Goclips LLC v. Tool Jungle Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GoClips, LLC, and Z Keepers, LLC (Florida)
  • Defendant: Tool Jungle, Inc. (New Jersey)
  • Plaintiff’s Counsel: Pierson Ferdinand, LLP
• Case Identification: 1:26-cv-00712, D.N.J., 01/22/2026
• Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant is a New Jersey corporation that regularly conducts business in the district, where a substantial part of the events giving rise to the action occurred.
• Core Dispute: Plaintiffs allege that Defendant’s sink anchoring clips infringe a patent related to devices and methods for undermounting a sink to a hard countertop surface.
• Technical Context: The technology relates to mechanical fasteners used in the home construction and remodeling industry to secure undermount sinks to stone countertops, a common and commercially significant installation process.
• Key Procedural History: Plaintiffs allege that prior to the patent’s issuance, their commercial products were marked with "Patent Pending" and that post-issuance, the packaging was modified to reflect the issued patent number.

Case Timeline

Date	Event
2014-12-10	’754 Patent Priority Date
2017-11-28	’754 Patent Issue Date
2026-01-22	Complaint Filing Date

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

U.S. Patent No. 9,828,754 - *"Sink Clamp and Methods"*

The Invention Explained

• Problem Addressed: The patent’s background section describes conventional methods for attaching undermount sinks to hard countertops—such as granite—as being "time consuming and of ten subject to failure due to human error" (’754 Patent, col. 1:13-15). These prior methods often required difficult steps like drilling into the countertop, using two-part epoxies, building wooden cradles, or hammering clips into place, all of which were difficult to perform in the confined space under a sink and risked damaging the materials (’754 Patent, col. 1:16-65).
• The Patented Solution: The invention is a clamping device that avoids drilling or adhesives. The solution involves a clamp with a "binding lip" designed for insertion into a shallow slot ground into the underside of the countertop. A clamp body extends from this lip over the edge of the sink, and a screw is tightened against the sink rim. This action uses the binding lip as an anchor, pulling it tight within the slot and creating a clamping force that secures the sink against the countertop (’754 Patent, Abstract; col. 4:1-10). Figure 1 of the patent illustrates a side view of the assembled clamp, showing the binding lip (14), clamp body (17), clamp screw (15), and an optional binding spring (16).
• Technical Importance: This slot-based anchoring approach is presented as a faster, easier, and more reliable installation method that does not require specialized tooling beyond a standard grinder, eliminating the risks associated with drilling or gluing fasteners to expensive countertop materials (’754 Patent, col. 6:61-65).

Key Claims at a Glance

• The complaint alleges infringement of "all of the claims of the '754 patent" (Compl. ¶20).
• Independent claim 11, directed to the clamping device itself, includes the following essential elements:
  • A clamp body;
  • An insertable end of the clamp body, configured for upward insertion into a slot in a countertop's bottom surface;
  • A clamping spring connected to the clamp body;
  • The clamping spring having a deflectable portion extending at an upward angle in a relaxed state;
  • The deflectable portion is configured to contact a portion of the sink and be deflected to transmit an upward clamping spring force to the sink;
  • The clamping spring has a hole and is connected to the clamp body by a fastener horizontally offset from the insertable end.

III. The Accused Instrumentality

Product Identification

• The accused products are sink anchoring devices sold under the names “PC VENOM CLIPS” and “Quick Clips” (Compl. ¶19).

Functionality and Market Context

• The complaint alleges the accused products are "knockoff devices" that are "substantially similar and nearly identical" in function and form to Plaintiffs' patented GoClips® products (Compl. ¶19, 21). They are used for securing undermount sinks to countertops and are marketed to professionals and consumers in the countertop installation and home improvement industries (Compl. ¶16, 18). A screenshot provided in the complaint shows packaging for the accused product labeled "Item#QuickClip" (Compl. p. 8). Another screenshot shows a product listing describing the devices as "Slot-Based Anchors that are Quick and Easy to Install" (Compl. p. 6).

IV. Analysis of Infringement Allegations

The complaint alleges that the accused "PC VENOM CLIPS" and "Quick Clips" embody all claims of the ’754 Patent (Compl. ¶20). It further alleges that the accused devices are "the same in function and in substantially the same form to authentic GoClips® devices" (Compl. ¶21). The complaint references a claim chart attached as Exhibit D, but this exhibit was not filed with the complaint itself (Compl. ¶20-21). Therefore, the specific mapping of accused product features to claim limitations is not detailed in the provided document. The infringement theory rests on the allegation that the accused products are "near identical copies" of Plaintiffs' patented products (Compl. ¶33).

• Identified Points of Contention:
  • Scope Questions: The complaint's reliance on the accused products being "nearly identical" to Plaintiffs' own commercial embodiment raises the question of whether there are any structural or functional differences that may place the accused products outside the literal scope of the claims. The analysis will depend on whether Plaintiffs' products perfectly embody the claims and whether the accused products are, in fact, identical copies.
  • Technical Questions: A central technical question will be whether the accused devices possess every element of the asserted claims. For example, for claim 11, the court will need to determine if the accused products have a distinct "clamp body" and a "clamping spring connected to" it, or if they are a single, unitary piece of metal where those functions are integrated. The nature of the "connection" via a "fastener" will also be a key factual determination.

V. Key Claim Terms for Construction

• The Term: "clamping spring connected to the clamp body" (from claim 11)

  • Context and Importance: This term is central to the structure of the claimed device. Whether the accused device infringes will depend on whether it has a component that meets the definition of a "clamping spring" and whether that component is "connected to" the "clamp body" in the manner required by the claim. Practitioners may focus on this term because the patent appears to describe both multi-part and unitary constructions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the clamp can be a single, integral piece: "Preferably the clamp 10 is a unitary or integral structure of the clamp body 17 formed with the binding lip 14 from a single material, such as a bent metal product" (’754 Patent, col. 3:36-39). This may support an argument that "connected" does not require two separate pieces joined together.
    • Evidence for a Narrower Interpretation: The claim language itself requires a "fastener" to connect the spring to the body, and the specification explicitly describes this fastener as potentially being "a screw and a rivet" (’754 Patent, col. 6:65-col. 7:4). This language may support an argument that the "spring" and "body" must be structurally distinct components joined by a separate fastener, potentially excluding a device formed from a single, continuous piece of metal.

• The Term: "deflectable portion extending at an upward angle" (from claim 11)

  • Context and Importance: This term defines the functional geometry of the spring element that contacts the sink. The existence and nature of this "upward angle" and its deflection are critical for generating the claimed "upward clamping spring force." The infringement analysis will require a factual determination of the accused product's shape and how it interacts with a sink rim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function broadly, stating the clamp is "configured to apply force" and that tightening a screw causes the device to "securely pull against the binding lip" to clamp the sink (’754 Patent, col. 3:17-18; col. 4:48-52). This focus on function could support a broader reading of the required geometry.
    • Evidence for a Narrower Interpretation: Figure 1 depicts a distinct angle between the clamp body (17) and the binding spring (16). An argument could be made that the term requires a specific, pre-formed angular relationship in the "relaxed state," as opposed to any component that merely flexes or bends under load.

VI. Other Allegations

• Willful Infringement: The complaint alleges that Defendant’s infringement is "knowing, willful and deliberate" (Compl. ¶22). The basis for this allegation includes claims that Defendant has been "placed on notice of the '754 patent" and continued to infringe, and that the accused products are "near identical copies" of Plaintiffs' patented devices, which were marked with the patent number (Compl. ¶17, 33, 34).

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

• A core issue will be one of claim construction and structural identity: How will the court construe the phrase "clamping spring connected to the clamp body by a fastener"? The case may turn on whether this language can read on a device manufactured from a single, unitary piece of material, or if it strictly requires two separate components joined together.
• A key evidentiary question will be one of factual comparison: In the absence of a detailed claim chart in the complaint, the central dispute will be a direct comparison of the accused "Quick Clips" to the limitations of the asserted claims. The allegation that the products are "nearly identical" will need to be substantiated with evidence demonstrating that every claim element is present in the accused devices, either literally or under the doctrine of equivalents.