Reiley v. Saldana

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Adrian Reiley and Nadiah Reiley (Hawaii), Pro Se
  • Defendant: Santino Saldana d/b/a "CureLids" (Michigan)
  • Plaintiff’s Counsel: Plaintiffs are proceeding Pro Se
• Case Identification: 3:25-cv-01643, S.D. Cal., 06/25/2025
• Venue Allegations: Venue is based on Defendant’s alleged acts of infringement within the district, specifically the sale and delivery of accused products to consumers in California via online platforms, and Plaintiffs’ own operational and warehousing activities in the district.
• Core Dispute: Plaintiffs allege that Defendant’s "CureLids" product, a smart container lid, infringes three utility patents and one design patent related to technology for monitoring and controlling the environment within storage containers for curing organic material.
• Technical Context: The technology at issue involves specialized lids for storage containers, such as fiber drums, incorporating features like digital hygrometers, access hatches, and automated air exchange to control the humidity for curing agricultural products.
• Key Procedural History: The complaint alleges a prior business relationship between the parties, including an exclusive distribution agreement for the accused product. Plaintiffs allege Defendant acknowledged their intellectual property, later breached the agreement, and continued selling the product after receiving a cease-and-desist notice, which forms the basis for the willfulness allegation.

Case Timeline

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

U.S. Patent No. 10,723,535 - Lid for Containers and Related Methods

The Invention Explained

• Problem Addressed: The patent describes a need in the storage of agricultural products for a container lid that allows for humidity monitoring without unsealing the container. Traditional lids for commercial drums are described as lacking integrated hygrometers and using "cumbersome" lever-locking mechanisms that make access difficult. (’535 Patent, col. 1:45-60).
• The Patented Solution: The invention is a lid that integrates several features to solve these problems. It includes a hygrometer on its topside to monitor internal humidity, a hatch that allows access to the container's contents without removing the entire lid, and a pocket on the underside for holding humidity control packs. (’535 Patent, col. 3:6-25; Fig. 3). This combination allows a user to monitor, access, and adjust the container's environment efficiently. (’535 Patent, col. 4:26-34).
• Technical Importance: This approach combines environmental monitoring and physical access into a single integrated unit, aiming to improve the process of curing and storing sensitive agricultural products. (Compl. ¶7).

Key Claims at a Glance

• The complaint does not identify specific claims, but its allegations appear to implicate independent claim 1.
• Essential elements of independent claim 1 include:
  • A lid for transforming a non-humidity controlled container into a humidity controlled container.
  • A circular rim configured to attach to the container.
  • A hygrometer on the topside adapted to monitor and digitally display humidity.
  • A semi-circular, selectively openable hatch positioned over an opening.
  • A rectangular pocket on the underside for at least one humidity pack.
  • A rectangular label surface on the topside opposite the pocket.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,230,414 - Lid for Containers and Related Methods

The Invention Explained

• Problem Addressed: This patent, a continuation-in-part of the application leading to the ’535 Patent, identifies additional needs for wirelessly regulating air exchange, transmitting container data, and sorting stored material. (’414 Patent, col. 2:29-36).
• The Patented Solution: The ’414 Patent adds new technical features to the lid concept. These include a "closable valve" to regulate air exchange, which can be controlled automatically or wirelessly; means for the hygrometer to transmit data to a mobile device; and an internal "webbing" (or cage) with an "extract container" designed to sort stored materials by size as the container is tumbled. (’414 Patent, col. 5:1-11, col. 5:12-28; Fig. 11).
• Technical Importance: The invention aims to advance the "smart container" concept by adding automation, remote monitoring, and mechanical processing capabilities to the storage lid. (Compl. ¶7).

Key Claims at a Glance

• The complaint’s allegation regarding "wireless communication functionality" appears to target features described in the patent and captured in claims such as independent claim 9 and dependent claims 2-3. (Compl., Count 2). For illustrative purposes, independent claim 1 is analyzed here.
• Essential elements of independent claim 1 include:
  • A lid for transforming a non-humidity controlled container.
  • A webbing connected to the underside of the lid.
  • An extract container connected to the webbing.
  • A circular rim, hygrometer, semi-circular hatch, rectangular pocket, and rectangular label surface, similar to the ’535 Patent.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 11,814,218 - Lid for Containers and Related Methods

The Invention Explained

• Technology Synopsis: The ’218 Patent further develops the technology by introducing an "interior lattice insert" that functions as a trimmer to automatically separate dry leaf matter from agricultural products when the container is rotated. It also discloses a system with powered intake and exhaust pumps that actively regulate the container's humidity based on real-time data from the hygrometer, providing more precise environmental control. (’218 Patent, col. 7:7-29, col. 6:49-68).

Key Claims at a Glance

• Asserted Claims: The complaint does not specify asserted claims; independent claim 1 covers the lid with the lattice insert.
• Accused Features: The complaint alleges the "digital environmental monitoring system used in Defendant's product mirrors the methods and structures" of the ’218 Patent. (Compl., Count 3).

U.S. Design Patent No. D859,155 S - Lid

The Invention Explained

• Technology Synopsis: This patent protects the ornamental design for a container lid. The claimed design consists of the visual appearance of a circular lid featuring a semi-circular hatch, a rectangular recessed area, a circular display, and specific hinge and latch features, as depicted in the patent's figures. (D’155 Patent, Figs. 1-3).

Key Claims at a Glance

• Asserted Claims: A single claim for the ornamental design as shown and described.
• Accused Features: The complaint alleges the accused product's "ornamental appearance is substantially the same as that depicted" in the D'155 Patent. (Compl., Count 4).

III. The Accused Instrumentality

Product Identification

The accused instrumentality is a product sold by Defendant under the brand name "CureLids". (Compl. ¶¶ 6, 10).

Functionality and Market Context

The complaint alleges the CureLids product is a "smart container system" that incorporates features protected by the patents-in-suit, including an "automatic venting system," "digital environmental controls," a "visual hygrometer," and "wireless communication functionality". (Compl. ¶¶ 7, Counts 1-3). The complaint alleges that the accused product is the "exact same product" that was the subject of a prior exclusive distribution agreement between the parties and that Defendant is selling it at prices "significantly lower than Plaintiffs' costs," causing market confusion and financial harm. (Compl. ¶¶ 10, 12).

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a complete claim-chart analysis. It alleges infringement in conclusory terms without mapping specific features of the "CureLids" product to the discrete elements of any asserted patent claim. The infringement theory is summarized below in prose.

• ’535 Patent Infringement Allegations: The complaint alleges that the CureLids product infringes by incorporating an "automatic venting system and environmental control components". (Compl., Count 1). This narrative suggests that the accused product's venting system is alleged to meet the "semi-circular hatch" limitation of claim 1, and its control components are alleged to meet the "hygrometer" and "pocket" limitations.
• Identified Points of Contention:
  • Scope Questions: A potential issue is whether the term "semi-circular hatch" in claim 1 of the ’535 patent reads on the accused product's "automatic venting system." The patent specification discloses that the hatch may be other shapes, but the claim itself is specific, raising a question of claim scope that may require construction. (’535 Patent, col. 3:32-35).
  • Technical Questions: The complaint alleges a "visual hygrometer," whereas claim 1 requires a hygrometer adapted to "digitally display" the humidity. (Compl., Count 2; ’535 Patent, col. 5:36-39). The litigation may require evidence on whether the accused product's display is "digital" as claimed.
• ’414 Patent Infringement Allegations: The complaint alleges the CureLids product infringes by including a "visual hygrometer and wireless communication functionality". (Compl., Count 2). While independent claim 1 of the ’414 Patent does not recite wireless functionality, this allegation appears to target features described in dependent claims (e.g., claim 3) and other independent claims (e.g., claim 9), which expressly claim wireless control and data transmission. (’414 Patent, col. 7:30-32, col. 7:60-63).
• Identified Points of Contention:
  • Evidentiary Questions: Independent claim 1 of the ’414 Patent requires specific physical structures: a "webbing connected to the underside of the lid" and an "extract container connected to the webbing." (’414 Patent, col. 7:3-6). The complaint provides no facts or evidence suggesting the accused CureLids product contains these internal sorting structures. A central question will be whether discovery uncovers evidence of these claimed elements in the accused product.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "semi-circular hatch" (’535 Patent, Claim 1)
• Context and Importance: The shape of the hatch is explicitly defined in the independent claim. The infringement analysis will depend on whether the accused product's "venting system" has this specific shape or if the claim can be construed more broadly. Practitioners may focus on this term because of the potential tension between limiting claim language and a more expansive disclosure in the specification.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states, "In an alternative embodiment, the hatch 30 may be shaped in a rectangle, triangle, square, diamond, pentagon, heptagon, hexagon, circle or other shape that allows a user to open the hatch". (’535 Patent, col. 3:32-36).
  • Evidence for a Narrower Interpretation: Claim 1 itself, which defines the scope of the invention, explicitly uses the limiting term "semi-circular." An argument may be made that the patentee deliberately chose to claim only the semi-circular embodiment in this specific claim.
• The Term: "webbing" (’414 Patent, Claim 1)
• Context and Importance: This term appears in the body of independent claim 1 and appears to be a critical structural element distinguishing the ’414 Patent from the earlier ’535 Patent. Infringement of this claim hinges on whether the accused product contains this specific internal structure for sorting materials.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification defines the term broadly as an "internal webbing 12 (also known as a cage or rack)". (’414 Patent, col. 5:12-13).
  • Evidence for a Narrower Interpretation: The specification describes the webbing’s specific function as being "used to sort material by size" via "gaps 12a in the webbing 12 which small material may fall though." This functional description implies a specific physical structure beyond a simple internal support. (’414 Patent, col. 5:20-24).

VI. Other Allegations

• Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement, such as allegations that Defendant's user manuals instruct customers to infringe or that the accused product has no substantial non-infringing uses.
• Willful Infringement: Willfulness is explicitly alleged. (Compl. ¶11). The complaint asserts a basis for pre-suit knowledge, alleging that Defendant "acknowledged Plaintiffs' intellectual property" during business discussions and continued to market the accused product after receiving a "cease-and-desist notice." (Compl. ¶¶ 10, 13).

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

• A primary issue will be one of evidentiary support: Given the complaint’s lack of technical specificity, the case will likely depend on whether discovery shows that the accused "CureLids" product incorporates the precise physical structures required by the asserted claims, particularly the internal "webbing" and "extract container" of the ’414 Patent and the automated pump systems of the ’218 Patent.
• A central legal question will concern claim scope: The dispute may turn on whether claim terms like "semi-circular hatch" in the ’535 Patent are limited to their plain meaning or can be interpreted more broadly in light of alternative embodiments disclosed in the specification, a determination that will be critical to the infringement analysis.
• Finally, the allegations of a prior business relationship and a disregarded cease-and-desist letter raise a significant question of willfulness: The court will likely need to examine whether the Defendant's alleged conduct, if proven, rises to the level of objective recklessness in the face of a known risk of infringing valid patents.