ADR Products LLC v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ADR Products LLC (Ohio)
  • Defendant: Tool-Home (People's Republic of China)
  • Plaintiff’s Counsel: Ni, Wang & Massand, PLLC
• Case Identification: 1:25-cv-09071, N.D. Ill., 09/08/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s indoor clothes dryer vent kits infringe one utility patent and one design patent related to lint catching systems.
• Technical Context: The technology concerns indoor filtration systems for electric clothes dryers, designed to capture lint from exhaust air when venting to the outside is not feasible.
• Key Procedural History: The operative pleading is an Amended Complaint. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the asserted patents.

Case Timeline

Date	Event
2014-02-28	Earliest Priority Date for D’418 Patent and ’904 Patent
2022-01-04	D’418 Patent Issued
2022-10-25	’904 Patent Issued
2025-09-08	Amended Complaint Filed

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

U.S. Patent No. 11,479,904 - Lint Catching System and Exhaust Assembly (Issued Oct. 25, 2022)

The Invention Explained

• Problem Addressed: The patent’s background section describes disadvantages of prior indoor dryer vents, including designs that use water (which can increase humidity and promote mold) and other designs with inefficient airflow that can lead to lint accumulation inside the filter housing rather than on the filter medium, reducing performance and creating potential hazards (’904 Patent, col. 1:47 - 2:57).
• The Patented Solution: The invention proposes a lint filter with a specially shaped housing, featuring flat front and back walls connected by curved end walls, intended to generate an advantageous "circulation pattern" of exhaust air (’904 Patent, col. 3:11-18). This design purports to enhance uniform airflow across the filter material, improve lint capture, and prevent lint from settling on the housing’s internal surfaces (’904 Patent, col. 7:15-37; Fig. 9). A notable feature is a movable cover over a secondary exhaust aperture, designed to automatically open if air pressure increases due to a clogged filter, thereby serving as both a safety relief valve and a visual indicator that maintenance is required (’904 Patent, col. 11:5-19).
• Technical Importance: The claimed system aims to improve the safety and efficiency of indoor dryer venting by using specific housing geometry to manage airflow for better filtration and by incorporating a pressure-sensitive indicator for filter clogs (’904 Patent, col. 1:41-44).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims," including "at least Claim 1" (Compl. ¶¶38-39).
• Independent Claim 1 recites the following essential elements:
  • A filter housing with an interior chamber defined by at least front and back panel walls and a curved end panel wall.
  • A filter housing inlet.
  • A filter housing outlet.
  • An exhaust aperture element in the curved end panel wall.
  • A cover element rotatably connected to the curved end panel wall, which covers the exhaust aperture at a first pressure and uncovers it at a second, higher pressure.

U.S. Design Patent No. D940,418 - Lint Catcher (Issued Jan. 4, 2022)

The Invention Explained

• Problem Addressed: Design patents protect the ornamental, non-functional appearance of an article of manufacture.
• The Patented Solution: The patent claims "the ornamental design for a lint catcher, as shown and described" (D’418 Patent, "CLAIM"). The claimed design consists of the specific visual appearance of the lint catcher depicted in the patent's figures. Key ornamental features include the overall rectangular housing with rounded top and bottom surfaces, a prominent square grid pattern on the front face, and a circular air inlet port extending from the bottom rounded surface (D’418 Patent, Figs. 1, 6).
• Technical Importance: The value of the design patent lies in protecting the product's distinct aesthetic appearance in the marketplace.

Key Claims at a Glance

• Design patents contain a single claim.
• Claim 1 claims the ornamental design for the lint catcher as illustrated in the patent's drawings (D’418 Patent, "CLAIM").

III. The Accused Instrumentality

Product Identification

• The accused products are "3-in-1 Indoor Dryer Vent Kit[s]" sold on the Amazon storefront TOOL-HOME under the brand name "Dkenicor" (Compl. ¶¶24-26).

Functionality and Market Context

• The complaint identifies the accused products as indoor dryer vents intended for electric dryers (Compl. ¶25). A product listing image included in the complaint shows a primary housing unit accompanied by polyester filters, a screen filter, and what is described as a "Water Drawer System" (Compl. p. 5). The listing also notes the product is an "Amazon's Choice" with "50+ bought in past month," suggesting a degree of commercial activity (Compl. p. 5).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts as exhibits but does not attach them (Compl. ¶¶32, 39). The infringement theories are therefore analyzed based on the complaint’s narrative allegations and accompanying visuals.

D’418 Patent Infringement Allegations

The complaint alleges that the design of the accused "Dkenicor" product is "substantially similar to the patented design of the D’418 Patent to the eye of an ordinary observer" (Compl. ¶33). This allegation relies on a direct visual comparison. The complaint provides a screenshot from an Amazon product listing showing the accused "Dkenicor" vent kit (Compl. p. 5).

• Identified Points of Contention:
  • Scope Questions: The central issue for design patent infringement is whether the accused design and the patented design are sufficiently similar to deceive an ordinary observer. A point of contention may arise from differences between the designs. For instance, the image of the accused product shows a hexagonal or honeycomb-style grid on its front face, whereas the D’418 Patent explicitly depicts a square grid pattern (Compare Compl. p. 5 with D’418 Patent, Fig. 1). The defense may argue that this prominent difference, among others, creates a distinct overall visual impression.

’904 Patent Infringement Allegations

The complaint asserts that the accused products meet every limitation of at least Claim 1, either literally or equivalently (Compl. ¶39).

• Identified Points of Contention:
  • Technical Questions: A primary technical question will concern the claimed "cover element rotatably connected to said curved end panel wall". The complaint provides no specific allegation as to what structure in the accused product performs this function. The product listing mentions a "Water Drawer System," which raises the question of whether this system is, or includes, a mechanical, rotatably connected cover that opens in response to air pressure, as the claim requires (Compl. p. 5).
  • Scope Questions: The construction of the term "curved end panel wall" may be a focus of dispute. The patent specification describes this element in the context of a "180 degree arc" (’904 Patent, col. 5:4-7). Whether the geometry of the accused product's housing falls within the scope of this claim term will be a central question for infringement.

V. Key Claim Terms for Construction

For the ’904 Patent:

• The Term: "cover element rotatably connected to said curved end panel wall"

• Context and Importance: This term defines the pressure-relief and maintenance-indicator feature, which is a key inventive concept. The definition of "rotatably connected" is critical to determining whether alternative pressure-relief mechanisms could infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the type of rotating connection. A party could argue that any component that pivots or hinges to uncover an aperture in response to pressure meets this limitation.
  • Evidence for a Narrower Interpretation: The specification discloses specific embodiments using "pivot elements" (66) that engage "pivot receiving members" (67) to form a hinge-like structure (’904 Patent, Figs. 11A-11C; col. 10:37-43). A party may argue that "rotatably connected" should be limited to such depicted mechanical pivot structures.

• The Term: "curved end panel wall"

• Context and Importance: This structural limitation is described in the patent as generating the advantageous airflow pattern central to the invention's function. Its scope will determine what housing shapes are covered by the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "curved" itself is general, and a plaintiff could argue it should be given its plain and ordinary meaning, covering any continuously bending, non-angular surface at the top or bottom of the housing.
  • Evidence for a Narrower Interpretation: The detailed description specifies that the curved end panel walls each have "a 180 degree arc disposed in opposed outwardly extending relation" (’904 Patent, col. 5:4-7). A defendant may argue this disclosure limits the claim term to the semi-circular geometry shown in the figures.

VI. Other Allegations

• Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement, as it does not plead specific facts related to inducing or contributory acts.
• Willful Infringement: The complaint alleges that Defendant’s infringement is "knowing[] and willful[]," basing this claim on knowledge of the patents "at least as of the filing of this amended complaint" (Compl. ¶¶28-29). This alleges willfulness based on post-suit knowledge.

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

1. A core issue for the design patent will be one of ornamental distinction: does the accused product's hexagonal front grid and overall configuration create a different visual impression in the eyes of an ordinary observer when compared to the patented design's square grid and specific proportions?
2. A key technical question for the utility patent will be one of structural equivalence: does the accused product's "Water Drawer System," or any other feature, function as the claimed "cover element rotatably connected" that opens in response to a specific increase in air pressure, or is there a fundamental mismatch in its structure and mechanism of operation?
3. A central question of definitional scope will be whether the term "curved end panel wall", which the patent specification ties to a "180 degree arc," can be construed to cover the apparently more rectangular geometry of the accused device's housing.