, an outer cap, and an intermediate plate fixed to the outer cap. The claims use more generic terms for the interlocking mechanism, referring to a "female coupler" and a "male coupler" that engage upon downward pressure, allowing the inner and outer caps to rotate in unison (’182 Patent, col. 4:20-56; Abstract).
  • Technical Importance: The invention provides a modular cap assembly that can be adapted to various container bodies while offering the benefits of a metal, child-resistant design.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 20 and dependent claims 2-4, 6, 7, 9, 10, 14, 15, 17, and 19 (Compl. ¶34).
  • The essential elements of independent claim 1 (a cap assembly) include:
    • A metal inner cap and a metal outer cap.
    • A plate disposed between the caps that is "rotationally and axially fixed relative to the outer cap."
    • A "female coupler" coupled to either the inner cap or the plate.
    • A "male coupler" coupled to the other of the inner cap or the plate.
    • The outer cap can move between a first position where it rotates freely relative to the inner cap and a second position where the female and male couplers engage to fix the caps for rotation together.
  • The complaint states that Plaintiff may assert additional claims (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

  • Defendant GPA’s "Linus" round tins and other similar child-resistant containers (collectively, the "Accused Products") (Compl. ¶6).

Functionality and Market Context

  • The complaint alleges the Accused Products are child-resistant containers marketed for use in the cannabis industry (Compl. ¶¶11, 26 fn. 2). The complaint does not provide technical details on the mechanism of the Accused Products beyond alleging that they meet the limitations of the asserted claims (Compl. ¶¶19, 35). The complaint alleges these products are developed, designed, made, distributed, marketed, and sold by GPA within the district and throughout the United States (Compl. ¶5).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 3 and 4) that were not provided with the filed document. The infringement theory is therefore summarized from the complaint’s narrative allegations.

  • ’375 Patent Infringement Allegations: The complaint alleges that the Accused Products directly infringe at least claim 1 of the ’375 Patent because they are child-resistant metal containers that embody each element of the claim (Compl. ¶¶18-19). The core of the infringement theory is that the Accused Products possess a cap assembly comprising a metal inner cap, a metal outer cap, and a separate metal plate fixed to the outer cap. This plate allegedly contains a "tongue" that engages a "groove" on the inner cap when a user presses down on the outer cap, thereby allowing the container to be opened (Compl. ¶19; ’375 Patent, Claim 1).
  • ’182 Patent Infringement Allegations: The complaint alleges the Accused Products directly infringe at least claim 1 of the ’182 Patent by embodying the claimed cap assembly (Compl. ¶¶34-35). The infringement theory is parallel to the ’375 Patent allegations: the Accused Products’ caps allegedly consist of a metal inner cap, a metal outer cap, and a fixed intermediate plate. One of these components includes a "female coupler" and another includes a "male coupler," which engage upon downward pressure to facilitate opening (Compl. ¶35; ’182 Patent, Claim 1).
  • Identified Points of Contention:
    • Structural Questions: The central technical dispute may concern the structure of the Accused Products’ cap assembly. A key question is whether the accused "Linus" tins contain the specific three-part structure required by the claims: a distinct inner cap, outer cap, and an intermediate "metal plate" that is "rotationally and axially fixed" to the outer cap. The litigation may focus on whether the accused device achieves its child-resistance function with a different mechanical configuration, such as a two-piece cap where features are integrally formed on the outer cap rather than on a separate plate.
    • Scope Questions: The definition of the couplers will also be at issue. The analysis will raise the question of whether the specific mechanism within the Accused Products functions as the claimed "groove" and "tongue" (’375 Patent) or can be properly characterized as the broader "female coupler" and "male coupler" (’182 Patent).

V. Key Claim Terms for Construction

  • The Term: "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" (from ’375 Patent, Claim 1 and ’182 Patent, Claim 1).
  • Context and Importance: This limitation is the structural linchpin of the asserted independent claims in both patents. The infringement analysis for both patents will depend on whether the Accused Products contain a component that meets this definition of a separate, intermediate, and fixed plate. Practitioners may focus on this term because a finding that the Accused Product uses a two-piece cap without such a distinct plate could be dispositive of non-infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes embodiments using a "center or locking plate" that can be "affixed to the inside of outer cap 102" or otherwise "rotationally fixed relative to outer cap 102 mechanically" (’375 Patent, col. 14:4-8; col. 13:40-42). This language may support a construction that covers various methods of attachment for a distinct component.
    • Evidence for a Narrower Interpretation: The specification also describes an alternative embodiment where the "center plate 110 can be absent and one or more indentations 106, 111 can be embossed or otherwise manufactured into the superior exterior surface plane of outer cap 102" (’375 Patent, col. 14:48-52). A party could argue that because the patent explicitly teaches an alternative design without a plate, the term "plate" in the claims must be construed as a structurally separate component, not an integral feature of the outer cap.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement theory is based on allegations that GPA provides the Accused Products to customers with instructions and encouragement to use them in an infringing manner (i.e., by packaging goods in them for sale) (Compl. ¶¶23, 39). The contributory infringement theory is based on allegations that the Accused Products are especially made to practice the patented inventions and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶¶26, 42).
  • Willful Infringement: The complaint alleges willful infringement of both patents based on pre-suit knowledge (Compl. ¶¶29, 45). For the ’375 Patent, knowledge is alleged from business collaborations with the inventor in 2019 and a cease-and-desist letter sent in December 2019, which GPA allegedly analyzed (Compl. ¶¶12-13). For the ’182 Patent, knowledge is alleged from its issuance date in November 2022, based on GPA’s position as a competitor and awareness of the patent family through product markings and prior dealings (Compl. ¶13).

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

  • A core issue will be one of structural identity: Does the accused "Linus" container utilize the specific three-part cap assembly—an inner cap, an outer cap, and a separate, fixed intermediate "metal plate"—recited in the asserted claims, or does it achieve a similar function through a different mechanical design that falls outside the literal scope of the claims?
  • A key evidentiary question will be one of scienter and intent: What evidence exists from the alleged 2019 collaboration and subsequent cease-and-desist correspondence to establish that GPA had pre-suit knowledge of its alleged infringement, and does this conduct rise to the level of willfulness required for enhanced damages?