DCT
1:25-cv-06218
Zhuhai Kelitong Electronic Co Ltd v. Lee
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Zhuhai Kelitong Electronic Co., Ltd. (China)
- Defendant: Hui-Ling Lee, an individual, and RESPONSIBLE INDUSTRIAL CO., LTD., dba "KITCHEN MAMA" (China, Taiwan)
- Plaintiff’s Counsel: STRATUM LAW LLC
- Case Identification: 1:25-cv-06218, N.D. Ill., 06/09/2025
- Venue Allegations: The complaint does not allege a basis for venue in the Northern District of Illinois, but notes that 35 U.S.C. § 293 vests jurisdiction over non-U.S. patentees in the Eastern District of Virginia.
- Core Dispute: Plaintiff seeks a declaratory judgment that its can opener products do not infringe Defendant’s patent and that the patent is invalid and unenforceable, following Defendant’s infringement complaints to Amazon which resulted in the takedown of Plaintiff’s product listings.
- Technical Context: The dispute centers on the mechanical design of automated, handheld can openers, a mature field within the consumer household products market.
- Key Procedural History: The litigation was precipitated by Defendant's patent infringement complaint to Amazon, which caused the removal of Plaintiff's Amazon storefronts. The complaint alleges that the patent-in-suit is invalid over a prior UK patent by the same inventor and is unenforceable due to the patentee's failure to disclose this reference to the USPTO during prosecution.
Case Timeline
| Date | Event |
|---|---|
| 2008-06-18 | Application date for alleged prior art patent GB2453615B |
| 2012-09-03 | Priority Date for ’895 Patent (U.S. Application Filing) |
| 2015-02-17 | ’895 Patent Issued |
| 2025-02-20 | Plaintiff's Amazon storefronts removed following "Takedown Notice" |
| 2025-03-09 | Defendant made patent infringement claim to Amazon |
| 2025-03-21 | Plaintiff's expert report on non-infringement released |
| 2025-06-09 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,955,227 - "Can Opener"
- Patent Identification: U.S. Patent No. 8,955,227, "Can Opener," issued February 17, 2015 (the "’895 Patent").
The Invention Explained
- Problem Addressed: The patent's background section describes conventional manual can openers as requiring significant user force and the use of two hands (one to hold the can, one to operate the opener), which is characterized as wasting energy and causing inconvenience (’895 Patent, col. 1:11-31).
- The Patented Solution: The invention is an automatic, motorized can opener that clamps onto a can lid, cuts it, and releases it without manual force. The solution relies on a specific gear train, including a driving gear, three distinct "driven gears," a torsion spring, and a cam (’895 Patent, Abstract). This mechanism works by translating motor rotation through the gears to move a slide, which in turn pushes an "idling wheel" against a "cutting wheel" to clamp and cut the can's rim (’895 Patent, col. 4:40-68). After cutting, the torsion spring provides a "restoring force" to reverse the process and release the can (’895 Patent, col. 5:1-5).
- Technical Importance: The described solution aims to provide a fully automated "hands-free" can opening process, improving user convenience over manual or semi-automatic devices (’895 Patent, col. 2:1-16).
Key Claims at a Glance
- The complaint’s non-infringement analysis focuses exclusively on independent claim 1 (Compl. ¶¶24-32).
- Essential elements of claim 1 include:
- a housing, a driving gear, and a reduction transmission device
- a cutting wheel rotated by the driving gear
- a movable slide and an idling wheel
- a first driven gear meshing with the driving gear
- a second driven gear
- a torsion spring biased between the first and second driven gears
- a third driven gear meshing with the second driven gear
- a cam rotated by the third driven gear to move the slide
- The complaint makes no mention of asserting dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are can openers sold by Plaintiff under the brand names Syaws, DERNORUS, and CIRCLE JOY on three different Amazon storefronts (Compl. ¶16).
Functionality and Market Context
- The complaint alleges that the accused products achieve automatic can opening in a mechanically distinct way from the patented invention (Compl. ¶35). Instead of the claimed multi-gear and torsion spring linkage, the accused products allegedly use "forward and reverse rotation of the motor, as well as the cooperative linkage and intermittent disengagement between the drive gear and the eccentric disk" to adjust the position of a sliding plate (Compl. ¶35). The products were sold on Amazon, which the complaint identifies as a "primary national marketplace," before being delisted due to Defendant's infringement assertions (Compl. ¶17, ¶42).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The analysis below summarizes the Plaintiff's allegations that its product is missing key elements of the asserted claim. No probative visual evidence provided in complaint.
- ’895 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first driven gear rotatably mounted in the housing and meshing with the driving gear | Plaintiff alleges the accused product does not have a first driven gear, and that the corresponding physical location is "an empty space." | ¶25 | col. 5:49-51 |
| a second driven gear rotatably mounted in the housing | Plaintiff alleges the accused product has no second driven gear, and the corresponding location is "an empty space." | ¶26 | col. 5:52-53 |
| a torsion spring biased between the first driven gear and the second driven gear... | As the accused product allegedly lacks the first and second driven gears, Plaintiff asserts it is "impossible for there to be a torsion spring set between them." | ¶27 | col. 5:54-57 |
| a third driven gear rotatably mounted in the housing and meshing with the second driven gear | As the accused product allegedly lacks a second driven gear, Plaintiff asserts it is "impossible to have a third driven gear that meshes with the second driven gear." | ¶28 | col. 5:58-60 |
| a cam mounted on and rotated by the third driven gear and received in the aperture of the slide to move the slide... | Plaintiff alleges the absence of a third driven gear means "there are no other structures connected to the third driven gear." | ¶29 | col. 5:60-63 |
| wherein the second driven gear has a surface provided with an arcuate guiding slot | Plaintiff alleges the accused product "does not have a feature corresponding to 'guiding slot'." | ¶30 | col. 6:0-2 |
| the first driven gear has a surface provided with a protrusion mounted in the guiding slot of the second driven gear | Plaintiff alleges the accused product "does not have a feature corresponding to 'protrusion'." | ¶31 | col. 6:3-6 |
- Identified Points of Contention:
- Scope Questions: The core dispute may turn on whether the accused product's "eccentric disk" mechanism (Compl. ¶35) can be construed as the claimed "cam" or performs an equivalent function. A further question is whether any components in the accused device meet the definitions of the "first driven gear," "second driven gear," or "third driven gear," either literally or under the doctrine of equivalents.
- Technical Questions: A central technical question is whether the accused product's mechanism operates in a fundamentally different way from the claimed invention, as alleged (Compl. ¶35). The complaint suggests the accused product uses motor direction reversal and an eccentric disk, whereas the patent describes a one-way motor action with a mechanical linkage and a "restoring force" from a torsion spring to reverse the clamping action.
V. Key Claim Terms for Construction
The complaint's non-infringement theory suggests claim construction will focus on the specific mechanical components of the gear train.
The Term: "a first driven gear," "a second driven gear," "a third driven gear"
Context and Importance: These terms define the specific mechanical linkage that translates motor force into the clamping and unclamping action of the cutting mechanism. Plaintiff alleges a complete absence of these elements (Compl. ¶¶25, 26, 28). The viability of the non-infringement case depends on establishing that no components in the accused product meet these structural limitations or their equivalents.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims the gears functionally (e.g., "meshing with the driving gear"). A party could argue that any component that receives rotational force from the driving gear and transmits it onward serves as a "first driven gear," regardless of its specific form.
- Evidence for a Narrower Interpretation: The specification and figures show a very specific arrangement of toothed, interacting gears (e.g., ’895 Patent, Fig. 3, items 20, 60, 70, 50). A party could argue that the terms should be limited to these specific disclosed structures, particularly in light of the complaint’s allegation that the accused product uses a different type of linkage, such as an "eccentric disk" (Compl. ¶35).
The Term: "torsion spring"
Context and Importance: The claimed torsion spring provides the "restoring force" that causes the mechanism to unclamp from the can lid after the cut is complete (’895 Patent, col. 4:9-11). Plaintiff alleges its product lacks this component entirely (Compl. ¶34). A key question will be whether the accused product's alleged use of "reverse rotation of the motor" to unclamp is a substantially different approach.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any element that stores and releases energy to reverse the clamping motion is a "torsion spring" or its equivalent.
- Evidence for a Narrower Interpretation: The specification describes the spring as being "biased between the first driven gear and the second driven gear" (’895 Patent, col. 3:1-3). This specific structural placement could be used to argue for a narrow construction, excluding mechanisms where the restoring force is generated by other means, such as reversing the motor itself.
VI. Other Allegations
- Invalidity and Unenforceability: The complaint contains a declaratory judgment count for invalidity and unenforceability (Compl. ¶¶36-38). It alleges that the ’895 Patent is invalid under 35 U.S.C. §§ 102 and 103 in view of a prior art UK patent, GB2453615B (Compl. ¶38). The complaint further alleges that the UK patent has the same inventor and applicant as the ’895 Patent and that the inventor's failure to disclose this reference to the USPTO during prosecution constitutes inequitable conduct, rendering the ’895 patent unenforceable (Compl. ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action will likely depend on the court’s answers to two main questions:
- A core issue will be one of structural and functional equivalence: Does the accused product's mechanism, which allegedly relies on "reverse rotation of the motor" and an "eccentric disk," operate in a substantially different way from the specific multi-gear linkage and "torsion spring" restoring force required by Claim 1 of the ’895 Patent?
- A critical question for the patent’s survival is one of validity and enforceability: Does the undisclosed UK patent GB2453615B, allegedly from the same inventor, anticipate or render obvious the claims of the ’895 Patent, and did the failure to disclose it to the USPTO rise to the level of inequitable conduct?