DCT

6:25-cv-01580

Trove Brands LLC v. Rumi LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-01580, W.D. La., 10/21/2025
  • Venue Allegations: Venue is alleged to be proper for Defendant Dius based on its principal place of business being located within the district. For Defendant Rumi, venue is alleged based on acts of infringement within the district and on the theory that Rumi functions as an alter ego of Dius.
  • Core Dispute: Plaintiff alleges that Defendants’ "Mr. Pen Shaker Bottle Lid" infringes two U.S. design patents covering the ornamental appearance of bottle lids.
  • Technical Context: The dispute is in the consumer products sector, specifically concerning the aesthetic design of lids for shaker bottles commonly used for mixing nutritional and dietary supplements.
  • Key Procedural History: The complaint alleges that Plaintiffs previously filed complaints with Amazon regarding the accused products, leading to correspondence from counsel for both Defendants at different times. Plaintiffs also allege sending cease-and-desist letters to Defendants on June 26, 2024, and August 2, 2024, which were allegedly ignored. These events are presented as evidence of willful infringement.

Case Timeline

Date Event
2012-09-07 U.S. Design Patent No. D696,551 Priority Date (Application Filing)
2013-06-06 U.S. Design Patent No. D748,478 Priority Date (Application Filing)
2013-12-31 U.S. Design Patent No. D696,551 Issues
2016-02-02 U.S. Design Patent No. D748,478 Issues
2024-01-22 Plaintiffs receive letter from counsel for Defendant Rumi
2024-06-26 Plaintiffs send first cease-and-desist letter to Defendants
2024-08-02 Plaintiffs send second cease-and-desist letter to Defendants
2025-04-17 Defendant Dius allegedly assigns "Mr. PEN" trademarks to Defendant Rumi
2025-10-21 Complaint Filed

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

U.S. Design Patent No. D696,551 - "BOTTLE LID HAVING INTEGRATED HANDLE"

  • Patent Identification: U.S. Design Patent No. D696,551 ("the '551 Patent"), "BOTTLE LID HAVING INTEGRATED HANDLE," issued December 31, 2013 (Compl. ¶12).

The Invention Explained

  • Problem Addressed: Design patents protect ornamental appearance rather than addressing a technical problem. The patent protects a specific aesthetic design for a bottle lid, intended to distinguish the product in the marketplace (Compl. ¶¶10-11).
  • The Patented Solution: The patent claims the ornamental design for a bottle lid featuring an integrated handle ('551 Patent, Claim). The specific aesthetic is defined by the visual characteristics shown in the patent's figures, including the overall shape of the lid, the contours of the cap, and the particular configuration of the carrying handle that flows from the lid's structure ('551 Patent, FIG. 1, 5).
  • Technical Importance: The complaint asserts that Plaintiff BlenderBottle "pioneered innovative technology and path-breaking designs to create premium products" in the dietary supplement market (Compl. ¶10). This design represents an effort to create a distinct and recognizable product identity.

Key Claims at a Glance

  • Design patents contain a single claim. The asserted claim is for "The ornamental design for a bottle lid with an integrated handle, as shown and described" ('551 Patent, Claim).
  • The scope of the claim is defined by the six figures in the patent, which depict the design from front, side, top, bottom, and perspective views. The broken lines showing a bottle in FIG. 6 are explicitly not part of the claimed design ('551 Patent, Description).

U.S. Design Patent No. D748,478 - "CLOSURE FOR A CONTAINER"

  • Patent Identification: U.S. Design Patent No. D748,478 ("the '478 Patent"), "CLOSURE FOR A CONTAINER," issued February 2, 2016 (Compl. ¶13).

The Invention Explained

  • Problem Addressed: As with the '551 Patent, this patent protects a specific ornamental design for a container closure from imitation (Compl. ¶11).
  • The Patented Solution: The patent claims the ornamental design for a container closure as depicted in the patent's drawings ('478 Patent, Claim). A key feature of the design is a movable carrying member, which is shown in a lowered position (e.g., FIG. 1) and a raised, carrying position (FIG. 8). The claim covers the visual appearance of the closure in its entirety, including the shape of the base, the flip-cap, and the carrying member in its various states ('478 Patent, Description).
  • Technical Importance: This design provides another distinct aesthetic for a shaker bottle lid, contributing to the portfolio of proprietary designs the plaintiff seeks to protect (Compl. ¶11).

Key Claims at a Glance

  • The single asserted claim is for "The ornamental design for a closure for a container, as shown and described" ('478 Patent, Claim).
  • The claim's scope is defined by the eight figures in the patent, which illustrate the design from multiple perspectives and show the carrying member in two different positions.

III. The Accused Instrumentality

Product Identification

  • The "Mr. Pen Shaker Bottle Lid" (Compl. ¶14).

Functionality and Market Context

  • The accused product is a lid for a shaker bottle, used for mixing dietary supplements and other beverages (Compl. ¶10, ¶14). The complaint alleges that Defendants manufacture, use, sell, and import these lids in various sizes and colors (Compl. ¶¶14-15). The lids are allegedly sold to consumers in the United States through Defendants' website (mrpen.com) as well as on Amazon.com and Walmart.com (Compl. ¶¶16-17). The complaint provides an image of the accused lid on a corresponding bottle. (Compl. p. 5).

IV. Analysis of Infringement Allegations

The standard for design patent infringement is whether, in the eye of an ordinary observer, the accused design is substantially the same as the claimed design, such that the observer would be deceived into purchasing one thinking it was the other (Compl. ¶32). The complaint presents its allegations through side-by-side visual comparisons.

'551 Patent Infringement Allegations

Claim Element (from the Single Claim) Alleged Infringing Functionality Complaint Citation Patent Citation
The ornamental design for a bottle lid with an integrated handle, as shown and described. The complaint alleges that the overall visual appearance of the "Mr. Pen Shaker Bottle Lid" is substantially the same as the design claimed in the '551 Patent. The complaint's side-by-side comparison chart highlights similarities in the profile, handle shape, and overall configuration. A representative comparison shows the side view of the patented design and a photograph of the accused product (Compl. p. 8). ¶31, ¶32 Claim

'478 Patent Infringement Allegations

Claim Element (from the Single Claim) Alleged Infringing Functionality Complaint Citation Patent Citation
The ornamental design for a closure for a container, as shown and described. The complaint alleges that the overall visual design of the "Mr. Pen Shaker Bottle Lid" is substantially similar to the design claimed in the '478 Patent. Visual comparisons are provided to show similarities in the closure's shape, flip-cap, and carrying member. A comparison shows the patented design and a photograph of the accused product from a similar perspective view (Compl. p. 12). ¶39, ¶40 Claim
  • Identified Points of Contention:
    • Scope Questions: A central issue in design patent cases is the scope of the patented design in view of the prior art. The litigation may raise the question of whether the asserted designs are valid and, if so, how different they are from prior bottle lid designs. The scope of protection may be narrowed if the overall design or its key features are shown to be common in the field.
    • Visual Similarity Questions: The core dispute will center on the "ordinary observer" test. The question for the court will be whether the visual similarities between the accused "Mr. Pen Shaker Bottle Lid" and the designs in the '551 and '478 Patents are significant enough to cause deception, or if the visual differences are sufficient to distinguish them in the eyes of a typical consumer. The complaint provides photographic evidence suggesting a high degree of similarity, such as a photo showing a user's finger lifting the handle on the accused product in a manner that mirrors the patented design (Compl. p. 13).

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on the visual impression of the design as a whole as depicted in the drawings, rather than the construction of specific textual terms. However, the interpretation of the design's scope will be critical.

  • The Feature: The overall ornamental design of the bottle lid, including the integrated handle/carrying member.
  • Context and Importance: This feature is the most prominent and character-defining aspect of both asserted designs. The infringement analysis will depend heavily on comparing the visual appearance of this feature on the accused product to its depiction in the patent drawings. Practitioners may focus on this feature because the complaint's visual evidence centers on its allegedly similar shape, proportions, and integration with the lid body (Compl. pp. 8-10, 12-13).
  • Intrinsic Evidence for Interpretation: The intrinsic evidence is entirely visual and contained within the patent figures. The scope is defined by what is shown in solid lines. For the '551 Patent, figures such as FIG. 1 (front view) and FIG. 5 (perspective view) define the specific, rigid shape of the integrated handle. For the '478 Patent, figures such as FIG. 1 and FIG. 8 define the appearance of the movable carrying member in both its stowed and deployed positions. The court will consider these drawings in their entirety to determine the scope of the claimed designs.

VI. Other Allegations

  • Indirect Infringement: The complaint's prayer for relief seeks to enjoin Defendants from "assisting or inducing" infringement (Compl. Prayer for Relief ¶C). However, the substantive counts for relief focus on allegations of direct infringement under 35 U.S.C. § 271, without pleading the specific elements of knowledge and intent required for an indirect infringement claim (Compl. ¶¶29-44).
  • Willful Infringement: The complaint alleges that Defendants' infringement was "knowingly, intentionally, and willfully" (Compl. ¶31, ¶39). This allegation is based on alleged pre-suit knowledge, specifically citing two cease-and-desist letters sent on June 26, 2024, and August 2, 2024, and Defendants' alleged refusal to cease their infringing activities thereafter (Compl. ¶¶23-26).

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

  • A core issue will be one of visual comparison: Will an ordinary observer, giving the attention a purchaser usually gives, find the accused "Mr. Pen Shaker Bottle Lid" to be substantially the same as the ornamental designs claimed in the '551 and '478 patents? The outcome will depend on a holistic comparison of the designs' overall visual effect.
  • A second key issue will be the impact of prior art: The scope of protection for the asserted design patents will be defined in the context of prior art for shaker bottle lids. A critical question is whether the similarities between the accused product and the patented designs are found only in novel, ornamental features, or if they reside in functional or conventional elements common to other products in the market.
  • Finally, a question of liability and damages may turn on the relationship between the two defendants. The complaint alleges that Defendant Rumi is the "alter ego" of Defendant Dius (Compl. ¶22). The court may need to determine if this allegation is substantiated, which could affect the scope of liability, the willfulness analysis, and the calculation of damages or profits.