DCT
2:19-cv-18544
Interlink Products Intl Inc v. Homewerks Worldwide LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Interlink Products International, Inc. (New Jersey)
- Defendant: Homewerks Worldwide, LLC (Illinois)
- Plaintiff’s Counsel: The Law Office Of JASON B. LATTIMORE, ESQ. LLC
- Case Identification: 2:19-cv-18544, D.N.J., 10/28/2019
- Venue Allegations: Plaintiff alleges venue is proper based on a forum selection clause in a prior settlement agreement between the parties, as well as Defendant's business activities in the District of New Jersey.
- Core Dispute: Plaintiff alleges that Defendant breached a 2016 settlement agreement by continuing to sell shower diverter products that infringe a patent related to a combined showerhead holder and water diverter.
- Technical Context: The technology concerns multi-function shower fixtures that combine a water diverter, a fixed showerhead, and a mount for a handheld sprayer nozzle into a single unit.
- Key Procedural History: The complaint is predicated on an alleged breach of a Settlement Agreement dated May 24, 2016. In that agreement, which resolved a prior infringement dispute over the same patent, Defendant allegedly agreed to refrain from selling products embodying any claim of the patent-in-suit. The current lawsuit alleges that Defendant has violated this agreement.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-14 | ’510 Patent Priority Date |
| 2007-11-27 | ’510 Patent Issue Date |
| 2015-11-17 | Plaintiff Interlink acquires the ’510 Patent by assignment |
| 2016-05-24 | Plaintiff and Defendant enter into the Settlement Agreement |
| 2019-10-28 | Complaint Filing Date |
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 identifies a problem with conventional shower fixtures where installing a handheld sprayer nozzle requires mounting a separate bracket, which often involves drilling holes into shower walls—a task many homeowners cannot easily perform (’510 Patent, col. 1:13-31). Existing solutions that do not require drilling, such as those using suction cups, are described as prone to sliding or moving over time (’510 Patent, col. 1:36-48).
- The Patented Solution: The invention is a single, integrated holder device that attaches directly to the main water outlet tube (shower arm) extending from the wall (’510 Patent, col. 2:8-16). This device contains a housing with an inlet for the shower arm, a first outlet for a fixed showerhead, and a second outlet for a handheld sprayer nozzle. Crucially, the housing itself incorporates an "attaching device" (a holder or hook) for the sprayer nozzle and an internal valve mechanism to control and divert the water flow between the two outlets or to both simultaneously (’510 Patent, col. 3:54-65). This design eliminates the need for a separate, wall-mounted bracket.
- Technical Importance: This integrated approach offers a more stable and easier-to-install solution for adding handheld sprayer functionality to an existing shower compared to prior art methods requiring separate brackets or less reliable suction mounts (’510 Patent, col. 1:50-55).
Key Claims at a Glance
- The complaint asserts that the accused products embody at least claims 3 and 11 of the ’510 Patent (Compl. ¶11).
- Independent Claim 3: A holder device for a water outlet tube comprising:
- a housing with an inlet, a first outlet port, and a second outlet port
- a casing inside the housing with a chamber communicating with the inlet and outlet ports
- two valve seats in the casing communicating with the respective outlet ports
- "means for controlling the water to flow out" through the outlet ports, which includes:
- a rotatable valve stem in the chamber with a passage to communicate the inlet with the outlets
- the valve stem has a compartment
- a spring-biased valve member is in the compartment to engage the valve seats and control water flow
- Independent Claim 11: A holder device for a water outlet tube comprising:
- a housing with an inlet, a first outlet port, and a second outlet port
- a casing inside the housing with a chamber
- "means for controlling the water to flow out," which includes a rotatable valve stem in the chamber
- a knob secured to the valve stem to rotate it
- the knob includes a barrel extended therefrom and attached to the valve stem
- the knob includes "at least one rib extended therein and coupled to said barrel, for reinforcing said barrel"
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The complaint identifies numerous accused products, including showerhead "Combo kit" models and "3-Way Shower Diverter" models sold under the AquaSource, Glacier Bay, Home2O, and Splash2O brand names (Compl. ¶11).
Functionality and Market Context
- The accused products are described as shower fixtures that include a diverter, allowing users to switch the flow of water between a stationary showerhead and a handheld sprayer (Compl. ¶11). The table of accused products, which serves as the primary visual evidence in the complaint, lists models described as "3 way diverter" or "2 way diverter," indicating their function of directing water flow. (Compl. ¶11).
- The complaint alleges these products are sold in direct competition with Plaintiff's own products and that Defendant has sold them to retailers such as Lowe's Home Improvement (Compl. ¶¶ 11, 13). Plaintiff alleges that it lost business from Lowe's as a result of Defendant's sales (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint does not provide a detailed element-by-element infringement analysis or a claim chart exhibit. The analysis below is constructed from the patent claims and the general allegations in the complaint.
’510 Patent Infringement Allegations (Claim 3)
| Claim Element (from Independent Claim 3) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing including an inlet for attaching to the water outlet tube... said housing including a first outlet port and at least one second outlet port | The accused products are shower diverters that attach to a shower arm and have outlets for a fixed showerhead and a handheld sprayer. | ¶11 | col. 3:12-23 |
| a casing received therein and having a chamber formed in said casing and communicating with said inlet and said first outlet port and said at least one second outlet port | The accused products allegedly contain an internal body with a water chamber connecting the inlet and outlets. | ¶11 | col. 3:36-43 |
| two valve seats formed in said casing and communicating with said first outlet port and said at least one second outlet port of said housing respectively | The internal body of the accused diverters allegedly includes valve seats to control flow to the different outlets. | ¶11 | col. 4:35-38 |
| means for controlling the water to flow out... including a valve stem rotatably attached in said chamber... and a spring-biased valve member received in said compartment of said valve stem | The accused products allegedly use a rotatable valve mechanism with an internal, spring-biased component to direct water flow. | ¶11 | col. 4:21-38 |
’510 Patent Infringement Allegations (Claim 11)
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a knob secured to said valve stem to rotate said valve stem relative to said casing and said housing | The accused products feature an external knob or lever used to operate the internal diverter valve. | ¶11 | col. 4:58-62 |
| said knob including a barrel extended therefrom and attached to said valve stem | The knob on the accused products allegedly includes a barrel-like structure that connects to the internal valve stem. | ¶11 | col. 5:7-12 |
| and at least one rib extended therein and coupled to said barrel, for reinforcing said barrel. | The knob on the accused products is alleged to contain an internal reinforcing rib coupled to its barrel structure. | ¶11 | col. 5:18-21 |
Identified Points of Contention
- Scope Questions: A central question for Claim 3 will be whether the accused products' valve mechanisms contain the corresponding structure for the "means for controlling" limitation, which the patent defines as a specific rotatable valve stem with an internal compartment holding a spring-biased valve member (’510 Patent, col. 7:5-10).
- Technical Questions: For Claim 11, the dispute may focus on a very specific structural feature: whether the control knobs on the accused products literally contain "at least one rib extended therein and coupled to said barrel, for reinforcing said barrel." The complaint does not provide visual or documentary evidence, such as product teardowns or design schematics, to substantiate this specific structural allegation.
V. Key Claim Terms for Construction
Term: "means for controlling the water to flow out" (Claim 3)
Context and Importance: This term, framed in means-plus-function format under 35 U.S.C. § 112(f), is the functional heart of Claim 3. Its scope is not defined by the words alone, but is limited to the specific structure disclosed in the specification for performing that function. The outcome of the infringement analysis for this claim will depend entirely on whether the accused products contain a structure that is identical or equivalent to what is disclosed in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the "controlling means" includes a "valve stem rotatably attached" and having a "passage formed therein" (’510 Patent, col. 7:1-4). A party might argue this language covers a range of rotating valve designs.
- Evidence for a Narrower Interpretation: The claim language itself, and the corresponding description, further requires that the valve stem include a "compartment formed therein, and a spring-biased valve member received in said compartment" (’510 Patent, col. 7:5-8; Fig. 4). A party will argue that the scope is strictly limited to this two-part structure (stem with an internal, spring-loaded member), and does not cover simpler, single-piece rotating valve designs.
Term: "at least one rib extended therein and coupled to said barrel, for reinforcing said barrel" (Claim 11)
Context and Importance: This term recites a highly specific and seemingly minor structural detail of the control knob. Practitioners may focus on this term because its specificity makes it a potential point of non-infringement. If the accused products achieve reinforcement of the knob through other means (e.g., thicker material, different geometry) without this exact "rib," it may provide a straightforward defense to infringement of Claim 11.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The complaint does not provide a basis for analysis of a broader interpretation.
- Evidence for a Narrower Interpretation: The patent specification explicitly shows this feature in its drawings (Fig. 4, element 61, though not explicitly labeled as "rib 54" in that view) and describes "one or more ribs 54 extended therein and coupled to the barrel 51, for reinforcing the barrel 51" (’510 Patent, col. 5:18-21). This provides a very clear, concrete structure that a court may use to define the term narrowly.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead separate counts for indirect infringement.
- Willful Infringement: While the complaint does not use the term "willful infringement," its central claim for "Breach of Settlement Agreement" serves a similar purpose by alleging a higher degree of culpability. The complaint alleges that Defendant entered into a settlement agreement on May 24, 2016, which explicitly prohibited it from selling products that infringe the ’510 Patent (Compl. ¶¶ 9, 10). The allegation that Defendant subsequently sold infringing products implies that Defendant acted with full knowledge of the patent and its obligations thereunder, which is the factual predicate for a willfulness finding.
VII. Analyst’s Conclusion: Key Questions for the Case
The dispute appears to center on whether the accused products, sold after the parties executed a settlement agreement, fall within the scope of the ’510 Patent’s claims. The case will likely turn on two primary questions:
- A core question of structural correspondence: Do the accused shower diverters contain the specific two-part valve structure—a rotatable stem with a separate, internal spring-biased member—that is disclosed in the patent as the "means for controlling" water flow required by Claim 3?
- A key evidentiary question of literal infringement: Can Plaintiff produce evidence showing that the control knobs on the accused products contain the precise internal "reinforcing rib" structure recited in Claim 11, or is there a structural mismatch that would defeat this claim?