Friend Enterprises LLC v. Bed Made Ez LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Friend Enterprisess LLC (Delaware)
  • Defendant: BED MADE EZ, LLC (Florida); Cki 2712218 LLC (Florida); Ridge Wallet LLC (California); Castle Fit Corp (Georgia); Zlumber LLC (Florida)
  • Plaintiff’s Counsel: Friend Enterprisess LLC, Pro Se
• Case Identification: 1:25-cv-01458, D. Del., 12/01/2025
• Venue Allegations: Plaintiff asserts venue is proper in the District of Delaware because Plaintiff resides and conducts business there, Defendants directed patent enforcement activities that caused injury in the district, and Plaintiff's product listings on Amazon were accessible nationwide.
• Core Dispute: Plaintiff, an Amazon merchant, seeks a declaratory judgment that its various consumer products do not infringe patents owned by the five distinct Defendants, who allegedly filed infringement complaints with Amazon, resulting in the suspension of Plaintiff’s product listings.
• Technical Context: The dispute spans several unrelated consumer product categories—wallets, mattress lifters, bed sheet grippers, and yoga straps—reflecting the nature of patent enforcement actions on large e-commerce platforms.
• Key Procedural History: The controversy arises from Defendants’ use of Amazon's intellectual property complaint system to remove five of Plaintiff’s product listings. The complaint states that Amazon requires a federal court order to reinstate the listings, prompting this declaratory judgment action.

Case Timeline

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

U.S. Design Patent No. D1,036,852 - "WALLET"

The Invention Explained

• Problem Addressed: Design patents protect the ornamental appearance of an article of manufacture rather than addressing a technical problem (D1,036,852).
• The Patented Solution: The patent claims the specific ornamental design for a wallet as depicted in its figures. The claimed design consists of a minimalist wallet constructed from two outer plates held together by fasteners. Key visual elements include the planar surfaces, exposed peripheral fasteners, a curved finger notch on one edge for pushing out cards, and a distinct cutout shape on an opposing edge (D1,036,852, Figs. 1-7).

Key Claims at a Glance

• Design patents contain a single claim for the ornamental design as shown in the drawings. The claim of the ’852 Patent recites: "The ornamental design for a wallet, as shown and described" (D1,036,852, col. 2:56-57).

U.S. Patent No. 8,191,191 - "APPARATUS AND METHOD FOR LIFTING A MATTRESS"

The Invention Explained

• Problem Addressed: The patent’s background section states that mattresses are typically "bulky and heavy to lift," which can cause physical strain for individuals, such as hotel housekeepers, who must repeatedly lift mattress corners to tuck in bed linens (’191 Patent, col. 1:31-35).
• The Patented Solution: The invention is a wedge-shaped ergonomic tool designed to be inserted between a mattress and its underlying support structure. The tool’s inclined body elevates a portion of the mattress, creating a gap for tucking in sheets without requiring the user to manually lift and hold the mattress's weight (’191 Patent, Abstract). The apparatus is constructed as a "continuous loop" formed by a base member, an incline member, a transition member, and a handle, which provides structural strength (’191 Patent, col. 2:40-44; Fig. 1).
• Technical Importance: The invention offers a simple mechanical aid to reduce the physical effort and potential for injury associated with the repetitive task of making a bed (’191 Patent, col. 1:36-45).

Key Claims at a Glance

• The complaint does not specify which claims are asserted. Independent claim 1 is representative of the core invention.
• The essential elements of independent claim 1 include:
  • A body comprising a lift portion extending from a distal to a proximal end.
  • A body interior region defined within the lift portion.
  • A handle with first and second ends fixedly coupled to the body.
  • An aperture defined by the body.
  • A continuous loop defined by the perimeter of the aperture and the handle.

U.S. Patent No. 11,383,119 - "MULTIMODAL FITNESS BAR"

Technology Synopsis

This patent describes a fitness device combining a rigid bar assembly with a flexible "resistance assembly," such as a fabric sheet with an opening for a user's foot (’119 Patent, Abstract). The configuration allows a user to perform a variety of resistance-based exercises and stretches by creating tension between the hands gripping the bar and a foot placed in the resistance assembly (’119 Patent, col. 1:34-42).

Asserted Claims

The complaint does not identify specific asserted claims, referring generally to "the '119 claims" (Compl. ¶33, 43).

Accused Features

The "Flex Friend Yoga Straps" are accused of infringement. Plaintiff alleges its products are non-infringing because they are made of "non-elastic woven nylon and lack the elastic looped-band resistance structure" allegedly required by the patent's claims (Compl. ¶33).

U.S. Patent No. 12,390,016 - "BED SHEET RETENTION SYSTEMS, SYSTEM COMPONENTS, AND METHODS OF MAKING AND USING THE SAME"

Technology Synopsis

The patent addresses the problem of bed sheets becoming untucked by disclosing retention devices, typically brackets, that are placed between a mattress and its support surface (’016 Patent, col. 1:40-47). The brackets include "sheet-engaging channels" designed to grip and hold the edge of a bed sheet, often with the aid of a separate "sheet locking strip" that is pressed into the channel to secure the fabric (’016 Patent, Abstract).

Asserted Claims

The complaint does not identify specific asserted claims, referring generally to the "'016 patent" (Compl. ¶31, 47).

Accused Features

The "Sheet Friend Bed Sheet Grippers / Holders" are accused of infringement. Plaintiff alleges non-infringement on the basis that its product "uses hook-and-loop straps with flat locking plates and contains no spring element or pivoting jaw," features which Plaintiff contends are required by the patent's claims (Compl. ¶31).

III. The Accused Instrumentality

Product Identification

• ASIN B0DTGY823C – "Secure Friend Slim RFID Wallet with AirTag"
• ASIN B0FJGHTP7G – “Wedge Friend 2 Pack Mattress Lifter & Sheet Tucking Tool"
• ASIN B0FCPF9HRH – “Sheet Friend Bed Sheet Grippers / Holders”
• ASINs B0FGJYG3TY & B0FFHDJZJ4 – “Flex Friend Yoga Straps”

Functionality and Market Context

• The complaint describes the functionality of its products primarily in terms of how they differ from the asserted patents. The "Secure Friend" wallet is described as having "rounded corners, an integrated AirTag recess, different fastener placement, and a multi-layer composite exterior" (Compl. ¶17). The "Wedge Friend" mattress lifter is described as a "one-piece polyurethane foam wedge" (Compl. ¶25). The "Sheet Friend" grippers are alleged to use "hook-and-loop straps with flat locking plates" (Compl. ¶31). The "Flex Friend" yoga straps are described as being made of "non-elastic woven nylon" (Compl. ¶33).
• The products are all sold on the Amazon.com e-commerce platform. The dispute arose from infringement complaints filed by the Defendants through Amazon's reporting system, which led to the suspension of Plaintiff's listings, indicating a competitive online marketplace context (Compl. ¶2-3).

IV. Analysis of Infringement Allegations

The complaint, being a declaratory judgment action for non-infringement, does not contain a claim chart alleging infringement. Instead, it presents narrative arguments for why Plaintiff's products do not infringe. A summary of these non-infringement theories is provided below.

No probative visual evidence provided in complaint.

D1,036,852 (Wallet) Non-Infringement Allegations

• Narrative Summary: Plaintiff alleges that its "Secure Friend" wallet is "materially distinct" from the design claimed in the ’852 Patent and creates a "different overall impression to an ordinary observer" (Compl. ¶36). The complaint identifies specific design differences, including "rounded corners, an integrated AirTag recess, different fastener placement, and a multi-layer composite exterior," which it argues are absent from the patented design (Compl. ¶17). Plaintiff's argument is framed around the "ordinary observer" test for design patent infringement (Compl. ¶19).
• Identified Points of Contention: The core dispute will involve a visual comparison of the accused wallet and the design shown in the ’852 Patent. A central question is whether the differences articulated by the Plaintiff are significant enough to prevent an ordinary observer from viewing the designs as "substantially the same."

’191 Patent (Mattress Lifter) Non-Infringement Allegations

• Narrative Summary: Plaintiff argues its "Wedge Friend" product omits "multiple required claim limitations" of the ’191 Patent, specifically citing the "patented lever geometry, handle configuration, and structural components" (Compl. ¶39). The product is described as a "one-piece polyurethane foam wedge" that lacks the "handle mechanism and lever geometry" claimed in the patent (Compl. ¶25). This suggests the accused product is a simple, solid wedge, unlike the patented device which is claimed as a "continuous loop" structure comprising a distinct handle and an aperture.
• Identified Points of Contention: The analysis may focus on whether the accused product's solid wedge form meets the structural limitations of the asserted claims. Key questions include whether any part of the accused wedge can be construed as a "handle" and whether a solid object can satisfy the "continuous loop" and "aperture" limitations required by the patent.

V. Key Claim Terms for Construction

Patent: U.S. Patent No. 8,191,191

The Term: "handle"

• Context and Importance: This term is critical because Plaintiff’s primary non-infringement argument rests on the assertion that its "one-piece polyurethane foam wedge" lacks a handle mechanism (Compl. ¶25, 27). The construction of "handle" will determine whether any portion of the accused product can be said to meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide a specific definition for "handle." A defendant (patentee) may argue for the term's plain and ordinary meaning: any part of the device designed or suitable for being gripped by a user to manipulate it.
  • Evidence for a Narrower Interpretation: The patent specification and figures consistently depict the handle as a distinct structural element (150) that is coupled to the main body and forms part of a "continuous loop" with an aperture (’191 Patent, Fig. 1; col. 2:13-16). Claim 1 requires "a first handle end" and "a second handle end... being fixedly coupled to the body," language which may support an interpretation that the handle must be a structurally distinguishable component rather than an undifferentiated portion of a solid wedge.

The Term: "continuous loop"

• Context and Importance: This structural feature is presented in the patent as providing strength and is a required element of independent claim 1 (’191 Patent, col. 2:19-21). If the accused product is a solid wedge, its ability to meet this limitation is questionable, making the term's construction central to the dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A patentee might argue that "continuous loop" refers to the closed-form force-bearing structure of the entire device, regardless of whether it contains an empty space or aperture.
  • Evidence for a Narrower Interpretation: Claim 1 explicitly defines the "continuous loop" as being "defined by the perimeter of the aperture and the handle." This language suggests that the presence of both an "aperture" (an opening) and a "handle" are prerequisites for the existence of the claimed "continuous loop." The figures consistently show a device with a clear opening (aperture 160) surrounded by the device's structural members (’191 Patent, Fig. 1).

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

• A key evidentiary question will be one of ornamental distinction: For the ’852 design patent, do the functional and aesthetic differences alleged by Plaintiff—such as the integrated AirTag recess and different corner geometry—create an overall visual impression in the eye of an ordinary observer that is "plainly dissimilar" from the patented wallet design, or are they minor variations that fail to negate substantial similarity?
• A core issue will be one of definitional scope: For the ’191 patent, can the claim terms "handle" and "continuous loop," which the patent specification and figures depict as distinct structural features defining an "aperture," be construed broadly enough to read on a "one-piece polyurethane foam wedge" that is alleged to be a solid object lacking such features?
• A significant procedural question is whether these four distinct patent disputes against five different defendants concerning unrelated technologies are properly joined in a single declaratory judgment action, or whether the cases should be severed, as the only common thread appears to be the Defendants' use of Amazon's third-party IP complaint process.