DCT
1:18-cv-02344
Interlink Products Intl Inc v. Aldi Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Interlink Products International, Inc. (New Jersey)
- Defendant: Aldi, Inc. (Illinois)
- Plaintiff’s Counsel: Spence, P.C.
- Case Identification: 1:18-cv-02344, N.D. Ill., 04/02/2018
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendant resides there, has its headquarters there, and maintains a regular place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Easy Home" brand dual showerhead products infringe two patents related to water diverter and holder devices for combination showerheads.
- Technical Context: The technology concerns the mechanical design of plumbing fixtures that combine a fixed showerhead with a handheld sprayer, allowing a user to divert water flow between them.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement of the ’510 Patent in 2017 and also warned Defendant about the ’954 Patent. The complaint further alleges that despite these warnings and discussions about a potential supply relationship, Defendant proceeded to source and sell allegedly infringing products in February 2018 from a different supplier.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-14 | U.S. Patent No. 7,299,510 Priority Date |
| 2006-04-24 | U.S. Patent No. 7,373,954 Priority Date |
| 2007-11-27 | U.S. Patent No. 7,299,510 Issued |
| 2008-05-20 | U.S. Patent No. 7,373,954 Issued |
| 2015-11-17 | Interlink acquires all right, title, and interest in the ’510 Patent |
| 2017-01-01 | Interlink informs Aldi of infringement of the ’510 Patent and warns of the ’954 Patent (approximate date) |
| 2018-01-19 | Aldi informs Interlink that a showerhead promotion was awarded to another vendor |
| 2018-02-01 | Aldi allegedly sells infringing products (approximate date) |
| 2018-04-02 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,373,954 - Multi-Ways Water Distributing Device (Issued May 20, 2008)
The Invention Explained
- Problem Addressed: The patent notes that prior art shower systems provided for water distribution in only two directions (e.g., to a fixed head or a hand-held sprayer) and required a separate bracket to hold the hand-held element, which was not integrated into the diverter mechanism (’954 Patent, col. 1:5-19).
- The Patented Solution: The invention is a single, integrated device that serves as a water diverter and a holder for a hand-held shower element. It uses a "turnable rod" within a casing to provide four modes of operation: water to the first outlet, water to the second outlet, water to both outlets simultaneously, and a complete shutoff of water flow (’954 Patent, Abstract; col. 2:30-36). The device is designed to be a compact, multi-function unit.
- Technical Importance: This design aims to provide more functionality (four water flow options) and physical integration (combined diverter and holder) than what the patent describes as available in existing devices (’954 Patent, col. 1:15-20).
Key Claims at a Glance
- The complaint asserts "all claims" of the patent (Compl. ¶20). Independent claim 1 is analyzed here.
- Independent Claim 1:
- A multi-way water distributing device, comprising
- a casing having one input pipe and two output pipes;
- means rotatable in said casing for providing a discharge of water in a first direction, or a discharge of water in a second direction and having a rotating handle;
- a rotatable holder for holding a working instrument,
- said handle and said holder being arranged on one axis at opposite sides of said casing as considered in an axial direction of said axis and being rotatable about said one axis;
- a non-rotatable screw which is screwed directly in said casing so as not to rotate relative to the latter, said holder being rotatable relative to said screw.
U.S. Patent No. 7,299,510 - Holder Device for Shower Head and Nozzle (Issued Nov. 27, 2007)
The Invention Explained
- Problem Addressed: The patent identifies a problem with typical shower appliance holders that require drilling holes into a wall to mount a bracket, a task many users cannot easily perform. It also notes that suction-cup alternatives can be unreliable and slide over time (’510 Patent, col. 1:13-49).
- The Patented Solution: The invention is a holder device that attaches directly to the existing water outlet tube extending from the wall, eliminating the need for drilling or separate wall mounts (’510 Patent, Abstract; col. 2:58-64). The device integrates a housing with an inlet and two outlets, a mechanism for controlling water flow between a fixed shower head and a handheld sprayer, and an "attaching device" to hold the sprayer nozzle (’510 Patent, col. 2:10-25).
- Technical Importance: This approach simplifies installation by leveraging the existing plumbing infrastructure as the mounting point for the entire dual-showerhead assembly.
Key Claims at a Glance
- The complaint asserts claims 1, 2, 3, 4, 9, 10, and 11 (Compl. ¶33). Independent claim 1 is analyzed here.
- Independent Claim 1:
- A holder device for attaching to a water outlet tube... said holder device comprising:
- a housing including an inlet for attaching to the water outlet tube... said housing including a first outlet port and at least one second outlet port, and including a partition secured thereto,
- means for controlling the water to flow out through said first outlet port and said at least one second outlet port,
- a sprayer nozzle attached to said at least one second outlet port of said housing,
- an attaching device rotatably attached to said partition of said housing for attaching said sprayer nozzle,
- said partition including a bore formed therein, and
- a follower rotatably engaged in said bore of said partition and secured to said attaching device.
III. The Accused Instrumentality
- Product Identification: The "Easy Home" brand dual showerhead products, including the "Multifunction 2-in-1 Showerhead Kit" and "Rain Showerhead Combo Kit" (Compl. ¶¶11, 20, 33).
- Functionality and Market Context:
- The accused products are described as consisting of two separate showerheads (one fixed, one handheld) packaged with a device that serves as a combined water diverter and holder for the handheld sprayer (Compl. ¶12).
- This diverter/holder allegedly features an inlet for water, two outlets, a valve controlled by a knob to direct water flow between the showerheads, and a holder for the handheld sprayer (Compl. ¶12).
- The complaint alleges that Defendant sells these products during special promotional periods and competes directly with Plaintiff in the retail market for dual showerhead products (Compl. ¶10).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’954 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a casing having one input pipe and two output pipes | The accused product includes a "plumbing device" with "an inlet for water to flow into the diverter, two outlets for water to flow out." | ¶12 | col. 2:40-43 |
| means rotatable in said casing for providing a discharge of water... and having a rotating handle | The device has "a valve for controlling water flow" and allows the user to "direct the flow of water between the showerheads using a knob on the diverter/holder." | ¶12 | col. 2:24-36 |
| a rotatable holder for holding a working instrument | The device "serves as a combined water diverter and handheld shower holder" and has "a holder for the handheld sprayer." | ¶12 | col. 2:49-55 |
| said handle and said holder being arranged on one axis at opposite sides of said casing... and being rotatable about said one axis | The complaint does not provide sufficient detail for analysis of this specific geometric arrangement. | col. 3:42-46 | |
| a non-rotatable screw... said holder being rotatable relative to said screw | The complaint does not provide sufficient detail for analysis of the internal assembly mechanism. | col. 3:46-col. 4:1 |
’510 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing including an inlet... a first outlet port and at least one second outlet port | The accused product's diverter/holder has "an inlet for water... [and] two outlets for water to flow out." The fixed showerhead and handheld sprayer attach to these outlets. | ¶12 | col. 3:10-23 |
| a partition secured thereto | The complaint does not provide sufficient detail for analysis of the internal components. | col. 4:1-3 | |
| means for controlling the water to flow out | The diverter/holder has "a valve for controlling water flow to the diverter outlets." | ¶12 | col. 3:28-33 |
| an attaching device rotatably attached to said partition... for attaching said sprayer nozzle | The device serves as a "combined water diverter and handheld shower holder." | ¶12 | col. 3:55-59 |
| a follower rotatably engaged in said bore of said partition and secured to said attaching device | The complaint does not provide sufficient detail for analysis of the internal components. | col. 4:3-10 |
- Identified Points of Contention:
- Structural Detail: The complaint provides a high-level functional description of the accused products but lacks specific allegations about their internal mechanical structure. This raises the question of what evidence supports infringement of claim limitations directed to internal components like the "partition", "follower", and "non-rotatable screw".
- Means-Plus-Function Scope (’954 Patent): Claim 1 of the ’954 patent recites a "means rotatable in said casing." This term may be construed as a means-plus-function limitation, the scope of which would be limited to the corresponding structure described in the specification (a "turning rod 2") and its equivalents. The infringement analysis will depend on whether the accused product's internal valve mechanism is structurally equivalent to the patent's disclosed turning rod.
- Rotatability (’510 Patent): Claim 1 of the ’510 patent requires an "attaching device rotatably attached to said partition." A key question will be whether the holder portion of the accused device is, in fact, "rotatably attached" in the manner claimed, an operational detail not explicitly described in the complaint.
V. Key Claim Terms for Construction
For the ’954 Patent:
- The Term: "means rotatable in said casing for providing a discharge of water"
- Context and Importance: This term appears to be a means-plus-function limitation under 35 U.S.C. § 112(f). Its construction will be central because the scope of the claim will be limited to the specific structure disclosed in the patent's specification for performing the recited function, and its equivalents. The entire infringement case for this patent may hinge on whether the accused product's valve is structurally equivalent to the patent's disclosed "turning rod."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue the term should cover any rotating valve mechanism that achieves the four-way water distribution. However, under means-plus-function jurisprudence, the interpretation is tied to the specification.
- Evidence for a Narrower Interpretation: The specification explicitly identifies the corresponding structure as a "turnable rod 2" that is "located inside the casing 1" and has specific openings (49, 50) that align with the casing's ports to control flow (’954 Patent, col. 2:24-26; col. 2:56-60; Figs. 13-14). This detailed disclosure is likely to define the scope of the claim term narrowly.
For the ’510 Patent:
- The Term: "an attaching device rotatably attached to said partition"
- Context and Importance: Practitioners may focus on this term because it defines a specific structural and functional relationship between the holder for the sprayer ("attaching device") and an internal component ("partition"). The infringement analysis will require determining if the accused product's holder is rotatable and, if so, whether it is attached to an internal partition as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function as allowing the user to adjust the position of the handheld sprayer. A party might argue this should cover any form of adjustable or pivoting holder.
- Evidence for a Narrower Interpretation: The specification discloses a specific assembly where the attaching device (24) is secured to a "follower" (30), which is in turn "rotatably engaged" within a "bore" (28) of the "partition" (26) (’510 Patent, col. 4:1-15; Fig. 3). This detailed mechanical linkage may support a narrower construction requiring this specific type of rotatable connection.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces infringement by selling the accused products and providing instructions and promotional materials that "encourage assembly, installation and use" by purchasers (Compl. ¶¶22, 25, 35, 38). It is alleged the products have no substantial non-infringing uses because their components cannot be assembled into a practical device that does not infringe (Compl. ¶¶25, 38).
- Willful Infringement: The complaint alleges willfulness based on pre-suit knowledge. It states that Plaintiff notified Defendant of its infringement of the ’510 Patent and warned it of the ’954 Patent during communications in 2017, prior to the sales of accused products in 2018 (Compl. ¶¶7, 13, 24, 37). The complaint alleges that Defendant acted despite an "objectively high likelihood" of infringement (Compl. ¶¶27, 40).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural correspondence: Does the internal valve mechanism of Aldi's "Easy Home" showerhead constitute an equivalent to the specific "turnable rod" structure disclosed in the ’954 patent, as required for infringement of its means-plus-function claim limitation?
- A key evidentiary question will be one of undisclosed technical detail: What evidence can Plaintiff produce to show that the accused products contain the specific internal components recited in the claims, such as the "partition" and "follower" of the ’510 patent, which are not described in the complaint's high-level functional allegations?
- The willfulness claim will likely depend on a question of notice and intent: Did the 2017 communications provide Aldi with knowledge of infringement that was so clear that its subsequent decision to sell the accused products from another supplier constituted "knowing disregard" of Interlink's patent rights?