DCT

3:25-cv-02101

Zhang v. Home Depot Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-02101, D. Conn., 12/16/2025
  • Venue Allegations: Venue is alleged to be proper for The Home Depot based on its twenty physical store locations within the District of Connecticut.
  • Core Dispute: Plaintiff alleges that sink installation brackets sold by Defendant The Home Depot under the "Numhew" brand infringe a patent related to an adjustable support bracket for sinks.
  • Technical Context: The technology concerns mechanical hardware accessories used in plumbing installations to provide structural support for heavy sinks, preventing deformation of countertops and water leakage.
  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

Date Event
2018-10-09 '269 Patent Priority Date
2021-07-13 '269 Patent Issue Date
2025-12-16 Complaint Filing Date

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

U.S. Patent No. 11,060,269 - "Bracket for Installing Sink"

The Invention Explained

  • Problem Addressed: The patent addresses the problem of heavy sinks being supported only by their outer flange on a countertop, which can lead to deformation, water leakage, and seepage. Existing solutions, such as welded tripods, are described as having a fixed length and angle, making them difficult to install and not universally applicable to different sink types or installation environments. (’269 Patent, col. 1:17-35).
  • The Patented Solution: The invention is an adjustable bracket designed to support a sink from below. It consists of a fixed base that mounts to a wall and a support rod that can be adjusted. The support rod can move vertically and rotate within the base to accommodate different sink positions and angles. An upper "jacking structure" abuts the corner of the sink, while a lower "holding structure" (e.g., a jacking bolt) allows for fine-tuning of the support height and pressure after installation. (’269 Patent, Abstract; col. 2:48-62; Fig. 1).
  • Technical Importance: This design approach aims to increase the versatility of sink brackets and simplify the installation process by allowing for on-site adjustments to both support length and angle. (’269 Patent, col. 3:1-14).

Key Claims at a Glance

The complaint asserts infringement of "the claims of the '269 Patent" without specifying particular claims (Compl. ¶17). Independent claim 1 is representative and includes the following essential elements:

  • A fixed base and a support rod.
  • The fixed base is installed via an "installing structure."
  • A lower end of the support rod extends into the fixed base and is movable upward-downward and rotatable.
  • An upper end of the support rod is configured with a "jacking structure for abutting against a corner" of the sink.
  • The fixed base is installed with a "holding structure for holding the lower end of the support rod."
  • The fixed base comprises first, second, and third vertical plates connected to form a rectangular structure with a cavity for the support rod.
  • The first and third vertical plates have extension plates with installing holes for screws.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies "brackets for installing sinks" sold by Home Depot under the trade name "Numhew" (Compl. ¶2-3).

Functionality and Market Context

  • The complaint alleges that these are brackets used for installing sinks (Compl. ¶2). It does not provide any technical description of the accused product's features or operation in the body of the complaint. Instead, it states that an example of the infringing bracket "is directly compared with Plaintiff's claimed bracket for installing sink in the '269 Patent. (Exhibit 4)" (Compl. ¶15). This exhibit, described as an "infringement chart," was not available for this analysis (Compl. ¶7). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an infringement chart in Exhibit 4, which is not provided in the filed document (Compl. ¶7, 15). The complaint's narrative asserts that Defendants are "making, using, offering for sale, selling, and/or importing... products that infringe directly and/or indirectly the claims of the '269 Patent" (Compl. ¶17). Without the referenced exhibit or more detailed factual allegations in the complaint body, a tabular analysis of the infringement theory is not possible. The core of the infringement allegation appears to rest on a direct structural comparison presented in the missing exhibit.

  • Identified Points of Contention:
    • Structural Questions: The central dispute will likely be a factual one: does the accused Numhew bracket possess the specific structural elements recited in the asserted claims? Key questions will include whether the accused product's base is constructed from the claimed "first vertical plate," "second vertical plate," and "third vertical plate" forming a "rectangular structure," and whether it employs a distinct "holding structure" and "jacking structure" as claimed.
    • Evidentiary Questions: The case will depend on the evidence presented, presumably mirroring that in the unattached Exhibit 4, to demonstrate that the accused product meets each limitation of an asserted claim.

V. Key Claim Terms for Construction

The Term: "jacking structure for abutting against a corner between a sink body of the sink and an installing plate for the sink" (Claim 1)

  • Context and Importance: This term defines the critical interface between the bracket and the sink. Its construction will determine the scope of protection for the mechanism that transfers force to the sink. Practitioners may focus on this term because the patent's specific embodiment shows a distinct shape, which could be used to argue for a narrower construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is functional, describing what the structure does ("for abutting against a corner"). This may support a construction that covers any structure performing this function.
    • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment as a "jacking plate 9 which has an upper abutting portion 901... and a lower abutting portion 902" that form a "corner structure." (’269 Patent, col. 5:15-21; Fig. 4). A defendant may argue the term should be limited to a structure with these distinct upper and lower abutting portions.

The Term: "holding structure for holding the lower end of the support rod" (Claim 1)

  • Context and Importance: This term defines the mechanism that secures the adjustable support rod in place. The definition will be critical to determining infringement, as different mechanical means could be used to achieve this "holding" function.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language of "holding structure" is broad and could encompass various mechanisms like clamps, set screws, or friction fittings.
    • Evidence for a Narrower Interpretation: The patent describes a preferred embodiment where the holding structure consists of an "installing block 10" with a "threaded hole" and a "jacking bolt 11" that is screwed upward to press against the bottom of the support rod (’269 Patent, col. 5:40-53). A party could argue that this detailed disclosure limits the scope of "holding structure" to this type of upward-pressing bolt mechanism.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a conclusory allegation of indirect infringement (Compl. ¶17) but does not plead specific facts to support the requisite knowledge or intent, such as referencing user manuals or advertising that instruct on an infringing use.
  • Willful Infringement: The complaint alleges that Defendants' infringement is willful (Compl. ¶18) and that they have "knowingly and willfully used" the patent (Compl. ¶12). No specific facts are alleged to support pre-suit knowledge of the patent or its infringement.

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

  • A central issue will be evidentiary and factual: does the accused Numhew bracket, which is not pictured or technically described in the complaint, actually embody the specific multi-part "fixed base" and distinct "holding structure" recited in detail in claim 1 of the ’269 Patent? The outcome may depend entirely on a direct structural comparison.
  • A secondary issue will be one of claim scope: will terms like "jacking structure" and "holding structure" be construed broadly according to their function, or will their scope be limited by the specific two-part plate and jacking-bolt mechanisms detailed in the patent's specification and drawings?