DCT
1:25-cv-00564
Evolutive Labs Co Ltd v. Ringo Products LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Evolutive Labs Co., Ltd. (Taiwan)
- Defendant: Ringo Products, LLC (Delaware)
- Plaintiff’s Counsel: O & Kelly, O'Rourke
- Case Identification: 1:25-cv-00564, D. Del., 05/07/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is a Delaware limited liability company and conducts business in the district, including by offering the accused products for sale to consumers via its website.
- Core Dispute: Plaintiff alleges that Defendant’s Ringo water bottle, which incorporates a magnetic mount for mobile devices, infringes a patent related to containers with attachments for magnetically securing electronic devices.
- Technical Context: The technology occupies the consumer accessories market, combining a beverage container with an integrated, adjustable magnetic phone holder to provide hands-free utility for users.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent application that matured into the patent-in-suit on or about May 9, 2024, prior to the patent's issuance. The complaint also asserts that the issued claims are "substantially identical" to the published claims, which may form a basis for seeking pre-issuance damages.
Case Timeline
| Date | Event |
|---|---|
| 2022-11-07 | '678 Patent Earliest Priority Date |
| 2024-05-09 | Publication of Application Maturing into '678 Patent |
| 2024-05-09 | Alleged Notice of Published Application to Defendant |
| 2024-05-20 | Alleged Date of Defendant's Knowledge of Patent |
| 2024-10-15 | '678 Patent Issue Date |
| 2025-05-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,119,678 - Container and Lid and Attachment Thereof
- Patent Identification: U.S. Patent No. 12,119,678, issued October 15, 2024.
The Invention Explained
- Problem Addressed: The patent's background section describes the inconvenience faced by individuals, particularly in fitness settings, who must carry separate accessories like tripods or mounts to position their mobile devices for recording or viewing content, in addition to fundamental items like water bottles ('678 Patent, col. 1:40-52).
- The Patented Solution: The invention is an attachment for a container, such as a water bottle, that integrates a magnetic mount for a mobile device ('678 Patent, Abstract). The core of the solution is a "magnetic attraction member" that is "independent from the lid" and connected to the container via a "connecting structure," which allows the magnetic member to be positioned for use while remaining affixed to the container assembly ('678 Patent, col. 5:12-32).
- Technical Importance: This approach seeks to improve convenience by combining the functionality of a beverage container and a mobile device stand into a single, integrated product ('678 Patent, col. 1:47-52).
Key Claims at a Glance
- The complaint asserts independent claim 1 and alleges infringement of "one or more claims" ('678 Patent, Compl. ¶¶ 23-24).
- Independent Claim 1 requires:
- An attachment adapted for a container with a lid.
- A magnetic attraction member that is independent from the lid and can magnetically connect to a mobile device.
- A connecting structure between the magnetic member and the container.
- The connecting structure allows for selectively fixing the magnetic member in at least a first or second position.
- At least a portion of the connecting structure is fixed to the container.
III. The Accused Instrumentality
Product Identification
- The "Ringo water bottle" is the accused product (Compl. ¶23).
Functionality and Market Context
- The Ringo water bottle is a beverage container with an integrated, hinged, ring-shaped handle (Compl. ¶¶ 26, 28). This handle is alleged to be a magnetic member capable of securing a mobile electronic device, marketed as a feature that allows users to "DITCH THE TRIPOD" (Compl. p. 7). The complaint includes a screenshot from a product page showing the bottle magnetically holding a phone for hands-free viewing (Compl. p. 7).
IV. Analysis of Infringement Allegations
'678 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An attachment adapted for a container for containing food or liquid, the container having a lid, and the attachment comprising: | The accused Ringo water bottle is a container for liquid with a lid and an attachment. An annotated image from a product listing identifies these components. (Compl. p. 6) | ¶26 | col. 5:12-16 |
| [a] a magnetic attraction member independent from the lid and adapted to be magnetically connected to a mobile electronic device; and | The Ringo water bottle is alleged to have a magnetic attracting member, shown as a ring, that is independent from the lid and connects to a mobile device. | ¶27 | col. 5:20-25 |
| [b] a connecting structure disposed between the magnetic attraction member and the container for selectively fixing the magnetic attraction member at a first position or a second position, [c] wherein at least a portion of the connecting structure is fixed to the container. | The Ringo bottle is alleged to have a connecting structure (a hinge) between the magnetic member and the container that fixes the magnetic member in different positions. The complaint alleges this connecting structure is fixed to the lid of the container, providing an annotated image to support this. (Compl. p. 8) | ¶¶28, 29 | col. 5:25-32 |
- Identified Points of Contention:
- Scope Questions: Claim 1 requires the connecting structure to be "fixed to the container." The complaint alleges the accused structure is "fixed to the lid of the container" (Compl. ¶29). A dispute may arise over whether the term "container," as used in this limitation, should be construed to include the lid, or if it is limited to the body portion of the bottle.
- Technical Questions: The claim requires the connecting structure to be capable of "selectively fixing" the magnetic member in at least two positions. The complaint alleges this functionality but does not provide detailed evidence of a specific locking or detent mechanism in the accused product's hinge (Compl. ¶28). The analysis may turn on whether the friction of the accused hinge is sufficient to meet the "selectively fixing" limitation, or if a more definite positioning mechanism is required by the claim.
V. Key Claim Terms for Construction
The Term: "fixed to the container"
Context and Importance: This term is central to the infringement analysis because the complaint's theory of infringement rests on the connecting structure being fixed to the lid (Compl. ¶29). The definition of "container" will determine if this allegation can meet the claim limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent itself provides support for construing "container" to include the lid. Claim 26, a dependent claim, explicitly states that the connecting structure can be "disposed on the lid or the body portion," which suggests the inventors considered attachment to the lid to be within the scope of the invention ('678 Patent, col. 22:11-13). The preamble of claim 1 also introduces the "container" as "having a lid."
- Evidence for a Narrower Interpretation: A party could argue that the patent consistently distinguishes between the "lid" and the "body portion" as separate components (e.g., '678 Patent, col. 5:14-15), suggesting that when the claim states "container," it means only the main body portion and not the detachable lid.
The Term: "independent from the lid"
Context and Importance: This term defines the required relationship between the magnetic portion and the lid. Practitioners may focus on this term because it appears to be a key point of novelty, distinguishing the invention from a lid with an integrated magnet.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification provides an explicit definition, stating the term "indicates that the magnetic attraction member 100A and the lid 20A are not integrally formed, and the magnetic attraction member 100A is not integrated in the lid 20A, either. That is, the magnetic attraction member 100A and the lid 20A are two independent components." ('678 Patent, col. 5:25-30). This suggests that as long as they are manufactured as separate parts, the limitation is met.
- Evidence for a Narrower Interpretation: An argument could be made that "independent" requires some degree of functional or operational freedom beyond just being separate components in an assembly. However, the patent's own express definition appears to counter such a narrow reading.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by "providing instruction and guidance regarding the use of the Ringo water bottle" with knowledge and intent to encourage infringement (Compl. ¶31). The complaint does not cite specific instructional materials.
- Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge. The complaint asserts that Defendant had knowledge of the patent's claims at least as early as May 2024, following a notice letter from Plaintiff regarding the then-published patent application ('678 Patent, Compl. ¶¶ 15, 30, 33). Continued alleged infringement after this date is asserted as the basis for willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: can the claim term "fixed to the container" be properly construed to read on a structure that is fixed to the container’s detachable lid, as the complaint alleges? The patent’s own specification provides language that may support both broader and narrower interpretations.
- A key evidentiary question will be one of technical operation: does the accused Ringo bottle’s hinge mechanism meet the "selectively fixing" limitation of Claim 1? The case may require a factual determination of whether the hinge provides distinct, stable positions or merely undifferentiated frictional resistance to movement.