DCT
3:24-cv-05205
Globe Union Industrial Corp v. Meijie Faucet Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Globe Union Industrial Corp. (Taiwan)
- Defendant: Meijie Faucet Company, Ltd. (China)
- Plaintiff’s Counsel: Finnegan, Henderson, Farabow, Garrett & Dunner, LLP
- Case Identification: Globe Union Industrial Corp. v. Meijie Faucet Company, Ltd., 3:24-cv-05205, N.D. Cal., 08/15/2024
- Venue Allegations: Venue is alleged to be proper as Defendant is a foreign corporation that directs products to customers in the district, markets to California customers, and imports products through California ports.
- Core Dispute: Plaintiff alleges that Defendant’s faucets contain an integral plastic faucet member that infringes a patent on the structure of such a member, which is created via a two-step injection molding process.
- Technical Context: The technology relates to faucet manufacturing, specifically using plastic injection molding to create a lightweight, integrated waterway core as an alternative to heavier and more costly traditional metal casting methods.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with a notice of infringement on December 12, 2023.
Case Timeline
| Date | Event |
|---|---|
| 2008-10-22 | ’752 Patent Priority Date |
| 2013-03-19 | ’752 Patent Issue Date |
| 2023-12-12 | Plaintiff's notice of infringement to Defendant |
| 2024-08-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,397,752 - "Process for Fabricating Integral Plastic Faucet Member and Finished Product Thereof"
- Patent Identification: U.S. Patent No. 8,397,752, "Process for Fabricating Integral Plastic Faucet Member and Finished Product Thereof," issued March 19, 2013.
The Invention Explained
- Problem Addressed: The patent describes conventional faucet manufacturing, particularly copper casting, as complicated, time-consuming, and expensive. An alternative method of adhering separately molded plastic parts is described as having high labor costs and low bonding strength, affecting product quality and service life (’752 Patent, col. 1:11-66).
- The Patented Solution: The invention is a finished faucet member and a process for making it that involves two main injection molding steps. First, a hollow inner tube ("first part") is molded. This part is then placed into a second mold, and a "second part"—comprising the outer body and valve seats—is injection molded directly around the first part. This process creates a single, integrally bonded plastic component with a strong bond and a simplified manufacturing flow (’752 Patent, Abstract; col. 2:20-49).
- Technical Importance: This two-injection process was designed to simplify the manufacturing of faucets, improve production efficiency, lower costs, and reduce product weight compared to conventional copper casting (’752 Patent, col. 2:33-49).
Key Claims at a Glance
- The complaint asserts independent claim 1 (’752 Patent, col. 7:6-8:26; Compl. ¶11).
- Essential elements of Claim 1 include:
- A finished product of an integral plastic faucet member consisting of:
- A first part, integrally injection molded from plastic into a hollowly elongated tube shape, with inner water inlets and at least one inner water outlet.
- A second part, wrapped around the first part via integral injection of plastic, comprising a wrapping part and two valve seat parts.
- The wrapping part is integrally wrapped around the outer surface of the first part and has an outer water outlet.
- The two valve seat parts are connected to the wrapping part and have mounting grooves that communicate with the inner water inlets of the first part.
- Two copper members.
- The second part also includes two support leg parts extending from the valve seat parts.
- The first and second parts are integrally injection molded from glass fiber mixed with nylon.
- The support leg parts are engaged with and fixed to the two copper members, which have external threads.
III. The Accused Instrumentality
Product Identification
- The complaint accuses certain Webber Faucets, specifically model numbers 5288074 and 5288075, and faucets marketed under the Project Source brand (Compl. ¶9, 13).
Functionality and Market Context
- The accused products are bathroom faucets that allegedly contain an "integral plastic faucet member" that serves as the core internal waterway (Compl. ¶13). An exemplary image provided in the complaint shows this component as a single, H-shaped plastic body with threaded brass-colored legs, identified as the "faucet member in model no. 5288075" (Compl. p. 4). The complaint alleges these products are sold through major retail channels, including Lowe's, and compete with Plaintiff's products (Compl. ¶7, 9).
IV. Analysis of Infringement Allegations
U.S. Patent No. 8,397,752 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first part, integrally injection molded from a plastic material and formed in a hollowly elongated tube shape, | The accused faucet member includes "a first part, integrally injection molded from a plastic material and formed in a hollowly elongated tube shape." A photograph depicts this component (Compl. p. 6). | ¶14 | col. 5:1-3 |
| each of two ends of the first part having an inner water inlet...being communicated between two inner water inlets, | The accused member has two ends with inner water inlets that communicate through a flowing passage. An annotated photo shows the communication path (Compl. p. 6). | ¶15 | col. 5:3-5 |
| and at least one inner water outlet in communication with the flow passage being disposed at a predetermined position of the flow passage; | The accused member has at least one inner water outlet in communication with the flow passage. An annotated photo highlights this outlet (Compl. p. 7). | ¶16 | col. 5:5-8 |
| a second part, being wrapped around the first part through integral injection of a plastic material and at least comprising a wrapping part and two valve seat parts, | The accused member includes a "second part, being wrapped around the first part through integral injection of a plastic material" and comprising a wrapping part and valve seat parts. A close-up annotated photo identifies the distinct first and second parts (Compl. p. 7). | ¶17 | col. 5:9-12 |
| the wrapping part being integrally wrapped around an outer surface of the first part... | The "wrapping part C" is alleged to be "integrally wrapped around the outer space of the elongated part." An annotated photo identifies parts A, B, and C (Compl. p. 8). | ¶18 | col. 5:12-13 |
| the two valve seat parts being integrally connected to two end sides of the wrapping part, each valve seat part being formed with a mounting groove... | The accused member includes two valve seat parts connected to the wrapping part, each with a mounting groove that communicates with the inner water inlets. | ¶20 | col. 5:15-20 |
| and two copper members; | The accused faucet member is alleged to include "two copper members." A photograph shows the member with two threaded, brass-colored components (Compl. p. 9). | ¶21 | col. 8:8 |
| wherein the second part further comprises two support leg parts... | The second part of the accused member is alleged to comprise two support leg parts extending from the valve seat parts, with internal flow passages. | ¶22 | col. 8:9-19 |
| wherein the first part and the second part are integrally injection molded from a plastic material of glass fiber mixed with nylon; | The complaint alleges that for the accused member, "the first part and the second part are integrally injection molded from a plastic material of glass fiber mixed with nylon." | ¶23 | col. 8:20-22 |
| wherein the outer peripheral wall of each support leg part is engaged with and fixed to each of the two copper members, and two outer peripheral walls of the two copper members have external threads. | The accused member's support leg parts are alleged to be engaged with the two copper members, and the copper members have external threads. A close-up photo shows a threaded copper member (Compl. p. 10). | ¶24 | col. 8:23-26 |
- Identified Points of Contention:
- Scope Questions: Claim 1 uses the transitional phrase "consisting of," which is generally interpreted to be closed, meaning the product cannot contain other material components. A question for the court will be whether the accused "integral plastic faucet member" contains any structural elements not recited in Claim 1 that would place it outside the claim's scope.
- Technical Questions: The claim requires that the "second part" be "wrapped around the first part through integral injection." The complaint supports this with a photograph showing the alleged "first part" and "second part" in a cross-section (Compl. p. 7, 10). A central question may be what evidence, beyond visual inspection, demonstrates that the parts were formed via this specific over-molding process, as opposed to being joined by other means like welding or adhesives.
V. Key Claim Terms for Construction
The Term: "integrally injection molded" / "integral plastic faucet member"
- Context and Importance: These terms appear throughout Claim 1 and are central to defining the invention's manufacturing method and resultant structure. The dispute will likely focus on whether this language requires the specific two-step over-molding process described in the patent's specification, or if it can read on a product that is functionally a single piece but potentially made differently.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the focus is on the final "finished product," and that any product with the claimed structural elements that functions as a single, bonded "integral" piece meets the limitation, regardless of the precise molding sequence.
- Evidence for a Narrower Interpretation: The specification heavily details a specific process: a "first part is then taken out and positioned in a prearranged mold for a second plastic injection so as to mold a second part" (’752 Patent, col. 2:23-27). This suggests "integrally injection molded" is a term of art defined by the patent as this specific two-shot process, and a product made any other way would not be "integral" in the claimed sense.
The Term: "consisting of"
- Context and Importance: This transitional phrase in the preamble of Claim 1 makes the claim closed to unrecited elements. Practitioners may focus on this term because if the accused faucet member is found to contain additional structural components beyond the first part, second part, and two copper members, it may avoid infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that additional, non-functional or trace elements resulting from the manufacturing process do not remove the product from the scope of a "consisting of" claim.
- Evidence for a Narrower Interpretation: The plain meaning of "consisting of" excludes other components. A party could argue that any additional structural element, such as an embedded seal or a third plastic component, would mean the accused product does not meet this strict limitation. The analysis may depend on whether other small parts shown in the complaint's photographs, such as o-rings, are considered part of the claimed "faucet member" or are separate components added during final assembly (Compl. p. 5).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement (§ 271(b)) and contributory infringement (§ 271(c)) by alleging Defendant offers for sale and sells faucets containing the accused components to its customers (Compl. ¶11). The complaint does not plead specific facts detailing how Defendant's actions cause a third party (e.g., a customer) to infringe.
- Willful Infringement: The complaint alleges willfulness based on two grounds: constructive knowledge from Plaintiff's public identification of the patent on its website, and actual knowledge from a notice of infringement sent to Defendant on December 12, 2023 (Compl. ¶25-26).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: Does the transitional phrase "consisting of" in Claim 1 preclude infringement if the accused faucet member is found to contain any structural elements beyond those explicitly recited? The court's interpretation of this term will be critical.
- A second issue concerns the product-by-process doctrine: To prove infringement of the "finished product" claim, must Plaintiff demonstrate that Defendant's product is necessarily made by the specific two-step "integral injection" process described in the patent, or is it sufficient to show that the accused product possesses the final structure defined by the claim language?
- A key evidentiary question will be what proof is required to establish the internal structure and composition of the accused device. While the complaint provides annotated photographs, the allegation that the parts are "integrally injection molded from a plastic material of glass fiber mixed with nylon" may require discovery into Defendant's manufacturing processes and materials or destructive testing of the accused products.