Reiley v. Twister Tech Keirton Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Adrian Reiley and Nadiah Reiley (Hawaii)
  • Defendant: Keirton USA, Inc. d/b/a Twister Technologies (Washington)
  • Plaintiff’s Counsel: Pro Se
• Case Identification: 3:25-cv-00799, D. Or., 06/26/2025
• Venue Allegations: Venue is alleged to be proper based on the Defendant conducting business and committing acts of infringement within the District of Oregon.
• Core Dispute: Plaintiffs allege that Defendant’s "Cure Puck" product infringes three patents related to specialized lids for container-based curing systems that provide for humidity monitoring, automated venting, and wireless environmental sensing.
• Technical Context: The technology addresses environmental control for storing and curing agricultural products, a critical factor for quality preservation in industries such as cannabis, herbs, and specialty foods.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date	Event
2017-12-27	Earliest Priority Date for Asserted Patents
2020-07-28	U.S. Patent No. 10,723,535 Issues
2022-01-25	U.S. Patent No. 11,230,414 Issues
2023-11-14	U.S. Patent No. 11,814,218 Issues
2025-06-26	Complaint Filed

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

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

• Patent Identification: U.S. Patent No. 11814218, "LID FOR CONTAINERS AND RELATED METHODS," issued November 14, 2023.

The Invention Explained

• Problem Addressed: The patent describes that traditional lids for commercial storage drums (e.g., fiber drums) used for agricultural products are cumbersome to use. They often require a "lever locking mechanism" that makes removal difficult and do not provide a way to monitor the internal humidity without opening the container, which can negatively affect the contents (’218 Patent, col. 1:50-64).
• The Patented Solution: The invention is a multi-function lid designed to solve these problems. It incorporates a hygrometer to display humidity levels, a hatch that allows access to the contents without removing the entire lid, and a pocket on the underside to hold humidity-control packs (’218 Patent, col. 4:10-28). This patent further discloses an "interior lattice insert" that can be placed inside the container to function as a trimmer or sifter for the agricultural product as the container is rotated (’218 Patent, col. 7:7-20).
• Technical Importance: The technology aims to improve quality control and efficiency in the post-harvest curing process for humidity-sensitive products by integrating monitoring, access, and environmental adjustment into a single device (’218 Patent, col. 2:11-15).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" (Compl. ¶15) but does not identify any specific claims asserted. Independent claim 1 is representative of the core technology.

• Independent Claim 1:
  • A lid for transforming a non-humidity controlled container into a humidity controlled container, comprising:
  • a topside and an underside;
  • a webbing connected to the underside of the lid;
  • an extract container connected to the webbing;
  • an interior lattice insert;
  • a circular rim configured to attach to the container;
  • a hygrometer on the topside adapted to monitor and digitally display humidity;
  • a semi-circular hatch for accessing contents without removing the lid;
  • a rectangular pocket on the underside for at least one humidity pack; and
  • a rectangular label surface on the topside.

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

• Patent Identification: U.S. Patent No. 11230414, "LID FOR CONTAINERS AND RELATED METHODS," issued January 25, 2022.

The Invention Explained

• Problem Addressed: Similar to its continuation, the '414 Patent addresses the lack of integrated humidity monitoring and convenient access in conventional lids for commercial storage containers (’414 Patent, col. 2:1-14).
• The Patented Solution: The '414 Patent discloses a lid with a hygrometer, access hatch, and humidity pack pocket, but adds automated and wireless capabilities. The solution includes a "closable valve" to regulate air exchange, which can be controlled wirelessly to perform an "autoburp feature," and a means to transmit humidity and temperature data to a mobile device via Bluetooth (’414 Patent, col. 4:60-67; col. 5:1-10).
• Technical Importance: This invention introduces automation and remote monitoring to the container-curing process, allowing for more precise environmental control without manual intervention (’414 Patent, col. 2:29-33).

Key Claims at a Glance

The complaint does not specify which claims are asserted (Compl. ¶15). Independent claims 1, 9, and 16 are available for assertion.

• Independent Claim 9:
  • A lid for augmenting a container, comprising:
  • a topside and an underside;
  • a rim configured to be secured around a container edge;
  • a hinged hatch for allowing access to contents;
  • a digital display hygrometer on the topside;
  • a pocket with vents on the underside for humidity packs;
  • a valve configured to connect the topside to the underside; and
  • means for wireless transmission of data to a mobile device.

U.S. Patent No. 10,723,535 - "LID FOR CONTAINERS AND RELATED METHODS"

• Patent Identification: U.S. Patent No. 10723535, "LID FOR CONTAINERS AND RELATED METHODS," issued July 28, 2020.

Technology Synopsis

The '535 Patent, the earliest in the asserted family, discloses the foundational technology: a lid for agricultural storage containers that integrates features for improved usability and environmental control. The invention aims to solve the problem of cumbersome lid removal and lack of humidity visibility by providing a lid with a built-in hygrometer, a hatch for easy access, and an underside pocket for holding humidity-regulating packs (’535 Patent, Abstract; col. 2:6-10).

Asserted Claims

The complaint asserts infringement of "one or more claims" but does not specify which ones (Compl. ¶15). Independent claims 1 and 11 are available for assertion.

Accused Features

The complaint alleges the "Cure Puck" product infringes by incorporating features such as automated venting, wireless sensing, and a hygrometer display (Compl. ¶2-3).

III. The Accused Instrumentality

Product Identification

The "Cure Puck" (Compl. ¶3).

Functionality and Market Context

The complaint provides a high-level functional description of the accused product, alleging it incorporates patented features including "(a) automated venting (auto-burping), (b) wireless environmental sensing and transmission, (c) digital or external hygrometer display, and (d) methods for converting a sealed container into an environmentally controlled curing device" (Compl. ¶2). The complaint alleges Defendant is "selling and marketing" the product but provides no further details on its operation, design, or market position (Compl. ¶3). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide element-by-element infringement allegations, technical documentation, or visual evidence sufficient to construct a detailed claim chart. It alleges in general terms that the "Cure Puck" product infringes by incorporating features covered by the Asserted Patents (Compl. ¶3, ¶11, ¶15).

• Identified Points of Contention: Based on the minimal information provided, the following questions may frame the infringement dispute:
  • Scope Questions: The independent claims of the Asserted Patents recite a "lid" that includes a "circular rim" for attaching to a container. A threshold question will be whether the accused "Cure Puck" is itself a "lid" that meets these structural limitations, or if it is an accessory device that functions differently from the claimed invention.
  • Technical Questions: The complaint alleges features like "automated venting" and "wireless environmental sensing" (Compl. ¶2). A central evidentiary question will be whether the "Cure Puck" in fact performs these functions and, if so, whether the implementation meets the specific technical requirements of the asserted claims (e.g., the structure and operation of the "closable valve" recited in the '414 Patent).

V. Key Claim Terms for Construction

The complaint does not identify any claim terms for construction. However, based on the patent specifications, the following terms may be central to the dispute.

Term from the ’218 Patent

• The Term: "interior lattice insert" (from claim 1)
• Context and Importance: This element is a required feature of independent claim 1 of the '218 Patent. Whether the accused "Cure Puck" system includes a component that meets this definition will be dispositive for infringement of this claim and may differentiate the infringement case for the ’218 Patent from the other asserted patents.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the element functionally as a "trimmer for the agricultural product" that "may catch dry leaf matter and automatically trims and separates it" when the container is rotated (’218 Patent, col. 7:21-26). This could support an interpretation covering various types of internal sifters or sorting structures.
  • Evidence for a Narrower Interpretation: The patent depicts a specific embodiment in FIG. 16 as a cylindrical cage with a "crisscross pattern with multiple equally-sized squares" of a particular dimension (’218 Patent, col. 7:40-48). This detailed description could be used to argue for a narrower construction limited to such a cage-like structure.

Term from the ’414 Patent

• The Term: "a valve configured to connect the topside of the lid to the underside of the lid" (from claim 9)
• Context and Importance: This term appears central to the "automated venting (auto-burping)" feature alleged in the complaint (Compl. ¶2). The construction of this term will determine what types of venting mechanisms can satisfy this claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests breadth by stating the valve can be controlled by various means, including "a timer, a humidistat, manually, or via a mobile device wirelessly," and can take multiple shapes (’414 Patent, col. 4:62-64, col. 5:1-2). This supports a functional definition focused on controllable air exchange.
  • Evidence for a Narrower Interpretation: The patent discloses a specific mechanical embodiment in FIGS. 12 and 13, showing a rotating element with a "void" that aligns with a "valve hole" to open or close the passage (’414 Patent, col. 5:51-60). This could support an argument that the term requires a specific type of rotating mechanical valve, not just any aperture.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant’s infringement has been and continues to be willful (Compl. ¶16). The factual basis for this allegation is that Defendant had "actual or constructive knowledge of Plaintiffs' patents based on years of industry overlap, shared trade show attendance, and publicly available patent filings" and continued its allegedly infringing conduct despite this knowledge (Compl. ¶12-13).

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

Based on the complaint and patents, the resolution of this case may turn on the following key questions:

1. A core issue will be one of structural identity: Does the accused "Cure Puck" constitute a "lid" as claimed in the patents, including elements such as a "circular rim" and an integrated "hatch," or is it an accessory device with a fundamentally different structure that falls outside the scope of the claims?
2. A central dispute will be one of evidentiary proof: The complaint makes functional allegations of "automated venting" and "wireless sensing." The case will depend on whether discovery produces evidence that the accused product actually performs these functions in a manner that satisfies the specific, detailed limitations recited in the asserted claims.
3. A key question for willfulness will be notice: Can the Plaintiffs substantiate the allegation of pre-suit knowledge with specific evidence beyond general assertions of "industry overlap," such as direct communications or specific instances of Defendant accessing the patent filings?