DCT

5:24-cv-01843

Nine Stars Group USA Inc v. Guangzhou Eko Trading Development Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Nine Stars Group (USA.) Inc. v. Guangzhou Eko Trading Development Co., Ltd., et al., 5:24-cv-01843, C.D. Cal., 12/31/2024
  • Venue Allegations: Venue is asserted based on the foreign residency of two defendants, which allows suit in any judicial district, and on the basis that all defendants offer to sell and sell the accused products to customers within the Central District of California.
  • Core Dispute: Plaintiff alleges that Defendant’s automatic trash cans infringe patents related to waterproof design features and power-saving electronic control methods.
  • Technical Context: The patents concern technologies for improving the durability and battery life of motion-activated trash containers, a common consumer electronics product.
  • Key Procedural History: The complaint is a Second Amended Complaint. Plaintiff alleges it provided Defendants with notice of infringement via a cease and desist letter dated February 3, 2024, prior to the initiation of the lawsuit.

Case Timeline

Date Event
2016-09-20 ’165 Patent Priority Date
2017-04-07 ’796 Patent Priority Date
2020-11-03 ’165 Patent Issue Date
2021-02-23 ’796 Patent Issue Date
2024-02-03 Alleged date of cease and desist letter
2024-12-31 Complaint Filing Date

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

U.S. Patent No. 10,822,165 - "Waterproof Induction Actuated Container," issued Nov. 3, 2020

The Invention Explained

  • Problem Addressed: The patent's background section describes how conventional motion-activated containers expose sensitive electrical and mechanical components to moisture, corrosive gases, and trash residuals from the main storage cavity, which can lead to damage and a shortened product lifespan (’165 Patent, col. 2:1-7).
  • The Patented Solution: The invention proposes a container lid with a "control housing" that includes "first and second side concealed compartments" (’165 Patent, col. 3:57-58). The "actuation unit" (e.g., motor and gears) and other electronics are sealed within these compartments in a "waterproof manner," isolating them from the container's opening and protecting them from contamination (’165 Patent, Abstract; col. 5:32-38).
  • Technical Importance: The design addresses a key durability and reliability issue for electronic appliances that must function in potentially wet or dirty consumer environments.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶17).
  • The essential elements of claim 1 include:
    • A container body with a storage cavity and an opening.
    • An induction-actuated container cover comprising:
      • A "control housing" with "first and second side concealed compartments" at a rear portion.
      • A "cover unit" with a "pivot shaft" whose ends extend into the concealed compartments.
      • An "automatic driving arrangement" with a sensor and an "actuation unit" that is itself "concealed in said first side concealed compartment".
      • An "element arranged to initially push up said cover panel".

U.S. Patent No. 10,928,796 - "Induction Trash Can Circuit Standby Power-Saving Method," issued Feb. 23, 2021

The Invention Explained

  • Problem Addressed: The patent identifies that conventional motion-activated trash cans consume significant power while in standby mode, awaiting a user's motion. This "standby power consumption" is noted to be much greater than the power used for the actual lid-opening action, resulting in short battery life (’796 Patent, col. 2:26-58).
  • The Patented Solution: The invention claims a power-saving method where the device's microcontroller periodically enters a "sleep state." During sleep, power to the active infrared sensor is cut off. A watchdog timer wakes the microcontroller at preset intervals to emit a brief infrared pulse to check for a user. If no user is detected, it immediately returns to the sleep state, drastically reducing overall energy use (’796 Patent, Abstract; Fig. 2).
  • Technical Importance: The method addresses a critical consumer issue—frequent battery replacement—by significantly improving the energy efficiency of the device's standby operation.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶24).
  • The essential elements of claim 1 include:
    • A power-saving method for an induction trash can circuit, comprising steps of:
    • "Controlling an active infrared sensor to emit an infrared pulse signal" via a microcontroller in a standby state.
    • "Setting a microcontroller into a sleep state" if no reflection signal is received, wherein in the sleep state, the microcontroller "cuts off a power of the active infrared sensor".
    • Remaining in a "working state" if a reflection signal is received and controlling a motor to open a lid.
    • Using a "watchdog timer" to wake the microcontroller from the sleep state to repeat the process.

III. The Accused Instrumentality

Product Identification

The complaint identifies "Defendants' Automatic Trash Can, 13.2 Gal, part number WM9226-50L" and "all reasonably similar products" as the Accused Products (Compl. ¶¶17, 24).

Functionality and Market Context

The complaint alleges these are motion-activated trash cans sold to retail customers, including through the Walmart website (Compl. ¶¶17, 26). The specific technical details of the accused products' internal structure and control logic are not described in the body of the complaint; instead, the complaint states that this information is detailed in claim chart exhibits which were not provided for this analysis (Compl. ¶¶18, 25).

IV. Analysis of Infringement Allegations

The complaint alleges that detailed infringement comparisons are contained in Exhibits B and D, which were not provided. The narrative infringement theories are summarized below. No probative visual evidence provided in complaint.

  • ’165 Patent Infringement Allegations

    • The complaint asserts that the Accused Products directly infringe at least claim 1 of the ’165 Patent (Compl. ¶¶17-18). The narrative theory suggests that the Accused Products embody the claimed invention by having a lid structure that isolates the motor and associated electronics within sealed or "concealed" compartments, separate from the main container opening, thereby allegedly protecting them in a "waterproof manner" as required by the claim (Compl. ¶¶17-18).

  • ’796 Patent Infringement Allegations

    • The complaint asserts that the Accused Products directly infringe at least claim 1 of the ’796 Patent by performing the claimed power-saving method (Compl. ¶¶24-25). The infringement theory is that the control circuitry of the Accused Products, during standby, places its microcontroller into a low-power "sleep state" and uses a timer to periodically wake it to check for a user's presence, allegedly cutting power to the sensor during the sleep cycle as recited in the claim (Compl. ¶¶24-25).

  • Identified Points of Contention:

    • Structural Questions (’165 Patent): A central question for the ’165 Patent will be structural. What evidence does the complaint provide that the compartments in the accused product's lid assembly qualify as "concealed compartments" that are sealed in a "waterproof manner" as those terms are used and described in the patent?
    • Functional Questions (’796 Patent): For the ’796 Patent, the dispute may focus on the specific operational logic of the accused product's control circuit. The analysis will question whether the accused device's "sleep state" includes the specific step of "cut[ting] off a power of the active infrared sensor" as required by claim 1, or if it utilizes an alternative low-power mode that does not meet this limitation.

V. Key Claim Terms for Construction

  • Term from ’165 Patent: "concealed compartment"

    • Context and Importance: This term is the central structural feature of the ’165 Patent's invention, intended to provide waterproof protection. The infringement analysis for the ’165 Patent will depend heavily on whether the accused product's internal housing is construed to be a "concealed compartment."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the purpose of the compartments is to "prevent any contamination of the electrical and mechanical components by moisture, corrosive gas, and/or trash residuals" (’165 Patent, col. 2:39-44). A party may argue that any structure achieving this protective isolation meets the definition.
      • Evidence for a Narrower Interpretation: The patent describes specific embodiments where the compartments are at the "rear portion of the control housing" and the housing has a "trapezoid cross section" to maximize their size (’165 Patent, col. 5:17-18, 5:40-44). A party could argue the term is limited to structures reflecting these specific disclosed characteristics.

  • Term from ’796 Patent: "sleep state"

    • Context and Importance: The definition of this term is critical to the method claim. The dispute will likely turn on what actions must occur for the microcontroller to be considered in a "sleep state" according to the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Practitioners may argue that "sleep state" is a general term in electronics referring to a variety of low-power modes, and that any such mode fulfills the claim's purpose.
      • Evidence for a Narrower Interpretation: Claim 1 itself appears to define the term, stating: "setting a microcontroller into a sleep state... wherein in the sleep state, the microcontroller cuts off a power of the active infrared sensor" (’796 Patent, col. 8:17-22). This language provides strong intrinsic evidence that the "sleep state" must include the specific action of cutting power to the sensor, not merely reducing it.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges contributory infringement for both patents. The factual basis is that Defendants provide the Accused Products to retail customers and end-users, whose subsequent use of the products constitutes direct infringement (Compl. ¶¶31, 38). This theory is particularly relevant for the method claims of the ’796 patent.
  • Willful Infringement: Willfulness is alleged based on Defendants having "direct prior knowledge" of the patents and their infringement, citing a cease and desist letter sent on or about February 3, 2024 (Compl. ¶¶20, 27). This alleges both pre-suit and ongoing post-suit willfulness.

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

The resolution of this case may depend on the court’s determination of the following key questions:

  1. A core issue will be one of structural definition: can the term "concealed compartment," as described in the ’165 Patent, be construed to read on the specific internal housing design of the accused trash can, and does that housing operate in the claimed "waterproof manner"?
  2. A second central issue will be one of functional specificity: does the accused product’s power-saving software execute the precise method of the ’796 Patent’s claim 1, specifically by "cut[ting] off a power of the active infrared sensor" during its "sleep state", or does it achieve energy efficiency through a technically distinct, non-infringing process?