DCT
3:22-cv-01655
SleekEZ v. EquiGroomer
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: SleekEZ, LLC (Montana)
- Defendant: EquiGroomer, LLC (Connecticut)
- Plaintiff’s Counsel: Fisherbroyles, LLP
- Case Identification: 3:22-cv-01655, D. Colo., 01/19/2022
- Venue Allegations: Venue is asserted based on Defendant’s alleged business activities in Colorado, including sales through retail stores and e-commerce platforms shipping to the state.
- Core Dispute: Plaintiff alleges that Defendant’s animal grooming tools infringe a patent related to a grooming blade with a wave-pattern tooth configuration.
- Technical Context: The technology resides in the consumer market for animal grooming products, specifically tools designed for removing shedding fur from horses and other domesticated animals.
- Key Procedural History: The complaint alleges that Plaintiff first provided Defendant with written notice of infringement in 2015, prior to the patent-in-suit’s issuance. It further alleges that after the patent issued, Defendant modified its product to incorporate the allegedly infringing wave-pattern blade.
Case Timeline
| Date | Event |
|---|---|
| 2015 | Plaintiff allegedly first notified Defendant of infringement |
| 2015-05-29 | '250 Patent Priority Date (Application Filing Date) |
| 2016-10-25 | U.S. Patent No. 9,474,250 Issued |
| 2021-08-01 (approx.) | Defendant allegedly began using "EasyGroomer" brand name |
| 2022-01-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,474,250, "Animal Grooming Tool With Wave Pattern Blade Teeth," issued October 25, 2016 (’250 Patent)
The Invention Explained
- Problem Addressed: The patent background suggests that prior art grooming tools lacked the unique structure and function to effectively remove hair, fur, dirt, and dander from animals (Compl. Ex. 1, ’250 Patent, col. 1:13-17).
- The Patented Solution: The invention is an animal grooming tool featuring a blade with teeth arranged in a non-linear, "wave pattern." The teeth are described as undulating along the blade's length, a configuration purported to allow the tool to glide through an animal's coat in a more efficient and effective manner than a tool with a conventional, straight-line tooth arrangement (’250 Patent, Abstract; col. 1:22-28; Fig. 5).
- Technical Importance: The patent presents the undulating wave pattern as a specific structural improvement that provides a more effective way of removing shedding hair and fur compared to tools using blades with teeth in a simple linear position (’250 Patent, col. 2:45-50).
Key Claims at a Glance
- The complaint does not specify which claims are asserted. The following analysis focuses on representative independent Claim 1.
- Independent Claim 1 requires:
- A handle with an elongated blade slot along a length of the handle;
- A blade, with a portion received and secured in the blade slot; and
- Blade teeth formed along the blade’s length that have a same length and are "undulating forward and backward" to form a specific "wave configuration," which is further defined by a repeating sequence where pluralities of teeth progressively decrease, then increase, then decrease in distance from the blade slot.
III. The Accused Instrumentality
Product Identification
- The "EquiGroomer" and "EasyGroomer" animal grooming products (collectively, the "Accused Products") (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the Accused Products consist of a handle with an elongated blade slot, a blade secured in the slot, and blade teeth that undulate along the blade's length to form a wave configuration (Compl. ¶13).
- A key allegation is that Defendant modified its original "EquiGroomer" product after the ’250 Patent issued, allegedly eliminating a "standard 'hacksaw blade'" and incorporating a "wave pattern blade" that is now used across all Accused Products (Compl. ¶16).
- The complaint alleges that Plaintiff's own product is a "best-selling product on Amazon," suggesting the parties compete in a significant consumer market (Compl. ¶9).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'250 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a handle with an elongated blade slot along a length of the handle; | The Accused Products comprise "a handle with an elongated blade slot along a length of the handle". | ¶13 | col. 2:58-65 |
| a blade, a portion of the blade received in the blade slot and secured thereto; | The Accused Products comprise "a blade, a portion of which is received in and secured to the blade slot". | ¶13 | col. 3:1-2 |
| blade teeth formed along a length of the blade, the blade teeth...undulating along the length of the blade to form a wave configuration. | The Accused Products comprise "blade teeth formed along a length of the blade, the blade teeth undulating along the length of the blade to form a wave configuration". | ¶13 | col. 3:3-14 |
- Identified Points of Contention:
- Scope Questions: The central dispute may turn on the scope of the term "wave configuration". Claim 1 defines this term with a very specific, multi-part functional description involving pluralities of teeth that "progressively decrease," "progressively increase," and then "progressively decrease" in distance from the handle's blade slot (’250 Patent, col. 3:6-14). The case will raise the question of whether the physical structure of the accused blade meets every step of this detailed functional definition.
- Technical Questions: A primary factual question will be what the precise physical geometry of the teeth on the Accused Products is. The complaint's allegation that Defendant changed its blade from a "hacksaw blade" to a "wave pattern blade" suggests that discovery will focus on the design history and technical specifications of Defendant’s products before and after the issuance of the ’250 Patent (Compl. ¶16).
V. Key Claim Terms for Construction
- The Term: "wave configuration"
- Context and Importance: This term is the central feature of the invention and the lynchpin of the infringement allegation. Its construction will likely be dispositive. Practitioners may focus on this term because the claim itself provides a detailed, and potentially limiting, definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue the term should be understood more generally in light of the patent's abstract and summary, which describe the invention as a "'wave' like configuration" and a "wave pattern" without reciting the full, detailed definition from Claim 1 (’250 Patent, Abstract; col. 1:24).
- Evidence for a Narrower Interpretation: The explicit language of Claim 1 itself provides a highly structured definition: "a first plurality of the blade teeth progressively decrease in distance...followed by a second plurality...progressively increasing...followed by a third plurality...progressively decreasing" (’250 Patent, col. 3:6-14). A party will likely argue that this language acts as its own lexicography, strictly limiting the term's scope to a blade that meets this precise, repeating geometric pattern.
VI. Other Allegations
- Indirect Infringement: The complaint alleges direct infringement under 35 U.S.C. § 271(a) (Compl. ¶21). It does not contain specific factual allegations to support claims for induced or contributory infringement.
- Willful Infringement: Willfulness is alleged based on two key assertions: (1) Plaintiff provided Defendant with written notice of infringement in 2015, establishing alleged pre-suit knowledge, and (2) after the ’250 Patent issued, Defendant allegedly modified its product to "specifically incorporate a wave pattern blade," which may suggest copying or deliberate disregard of Plaintiff's patent rights (Compl. ¶16).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the term "wave configuration", as strictly defined by the multi-part "decrease-increase-decrease" language in Claim 1, read on the actual geometry of the blade used in Defendant’s "EquiGroomer" and "EasyGroomer" products? This question combines claim construction with factual infringement analysis.
- A key evidentiary question will be one of intent and causation: what evidence supports the allegation that Defendant modified its product from a "standard 'hacksaw blade'" to a "wave pattern blade," and can Plaintiff establish that this change was made with knowledge of, and in response to, the invention claimed in the ’250 Patent? The answer will be critical for both infringement and the allegation of willfulness.