Interlink Products Intl Inc v. Homewerks Worldwide LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Interlink Products International, Inc. (New Jersey) and Eli Zhadanov (New York)
  • Defendant: Homewerks Worldwide, LLC (Illinois)
  • Plaintiff’s Counsel: The Law Office Of Jason B. Lattimore, Esq. LLC
• Case Identification: 2:19-cv-11751, D.N.J., 04/29/2019
• Venue Allegations: Venue is alleged to be proper based on a forum selection clause in a contract between the parties, as well as Defendant's business activities in the district.
• Core Dispute: Plaintiffs allege that Defendant breached a prior settlement agreement, which had resolved an earlier dispute concerning alleged infringement of a patent related to mounting systems for bathroom accessories.
• Technical Context: The technology concerns a dual-use mounting system for bathroom accessories, allowing them to be either affixed semi-permanently to a wall via an adhesive bracket or used temporarily via a traditional suction cup mechanism.
• Key Procedural History: The complaint states that on or about May 24, 2016, the parties entered into a settlement agreement to resolve Plaintiffs' prior allegations that Defendant had infringed the patent at issue. The current lawsuit alleges a breach of that agreement, making the contract's terms, rather than direct patent infringement, the central cause of action.

Case Timeline

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

The complaint is for breach of a settlement agreement concerning U.S. Patent No. 8,292,253. While not directly asserted for infringement in this action, the patent's technology and claims form the basis of the underlying dispute.

U.S. Patent No. 8,292,253 - "Device for Supporting Bathroom Accessories and The Like"

• Patent Identification: U.S. Patent No. 8,292,253, "Device for Supporting Bathroom Accessories and The Like," issued October 23, 2012.

The Invention Explained

• Problem Addressed: The patent background suggests a need for an improved device for supporting bathroom accessories, implying that conventional methods are limited (e.g., suction cups only work on smooth, non-porous surfaces like tile, but not on drywall or textured surfaces) (Compl. ¶8; ’253 Patent, col. 1:5-10).
• The Patented Solution: The invention is a two-part system. It consists of a standard suction-based accessory holder and a separate mounting element with an adhesive backing. The mounting element is affixed to a wall, and its front face has a groove designed to receive and hold the suction element. This allows a suction-based accessory to be mounted on surfaces that would not typically support suction. A key feature is that the suction element can be removed from the mounting bracket and then used independently as a conventional suction cup device on a suitable surface, such as the inside of a bathtub (’253 Patent, col. 2:28-46; Fig. 5).
• Technical Importance: The invention provides versatility, allowing a single accessory to be mounted semi-permanently on a wider variety of wall surfaces via the adhesive bracket, while retaining the ability to be used as a temporary, portable suction device in other locations (’253 Patent, col. 2:38-46).

Key Claims at a Glance

• The complaint does not assert specific claims, as it is not a patent infringement action. However, the core invention is captured in independent claim 1.
• Independent Claim 1 requires, in part:
  • A "suction element" with a "suction part" and a "holding part" for an accessory.
  • A "mounting element" with an "adhesive member" on one side and a "transverse groove" on the other.
  • The suction element's "suction part and said central disc" are "insertable transversely" into the groove.
  • Crucially, the suction element is "removable from said transverse groove" and, when removed, is "attachable without said mounting element to the wall directly by suction."
  • The groove is defined as being "formed exclusively by two oppositely located projections."

III. The Accused Instrumentality

The complaint does not identify a specific accused product or instrumentality. The action is for breach of a settlement agreement, and the complaint offers only the conclusory statement that "Defendant breached the settlement agreement" without detailing the specific conduct or product that allegedly constitutes the breach (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint does not allege patent infringement and therefore provides no infringement allegations or claim charts. The sole count is for "Claim for Breach of Settlement Agreement" (Compl. p. 3). The Prayer for Relief seeks damages for this breach, not for patent infringement (Compl. p. 3, A-C).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

While there is no active infringement claim, any dispute over whether conduct violates a settlement agreement tied to the ’253 Patent would likely require interpreting the patent's claims. Based on Claim 1, the following terms may be central.

• The Term: "transverse groove...formed exclusively by two oppositely located projections"

• Context and Importance: This term defines the specific physical interface between the two main components of the device. The "exclusively" and "oppositely located" limitations are highly specific. Practitioners may focus on this term because a competing product might use a different groove structure (e.g., a fully enclosed channel, a single hook, or more than two projections) in an attempt to design around the claim.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of this element.
  • Evidence for a Narrower Interpretation: The specification explicitly shows this structure, identifying "two projections 13 which form a groove 14 therebetween" (’253 Patent, col. 2:5-7; Fig. 3). This ties the claim language directly to a specific embodiment, which could support a narrow construction limited to a structure substantially identical to the figures.

• The Term: "removable...and when it is removed, then said suction cup element is attachable without said mounting element to the wall directly by suction"

• Context and Importance: This limitation defines the core dual-functionality of the invention. Practitioners may focus on this term because the dispute could hinge on whether a product's suction component is truly designed to be repeatedly removed and used independently, or if it is effectively a one-time or permanent assembly.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint does not provide sufficient detail for analysis of this element.
  • Evidence for a Narrower Interpretation: The specification describes a specific use case where the user disassembles the device to "move a soap-holder to another location, for example for bathing a child in a bathtub" and then re-attaches it using its own suction power (’253 Patent, col. 2:28-40). This description of disassembly and independent re-use could be used to argue that the claim requires a design that facilitates such functionality, not merely one that can be physically separated.

VI. Other Allegations

The complaint does not allege indirect infringement or willful infringement. The single cause of action is for breach of the prior settlement agreement (Compl. ¶¶ 8-11).

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

The resolution of this case appears to depend on questions of contract law, which may in turn require an analysis of the underlying patent.

• A primary issue will be contractual interpretation: what are the specific terms and prohibitions defined in the May 2016 settlement agreement? The complaint does not disclose these terms, which will be central to determining whether a breach occurred.
• A key secondary question will be the interplay between the contract and patent scope: does the settlement agreement define the prohibited conduct by referencing the claims of the ’253 Patent (e.g., "Defendant shall not sell any product covered by Claim 1 of the '253 Patent")? If so, the court may need to construe the patent's claims to determine whether Defendant's subsequent actions fell within the scope of the patent and, therefore, breached the agreement.