DCT

1:25-cv-02364

Chulandianzikeji Shenzhen Youxiangongsi v. Taizhou Huangyan Mengsheng Technology Co Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-02364, N.D. Ill., 03/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant targets business activities and sales to customers in the United States, including Illinois, via interactive e-commerce storefronts on Amazon.com. The complaint further alleges that Defendant's patent assertion campaign through Amazon has directly impacted Plaintiff's business in Illinois.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its automatic pet water feeders do not infringe Defendant’s patent and/or that the patent is invalid, following an infringement complaint filed by Defendant against Plaintiff through Amazon.com's intellectual property notice program.
  • Technical Context: The technology concerns gravity-fed, automatic pet water feeders that incorporate a water filtration system to provide clean drinking water.
  • Key Procedural History: The lawsuit was precipitated by Defendant filing a patent infringement complaint against Plaintiff on Amazon.com on or about February 18, 2025. This action threatened the removal of Plaintiff's product listings from the Amazon marketplace, creating a justiciable controversy that prompted Plaintiff to file this declaratory judgment action in federal court.

Case Timeline

Date Event
2023-04-10 '025 Patent Priority Date (Application Filing)
2023-09-26 '025 Patent Issue Date
2025-02-18 Defendant files infringement complaint on Amazon.com
2025-03-05 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 11,766,025 - “AUTOMATIC WATER FEEDER FOR PET,” issued September 26, 2023

The Invention Explained

  • Problem Addressed: The patent identifies shortcomings in conventional pet water feeders, noting they are often made of plastic that is difficult to clean, can breed bacteria, and provide unfiltered water, which may lead to pet health issues (’025 Patent, col. 1:10-21).
  • The Patented Solution: The invention is a multi-component automatic pet water feeder designed to solve these problems. It consists of a water reservoir ("bucket body"), a filter assembly, and a base with a drinking container (’025 Patent, col. 3:7-24). The core mechanism involves a "movable pin" that automatically opens a "silicone plug" when the water bucket is placed on the base, allowing water to flow through a filter element and into the drinking bowl. When the bucket is lifted for refilling, the mechanism automatically re-seals the bucket to prevent spills (’025 Patent, col. 4:17-26). The use of materials like stainless steel for the container is also presented as a solution to inhibit bacteria growth (’025 Patent, col. 2:32-34).
  • Technical Importance: The claimed invention seeks to provide a more hygienic and user-friendly solution for pet hydration by combining continuous water filtration with a spill-proof refilling mechanism (’025 Patent, col. 2:25-39).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement and invalidity of "at least one claim" of the ’025 Patent, and its prayer for relief covers all claims (Compl. ¶24; Prayer for Relief ¶¶ 1-2). Independent claim 1 is central.
  • Independent Claim 1 recites:
    • A water replenishing assembly with a bucket body, bucket cover, a silicone plug, and a movable pin to telescopically drive the plug.
    • A filter assembly with a shell and a filter element, where the bucket cover inserts into the shell to allow water to flow through the filter.
    • A base assembly with a base body and a container for the pet.
    • A specific structural arrangement wherein the filter's shell is inside the container and the shell itself comprises an upper and lower cover, with the bucket cover inserting through a "tapered opening" in the upper cover.

III. The Accused Instrumentality

Product Identification

The accused products are identified as Plaintiff's "automatic pet water feeders," referred to as the "Non-Infringing Product" (Compl. ¶2). The complaint provides a list of over twenty Amazon Standard Identification Numbers (ASINs) corresponding to these products (Compl. ¶¶ 14, 25).

Functionality and Market Context

The complaint does not describe the specific technical features or operation of the accused products. It makes the conclusory allegation that "none of the Non-Infringing Products possess all the elements and limitations of any claim of the '025 B2 Patent" (Compl. ¶22). The commercial context is a dispute between competing sellers on the Amazon.com marketplace, with the patent being used as a tool to remove a competitor's listings (Compl. ¶¶ 2, 13, 19). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not contain affirmative infringement allegations or a claim chart. It asserts in general terms that Plaintiff's products do not infringe (Compl. ¶22). The complaint does not provide sufficient detail for a claim-by-claim analysis of potential infringement.

Identified Points of Contention

  • Structural Equivalence: The primary dispute will be factual: do the Plaintiff's products contain the specific structures recited in the claims of the ’025 Patent? The analysis will likely focus on whether the accused devices incorporate every element of claim 1, such as the "movable pin configured to telescopically drive the silicone plug" or the two-part "shell" with its "upper cover" and "lower cover" (’025 Patent, col. 6:8-25).
  • Evidentiary Question: A central question for the court will be what the evidence shows regarding the design and operation of the accused pet water feeders. As the complaint offers no technical description of the products, discovery will be necessary to determine if a factual basis for infringement exists.
  • Divided Infringement: The complaint states that "Plaintiff alone does not perform all the steps recited the claims of the ‘025 B2 patent as is required for direct infringement" (Compl. ¶27). While claim 1 is an apparatus claim, not a method claim, this allegation suggests a potential defense that no single actor makes, uses, or sells a fully assembled, infringing device, or it may anticipate an argument related to user assembly.

V. Key Claim Terms for Construction

The Term: "movable pin configured to telescopically drive the silicone plug"

  • Context and Importance: This phrase describes the core valve mechanism that controls water flow. The infringement analysis may hinge on whether the accused product's valve operates via a "movable pin" that "telescopically drives" a plug, or if it uses a functionally different mechanism.
  • Intrinsic Evidence for a Broader Interpretation: The patent's summary describes the function more broadly as a pin that drives a plug "to block and dredge the mouth of the bucket body" (’025 Patent, col. 1:29-31), which could support interpreting the term to cover any pin-like structure that achieves this open/close function.
  • Intrinsic Evidence for a Narrower Interpretation: The detailed description and figures illustrate a specific mechanical interaction involving a pin (15), a boss (16) that abuts a bump (241), and a spring (17) (’025 Patent, col. 4:7-26; Fig. 2). A party could argue that "telescopically drive" requires the specific linear, spring-assisted action shown in the preferred embodiment.

The Term: "shell comprises an upper cover and a lower cover"

  • Context and Importance: Claim 1 requires the filter housing ("shell") to be constructed from two distinct components: an "upper cover" and a "lower cover" (’025 Patent, col. 6:20-21). A device with a single-piece, integrated filter housing may not meet this limitation.
  • Intrinsic Evidence for a Broader Interpretation: The term "comprises" is typically open-ended, suggesting the shell must have these parts but could have others. A party might argue that two functionally distinct regions of a single piece could satisfy the "upper" and "lower" cover limitations.
  • Intrinsic Evidence for a Narrower Interpretation: The patent specification explicitly states "the shell 20 includes an upper cover 21 and a lower cover 22" and describes how they are assembled via a "clamping ring 28" and "clamping groove 27," implying they are separate physical components (’025 Patent, col. 3:27-28; col. 4:46-53). Figure 4 clearly depicts the upper cover (21) and lower cover (22) as separate parts.

VI. Other Allegations

Indirect Infringement

The complaint makes a blanket denial of any direct or indirect infringement (Compl. ¶25). It does not provide specific facts to address inducement or contributory infringement, aside from the ambiguous allegation that Plaintiff does not perform all steps of the claims (Compl. ¶27).

Willful Infringement

Willfulness is not alleged against the Plaintiff. Instead, Plaintiff alleges that Defendant's infringement accusations on Amazon.com are "baseless and exceptional," which may warrant an award of attorneys' fees to Plaintiff under 35 U.S.C. § 285 (Compl. ¶29). This claim is based on the allegation that Defendant knowingly made false claims of infringement to disrupt Plaintiff's business (Compl. ¶4).

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

  • A central issue will be one of factual comparison: Does the Plaintiff's product, once examined, actually contain the specific multi-part valve assembly ("movable pin," "silicone plug," "boss") and the two-part filter "shell" ("upper cover," "lower cover") as strictly required by the language of Claim 1? The case's trajectory depends entirely on this feature-by-feature technical evidence, which is absent from the complaint.
  • The case will also involve a question of invalidity: The complaint seeks a declaration that the ’025 Patent is invalid as anticipated or obvious (Compl. ¶¶ 32-33). A key battleground will be whether the combination of a gravity-fed reservoir, a user-activated valve, and a filter element in a pet waterer was obvious to a person of ordinary skill in the art at the time of the invention.
  • Finally, a procedural and tactical question is presented by the commercial context: To what extent will Defendant's use of Amazon's private enforcement mechanism, and Plaintiff's characterization of it as an anticompetitive tactic, influence the court's view of the equities in the case, particularly regarding Plaintiff's claim for attorneys' fees?