DCT
2:25-cv-10939
Jiangxi Yibo E Tech Co Ltd v. ML Products Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Jiangxi Yibo E-Tech Co. Ltd. (People's Republic of China)
- Defendant: ML Products Inc. (California)
- Plaintiff’s Counsel: Hawkinson Yang LLP
- Case Identification: 2:25-cv-10939, C.D. Cal., 11/14/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant resides there, maintains a regular and established place of business in the district, and has committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s compatible toner cartridges for Brother printers infringe a patent related to the internal electrical architecture of developing cartridges.
- Technical Context: The technology concerns electrophotographic imaging, specifically the design of replaceable toner cartridges, a high-volume consumable product in the printer market.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2023-04-27 | U.S. Patent No. 12,197,145 Priority Date |
| 2025-01-14 | U.S. Patent No. 12,197,145 Issued |
| 2025-11-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,197,145 - "Developing Cartridge"
- Patent Identification: U.S. Patent No. 12,197,145, "Developing Cartridge," issued January 14, 2025 (the "'’145 Patent").
The Invention Explained
- Problem Addressed: The patent's background section describes conventional developing cartridges where a single electrode transmits power to both the developing roller shaft and the supply roller shaft (Compl. ¶12; ’145 Patent, col. 1:10-23). This approach is described as complicating the mechanical structure and increasing manufacturing costs due to the use of more conductive material (Compl. ¶12; ’145 Patent, col. 1:24-28).
- The Patented Solution: The invention claims to solve this problem by rerouting the electrical pathway within the cartridge. Instead of directly energizing the developing roller shaft, the patented design insulates the shaft with a "covering layer" and connects the external electrode to the "layer thickness regulating member" (a component, often a blade, that controls the amount of toner on the roller) (Compl. ¶12; ’145 Patent, col. 1:45-51). This design simplifies the electrode structure and reduces manufacturing costs (’145 Patent, col. 1:31-33).
- Technical Importance: This design change purports to reduce the complexity and material cost of a high-volume consumable product without compromising its function (’145 Patent, Abstract).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert other claims (’145 Patent, Compl. ¶18).
- Claim 1 of the ’145 Patent requires:
- A developing roller rotatable about a rotational axis
- A casing to accommodate developer
- An input gear rotatable about a first axis
- A layer thickness regulating member to regulate the developer layer on the roller
- An electrode with an electrical contact surface
- The developing roller comprises a shaft, a "covering layer" over the shaft, and an elastic layer
- The electrical contact surface is "electrically connected" to the layer thickness regulating member
- The covering layer is made of a "non-metallic material or an electrically insulating material"
III. The Accused Instrumentality
Product Identification
The accused products are sold under brand names including "Be Green Ink" and "BGI Eco Smart," and are specifically identified as the "Be Green Ink Compatible Toner Cartridge Replacement for Brother TN760" (the "TN760 cartridge") (Compl. ¶¶13-14).
Functionality and Market Context
The TN760 cartridge is alleged to be a developing cartridge for use in various models of Brother laser printers (Compl. ¶14). The complaint provides images of the accused product, which appears to be a standard third-party replacement toner cartridge. The complaint shows an exterior view of the accused TN760 cartridge (Compl. ¶20, Fig. 1). The product competes in the market for consumable printer supplies, offering an alternative to cartridges sold by the original equipment manufacturer.
IV. Analysis of Infringement Allegations
'145 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a developing roller rotatable about a rotational axis extending in a first direction; a casing configured to accommodate developer therein; | The TN760 cartridge allegedly includes a developing roller and a casing that holds toner. | ¶21 | col. 6:21-24 |
| an input gear rotatable about a first axis extending in the first direction, the input gear being positioned at one side of the casing in the first direction; | The TN760 cartridge allegedly includes an input gear on one side of its casing. The complaint provides an image showing the side of the cartridge with its gear train (Compl. ¶22, Fig. 3B). | ¶22 | col. 6:28-33 |
| a layer thickness regulating member configured to regulate a thickness of a developer layer carried on a surface of the developing roller; | The TN760 cartridge is alleged to include a layer thickness regulating member, depicted as a blade adjacent to the roller. An image highlights this component inside the cartridge (Compl. ¶23, Fig. 4). | ¶23 | col. 8:1-9 |
| an electrode with an electrical contact surface; | The TN760 cartridge is alleged to have an electrode with an external electrical contact surface. | ¶24 | col. 8:16-25 |
| wherein the developing roller comprises a developing roller shaft extending in the first direction, a covering layer covering a surface of the developing roller shaft, and an elastic layer rotating synchronously with the developing roller shaft; | The complaint alleges the TN760's developing roller has a shaft, a covering layer, and an elastic layer. | ¶25 | col. 6:47-57 |
| wherein the electrical contact surface is electrically connected to the layer thickness regulating member, | The complaint alleges a direct electrical connection between the contact surface and the regulating member, supported by a photograph of a multimeter showing a near-zero resistance reading between the two components (Compl. ¶26, Fig. 7). | ¶26 | col. 8:43-52 |
| and the covering layer is made of a non-metallic material or an electrically insulating material. | The complaint alleges the covering layer is insulating, supported by a photograph of a multimeter showing an open loop or infinite resistance reading when measuring between the layer and the shaft (Compl. ¶27, Fig. 8). | ¶27 | col. 7:1-2 |
Identified Points of Contention
- Scope Questions: The dispute may turn on whether the incidental physical contact between the cartridge's electrode assembly and the layer thickness regulating member, as shown in the complaint's multimeter test (Compl. ¶26, Fig. 7), meets the claim requirement of being "electrically connected." A defendant could argue this term implies a more deliberate, designed electrical pathway.
- Technical Questions: What level of resistance constitutes an "electrically insulating material" for the "covering layer"? The complaint provides a multimeter reading showing an open circuit, but the functional requirements for insulation within the patent's context may become a point of dispute requiring expert testimony.
V. Key Claim Terms for Construction
The Term: "electrically connected"
- Context and Importance: This term is central to the patent's novel contribution and the infringement allegation. The complaint's evidence rests on a multimeter showing electrical continuity between two components (Compl. ¶26, Fig. 7). The case may depend on whether this is sufficient to meet the claim limitation, or if a more specific type of connection is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain and ordinary meaning of the term suggests that if electricity can flow between two points, they are connected. The specification describes the second contact portion of the electrode "contact[ing] the blade holder" to "form an electrical connection" without specifying the type of contact required (’145 Patent, col. 8:49-52).
- Evidence for a Narrower Interpretation: A defendant may argue that in the context of the patent's figures and description, "electrically connected" implies a connection designed for the purpose of reliable power transmission, potentially distinguishing it from incidental contact between adjacent metal parts.
The Term: "covering layer ... made of a ... non-metallic material or an electrically insulating material"
- Context and Importance: The functionality of the invention relies on this layer preventing the developing roller shaft from being energized directly. Practitioners may focus on this term because the degree of insulation required is not quantified in the claim. The infringement allegation is supported by a multimeter test showing no continuity (Compl. ¶27, Fig. 8).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the disjunctive "or," suggesting that being made of any "non-metallic material" is independently sufficient, regardless of its specific insulating properties.
- Evidence for a Narrower Interpretation: The specification repeatedly frames the purpose of this layer as providing insulation (e.g., "the developing roller shaft 2a is insulated from the conductive member 6," ’145 Patent, col. 9:35-36). This purpose-driven context suggests the material must be sufficiently insulating to perform the function of preventing the shaft from receiving external power.
VI. Other Allegations
Indirect Infringement
The complaint includes a boilerplate allegation of indirect infringement, stating Defendant has "intentionally induc[ed] and/or contribut[ed] to the infringing activities of others" (Compl. ¶16). However, the complaint does not plead specific facts to support the knowledge and intent elements required for such claims, such as referencing user manuals or advertising that instruct on an infringing use.
Willful Infringement
The complaint does not contain an allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim scope and interpretation: Does the term "electrically connected," as used in Claim 1, encompass incidental but measurable electrical continuity between two separate components, as Plaintiff's multimeter evidence suggests, or does the patent require a more integrated and deliberate electrical pathway?
- A second core question will be evidentiary and functional: Assuming the court adopts Plaintiff's proposed claim construction, does the accused TN760 cartridge's "covering layer" provide sufficient electrical insulation in actual operation to meet the functional requirements described in the '145 Patent, and does the alleged connection to the regulating member serve the power transmission function central to the invention?