Interlink Products Intl Inc v. Feelso Life

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Interlink Products International, Inc. (New Jersey)
  • Defendant: Feelso Life, ABC Corp., and John Doe (Jurisdiction Undisclosed)
  • Plaintiff’s Counsel: The Law Office Of Jason B. Lattimore, ESQ. LLC
• Case Identification: 2:19-cv-08950, D.N.J., 03/26/2019
• Venue Allegations: Venue is alleged to be proper based on Defendants regularly conducting business in the district, including advertising, offering for sale, and selling the accused products to customers in New Jersey.
• Core Dispute: Plaintiff alleges that Defendant’s dual showerhead product infringes a patent related to a combined water diverter and holder, and further alleges false advertising and unfair competition related to the product's performance and online reviews.
• Technical Context: The technology concerns plumbing fixtures, specifically integrated devices that both divert water between a fixed showerhead and a handheld sprayer and provide a holder for the handheld sprayer.
• Key Procedural History: Plaintiff alleges it acquired the patent-in-suit by assignment in 2015. The complaint also states that Plaintiff sent multiple pre-suit cease and desist letters to Defendants, notifying them of the patent and the alleged infringement, with the most recent letter dated prior to the complaint's filing.

Case Timeline

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

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

• Issued: November 27, 2007

The Invention Explained

• Problem Addressed: The patent’s background section identifies the difficulty and inconvenience for consumers of installing typical shower fixtures, which often require drilling holes into walls to mount brackets, a task for which many households lack the necessary tools or expertise (’510 Patent, col. 1:16-26). Existing solutions without drilling, such as those using suction cups, are described as prone to moving or sliding over time due to the weight of the shower components (’510 Patent, col. 1:36-49).
• The Patented Solution: The invention is a single, integrated holder device that attaches directly to the pre-existing water outlet tube extending from the shower wall (’510 Patent, col. 2:6-15). This device contains a housing with an inlet for receiving water, a first outlet for a fixed showerhead, a second outlet for a handheld sprayer, and an internal valve mechanism to control water flow between the two outlets (’510 Patent, Abstract; col. 3:17-48). The housing itself also incorporates a feature for holding the handheld sprayer nozzle, thus combining the functions of a water diverter and a nozzle holder into one unit that does not require separate mounting to the wall (’510 Patent, col. 3:55-59).
• Technical Importance: This design simplifies installation for consumers by consolidating multiple plumbing functions into a single component that leverages the existing, standardized water outlet pipe.

Key Claims at a Glance

• The complaint asserts independent claims 3 and 10, and dependent claim 11 (Compl. ¶55).
• Independent Claim 3 recites the core elements of the device, including:
  • A housing with an inlet, a first outlet port, and at least one second outlet port.
  • A casing within the housing with a chamber communicating with the inlet and outlets.
  • Two valve seats within the casing communicating with the respective outlet ports.
  • A "means for controlling the water," which includes a rotatable valve stem with a compartment and a spring-biased valve member inside that engages with the valve seats.
• Independent Claim 10 recites a device with similar elements, focusing on the user control mechanism:
  • A housing with an inlet, outlets, and an internal casing and chamber.
  • A "means for controlling the water" including a rotatable valve stem.
  • A knob secured to the valve stem for rotation.
  • A spring-biased projection in the housing that is engageable with the knob to position it at selected locations.

III. The Accused Instrumentality

Product Identification

The accused products are the "FEELSO High Pressure Rainfall 9” Adjustable Showerhead and 3 Settings Handheld Shower Spray Combo" and its standalone "holder/diverter component" (Compl. ¶¶17, 51-52). These are referred to collectively as the "FEELSO Products" (Compl. ¶55).

Functionality and Market Context

The complaint describes the accused product as a dual showerhead system consisting of a fixed showerhead, a handheld sprayer, and a plumbing device that functions as both a water diverter and a holder for the handheld sprayer (Compl. ¶51). The diverter/holder allegedly has an inlet for water, two outlets for the respective showerheads, and a knob that allows the user to control the water flow between the outlets (Compl. ¶51). An image attached as Exhibit E to the complaint depicts the complete dual showerhead product sold by the Defendant (Compl. ¶51).

IV. Analysis of Infringement Allegations

’510 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: Claims 3 and 10 both recite a "means for controlling the water," which is a means-plus-function limitation. The scope of this element is not the broad function of "controlling water," but is limited to the specific corresponding structure disclosed in the patent's specification and its equivalents (’510 Patent, col. 4:21-38; Fig. 3). A central question for the court will be whether the internal valve mechanism of the FEELSO Products is structurally equivalent to the patent's disclosed assembly of a rotatable valve stem (40), a spring-biased valve member (44, 45), and valve seats (46, 47).
• Technical Questions: The complaint alleges infringement based on the external configuration and user-facing function of the accused product (Compl. ¶51). It does not provide evidence, such as a teardown or internal diagrams, showing that the accused diverter contains the specific internal components required by the claims, such as the two distinct valve seats or the spring-biased valve member. A key evidentiary question will be whether discovery reveals that the internal construction of the FEELSO Products matches these claimed structural limitations.

V. Key Claim Terms for Construction

• The Term: "means for controlling the water to flow out through said first outlet port and said at least one second outlet port" (Claim 3).
• Context and Importance: This is a means-plus-function limitation under 35 U.S.C. § 112, para. 6. Its construction is critical because it will define the precise structure required to infringe, rather than just any mechanism that performs the function of diverting water. Practitioners may focus on this term because the infringement analysis will hinge on a comparison between the specific structure disclosed in the '510 patent and the internal structure of the accused device.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue for a broader range of equivalents, but the interpretation is fundamentally tied to the disclosed structure. The function itself—"controlling the water to flow"—is broadly stated in the claim.
  • Evidence for a Narrower Interpretation: The specification provides a very specific corresponding structure for this function. This includes the "valve stem 40 rotatably attached" within the housing's chamber, which contains a "compartment 43," a "valve member 44," and a "spring member 45" designed to bias the valve member against one of two "valve seats 46, 47" (’510 Patent, col. 4:21-38; Fig. 4). A court will likely construe the "means for controlling" to be this specific assembly and its structural equivalents.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants' advertising, promotional materials, and instructions encourage purchasers to assemble, install, and use the product in an infringing manner (Compl. ¶¶57, 60). It further alleges that the components have no substantial non-infringing use, as they "cannot be assembled or combined into any ordinary or practical device that does not infringe" (Compl. ¶60).
• Willful Infringement: The willfulness allegation is based on alleged pre-suit knowledge. The complaint asserts that Plaintiff sent "multiple cease and desist letters," with the most recent dated February 12, 2019, which notified Defendants of the ’510 Patent and the infringing nature of the FEELSO Products (Compl. ¶58). The complaint also alleges an "objectively high likelihood" of infringement that was or should have been known to Defendants (Compl. ¶62).

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

1. A central issue will be one of structural equivalence under means-plus-function claiming: Will the internal valve mechanism of the accused FEELSO diverter be found to be the same as or equivalent to the specific rotatable valve stem assembly with its spring-biased valve member and dual valve seats, as disclosed in the '510 patent specification?
2. A key dispute will likely concern the level of proof: Can the Plaintiff, through discovery, produce sufficient evidence of the accused product's internal construction to demonstrate, on an element-by-element basis, that it contains the specific structural features recited in independent claims 3 and 10, moving beyond the functional description provided in the complaint?