MM Casa Inc v. Delta Faucet Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: MM CASA INC et. al. (Massachusetts / China)
  • Defendant: Delta Faucet Company (Indiana)
  • Plaintiff’s Counsel: Aronberg Goldgehn Davis & Garmisa
• Case Identification: 1:25-cv-12322, N.D. Ill., 10/08/2025
• Venue Allegations: Plaintiffs allege venue is proper because Defendant maintains a business presence and office within the Northern District of Illinois.
• Core Dispute: Plaintiffs seek a declaratory judgment that their glass rinsing products do not infringe Defendant's patent related to a vessel rinsing apparatus, and that the patent is invalid as obvious in view of prior art.
• Technical Context: The technology concerns sink-mounted, pressure-activated devices designed for the rapid rinsing of glassware, commonly used in commercial and residential settings.
• Key Procedural History: The complaint alleges that Defendant filed complaints with Amazon through its Patent Evaluation Express Program (APEX), accusing Plaintiffs' products of infringement and causing their removal from the platform. This action by the patent holder appears to have prompted the Plaintiffs to file this declaratory judgment lawsuit.

Case Timeline

Date	Event
2018-09-14	’277 Patent Priority Date
2022-10-18	’277 Patent Issue Date
2025-10-08	Complaint Filing Date

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

U.S. Patent No. 11,473,277 - "Vessel Rinsing Apparatus"

• Patent Identification: U.S. Patent No. 11,473,277, “Vessel Rinsing Apparatus,” issued October 18, 2022.

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty of effectively cleaning the interior of glasses and other small vessels, noting that conventional methods like sponges or standard faucets often fail to provide the directional, pressurized water flow needed to remove dirt and debris from internal extremities (’277 Patent, col. 1:17-29).
• The Patented Solution: The invention is a self-contained vessel rinsing apparatus designed for installation in a standard countertop opening. It comprises a fluid discharge member with multiple nozzles that is activated when a user presses an inverted glass down onto a trigger. This action opens a valve, spraying water into the glass. A key feature is an integrated drain bowl, or escutcheon, that surrounds the spray mechanism to collect and direct the wastewater into the sink basin. The complaint includes a figure from the patent showing an embodiment of the apparatus integrated with a kitchen faucet. (Compl. p. 5; ’277 Patent, Abstract; col. 1:31-52).
• Technical Importance: The patented design provides a dedicated, integrated solution for high-pressure vessel rinsing at the sink, addressing a common need in both commercial and residential environments (’277 Patent, col. 1:29-33).

Key Claims at a Glance

• The complaint identifies independent claims 1, 11, and 20 as being at issue (Compl. ¶26).
• Independent Claim 1, for example, recites the following essential elements:
  • A mounting member configured to extend through a mounting deck aperture.
  • A fluid discharge member with nozzles and a trigger, where the member is movable relative to the mounting member.
  • A valve member coupled to the fluid discharge member that controls water flow in response to the trigger's movement.
  • A drain bowl coupled to the mounting member, which includes a lower wall, an upwardly extending wall, and a drain channel through that wall to discharge water into a sink.
• The complaint seeks a declaration that all 24 claims of the ’277 Patent are invalid (Compl. ¶32).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as "glass rinsing products" sold by the Plaintiffs on Amazon.com (Compl. ¶27). Specific products are referenced by their Amazon Standard Identification Numbers (ASINs) listed in the complaint (Compl. ¶¶29-30).

Functionality and Market Context

• The complaint does not provide a technical description of the Plaintiffs' products. Instead, it states that Defendant has accused these products of infringement through Amazon's APEX program, which led to their removal from the website (Compl. ¶¶28-31). The lawsuit is a direct response to these accusations, seeking a court declaration that the products do not infringe.

IV. Analysis of Infringement Allegations

The complaint is a declaratory judgment action for non-infringement and invalidity; therefore, it does not contain affirmative infringement allegations or a claim chart. The Plaintiffs' primary argument for non-infringement is that the ’277 Patent is invalid under 35 U.S.C. § 103 as obvious in view of prior art, and that an invalid patent cannot be infringed (Compl. ¶¶40-41).

The complaint's invalidity theory centers on prior art references, including U.S. Patent Application Publication No. 2008/0142095 ("Van Der Linden") (Compl. ¶35). The complaint includes a figure from the Van Der Linden prior art patent application, depicting an example of a glass cleaner with a plunger, nozzle, and drain bowl (Compl. p. 4). Plaintiffs allege that this and other references disclose or render obvious all limitations of the asserted claims (Compl. ¶¶35-37).

• Identified Points of Contention:
  • Validity Question: The central dispute presented in the complaint is whether the combination of the cited prior art references (including Van Der Linden, Shen Wei, and Albers) discloses or renders obvious all limitations of the asserted claims, particularly the claimed combination of a movable fluid discharge member and an integrated drain bowl with a specific drain channel configuration (Compl. ¶¶35-37).
  • Procedural Question: As the complaint's non-infringement count is predicated almost entirely on its invalidity argument, a threshold question for the case is whether the court will first resolve the patent's validity before addressing any technical arguments for non-infringement that may be raised later in the proceedings.

V. Key Claim Terms for Construction

While the complaint does not raise specific claim construction disputes, the following terms from the independent claims may become central to the litigation.

The Term: "drain bowl"

• Context and Importance: The structure and function of the "drain bowl" appear to be a key element of the invention. The scope of this term will be critical for both infringement and validity analyses, as Plaintiffs' invalidity argument relies on prior art allegedly disclosing this feature (Compl. ¶35).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the feature functionally as a "drain receptacle or bowl 52 for the collection and disposal of debris and wastewater," which could support a broader definition not tied to a specific structure (’277 Patent, col. 4:8-10).
  • Evidence for a Narrower Interpretation: Claim 1 requires a specific structure, including "a lower wall, an upwardly extending wall operably coupled to the lower wall, and a drain channel extending through the upwardly extending wall" (’277 Patent, col. 7:10-15). The specification further shows the drain bowl is defined by the cooperation of an escutcheon and the upper plate of the mounting base, which could support a narrower construction limited to this arrangement (’277 Patent, col. 5:46-52).

The Term: "movable relative to the mounting member"

• Context and Importance: This term defines the action of the fluid discharge member that activates the water spray. The required type and degree of movement (e.g., linear vs. tilting) could be a point of contention in an infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is facially broad. The specification describes the movement as being "along the longitudinal axis 68 between a raised (or rest) position (FIG. 5), and a lowered (or active) position (FIG. 6)," which confirms at least one type of movement is covered (’277 Patent, col. 5:1-4).
  • Evidence for a Narrower Interpretation: The detailed description and figures exclusively depict a linear, up-and-down movement of the central body within the mounting shank opening (’277 Patent, col. 4:65-68; Figs. 5-6). A party could argue that "movable" should be construed as being limited to this specific linear motion.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement.

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

• A core issue will be one of patent validity: Do the prior art references cited by the Plaintiffs, individually or in combination, disclose or render obvious every element of the asserted claims of the ’277 Patent, particularly the specific configuration of the drain bowl and its integration with the mounting and discharge members?
• A central legal question will be one of claim scope: How will the court construe the term "drain bowl"? A narrow construction tied to the specific structural arrangement shown in the patent's embodiments may make the patent harder to invalidate but also harder to infringe, while a broader, more functional definition would have the opposite effect.
• A key procedural question will be one of litigation focus: Given that the complaint's non-infringement theory is almost entirely dependent on its invalidity arguments, will the case proceed primarily as a validity challenge, or will distinct technical non-infringement arguments emerge as the primary battleground?