1:25-cv-00148
Dongguan Meishida E Commerce Co Ltd v. Kelley
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dongguan Meishida E-commerce Co., Ltd. d/b/a JEEVONY (China)
- Defendant: Kevin Patrick Kelley (North Carolina)
- Plaintiff’s Counsel: Aronberg Goldgehn; Carruthers & Roth, P.A. (Local Counsel)
- Case Identification: 1:25-cv-00148, W.D.N.C., 05/22/2025
- Venue Allegations: Venue is alleged to be proper as the Defendant, an individual, resides in the Western District of North Carolina.
- Core Dispute: Plaintiff seeks a declaratory judgment that its magnetic dryer vent attachment does not infringe Defendant's patent, and that the patent is invalid, following Defendant’s infringement complaint filed through Amazon's internal patent evaluation program.
- Technical Context: The technology concerns magnetic couplings for clothes dryer vents, a consumer product field where ease of installation, safety, and reliable performance in confined spaces are key market drivers.
- Key Procedural History: The action was precipitated by Defendant's complaint filed via the Amazon Patent Evaluation ("APEX") program, which sought to delist Plaintiff's product. The complaint also highlights the patent's prosecution history, including terminal disclaimers filed to overcome double patenting rejections, which Plaintiff suggests limits the enforceable scope of the patent's claims.
Case Timeline
| Date | Event |
|---|---|
| 2010-07-27 | Earliest Priority Date for '855 Patent (from App. No. 12/804,691) |
| 2023-04-25 | '855 Patent Issue Date |
| 2025-03-27 | Defendant files complaint with Amazon APEX program |
| 2025-05-22 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,634,855 - "Magnetically positioned and engaged dryer vent attachment and method," issued April 25, 2023
The Invention Explained
- Problem Addressed: The patent's background describes the difficulty of attaching flexible dryer ducts in the confined space behind a clothes dryer, a process that can result in kinked or compressed hoses, leading to restricted airflow, reduced dryer efficiency, and increased fire risk due to lint accumulation (U.S. Patent No. 11,634,855, col. 1:16-34).
- The Patented Solution: The invention is a two-part coupling that uses magnets to create a secure, self-aligning connection between the dryer's exhaust port and the wall vent. One half of the coupling attaches to the dryer hose and the other to the wall port; when the dryer is pushed into place, the two halves are drawn together by magnetic force to form a seal, eliminating the need for manual access behind the unit (’855 Patent, Abstract; col. 2:16-28). The design intends to allow for "inaccuracy in the installation of the wall box" and tolerate bumps and vibrations (’855 Patent, col. 2:25-28).
- Technical Importance: The technology aims to provide a safer and more reliable method for dryer venting by ensuring a proper seal, which in turn can increase dryer efficiency and simplify the process of disconnecting the vent for routine cleaning (’855 Patent, col. 2:35-44).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 10 as being at issue (Compl. ¶34).
- The essential elements of independent claim 1 include:
- A flexible exhaust duct with two ends.
- A first mounting substrate at one end of the duct, comprising a first magnet.
- A second mounting substrate for locating near a dryer or wall port, comprising a second magnet with an opposite polarity.
- The first and second mounting substrates having "respective complementary surfaces configured to nest together between said inner and outer perimeters."
- A "whereby" clause stating that when moved into proximity, the magnets attract to "self-align and self-assemble" and create an "audible snapping sound" indicating a seal.
- The complaint seeks a declaratory judgment that its product does not infringe any claim of the patent (Compl., Prayer for Relief ¶1).
III. The Accused Instrumentality
Product Identification
The accused product is the "Magnetic Dryer Vent Coupling DV180 Airtight Seal Dryer Vent Connector Kit," sold by the Plaintiff under the brand name JEEVONY on Amazon.com (ASIN BODRRYM7GL) (Compl. ¶¶ 20, 21).
Functionality and Market Context
The product is a dryer vent attachment comprising two primary components that use magnets to connect and disconnect a dryer vent hose (Compl. ¶21). The complaint presents a screenshot of the Amazon product listing, which advertises an "innovative strong magnets self-align mechanism" for a "Quick Connect & Disconnect" and an "Airtight Connection" (Compl. ¶21, p. 3). The complaint alleges the product is popular and that access to the U.S. market via Amazon is critical to its business (Compl. ¶¶ 22, 24). The central assertion for non-infringement is that the product's connecting surfaces are flat and do not "nest" (Compl. ¶47).
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment, the following table summarizes the Plaintiff's (Jeevony's) core allegation of non-infringement with respect to a key limitation in the asserted patent claim.
'855 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| said first and second mounting substrates comprising respective complementary surfaces configured to nest together between said inner and outer perimeters... | The Plaintiff's product is alleged to include two flat surfaces, labeled A and B in a provided image, which do not "nest together." | ¶47 | col. 7:19-22 |
| ...such that said first and second magnets create an audible snapping sound when engaged thereby indicating a close magnetic seal... | The complaint does not provide sufficient detail for analysis of this element. | col. 7:33-36 |
Identified Points of Contention
- Scope Questions: The primary dispute revolves around claim construction. The complaint argues that the term "nest together" requires a specific geometry where one component fits inside another, as illustrated by the "nesting cones" in the patent's Figure 6 (Compl. ¶41, p. 7). A central question for the court will be whether the term "nest together" is limited to this conical configuration or if it can be construed more broadly to cover the face-to-face contact of the accused product's flat magnetic surfaces. The complaint provides a side-by-side image of its product's flat surfaces to contrast with the patent's conical embodiment (Compl. ¶47, p. 8).
- Technical Questions: A key factual question will be how the patent's disclosure of an alternative embodiment with "flattened toroid" magnets (shown in Fig. 2) informs the meaning of "nest together" in the claims. The complaint contrasts the "nesting cones" of Figure 6 with the "flat surfaces" of Figure 2, arguing the latter do not nest (Compl. ¶¶ 45-46). The court may need to determine if the interaction of the flat surfaces in Figure 2 is considered "nesting" within the context of the patent.
V. Key Claim Terms for Construction
The Term
"complementary surfaces configured to nest together"
Context and Importance
The definition of this term appears to be dispositive for the non-infringement analysis. The Plaintiff's entire argument, as laid out in the complaint, hinges on the assertion that its product's flat surfaces do not "nest together" as required by the claims (Compl. ¶¶ 40, 52). Practitioners may focus on this term because the specification provides a specific visual example that Plaintiff argues defines and limits the term's scope.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent claims do not specify a particular geometry (e.g., "conical") for the nesting surfaces. An argument could be made that any configuration where the surfaces are "complementary" and fit together to form a seal meets the limitation. The patent also describes an embodiment in Figure 2 with flattened toroidal magnets, where the seal is formed "between the magnetic faces" rather than a lip, which may support a broader reading beyond a physical interlock (’855 Patent, col. 4:54-60).
- Evidence for a Narrower Interpretation: The complaint argues that the only explicit definition of "nesting" in the patent is provided in relation to an alternate embodiment, stating "the two halves 18" and 36" of the coupling are nesting cones" (’855 Patent, col. 6:50-52; Compl. ¶44). The Plaintiff uses this specific disclosure to argue that "nesting" requires a conical or similar interlocking structure, which its flat-surfaced product allegedly lacks (Compl. ¶¶ 41, 45, 47).
VI. Other Allegations
Indirect Infringement
The complaint does not contain allegations of indirect infringement.
Willful Infringement
As a declaratory judgment action, the complaint does not allege willfulness. However, it does allege that the Defendant's infringement assertions to Amazon were "baseless," "frivolous and egregious," and "make this an exceptional case" under 35 U.S.C. § 285, which is the statutory basis for awarding attorneys' fees in patent litigation (Compl. ¶¶ 59-60, 63). This allegation is supported by the argument that the Defendant's own counsel, who prosecuted the patent, should have known the Plaintiff's flat-surfaced product could not infringe the "nest together" limitation (Compl. ¶52).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "nest together," which is explicitly exemplified in the patent specification with "nesting cones," be construed to cover the direct, flat-surface-to-flat-surface magnetic coupling of the accused product?
- A second major issue will be one of validity and estoppel: does the patent's prosecution history, including arguments made to overcome prior art and terminal disclaimers filed to obviate double patenting rejections, limit the scope of the claims in a way that precludes them from covering the accused product or, alternatively, render the claims invalid over prior art teaching flat-surfaced magnetic couplings (Compl. ¶¶ 84-85)?
- A related question is one of indefiniteness: does the patent specification provide adequate written description and enablement for the claimed "annular inner peripheral edge," as required by 35 U.S.C. §112, or is the claim invalid for failing to describe the structure corresponding to this function (Compl. ¶¶ 86-87)?