DCT
1:23-cv-01633
Delta Faucet Co v. Wenzhou Xin Xin Sanitary Ware Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Delta Faucet Company (Indiana)
- Defendant: Wenzhou Xin Xin Sanitary Ware Co., Ltd. (People's Republic of China)
- Plaintiff’s Counsel: Maginot, Moore & Beck, LLP; Harness, Dickey & Pierce, P.L.C.
- Case Identification: 1:23-cv-01633, S.D. Ind., 09/11/2023
- Venue Allegations: Venue is alleged to be proper based on Defendant having committed substantial acts of infringement in the Southern District of Indiana, including offering to sell and selling accused products to customers within the district through intermediaries such as Amazon.
- Core Dispute: Plaintiff alleges that Defendant’s vessel rinsing apparatuses, sold online, infringe a patent related to pressure-activated, multi-nozzle glass rinsers.
- Technical Context: The technology concerns sink-mounted devices that use directed jets of water to clean the inside of vessels like cups and glasses, a common accessory in modern kitchens.
- Key Procedural History: The complaint alleges that Defendant previously filed an Inter Partes Review (IPR) on a related patent. This allegation may be used to support claims of pre-suit knowledge for the purposes of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2018-09-14 | ’369 Patent Priority Date |
| 2023-08-15 | ’369 Patent Issue Date |
| 2023-09-11 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,725,369 - Vessel Rinsing Apparatus (issued Aug. 15, 2023)
The Invention Explained
- Problem Addressed: The patent addresses the difficulty of effectively cleaning the interior of small vessels, such as glasses and cups, noting that conventional faucets lack the directional, pressurized water flow needed to remove debris from interior extremities (’369 Patent, col. 1:20-28).
- The Patented Solution: The invention is a vessel rinsing apparatus, typically installed in a countertop, that includes a fluid discharge member activated by pressing a vessel down onto a trigger. This action opens a valve, releasing water through a plurality of nozzles specifically oriented to direct water to different areas inside the vessel (’369 Patent, Abstract; col. 4:42-53). For example, Figure 6 illustrates how different nozzles (84a, 84c, 84e) are angled to spray various internal surfaces of a vessel (60) (’369 Patent, Fig. 6).
- Technical Importance: The technology provides a dedicated, integrated solution for vessel cleaning that aims to be more effective than manual methods or standard kitchen faucets by using targeted, high-pressure water jets (’369 Patent, col. 1:29-33).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶18).
- The essential elements of independent claim 1 include:
- a mounting member extending along a longitudinal axis, configured to extend through a mounting deck;
- a fluid discharge member including a central body supporting a sprayface and a trigger, with the sprayface supporting a plurality of nozzles;
- a valve member operably coupled to the fluid discharge member to control water flow in response to movement of the trigger;
- wherein the plurality of nozzles includes a center nozzle configured to discharge water upwardly parallel to the longitudinal axis;
- and a first peripheral nozzle oriented at a first angle from the longitudinal axis to direct water to a distal portion of a first vessel;
- and a second peripheral nozzle oriented at a second angle from the longitudinal axis to direct water to a distal portion of a second vessel.
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (’369 Patent, col. 7:1-22; Compl. ¶17).
III. The Accused Instrumentality
Product Identification
- The complaint identifies a series of "glass rinsers" sold by Defendant on Amazon.com under various Amazon Standard Identification Numbers (ASINs), collectively referred to as the "Accused Products" (Compl. ¶16).
Functionality and Market Context
- The Accused Products are described as sink-mounted glass rinsers that are "functionally equivalent" to Plaintiff's commercial embodiment (Compl. ¶16). A marketing image for one of the Accused Products depicts a device with a base, an actuator plate, and "10 Powerful water spraying holes" that provide "multi-dimension cleaning" when a user presses a glass down on the plate (Compl. ¶21, p. 5 visual). The complaint alleges these products are sold through intermediaries like Amazon to customers in the United States, positioning them as direct competitors to the Plaintiff in the kitchen accessories market (Compl. ¶4, ¶6). The complaint provides an image from an Amazon product listing showing the Accused Product's features, including its spray holes and installation components (Compl. ¶21, p. 5 visual).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in an "Exhibit 2," which was not filed with the complaint. The following analysis is based on the narrative allegations and visual evidence within the complaint itself.
'369 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mounting member extending along a longitudinal axis, the mounting member configured to extend though a mounting aperture formed within a mounting deck | The Accused Products are depicted with a threaded mounting shank and associated hardware for installation in a standard countertop or sink opening, described as a "Simple DIY project." | ¶21, p. 5 visual | col. 4:20-31 |
| a fluid discharge member including a central body supporting a sprayface and a trigger... the central body being movable relative to the mounting member | The Accused Product has a top plate with spray holes that a user presses down with a vessel to activate the water flow, functioning as both the sprayface and trigger. | ¶21, p. 5 visual | col. 4:42-53 |
| a valve member operably coupled to the fluid discharge member and configured to control water flow through the central body to the plurality of nozzles in response to movement of the trigger | The complaint does not provide specific detail for analysis of the internal valve mechanism, but alleges the products are "functionally equivalent" and operate by pressing down to release water, implying the presence of an internal, coupled valve. | ¶16 | col. 5:1-9 |
| wherein the plurality of nozzles includes a center nozzle configured to discharge water upwardly parallel to the longitudinal axis, a first peripheral nozzle oriented at a first angle... and a second peripheral nozzle oriented at a second angle... | The Accused Product's top surface features "10 Powerful water spraying holes" advertised as providing "multi-dimension cleaning." The complaint alleges these practice the claim, but provides no specific evidence regarding the orientation or angle of each jet. | ¶21, p. 5 visual | col. 4:54-64 |
- Identified Points of Contention:
- Technical Questions: A primary technical question will be whether the "10 Powerful water spraying holes" of the Accused Product meet the specific geometric limitations of Claim 1. What evidence does the complaint provide that the accused device has a "center nozzle" spraying "upwardly parallel to the longitudinal axis" and distinct "peripheral" nozzles oriented at specific, different angles, as opposed to a generic, undifferentiated spray pattern?
- Scope Questions: The dispute may raise the question of whether the claimed configuration—requiring at least three nozzles with distinct, specified orientations (one parallel, two at different angles)—can be read onto the accused device's array of holes. The court may need to determine if the claim requires structurally distinct and purposefully angled nozzles or if a general spray pattern from simple holes can satisfy the limitation.
V. Key Claim Terms for Construction
- The Term: "a first peripheral nozzle oriented at a first angle from the longitudinal axis... and a second peripheral nozzle oriented at a second angle from the longitudinal axis"
- Context and Importance: This limitation is critical because it defines the specific geometric configuration of the water jets, which appears to be a core aspect of the invention. Infringement will likely depend on whether the Accused Product's simple array of "spraying holes" can be shown to have nozzles oriented at distinct, different angles as required by the claim language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the term "oriented at an... angle" does not require a specific, measurable degree but simply means directed away from the central axis. The patent states that the "number and placement of the nozzles 84 may vary," which could support an argument that the precise arrangement is not strictly limiting (’369 Patent, col. 4:52-53).
- Evidence for a Narrower Interpretation: The specification provides highly specific examples of different angles for different nozzles, each intended to clean a specific part of a different type of vessel (e.g., "a first angle... for directing water to a distal corner of a mug," "a second angle... for directing water to a distal corner of a highball glass") (’369 Patent, col. 4:58-64). This language may support a narrower construction requiring demonstrably different and purposeful orientations for the peripheral nozzles, rather than a generic radial spray.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement, stating that Defendant provides "instructions, user manuals, advertising and/or marketing materials on Amazon's website" that direct and encourage end-users to install and operate the Accused Products in an infringing manner (Compl. ¶21). The visual evidence from an Amazon listing supports this allegation by showing installation and use instructions (Compl. ¶21, p. 5 visual).
- Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’369 Patent. This knowledge is asserted to arise from two sources: first, Defendant's alleged filing of an IPR on a related patent, which suggests awareness of Plaintiff's patent portfolio; and second, the filing of the instant complaint itself (Compl. ¶20).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the court’s determination of the following key questions:
- A central issue will be one of claim scope and construction: Do the claim limitations requiring a "center nozzle" spraying "parallel" to the axis and at least two "peripheral" nozzles spraying at different, distinct "angles" require structurally separate and individually aimed nozzles, or can this language be read upon a generic array of holes that produces a multi-directional spray?
- A key evidentiary question will be one of technical proof: Assuming the claim requires specific, distinct angles, what factual evidence can Plaintiff produce to demonstrate that the water jets from the Accused Product's spray holes actually meet the geometric orientation requirements recited in Claim 1, beyond general marketing claims of "multi-dimension cleaning"?