DCT
1:25-cv-00365
Yangjiang Xinhe Houseware Co Ltd v. Telebrands Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Yangjiang Xinhe Houseware Co., Ltd. (China)
- Defendant: Telebrands Corp. (New Jersey)
- Plaintiff’s Counsel: Rimon, P.C.
- Case Identification: 1:25-cv-00365, D. Del., 05/19/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is subject to personal jurisdiction in the District of Delaware. This jurisdiction is based on Defendant initiating multiple lawsuits in the district and on its infringement notifications to Amazon, which allegedly caused economic harm to Plaintiff's resellers and customers within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its expandable garden hose products do not infringe two of Defendant’s patents, following Defendant's infringement notifications to Amazon that resulted in the delisting of Plaintiff's products.
- Technical Context: The technology concerns expandable garden hoses that are lightweight and compact for storage but extend significantly in length and width when filled with pressurized water.
- Key Procedural History: This declaratory judgment action was prompted by Defendant Telebrands submitting infringement notifications to Amazon against Plaintiff Xinhe’s resellers. The complaint notes that Defendant was aware of Plaintiff's noninfringement arguments from at least August 21, 2024, in connection with a separate lawsuit filed in the District of New Jersey.
Case Timeline
| Date | Event |
|---|---|
| 2011-11-04 | Earliest Priority Date for ’870 and ’915 Patents |
| 2018-11-15 | Plaintiff established under former name |
| 2019-01-08 | U.S. Patent No. 10,174,870 issues |
| 2023-03-21 | U.S. Patent No. 11,608,915 issues |
| 2024-08-16 | Plaintiff changes name to Yangjiang Xinhe Houseware Co., Ltd. |
| 2024-08-21 | Date of prior complaint in D.N.J. referenced, establishing Defendant's alleged knowledge of Plaintiff's arguments |
| 2025-02-17 | First Amazon delisting of Plaintiff's products occurs |
| 2025-05-19 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,608,915 - Expandable and Contractible Garden Hose
Issued March 21, 2023
The Invention Explained
- Problem Addressed: The patent describes conventional garden hoses as bulky, difficult to store, and prone to kinking when unwrapped (Compl. Ex. A, '915 Patent, col. 1:57-65).
- The Patented Solution: The invention is a hose comprising an elastic inner tube and a distinct, non-elastic outer tube. When pressurized water is introduced, the elastic inner tube expands both longitudinally (in length) and laterally (in width), constrained by the non-elastic outer tube, which unfolds to a maximum length. Upon release of pressure, the inner tube automatically contracts, causing the outer tube to gather and fold, returning the hose to a compact, storable state (’915 Patent, Abstract; col. 8:15-34).
- Technical Importance: This design allows a hose to be lightweight and compact for storage while automatically extending to a full, usable length under normal water pressure, addressing common user frustrations with conventional hoses (Compl. Ex. A, '915 Patent, col. 2:25-36).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 and 14 (Compl. ¶25).
- Independent Claim 1 Essential Elements:
- A flexible outer tube with a maximal length.
- A flexible inner tube made of elastic material with a relaxed length less than the outer tube's maximal length.
- First and second couplers secured to the ends of both tubes.
- The flexible inner tube is "unsecured to said flexible outer tube between said first and second ends so that said flexible outer tube can move freely over said flexible inner tube."
- A flow restrictor, whereupon an increase in water pressure "expands said inner tube longitudinally along a length... and laterally across a width of said flexible inner tube."
- The complaint reserves the right to address other claims.
U.S. Patent No. 10,174,870 - Expandable and Contractible Garden Hose
Issued January 8, 2019
The Invention Explained
- Problem Addressed: Similar to the ’915 patent, the ’870 patent addresses the problems of storing and handling heavy, bulky garden hoses that are prone to kinking and tangling (’870 Patent, col. 1:57-2:30).
- The Patented Solution: The patent discloses a hose with an elastic inner tube concentrically positioned within a non-elastic outer tube. The tubes are secured only at the ends. Water pressure causes the inner tube to expand radially and longitudinally to the dimensions of the outer tube. When pressure is released, the inner tube retracts, pulling the ends together and causing the outer tube to gather into a compact form (’870 Patent, Abstract; col. 7:5-15).
- Technical Importance: This dual-tube construction provides a self-extending and self-retracting hose, simplifying use and storage for homeowners by creating a product that is significantly lighter and less prone to tangling than traditional hoses (’870 Patent, col. 12:50-68).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 and 16 (Compl. ¶43).
- Independent Claim 1 Essential Elements:
- A flexible elongated outer tube made from a fabric material.
- A flexible elongated inner tube made of an elastic material.
- First and second couplers secured to the ends of both tubes.
- The inner and outer tubes are "unsecured between said first and second ends so that said outer tube is not held in frictional contact with said inner tube so that said outer tube can move freely along said inner tube."
- A flow restrictor, wherein an increase in fluid pressure "expands said inner tube longitudinally... and laterally across a width of said inner tube."
- The complaint reserves the right to address other claims.
III. The Accused Instrumentality
Product Identification
- Expandable garden hoses manufactured by Plaintiff Yangjiang Xinhe Houseware Co., Ltd., and sold on Amazon.com by various resellers under 30 different Amazon Standard Identification Numbers (ASINs) (the "Accused Products") (Compl. ¶8).
Functionality and Market Context
- The complaint alleges the Accused Products consist of a three-layer construction: an inner layer, a middle textile layer, and an outer layer (Compl. ¶29). A photograph provided in the complaint depicts a cross-section of the accused hose showing these three distinct layers (Compl. ¶29, p. 8).
- Plaintiff alleges that this construction, particularly the middle textile layer, is designed to restrict the hose from widening under pressure (Compl. ¶¶30, 33). It further alleges that the layers are bonded together, in some cases with an adhesive, preventing them from moving freely relative to one another (Compl. ¶¶34-35).
- The products are sold through third-party resellers on the Amazon.com marketplace, and the delisting of these products following Defendant's infringement notifications is the basis for the lawsuit (Compl. ¶¶6-8).
IV. Analysis of Infringement Allegations
This action is for a declaratory judgment of non-infringement. The following tables summarize Plaintiff's allegations as to why its products do not meet the limitations of the asserted claims.
U.S. Patent No. 11,608,915 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an increase in water pressure expands said inner tube ... laterally across a width of said flexible inner tube | The Accused Products allegedly do not expand laterally. An experiment cited in the complaint purports to show that under water pressure, the hose's diameter contracts from 15.51mm to 13.98mm. | ¶¶30, 32 | col. 7:26-30 |
| said flexible inner tube unsecured to said flexible outer tube between said first and second ends so that said flexible outer tube can move freely over said flexible inner tube | The Accused Products have a three-layer construction. The complaint alleges the layers are bonded, and in some versions, an adhesive is used, preventing the inner layer from moving freely with respect to the outer layer. A photograph shows a cut-open hose with a substance labeled "adhesive" between the inner and middle layers. | ¶¶29, 34-35 | col. 7:11-15 |
U.S. Patent No. 10,174,870 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| said increase in fluid pressure expands said inner tube ... laterally across a width of said inner tube | As with the ’915 patent, Plaintiff alleges its products contract, rather than expand, laterally under pressure, citing experimental results. A series of photographs in the complaint depicts a digital caliper measuring a hose sample before and after pressurization to demonstrate this alleged contraction. | ¶¶48, 50 | col. 9:20-28 |
| said inner and outer tubes unsecured between said first and second ends so that said outer tube ... can move freely along said inner tube | Plaintiff alleges its products employ a three-layer construction where the layers expand and contract in unison because they are bonded together and are therefore not "unsecured" or able to "move freely." | ¶¶47, 52-53 | col. 9:3-10 |
- Identified Points of Contention:
- Factual/Technical Question: The primary dispute is factual: do the Accused Products "expand... laterally" as claimed, or do they contract laterally as Plaintiff alleges? The complaint presents photographic evidence from an experiment purporting to show lateral contraction (Compl. ¶¶32, 50). The resolution of this may depend on the credibility of the evidence presented.
- Scope Questions: The case raises questions about the scope of two key limitations:
- Does the claim term "expands... laterally across a width" require a net increase in diameter, or could it be interpreted to cover any change in shape or internal volume, even if the outer diameter decreases?
- Can a hose with a multi-layer, bonded construction, in some cases allegedly using adhesive, be considered "unsecured" such that one tube "can move freely" with respect to another? The complaint's photograph of a "Licensed Patent" is used to argue its own product's construction is designed to restrict enlargement, contrary to the asserted patents' teachings (Compl. ¶¶33, 51).
V. Key Claim Terms for Construction
The Term: "expands ... laterally across a width" (from '915 Claim 1; '870 Claim 1)
- Context and Importance: This term is central to the dispute, as Plaintiff's primary non-infringement argument is that its hoses contract, rather than expand, in width. The definition will determine whether a product that lengthens but narrows in diameter infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patents repeatedly describe the hose expanding to fill the non-elastic outer tube, which has a fixed, larger diameter than the inner tube's relaxed state. A party could argue any lateral expansion of the inner tube, regardless of the final outer dimension, meets the limitation (’870 Patent, col. 8:29-34).
- Evidence for a Narrower Interpretation: The term "expands" in its plain and ordinary sense implies an increase in size. The patents consistently describe the hose expanding in both length and width to an "expanded condition" (’870 Patent, col. 10:50-56). Plaintiff's experimental evidence of a net decrease in diameter may support an argument that this term is not met.
The Term: "unsecured ... so that said flexible outer tube can move freely over said flexible inner tube" (from '915 Claim 1) / "unsecured ... so that said outer tube can move freely along said inner tube" (from '870 Claim 1)
- Context and Importance: Plaintiff alleges its hoses have a bonded, three-layer construction, which directly challenges whether the tubes are "unsecured" and can "move freely." This term's construction is critical to the second pillar of Plaintiff's non-infringement case.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "move freely" does not require complete separation, but only enough relative movement to allow the outer tube to gather and fold upon contraction, a function the Accused Products presumably perform.
- Evidence for a Narrower Interpretation: The patents state the outer tube is "unattached, unconnected, unbonded, and unsecured to the inner tube along the entire length" between the couplers (’870 Patent, col. 9:3-10). This language suggests a complete lack of bonding. Plaintiff's allegations of a bonded, multi-layer construction, including the use of adhesive shown in a complaint photograph (Compl. p. 12), would support a narrow construction that excludes its products.
VI. Other Allegations
- State Law Claims: The complaint includes claims for Tortious Interference with Contractual Relations, Tortious Interference with Prospective Business Relations, Common Law Unfair Competition, and violation of the Delaware Uniform Deceptive Trade Practices Act (Compl. ¶¶60-105). These claims are based on the allegation that Defendant knowingly submitted "baseless" infringement notifications to Amazon with the intent to disrupt Plaintiff's business relationships with its resellers and customers (Compl. ¶¶66, 98).
- Request for Fees: Plaintiff seeks a declaration that the case is "exceptional" under 35 U.S.C. § 285, which would entitle it to attorneys' fees (Compl. ¶¶41, 59). This is based on the allegation that Defendant knew or should have known the infringement claims were baseless, particularly after being put on notice of the non-infringement arguments in a prior D.N.J. case (Compl. ¶38).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on two fundamental questions that will require judicial resolution:
- A core issue will be one of factual determination and claim scope: Does the phrase "expands... laterally across a width" require a net increase in the hose's external diameter? The court will need to construe this term and then evaluate the evidence to determine if the Accused Products, which allegedly contract laterally, fall within that scope.
- A key claim construction question will be one of structural configuration: Can a hose constructed with multiple, bonded layers be considered "unsecured" with parts that "move freely" as required by the claims? The outcome will depend on how the court defines these terms in light of the patent specification, which describes a complete lack of attachment between the tubes' lengths.