Reiley v. Saldana

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CureTube (California)
  • Defendant: Santino Saldana, Cure Lids (Jurisdiction not specified)
  • Plaintiff’s Counsel: Pro Se
• Case Identification: 3:25-cv-00106, S.D. Cal., 01/15/2025
• Venue Allegations: The complaint header indicates filing in the Central District of California, but the filing stamp is from the clerk for the Southern District of California. The complaint does not contain specific allegations to establish the basis for venue in either district.
• Core Dispute: Plaintiff alleges that Defendant’s specialized container lids infringe two patents related to humidity control and access features, and further alleges breach of an exclusive distribution agreement between the parties.
• Technical Context: The technology concerns lids for storage containers, such as commercial drums, designed to preserve humidity-sensitive contents like agricultural products by integrating features for monitoring, access, and humidity regulation.
• Key Procedural History: The complaint alleges that the parties entered into an "Exclusive Distribution Agreement" in July 2024. The current dispute appears to stem from alleged breaches of this agreement, including Defendant’s independent marketing of allegedly infringing products, which Plaintiff claims led to the filing of this suit.

Case Timeline

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

U.S. Patent No. 11,230,414 - "LID FOR CONTAINERS AND RELATED METHODS," issued January 25, 2022

The Invention Explained

• Problem Addressed: The patent identifies a need for a more efficient way to manage the contents of commercial storage drums, particularly for humidity-sensitive agricultural products. Conventional lids are described as cumbersome to remove and lack integrated means for monitoring or adjusting internal humidity. (’414 Patent, col. 1:46 - col. 2:17).
• The Patented Solution: The invention is a multi-function lid that aims to solve these problems by combining several features. It includes a hygrometer for monitoring humidity, a hatch that allows access to the container's contents without removing the entire lid, an underside pocket to hold humidity-regulating packs, and an erasable surface for labeling. (’414 Patent, Abstract; col. 4:6-53). This combination transforms a standard container into a humidity-controlled environment.
• Technical Importance: The invention provides an all-in-one system for preserving stored goods, integrating monitoring, access, and humidity control features that were previously handled by separate, less convenient means. (’414 Patent, col. 1:53-65).

Key Claims at a Glance

The complaint does not specify which claims are asserted. Independent Claim 1 appears to cover the core combination of features. Its essential elements include:

• A lid with a first and second half.
• A circular rim to attach the lid to a container.
• A hygrometer on the lid's topside.
• A semi-circular, openable hatch positioned over an opening in the lid.
• A rectangular pocket on the lid's underside for holding at least one humidity pack.
• A rectangular label surface on the lid's topside.

U.S. Patent No. 11,814,218 - "LID FOR CONTAINERS AND RELATED METHODS," issued November 14, 2023

The Invention Explained

• Problem Addressed: The '218 Patent addresses the same general problems as the '414 Patent regarding access and humidity control for storage containers. (’218 Patent, col. 1:50 - col. 2:16).
• The Patented Solution: This patent discloses additional features that build upon the earlier invention. A key addition is an "interior lattice insert" designed to function as a trimmer or sifter for agricultural products stored inside the container, separating desirable material from undesirable material (e.g., dry leaves) when the container is tumbled or rotated. (’218 Patent, col. 7:7-35). The specification also describes more advanced "auto-burp" systems using powered pumps to automatically regulate air exchange and humidity. (’218 Patent, col. 6:48-65).
• Technical Importance: This patent extends the concept of an integrated storage solution by adding automated processing and sorting capabilities directly into the container lid system. (’218 Patent, col. 7:21-26).

Key Claims at a Glance

The complaint does not specify which claims are asserted. Independent Claim 1 is representative of the invention. Its essential elements are largely similar to Claim 1 of the ’414 Patent but add a key limitation:

• A lid with a topside, underside, rim, hygrometer, hatch, pocket, and label surface.
• An interior lattice insert.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are products promoted and sold by Defendants under the brand "Cure Lids." (Compl. ¶15).

Functionality and Market Context

The complaint alleges the accused products incorporate features patented by CureTube, specifically "a dry-erase sticker identical to CureTube's patented design" and an "automatic air exchange ('auto-burping') mechanism." (Compl. ¶18). The complaint claims that Defendant admitted to selling 500 units of the "infringing product" for an estimated total of $60,000. (Compl. ¶17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or specify asserted claims. The following analysis is based on a reading of representative Independent Claim 1 for each patent against the general allegations in the complaint.

’414 Patent Infringement Allegations

• Identified Points of Contention:
  • Evidentiary Questions: The complaint's allegations focus on a "dry-erase sticker" and an "auto-burping" mechanism (which is not an element of independent claim 1). A central issue will be whether Plaintiff can provide evidence that the accused "Cure Lids" product contains the hygrometer, hatch, and humidity pack pocket required by Claim 1. The complaint is silent on these elements.

’218 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The primary question for this patent is factual: does the accused product contain an "interior lattice insert"? Claim 1 of the ’218 Patent requires this element. The complaint makes no mention of such a feature in the accused product, raising a significant question as to whether Plaintiff has stated a plausible claim for infringement of this patent.

V. Key Claim Terms for Construction

• The Term: "interior lattice insert"
• Context and Importance: This term is a required limitation of the representative independent claim of the ’218 Patent. As the complaint does not allege the presence of this feature in the accused product, its construction will be critical to determining if any component of the accused product could meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the insert's function broadly as a "trimmer for the agricultural product" that "separate[s] the larger agricultural material from the smaller material that has been trimmed." (’218 Patent, col. 7:21-35).
  • Evidence for a Narrower Interpretation: Specific embodiments and figures describe the insert as a removable, cylindrical structure with a "crisscross pattern with multiple equally-sized squares" of a particular dimension (e.g., ½ to ¾ inches) designed to "catch dry leaf matter." (’218 Patent, col. 7:40-52; FIG. 16-18).

VI. Other Allegations

• Indirect Infringement: The complaint does not plead a separate count for indirect infringement and does not allege specific facts to support the requisite knowledge and intent beyond the general allegation of distributing the product. (Compl. ¶4).
• Willful Infringement: The complaint alleges "willful patent infringement." (Compl. ¶1). This allegation may be based on the prior business relationship between the parties via the "Exclusive Distribution Agreement," which could be used to argue Defendant had pre-suit knowledge of the patents-in-suit. (Compl. ¶3). The complaint also alleges Defendant was "confronted about their breaches" before allegedly terminating the agreement, which may further support knowledge. (Compl. ¶4).

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

1. Evidentiary Sufficiency: A threshold issue will be whether the Plaintiff can produce evidence that the accused "Cure Lids" product practices all elements of the asserted claims. The complaint's allegations are silent on several key limitations recited in the patents, such as the hygrometer, access hatch, humidity pack pocket, and, most notably, the "interior lattice insert."

2. Correspondence of Accusation to Claim Scope: The case for the '218 Patent will likely turn on a fundamental question of factual correspondence. Can the Plaintiff show that the accused product contains an "interior lattice insert" as required by the patent's independent claim? The complaint's failure to allege facts supporting this element raises a substantial question about the infringement theory for this patent.

3. Interplay of Contract and Patent Law: A key strategic question will be how the parties' prior contractual relationship influences the patent dispute. While the "Exclusive Distribution Agreement" may provide strong evidence for willfulness, it also frames the conflict as a business dispute between former partners, which could complicate the narrative and potential remedies sought for patent infringement versus breach of contract.