DCT
1:25-cv-15675
Wuhan Jiahao E Commerce Co Ltd v. Interlink Products Intl Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wuhan Jiahao E-commerce Co., Ltd. (China)
- Defendant: Interlink Products International, Inc. (New Jersey)
- Plaintiff’s Counsel: West Atlantic Law Firm, PLLC
- Case Identification: 1:25-cv-15675, N.D. Ill., 12/28/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant sells products to customers in the district and initiated an Amazon patent enforcement action that foreseeably caused commercial harm to Plaintiff's sales within the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its showerhead products do not infringe, and that the claims are invalid, of Defendant’s patent related to multi-function showerheads with distinct nozzles for showering and cleaning.
- Technical Context: The technology at issue addresses showerheads that incorporate multiple, independently selectable sets of nozzles to provide different water spray patterns, such as a wide spray for showering and a high-pressure jet for cleaning surfaces.
- Key Procedural History: The complaint states this action was filed in response to an intellectual property complaint submitted by Defendant to Amazon on or around December 12, 2025, which alleged that Plaintiff's products infringe the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2020-12-10 | ’435 Patent Priority Date |
| 2025-12-02 | ’435 Patent Issue Date |
| 2025-12-12 | Defendant submits patent infringement complaint to Amazon |
| 2025-12-28 | Plaintiff files Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,485,435 - "SHOWERHEAD HAVING SELECTOR FOR DIRECTING WATER FLOW IN INDEPENDENT DIRECTIONS"
- Patent Identification: U.S. Patent No. 12,485,435, “SHOWERHEAD HAVING SELECTOR FOR DIRECTING WATER FLOW IN INDEPENDENT DIRECTIONS,” issued December 2, 2025 (the “’435 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section states that while conventional showerheads are designed for showering, their resulting water pressure and spray patterns may be "undesirable for cleaning purposes," such as rinsing soap from tiled walls or tubs (’435 Patent, col. 1:12-29).
- The Patented Solution: The invention is a showerhead that incorporates separate sets of nozzles for different functions. It includes a primary set of nozzles on the main faceplate for showering and at least one other set of nozzles, located elsewhere on the head portion, designed for cleaning tasks (’435 Patent, Abstract). A "flow selector" allows a user to move a flow director internally to channel water to either the showering nozzles or the cleaning nozzles, which can be configured to produce distinct spray types like a "fan-shaped spray" or a "jet stream of water" (’435 Patent, col. 2:1-15; col. 4:30-40).
- Technical Importance: The patented design integrates both personal showering and targeted, higher-pressure cleaning functionalities into a single fixture, enhancing utility and convenience (’435 Patent, col. 3:40-51).
Key Claims at a Glance
- The complaint states that at least independent claim 1 is at issue (Compl. ¶30).
- The essential elements of independent claim 1 include:
- A head portion and a handle.
- A plurality of "first nozzles" that direct water in a "first direction" (for showering).
- At least one "second nozzle" directing water in a "second direction."
- At least one "third nozzle" adjacent to the second nozzle, directing water in a "third direction."
- A "flow selector" that is movable between first, second, and third positions to direct water through the corresponding nozzle sets.
- A geometric limitation wherein the second and third directions are "substantially the same and transverse to the first direction."
- A functional limitation wherein the second nozzle creates a "first type of the flow of water" and the third nozzle creates a "second type of the flow of water different from the first type."
(’435 Patent, col. 9:1-26).
- The complaint does not explicitly reserve the right to assert dependent claims, as it is a complaint for declaratory judgment of non-infringement.
III. The Accused Instrumentality
Product Identification
Plaintiff’s "SHOWERHEAD product," also referred to as the "Non-Infringing Product," sold on Amazon.com under ASINs including B0FBR9BJW7, B0FBRF9RJB, B0FQNMRSFR, and B0FKB4FCQH (Compl. ¶3, ¶25).
Functionality and Market Context
The complaint provides very limited detail on the functionality of the accused product itself. Instead, it focuses on asserting structural differences from the patent. It alleges that the product "does not incorporate this rear-mounted flow selector" and that "the distribution and types of [the] first nozzles are completely different" from the patent’s disclosures (Compl. ¶¶30-31). The complaint asserts these products are sold through Amazon's e-commerce marketplace (Compl. ¶13).
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement and does not contain an affirmative claim chart from the patentee. It references a non-infringement analysis in an "Exhibit D," which was not provided with the complaint (Compl. ¶28). The following table summarizes the plaintiff’s non-infringement contentions as described in the body of the complaint.
No probative visual evidence provided in complaint.
’435 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flow selector moveable between a first position ... a second position ... and a third position | Plaintiff alleges its product "does not incorporate this rear-mounted flow selector." The complaint does not describe what mechanism, if any, the accused product uses to select flow modes. | ¶30 | col. 9:12-18 |
| a plurality of first nozzles configured to direct water flow in a first direction | Plaintiff alleges that "the distribution and types of [the] first nozzles are completely different" between its product and the patent's drawings. | ¶31 | col. 9:4-6 |
Identified Points of Contention
- Scope Questions: The primary dispute appears to center on claim construction. A central question will be whether the term "flow selector" is limited by the specification's embodiments, which depict it as a switch on the rear of the showerhead (e.g., ’435 Patent, Fig. 2A, item 116), or if the term can be construed more broadly to cover other types of mode-selection mechanisms located elsewhere.
- Technical Questions: A key factual question will be what structure the accused "SHOWERHEAD product" actually uses. The complaint denies infringement but does not describe the product's alternative structure or operation, stating only that it lacks a "rear-mounted" selector (Compl. ¶30). The court will have to analyze whether the product's actual mechanism, whatever it may be, meets the functional and structural requirements of the construed claim.
V. Key Claim Terms for Construction
"flow selector"
- Context and Importance: Plaintiff's primary non-infringement argument is that its product lacks a "rear-mounted flow selector" (Compl. ¶30). The patentee, Defendant, will likely argue that the claim term is not limited by location. The definition of this term may be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 itself defines the "flow selector" functionally as a component that is "moveable between a first position... a second position... and a third position" to direct water flow, without any specific limitation as to its location or physical form (’435 Patent, col. 9:12-18).
- Evidence for a Narrower Interpretation: The patent's written description and figures consistently depict the flow selector (116) as a switch located on the side of the head portion opposite the main faceplate (’435 Patent, col. 4:31-33; Figs. 2A, 3A, 4A). Plaintiff may argue that these consistent embodiments define the scope of the claimed invention.
"a 'first type' and a 'second type' of the flow of water 'different from the first type'"
- Context and Importance: This limitation requires that the second and third nozzles produce functionally different sprays. Infringement will depend on whether the accused product's nozzles, if any, meet this requirement and how "different" is defined. Practitioners may focus on this term because it introduces a degree of subjectivity that could be a point of non-infringement or invalidity for indefiniteness.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is broad, simply requiring the spray types to be "different." This could encompass any number of variations in pressure, pattern, or volume.
- Evidence for a Narrower Interpretation: The specification provides specific examples: the "second nozzle is configured to create a first type of the flow of water" which claim 8 specifies is a "fan-shaped spray," while the "third nozzle is configured to create a second type" which claim 8 specifies is a "jet stream of water" (’435 Patent, col. 9:22-26, col. 10:1-4). A party could argue these examples limit the interpretation of "different types."
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement "directly or indirectly, literally or under the doctrine of equivalents," but it provides no specific facts or allegations related to indirect infringement theories (Compl. ¶26).
- Willful Infringement: This allegation is not applicable, as this is a declaratory judgment action brought by the accused infringer.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Is the term "flow selector," as recited in claim 1, limited to the rear-mounted switch depicted in the ’435 Patent’s embodiments, or does its scope extend to any mechanism capable of redirecting water flow between different nozzle sets, regardless of location?
- A central evidentiary question will be one of structural comparison: What is the actual design and mechanism of the accused showerhead? The complaint’s focus on what the product lacks leaves open the critical question of what structure it possesses and whether that structure meets the limitations of the patent's claims as construed by the court.
- A third key question will concern invalidity: The complaint includes a general allegation that the ’435 Patent is invalid (Compl. ¶¶35-39). The viability of this defense will depend on whether the plaintiff can produce prior art that discloses a showerhead with distinct, selectable spray functions for both general showering and targeted cleaning, thereby anticipating or rendering obvious the claimed invention.