DCT
1:25-cv-00378
GoClips LLC v. Xiamen Aoyin Industry & Trade Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GoClips LLC and Z Keepers LLC (Florida)
- Defendant: XIAMEN AOYIN INDUSTRY & TRADE CO., LTD d/b/a AOYIN TOOLS (People's Republic of China)
- Plaintiff’s Counsel: Pierson Ferdinand, LLP
- Case Identification: 1:25-cv-00378, N.D. Ga., 01/28/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because Defendant is said to regularly conduct business in the district, a substantial part of the events giving rise to the action occurred there, and the acts of infringement were committed within the district.
- Core Dispute: Plaintiffs allege that Defendant’s sink anchoring clips infringe a patent related to sink clamps and the methods for their use in undermounting sinks.
- Technical Context: The technology concerns mechanical fasteners used in the construction and remodeling industry to secure undermount sinks to the underside of hard countertops like granite.
- Key Procedural History: The complaint notes that Plaintiffs’ commercial products were marked as "Patent Pending" prior to the patent’s issuance and have been marked with the patent number since the grant, which may be relevant to establishing notice for damages calculations.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-10 | ’754 Patent Priority Date |
| 2017-11-28 | U.S. Patent No. 9,828,754 Issued |
| 2025-01-28 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,828,754 - "SINK CLAMP AND METHODS," issued November 28, 2017
The Invention Explained
- Problem Addressed: The patent’s background section identifies conventional methods for mounting undermount sinks as "time consuming and of ten subject to failure due to human error" (’754 Patent, col. 1:11-13). These prior art methods involved difficult and potentially damaging steps such as drilling into countertops, using epoxies that could fail, or hammering clips into place in confined under-sink spaces (’754 Patent, col. 1:14-64).
- The Patented Solution: The invention is a clamping device designed for installation into a narrow slot ground into the underside of the countertop, adjacent to the sink opening. The device has a "binding lip" that inserts into the slot; a screw is then tightened against the sink's rim, which causes the lip to bind within the slot and securely clamp the sink in place (’754 Patent, Abstract). This design, illustrated in figures such as Fig. 1, is intended to be installed without drilling or hammering, thereby simplifying the process and reducing the risk of damage to the countertop or sink (’754 Patent, col. 5:62-65).
- Technical Importance: The technology aims to provide a "quick and easy attachment of a sink to a surface of a counter," addressing the labor intensity and reliability problems associated with prior methods (’754 Patent, col. 2:7-8).
Key Claims at a Glance
- The complaint does not specify which claims are asserted but alleges infringement of "the claims" of the '754 patent (Compl. ¶20). Independent claim 1 is representative of the asserted technology.
- Independent Claim 1 recites an "undercounter sink attachment system" with the following essential elements:
- A sink with an outer edge, intended for use with a countertop that has a "generally vertical slot" formed in its bottom surface.
- A clamping device for attaching the sink.
- The device includes a "clamp body" with an "insertable end" configured for upward insertion into the countertop slot.
- A "clamping spring" is "connected to the clamp body" and includes a deflectable portion extending at an upward angle.
- This deflectable portion is configured to contact the sink's edge and be deflected, transmitting an "upward clamping force" to the sink.
- The clamping spring has a hole and is "connected to the clamp body by a fastener horizontally offset from the insertable end."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are identified as "Sinkits Sink Clips" (Compl. ¶19).
Functionality and Market Context
- The complaint alleges that the "Sinkits Sink Clips" are "knockoff devices" that are "identical in appearance, form and function to authentic GoClips®" sink anchors (Compl. ¶5, ¶21). The complaint provides an image from Defendant’s product catalogue depicting the accused "Sinkits Sink Clips" (Compl., p. 9). The function of the accused devices is to anchor sinks to the underside of countertops (Compl. ¶5). The complaint alleges Defendant manufactures these products in China and exports, markets, and sells them within the United States, targeting Plaintiffs' customers (Compl. ¶19, ¶22).
IV. Analysis of Infringement Allegations
'754 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a sink having an outer edge configured to fit about an opening of a countertop having a generally vertical slot formed in a bottom surface of the countertop beside the sink | The accused "Sinkits Sink Clips" are allegedly sold for the purpose of attaching sinks to countertops in a system identical to that of Plaintiffs' products. | ¶5, ¶21 | col. 6:31-36 |
| a clamp body having an insertable end, said insertable end being configured to insert into the slot of the countertop above the clamp body in an upward insertion direction | The accused device, as depicted in the complaint, includes a body with an upward-bent end piece, alleged to function as the claimed insertable end. | ¶19, p. 9 | col. 6:46-50 |
| a clamping spring connected to the clamp body, the clamping spring in a relaxed state including a deflectable portion extending upwardly form the clamp body forming an upward angle | The accused device has an upper portion that extends upwardly from the body, alleged to be a clamping spring. | ¶19, p. 9 | col. 6:51-54 |
| said upward angle of the relaxed deflectable spring portion configured to be deflected by contact of the deflectable spring portion with a peripheral portion of the sink...to transmit an upward clamping force | The complaint alleges the accused device is identical in function, suggesting this upper portion is intended to deflect against a sink rim to create a clamping force. A marketing image shows the Plaintiff's GoClips® product installed, illustrating this intended function (Compl., p. 6). | ¶21 | col. 6:54-62 |
| wherein the clamping spring has a hole and the clamping spring is connected to the clamp body by a fastener horizontally offset from the insertable end | The image of the accused device appears to show a fastener connecting the upper "spring" portion to the lower "body" portion. | ¶19, p. 9 | col. 6:62-65 |
Identified Points of Contention
- Scope Questions: A central question is whether the accused product, depicted only in a single catalogue image, contains every limitation of the asserted claims. For example, the complaint alleges functional identity, but a court will require element-by-element proof. A potential dispute may arise over whether the "Sinkits Sink Clips" are sold as part of a "system" that includes the claimed sink and countertop with a slot, or merely as a standalone component.
- Technical Questions: The complaint's allegation of infringement rests heavily on the assertion that the accused product is "identical in function" (Compl. ¶21). A key technical question will be whether the accused clip's upper portion actually operates as a "clamping spring" that deflects to "transmit an upward clamping force" in the specific manner required by the claim, a fact that will require technical evidence beyond the provided images.
V. Key Claim Terms for Construction
- The Term: "clamping spring connected to the clamp body by a fastener"
- Context and Importance: The relationship between the "spring" and the "body" is a core structural limitation of claim 1. The construction of this phrase will be critical, as it may determine whether a device made from a single, continuous piece of metal can infringe. Practitioners may focus on this term because if the accused product is a unitary component, the defendant could argue it lacks a distinct "spring" that is "connected" to a "body" via a "fastener."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that "Preferably the clamp 10 is a unitary or integral structure of the clamp body 17 formed with the binding lip 14 from a single material, such as a bent metal product" (’754 Patent, col. 3:36-39). Plaintiffs may argue that "connected" can describe the relationship between two distinct functional regions of a single part.
- Evidence for a Narrower Interpretation: Claim 1 explicitly requires the spring to be "connected to the clamp body by a fastener." The specification and figures consistently depict this as two separate parts: a binding spring (16) attached to a clamp body (17) with a rivet or screw (27, 47) (’754 Patent, Fig. 1; col. 4:21-25; col. 4:51-53). This language strongly supports an interpretation requiring two physically distinct components joined together.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges that "Defendant's knockoff products have no alternate, non-infringing use" (Compl. ¶33), a factual predicate often used to support a claim for contributory infringement.
- Willful Infringement: Willfulness is alleged based on Defendant’s conduct being "knowing, willful and deliberate" (Compl. ¶22, ¶31). The complaint alleges Defendant was placed on notice of the '754 patent (Compl. ¶34), seemingly through constructive notice via Plaintiffs’ marking of their commercial products with the patent number (Compl. ¶17), and purposefully targeted Plaintiffs' customers despite this notice (Compl. ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the phrase "clamping spring connected to the clamp body by a fastener," as used in Claim 1, be interpreted to cover a device potentially manufactured from a single, unitary piece of metal, or does it unambiguously require two separate components joined together, as depicted in the patent's preferred embodiments?
- A key evidentiary question will be one of factual proof: beyond the general allegations of identity and a single product image, what evidence can Plaintiffs produce to demonstrate that the accused "Sinkits Sink Clips" actually meet every structural and functional limitation of the asserted claims, particularly the specific mechanism of deflection and force transmission required of the "clamping spring"?