DCT

1:25-cv-00418

HydraFacial LLC v. Candela Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00418, D. Del., 04/03/2025
  • Venue Allegations: Venue is alleged as proper because Defendant Candela is a Delaware corporation, and Defendant TermoSalud is a foreign company that may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ hydrodermabrasion systems infringe four U.S. patents related to skin treatment devices that combine fluid delivery with skin exfoliation and vacuum extraction.
  • Technical Context: The technology at issue involves aesthetic medical devices for hydrodermabrasion, a non-invasive skin resurfacing procedure popular in the cosmetic and dermatology markets.
  • Key Procedural History: The complaint alleges that Plaintiff sent a cease and desist letter to Defendant Candela on February 28, 2025, notifying Candela of the asserted patents. This pre-suit notice is asserted as a basis for willful infringement.

Case Timeline

Date Event
2005-12-30 Earliest Priority Date for all Asserted Patents
2017-01-24 U.S. Patent No. 9,550,052 Issues
2022-09-20 U.S. Patent No. 11,446,477 Issues
2024-01-09 U.S. Patent No. 11,865,287 Issues
2024-08-06 U.S. Patent No. 12,053,607 Issues
2024-12-01 Alleged earliest date Candela offered instructional materials
2025-02-28 Candela receives Cease & Desist Letter from HydraFacial
2025-03-07 Candela exhibits Accused Product at industry meeting
2025-03-12 Candela responds to HydraFacial's letter
2025-04-03 Complaint filed

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

U.S. Patent No. 9,550,052 - "CONSOLE SYSTEM FOR THE TREATMENT OF SKIN"

  • Patent Identification: U.S. Patent No. 9550052, "CONSOLE SYSTEM FOR THE TREATMENT OF SKIN," issued January 24, 2017.

The Invention Explained

  • Problem Addressed: The patent family specification describes conventional dermabrasion as messy and painful, while microdermabrasion, which uses a stream of grit, removes moisture from the skin and requires a separate, subsequent application of moisturizing creams that may not penetrate deeply. (’477 Patent, col. 1:29-65).
  • The Patented Solution: The invention is an integrated system comprising a console, a handpiece with a treatment tip, and a manifold connected to multiple fluid containers. (’052 Patent, Abstract). This configuration allows a user to select different treatment liquids (e.g., serums) to be delivered to the skin through the handpiece, while a vacuum system simultaneously exfoliates the skin and removes waste fluid and debris through a separate conduit. (’052 Patent, col. 7:35-44).
  • Technical Importance: This integrated approach combines skin exfoliation, debris extraction, and targeted serum infusion into a single, continuous process, which may improve both the efficiency and efficacy of the skin treatment compared to multi-step prior art methods. (’477 Patent, col. 2:1-15).

Key Claims at a Glance

  • The complaint asserts independent Claim 1. (Compl. ¶40).
  • Claim 1 requires:
    • A console with a manifold in fluid communication with at least two fluid containers holding a liquid treatment material.
    • A handpiece assembly with a tip for contacting skin.
    • A supply conduit connecting the manifold to the handpiece.
    • A manifold configured to control the flow of treatment material from the containers.
    • A vacuum source.
    • A waste conduit connecting the handpiece tip to the vacuum source.
    • A configuration that permits a user to select which treatment material to deliver.
    • A functional step wherein activating the vacuum creates a suction force that both removes waste via the waste conduit and draws treatment material from a container to the tip via the supply conduit.
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,865,287 - "DEVICES AND METHODS FOR TREATING SKIN"

  • Patent Identification: U.S. Patent No. 11865287, "DEVICES AND METHODS FOR TREATING SKIN," issued January 9, 2024.

The Invention Explained

  • Problem Addressed: As a member of the same patent family, this patent addresses the same technical problems of messy, painful, or dehydrating conventional skin abrasion techniques. (’477 Patent, col. 1:29-65).
  • The Patented Solution: The invention is a skin treatment system featuring a console containing a "block" that manages fluid flow from multiple containers. (’287 Patent, Abstract). The block is configured to selectively receive fluid from different containers and deliver it to a handpiece, which also communicates with a console-based vacuum source to remove waste. (’287 Patent, col. 5:26-40). The system is specifically configured to deliver the different treatment fluids "sequentially." (’287 Patent, col. 5:47-51).
  • Technical Importance: This patent focuses on the fluid management architecture within the console, claiming a "block" that enables the sequential delivery of different treatment fluids during a procedure, providing a structured, multi-stage treatment capability. (’287 Patent, col. 5:47-51).

Key Claims at a Glance

  • The complaint asserts independent Claim 1. (Compl. ¶52).
  • Claim 1 requires:
    • A console configured to receive a first container and at least one additional container.
    • A handpiece to contact skin tissue.
    • A "block" in the console that is configured to (i) selectively receive fluid from the first container, (ii) selectively receive fluid from the additional container, and (iii) be in fluid communication with the handpiece.
    • A vacuum source within the console.
    • The handpiece being in fluid communication with the vacuum source via a second conduit.
    • A final configuration wherein the system is configured to deliver the treatment fluids from the first and additional containers to the handpiece "sequentially."
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 11,446,477 - "DEVICES AND METHODS FOR TREATING SKIN"

  • Patent Identification: U.S. Patent No. 11446477, "DEVICES AND METHODS FOR TREATING SKIN," issued September 20, 2022.
  • Technology Synopsis: This patent addresses the technical challenge of combining effective skin abrasion with simultaneous hydration. The invention provides a system with a console-based manifold that controls fluid flow from multiple containers to a handpiece, which has a working end for skin contact and is connected to both a supply conduit and a vacuum-driven waste conduit. (’477 Patent, Abstract).
  • Asserted Claims: At least Claim 1 is asserted. (Compl. ¶64).
  • Accused Features: The complaint accuses the Glace system's console, internal manifold, fluid containers, handpiece with a working end, and vacuum source of infringing. (Compl. ¶¶64-65).

U.S. Patent No. 12,053,607 - "DEVICES AND METHODS FOR TREATING SKIN"

  • Patent Identification: U.S. Patent No. 12053607, "DEVICES AND METHODS FOR TREATING SKIN," issued August 6, 2024.
  • Technology Synopsis: This patent discloses a skin treatment system comprising a console, a handpiece, and supply and waste lines. A key feature is a vacuum source configured to perform a dual function: it draws waste material from the handpiece for disposal while simultaneously drawing treatment material from a container to the handpiece when its tip is pressed against the skin. (’607 Patent, Abstract).
  • Asserted Claims: At least Claim 1 is asserted. (Compl. ¶76).
  • Accused Features: The infringement allegations target the Glace system's integrated console, handpiece, fluid containers, and particularly the alleged dual-function operation of its vacuum system to draw both waste and treatment fluid. (Compl. ¶¶76-77).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are the Glace™ Solution system ("Glace") and the deep2™ system. (Compl. ¶¶17-18). The complaint alleges that these are the same hydrodermabrasion device sold under different branding. (Compl. ¶20).

Functionality and Market Context

The Accused Products are described as hydrodermabrasion systems that include a console, fluid containers for serums, tubing, and a handpiece with a "DiamondGlacē tip." (Compl. ¶¶23-24). The system is alleged to utilize a "GlacēVac™ closed vacuum system" that "allows for simultaneous extraction and suction to cleanse skin while infusing serums." (Compl. ¶25). A touchscreen on the console allows users to select different treatment solutions. (Compl. ¶40, p. 20). The complaint includes an image of the Glace system's user interface, which provides icons for selecting a treatment material to be delivered to the handpiece. (Compl. ¶40, p. 20). The products are marketed as professional skin treatments that compete with Plaintiff's systems. (Compl. ¶¶16, 18).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,550,052 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a console including a manifold... in fluid communication with a first fluid container and at least a second fluid container, The accused Glace system comprises a console with an internal manifold structure that is in fluid communication with multiple fluid containers. ¶40 col. 5:20-23
a handpiece assembly comprising a tip, the tip being configured to contact a skin surface of a subject; The Glace system includes a handpiece with an attached tip that is configured to contact a subject's skin during treatment. An image in the complaint depicts the handpiece tip in contact with a patient's skin surface. (Compl. ¶40, p. 16). ¶40 col. 6:31-33
a supply conduit placing the manifold of the console in fluid communication with the handpiece assembly... The Glace system uses tubing that includes a supply conduit to connect the console's manifold to the handpiece assembly. ¶40 col. 7:26-34
wherein the manifold is configured to control a flow of treatment material from the first fluid container and at least the second fluid container through the supply conduit; The Glace system's manifold is allegedly configured to control the flow of treatment serums from the fluid containers through the supply conduit to the handpiece. ¶40 col. 5:18-20
a vacuum source; The Glace system contains a "GlaceVac™ closed vacuum system" that provides suction. ¶40 col. 7:38-44
a waste conduit in fluid communication with the tip of the handpiece assembly to remove waste away from a skin surface... The system's tubing allegedly includes a waste conduit that connects the tip of the handpiece assembly to the vacuum source to remove waste from the skin surface. ¶40 col. 7:20-25
wherein the system is configured to permit a user to select the treatment material from the first fluid container or the at least second fluid container to be delivered... The Glace system's touchscreen interface allegedly contains icons that permit a user to select which treatment material is delivered to the handpiece. ¶40 col. 6:17-20
wherein, when the vacuum source is activated... a suction force is created... thereby removing waste... while drawing treatment material... The Glace vacuum source allegedly creates a suction force that simultaneously removes waste from the skin via the waste conduit and draws treatment serum from a container to the tip via the supply conduit. ¶40 col. 7:35-44

Identified Points of Contention

  • Scope Questions: A central question may be whether the accused product's internal fluid-routing components constitute a "manifold" as that term is used in the patent. The complaint provides a diagram labeling an "Manifold (Internal)," suggesting this will be a point of analysis. (Compl. ¶40, p. 14).
  • Technical Questions: The final functional "wherein" clause requires that the vacuum's "suction force" performs the dual function of removing waste while also drawing treatment material from the container to the tip. A potential point of contention is whether the accused product's vacuum system actually performs this drawing function, or if treatment fluid is delivered by a separate mechanism (e.g., a positive pressure pump) while the vacuum is limited to waste removal.

U.S. Patent No. 11,865,287 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a console configured to receive a first container and at least one additional container; The accused Glace console is configured to receive multiple fluid containers for treatment serums. ¶52 col. 5:26-31
a handpiece configured to contact skin tissue of a subject; The system includes a handpiece with a tip designed to make contact with skin tissue during a procedure. ¶52 col. 5:32-35
a block in the console, wherein the block is: configured to selectively receive fluid from the first container... [and] from the at least one additional container... The complaint alleges the console contains a "block" that is configured to selectively receive fluid from the first container and additional containers when they are connected. A complaint diagram shows multiple containers coupled to an internal block. (Compl. ¶52, p. 27). ¶52 col. 5:28-31
[the block is] configured to selectively be in fluid communication with the handpiece through a first conduit... The block is allegedly placed in fluid communication with the handpiece via tubing when the handpiece is connected to the console. ¶52 col. 5:26-28
a vacuum source, wherein the console comprises the vacuum source; The Glace console allegedly comprises a "GlaceVac™ closed vacuum system." ¶52 col. 6:49-54
wherein the system is configured to deliver the first treatment fluid... and the additional treatment fluid... to the handpiece sequentially. The system allegedly delivers a "two-phase serum treatment" and has selection buttons that allow a user to deliver fluid from different containers one at a time. ¶52 col. 5:47-51

Identified Points of Contention

  • Scope Questions: A primary issue for claim construction will likely be the term "block." The specification for the patent family primarily uses the term "manifold system." The question for the court will be whether the accused device's internal fluid management system qualifies as a "block," and what structural or functional characteristics that term implies.
  • Technical Questions: The meaning of "sequentially" will likely be disputed. The complaint alleges that user-selectable, one-at-a-time delivery meets this limitation. A defendant may argue that "sequentially" requires an automated, pre-programmed sequence of fluid delivery rather than manual, ad-hoc selection by an operator.

V. Key Claim Terms for Construction

The Term: "manifold" (’052 Patent, Claim 1)

  • Context and Importance: This term defines the core fluid management component of the claimed invention. Whether the accused device's internal fluidics system meets the definition of a "manifold" is critical to the infringement analysis for the ’052 patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides a functional description, stating the "manifold system 24 can control the flow of treatment material from containers 26 into and through the line 20." (’052 Patent, col. 5:18-20). This language could support a construction that covers any component performing this fluid-holding and flow-control function.
    • Evidence for a Narrower Interpretation: The figures depict a specific physical structure: a block-like component into which multiple containers are directly coupled. (’052 Patent, Fig. 1). A defendant may argue that the term "manifold" should be limited to a structure reflecting this embodiment, rather than a more distributed system of valves and tubing.

The Term: "block" (’287 Patent, Claim 1)

  • Context and Importance: This term replaces "manifold" in Claim 1 of the ’287 patent, making its construction central to infringement. Practitioners may focus on this term because the patent specification primarily uses "manifold system" to describe the same component, creating ambiguity as to whether "block" carries a more specific structural meaning.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff may argue that "block" is used as a generic, functional term for the component that selectively receives and directs fluid, consistent with the functions described for the "manifold system" throughout the specification. (’287 Patent, col. 5:28-40).
    • Evidence for a Narrower Interpretation: A defendant could argue that the choice of the word "block" over "manifold" in the claim implies a more specific physical structure, such as a single, integrated component. The patent figures depicting the "manifold system" as a physical block (e.g., ’477 Patent, Fig. 15A) could be cited to support a narrower, more structural interpretation.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendants market, sell, and provide instructional materials, training, and demonstrations that direct and encourage customers to use the Accused Products in an infringing manner. (Compl. ¶¶43, 55). Contributory infringement is based on allegations that the Accused Products are material parts of the patented inventions and are not staple articles of commerce suitable for substantial non-infringing use. (Compl. ¶¶46, 58).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It specifically pleads that Defendant Candela received a cease and desist letter identifying the Asserted Patents on February 28, 2025, and continued its allegedly infringing activities thereafter. (Compl. ¶¶32, 48).

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

  • A core issue will be one of definitional scope: can the terms "manifold" ('052 patent) and "block" ('287 patent) be construed to cover the specific internal fluid-handling architecture of the accused Glace system, or do the terms require a physical structure that is materially different?
  • A key evidentiary question will be one of technical operation: does the accused product's vacuum system perform the dual function of simultaneously drawing waste from the skin and drawing treatment fluid from a container to the handpiece, as required by claims of the '052 and '607 patents, or are these functions performed by separate mechanisms?
  • The dispute may also turn on a question of functional interpretation: does the term "sequentially" in the '287 patent simply require that the system be capable of delivering fluids one after another via manual user selection, or does it require an automated, pre-programmed sequence of delivery?