DCT
8:25-cv-01246
Hydrapak LLC v. Sawyer Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: HydraPak LLC (California)
- Defendant: Sawyer Products, Inc. (Florida)
- Plaintiff’s Counsel: Kolitch Romano Dascenzo Gates LLC
- Case Identification: 8:25-cv-01246, M.D. Fla., 05/14/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, maintains a regular and established place of business in the district, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s flexible hydration containers, specifically a bladder and a bottle, infringe two patents related to reservoir closure systems and methods of flexible container construction.
- Technical Context: The technology concerns portable, flexible containers for liquids, such as those used for personal hydration in the outdoor and recreational products market.
- Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the asserted patents, or prior licensing history.
Case Timeline
| Date | Event |
|---|---|
| 2006-06-02 | U.S. Patent No. 8,186,881 Priority Date |
| 2012-03-06 | U.S. Patent No. 10,897,980 Priority Date |
| 2012-05-29 | U.S. Patent No. 8,186,881 Issues |
| 2021-01-26 | U.S. Patent No. 10,897,980 Issues |
| 2025-05-13 | Accused Product Website Screenshot Date |
| 2025-05-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,186,881 - "Reservoir Closure System and Method," Issued May 29, 2012
The Invention Explained
- Problem Addressed: The patent describes a need for fluid reservoirs that have a wide opening for easy cleaning and filling but can also be sealed securely enough to withstand significant internal fluid pressure, a common failing of conventional zipper-type closures. (U.S. Patent No. 8,186,881, col. 1:45-57).
- The Patented Solution: The invention is a closure system comprising a flexible container with an orifice and a separate, elongated slider. The container's opening is lined with specially configured "catches," and the slider is designed to slidably engage these catches, forcing the orifice closed to create a pressurized seal. (’881 Patent, Abstract; col. 2:5-14).
- Technical Importance: This technology sought to provide a robust, wide-mouth closure that was faster to operate than roll-top closures and stronger than simple press-fit zippers, addressing a key usability trade-off in soft-sided hydration systems. (’881 Patent, col. 1:50-57, col. 2:1-2).
Key Claims at a Glance
- The complaint asserts claims 10-16, which include independent claims 10, 15, and 16. (Compl. ¶18).
- Independent Claim 10 recites:
- A reservoir closure system comprising a container with a first end, a first lip, a second lip, a reservoir, an orifice, and a fold configured to concurrently fold the first and second lip.
- The container has at least two catches on a first side when in an open configuration.
- A sealing member (slider) configured to slidably attach to the container and seal the orifice.
- The sealing member has a channel with arms to compress the lips and catches to prevent movement.
- The complaint reserves the right to assert dependent claims.
U.S. Patent No. 10,897,980 - "Flexible Container," Issued January 26, 2021
The Invention Explained
- Problem Addressed: The patent identifies shortcomings in conventional soft reservoirs, which often lack handles and cannot stand upright on their own, and notes that methods for constructing them present challenges. (’980 Patent, col. 1:42-45).
- The Patented Solution: The invention is a hybrid container constructed with a rigid or semi-rigid molded top portion and a similar molded bottom portion, connected by a flexible, unmolded reservoir body. The flexible body is formed by folding and welding a panel of film, which allows for a collapsible design that still incorporates structural elements like a base for stability. (’980 Patent, Abstract; col. 2:6-15).
- Technical Importance: The invention describes a method for manufacturing hybrid containers that combine the structural advantages of rigid bottles (e.g., stability, integrated handles) with the light weight and collapsibility of flexible film reservoirs.
Key Claims at a Glance
- The complaint asserts claims 31-34 and 36-37. (Compl. ¶24).
- Independent Claim 31 recites:
- A flexible container device with a rigid container top portion, a rigid cap, and a rigid container bottom.
- A flexible reservoir body is situated between the top and bottom portions.
- The flexible reservoir body is formed by a flexible panel that is folded and attached to itself along one or more body seams.
- The flexible reservoir body is collapsible, foldable, and configured to be partially filled by a fluid.
- The complaint reserves the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The complaint names the "Cnoc Premium 2 Liter Bladder" and the "Cnoc Premium 1 Liter Bottle" as the Accused Products. (Compl. ¶12).
Functionality and Market Context
- The Accused Products are described as flexible containers for liquids sold by Defendant Sawyer for use in the outdoor and water filtration markets. (Compl. ¶11, ¶13).
- An image in the complaint depicts the "Cnoc Premium 2 Liter Bladder" as a flexible reservoir with a wide top opening and a separate piece that appears to be a slide-on closure. (Compl. p. 6).
- The same image shows the "Cnoc Premium 1 Liter Bottle" as a container with a threaded neck for a cap and a body that appears to be made of flexible material. (Compl. p. 6).
- The complaint alleges these products are sold through Defendant's website and retail partners. (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint references claim chart exhibits (Exhibits D and E) that were not provided with the filing. (Compl. ¶14). The analysis below is based on the narrative infringement theory, the patent claims, and the visual evidence within the complaint.
'881 Patent Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a container wherein the container comprises a first end, the first end having a first lip, a second lip, a reservoir and an orifice... wherein the container comprises a fold configured to concurrently fold the first lip and the second lip | The Cnoc Premium 2 Liter Bladder is a container with a reservoir and an orifice at its top end, which forms two lips that are folded together for closure. | ¶18, p. 6 | col. 10:11-19 |
| wherein when the container is in the open configuration the container has at least two catches on a first side of the container... and wherein when the container is in a closed configuration the container has at least one catch on the first side of the container and at least one catch on the second side of the container | The complaint alleges via its exhibit that the bladder’s opening has structures that function as the claimed "catches" for engagement with the sealing member. | ¶15, ¶18 | col. 11:12-20 |
| a sealing member configured to slidably attach to the container... wherein the sealing member comprises a channel defined by a sealing member first side, a sealing member second side, and... arms extending from the sealing member first side and positioned opposite... arms extending from the sealing member second side | An image shows the Cnoc Premium 2 Liter Bladder includes a separate, elongated slider piece that slidably attaches to the top opening to seal it. This slider is alleged to have the channel and arm structures of the claim. | ¶18, p. 6 | col. 10:21-36 |
Identified Points of Contention:
- Technical Question: A primary evidentiary question will be whether the structures lining the opening of the Cnoc Premium 2 Liter Bladder meet the specific definitions and structural requirements of the "catches" and the "fold" as recited in claim 10. The complaint's allegations on this point are conclusory, referencing an exhibit that is not available for review. (Compl. ¶15).
- Scope Question: The claim requires a specific configuration of "at least two catches on a first side" in the open configuration, which shifts to catches on both sides in the closed configuration. The litigation may focus on whether the accused product's closure geometry satisfies this dynamic structural limitation.
'980 Patent Infringement Allegations
| Claim Element (from Independent Claim 31) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A flexible container device, comprising: a rigid container top portion... a rigid cap... a rigid container bottom having a bottom footprint | The Cnoc Premium 1 Liter Bottle is alleged to have a rigid top/cap and a base that constitutes a "rigid container bottom." | ¶24, p. 6 | col. 23:46-53 |
| a flexible reservoir body in between the rigid container top portion and the rigid container bottom... wherein the flexible reservoir body is formed by a flexible panel folded... | The body of the Cnoc Premium 1 Liter Bottle is a flexible reservoir, which the complaint alleges is formed from a folded and seamed flexible panel. | ¶24, p. 6 | col. 23:54-62 |
| wherein the flexible reservoir body is collapsible and foldable, and wherein the flexible reservoir body is configured to be partially filled by a fluid | The accused bottle's body is made of flexible material, alleged to be collapsible and foldable for storing liquid. | ¶24, p. 6 | col. 23:63-65 |
Identified Points of Contention:
- Scope Question: A central dispute will likely be whether the base of the accused "Cnoc Premium 1 Liter Bottle," which appears to be made of flexible material, can be construed as a "rigid container bottom" as required by claim 31. The patent specification repeatedly distinguishes between "rigid or semi-rigid, molded" elements and "flexible, unmolded" reservoir elements, which may support an argument that the claim requires a structurally distinct, non-flexible base. (’980 Patent, col. 2:6-11).
- Technical Question: Infringement of claim 31 also depends on the product’s method of manufacture. Proving that the accused bottle's body is "formed by a flexible panel folded and attached to itself along one or more body seams" will require evidence from Defendant’s manufacturing process, which is not available in the complaint.
V. Key Claim Terms for Construction
Term: "a rigid container bottom" (’980 Patent, Claim 31)
- Context and Importance: This term appears dispositive for the infringement analysis of the '980 patent against the accused Cnoc Premium 1 Liter Bottle. The visual evidence suggests the accused product is a soft, flexible bottle. Practitioners may focus on this term because its construction will determine whether the claim can read on a product that lacks a traditionally rigid base.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue that "rigid" is a relative term and that the base of the bottle, if made of thicker or molded material than the sidewalls, is "rigid" in the context of the invention, which contrasts it with the "flexible reservoir body."
- Evidence for a Narrower Interpretation: The specification explicitly contrasts "a first rigid or semi-rigid, molded element" with a "flexible, unmolded reservoir element." (’980 Patent, col. 2:6-11). It also describes the container bottom as having a "flat bottom terminal end" that can "support the reservoir" and "enable the container 2 to stand vertically," features which imply a degree of structural rigidity not apparent in the accused product's image. (’980 Patent, col. 6:8-12).
Term: "fold configured to concurrently fold the first lip and the second lip" (’881 Patent, Claim 10)
- Context and Importance: This functional language is at the heart of how the claimed closure operates. Practitioners may focus on this term because its interpretation will define whether a specific, pre-formed structure is required or if any incidental creasing during closure suffices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language is functional, and a plaintiff could argue that any structure on the container that causes the lips to fold together when the slider is engaged meets the limitation, regardless of its specific form.
- Evidence for a Narrower Interpretation: A defendant could argue that the "fold" is a discrete structural element, pointing to related claims like claim 15, which recites "a flexible, semi-rigid elongated splint" where the container "comprises a fold coincident with the upper edge of the splint." (’881 Patent, col. 12:59-62). This suggests the "fold" is a specific feature that can be located relative to another component.
VI. Other Allegations
- Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement, as it does not allege specific facts related to inducement or contributory infringement, such as the role of user manuals or instructions.
- Willful Infringement: The complaint alleges that Defendant’s infringement has been and continues to be willful. (Compl. ¶19, ¶25). This allegation is made "on information and belief" and does not specify a basis for pre-suit knowledge, such as a prior notice letter or previous litigation. (Compl. ¶16).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: For the '980 patent, can the term "rigid container bottom," which the patent links to structural, molded components that enable standing, be construed to read on the flexible base of the accused soft bottle?
- A second key question will be one of factual correspondence: For the '881 patent, does the accused bladder’s slide-on closure possess the specific structural geometry of the claimed "catches" and "fold," a determination that will depend on evidence not yet available in the public record.
- Finally, the case may turn on an issue of manufacturing evidence: Infringement of the '980 patent requires proving the accused bottle's body is made from a "flexible panel folded and attached to itself," which will necessitate discovery into Defendant's confidential manufacturing methods.