Interlink Products Intl Inc v. Changchun Chengji Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Interlink Products International, Inc. (New Jersey)
  • Defendant: Changchun Chengji Technology Co., Ltd. (d/b/a Clofy US) (People's Republic of China)
  • Plaintiff’s Counsel: The Law Office Of JASON B. LATTIMORE, ESQ. LLC
• Case Identification: 2:18-cv-09315, D.N.J., 05/16/2018
• Venue Allegations: Venue is asserted based on Defendant's business activities in the District of New Jersey, including advertising, offering for sale, and shipping the accused products to customers located within the district.
• Core Dispute: Plaintiff alleges that Defendant’s dual-function showerhead products, which feature a diverter mount, infringe a patent related to a combination holder and water-flow control device.
• Technical Context: The technology concerns shower fixtures that allow a user to divert water from a single wall pipe to either a fixed showerhead, a handheld sprayer, or both simultaneously.
• Key Procedural History: Plaintiff Interlink acquired the patent-in-suit by assignment from the original inventor on November 17, 2015. The complaint alleges that Defendant was provided prior notice of the patent and the alleged infringement.

Case Timeline

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

U.S. Patent No. 7,299,510 - "HOLDER DEVICE FOR SHOWER HEAD AND NOZZLE"

• Patent Identification: U.S. Patent No. 7,299,510, issued November 27, 2007.

The Invention Explained

• Problem Addressed: The patent addresses the difficulty and inconvenience for consumers of installing conventional shower fixtures, which often require drilling holes into walls or using unreliable suction cups to mount holders for handheld sprayers ('510 Patent, col. 1:16-49).
• The Patented Solution: The invention is a single, integrated holder device that attaches directly to the existing water outlet tube (shower arm) extending from the wall. This device incorporates an internal valve to control and divert water flow between a primary showerhead and a secondary handheld sprayer nozzle, and also includes a built-in cradle to hold the sprayer nozzle when not in use ('510 Patent, col. 2:5-24; Fig. 1).
• Technical Importance: The described approach aimed to provide a shower diverter and holder that could be installed by a user without specialized tools or permanent modifications to the bathroom wall ('510 Patent, col. 2:1-4).

Key Claims at a Glance

• The complaint asserts independent claims 1, 3, and 10, and dependent claims 2, 4, and 11 ('Compl. ¶33).
• Independent Claim 1, the first asserted, requires:
  • A housing with an inlet for attaching to a water outlet tube, a first outlet port, and a second outlet port.
  • A partition secured within the housing.
  • A "means for controlling the water to flow" through the outlet ports.
  • A sprayer nozzle attached to the second outlet port.
  • An "attaching device" (a holder for the sprayer) that is rotatably attached to the partition.
  • The partition including a bore.
  • A "follower" that is rotatably engaged in the partition's bore and is secured to the attaching device.

III. The Accused Instrumentality

Product Identification

• The complaint names Defendant's "28-Setting Combo" showerhead (Part No. SFH-YS01) and any other of Defendant's "dual showerhead products employing diverter mounts that are identical or equivalent" (collectively, "the Clofy Showerheads") (Compl. ¶33).

Functionality and Market Context

• The complaint describes the accused products as "dual showerhead products" that utilize a "diverter mount," which suggests a function of receiving water from a single source and directing it to one of two showerheads (Compl. ¶33).
• Plaintiff alleges that Defendant is a direct competitor in the online market for showerheads, including on Amazon.com, and that the infringement has caused competitive harm and lost sales (Compl. ¶9, ¶40).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'510 Patent Infringement Allegations

• Identified Points of Contention:
  • Structural Questions: The complaint alleges infringement in a conclusory manner by stating the accused products "embody the elements" of the claims. A central dispute will likely concern whether the accused "diverter mount" contains the specific internal structures recited in Claim 1, such as the "partition secured thereto", the "bore" within that partition, and the "follower" that connects the partition to the "attaching device". The complaint does not provide factual support detailing these internal components.
  • Scope Questions: The claim requires that the "attaching device" (the sprayer holder) be "rotatably attached to said partition." The factual basis for whether the accused product's sprayer holder rotates, and if so, whether it is attached via the specific "partition" and "follower" mechanism as claimed, is not established in the complaint and raises a key question for infringement.

V. Key Claim Terms for Construction

• The Term: "means for controlling the water to flow"

  • Context and Importance: This term is drafted in means-plus-function format under 35 U.S.C. § 112(f). Its scope is not limitless but is confined to the specific corresponding structure disclosed in the patent's specification and its equivalents. The infringement analysis for this element will therefore require a direct comparison between the internal valve mechanism of the accused product and the specific structure described in the '510 Patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue for a broader range of equivalents, focusing on the overall function of diverting water.
    • Evidence for a Narrower Interpretation: The specification discloses a very specific corresponding structure: a "valve stem (40)" that is rotatably received in the housing's "chamber (15)". This stem includes a "passage (42)", a "compartment (43)", a spring-biased "valve member (44)", and engages with "valve seats (46, 47)" to block or open the outlet ports ('510 Patent, col. 4:21-38). A court will likely construe the "means for controlling" to be this specific assembly and its structural equivalents.

• The Term: "an attaching device rotatably attached to said partition"

  • Context and Importance: Practitioners may focus on this term because infringement hinges on whether the accused product's holder for the handheld sprayer has the specific rotational capability and, critically, the claimed mechanism of attachment. The complaint lacks specific allegations on how the accused holder is constructed or attached.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff may argue the term simply requires a sprayer holder that can swivel, pointing to the functional goal of allowing a user to "hook[] or attach[] the sprayer nozzle" ('510 Patent, col. 3:58-59).
    • Evidence for a Narrower Interpretation: A defendant may argue the claim requires a specific structural arrangement. The claim language links the "attaching device" directly to the "partition" via a "follower" engaged in a "bore" ('510 Patent, cl. 1). The specification's detailed description and Figure 3 illustrate this specific multi-part assembly, suggesting the method of attachment is a limitation, not just the resulting rotation ('510 Patent, col. 4:1-8).

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant sells products that purchasers subsequently "make, assemble, install and use" in an infringing manner (Compl. ¶35).
• Willful Infringement: The complaint alleges that Defendant had knowledge of the '510 Patent through "prior notice" and that its continued sales constitute willful and knowing disregard of Plaintiff's patent rights (Compl. ¶36, ¶37). The willfulness claim is also based on notice provided by the filing of the complaint itself (Compl. ¶36).

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

• A central issue will be one of structural correspondence: does the accused "diverter mount" possess the specific internal mechanical assembly recited in Claim 1—namely, a distinct "partition" with a "bore" and a "follower"—to achieve a "rotatably attached" sprayer holder? The complaint's general allegations leave this as a primary open question of fact.
• A key legal and technical question will be the scope of the means-plus-function term "means for controlling the water." The case will likely require a detailed comparison of the internal valve mechanism of the accused product against the specific "valve stem" assembly disclosed in the '510 patent to determine structural equivalence.