DCT
2:24-cv-00328
Interlink Products Intl Inc v. Xiamen Lota Intl Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Interlink Products International, Inc. (New Jersey)
- Defendant: Xiamen Lota International Co., Ltd. (China)
- Plaintiff’s Counsel: The Law Office of JASON B. LATTIMORE, ESQ. LLC
- Case Identification: 2:24-cv-00328, D.N.J., 01/19/2024
- Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant ships its products to the state, including through Port Newark, for sale by major retailers such as Walmart and Home Depot, who operate distribution centers and retail locations within the district.
- Core Dispute: Plaintiff alleges that Defendant’s dual showerhead products infringe a patent related to an integrated water diverter and showerhead holder device.
- Technical Context: The technology concerns plumbing fixtures, specifically combination showerhead systems that integrate a fixed showerhead, a handheld sprayer, and a diverter valve into a single unit.
- Key Procedural History: Plaintiff acquired the patent-in-suit by assignment on November 17, 2015. The complaint alleges that Plaintiff sent a letter to Defendant on April 6, 2023, providing notice of the patent and its alleged infringement, an event that could be relevant to claims of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2005-03-14 | ’510 Patent Priority Date |
| 2007-11-27 | ’510 Patent Issue Date |
| 2015-11-17 | Plaintiff acquires ’510 Patent by assignment |
| 2023-04-06 | Plaintiff sends notice letter to Defendant |
| 2024-01-19 | 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
(Compl. ¶10; ’510 Patent, cover)
The Invention Explained
- Problem Addressed: The patent addresses the difficulty and inconvenience for consumers of installing showerhead holders, which traditionally required drilling holes in shower walls to mount brackets (’510 Patent, col. 1:12-24). Alternative solutions, such as suction cups, were described as prone to moving or sliding due to the weight of the showerhead over time (’510 Patent, col. 1:36-43).
- The Patented Solution: The invention is a single, integrated holder device that attaches directly to the water outlet tube extending from the shower wall, eliminating the need for separate brackets or drilling (’510 Patent, col. 2:6-15). The device’s housing contains an inlet for the water tube, a first outlet for a fixed showerhead, a second outlet for a handheld sprayer, and an internal controlling device (a diverter valve) to direct the flow of water to either or both outlets (’510 Patent, col. 3:13-36). The housing also incorporates a structure to hold the handheld sprayer when not in use (’510 Patent, col. 3:55-59).
- Technical Importance: The design consolidates the functions of a water diverter, a fixed showerhead mount, and a handheld sprayer holder into a single unit that simplifies installation for consumers (’510 Patent, col. 2:1-5).
Key Claims at a Glance
- The complaint asserts at least independent claims 3 and 11 (Compl. ¶¶13, 15, 19).
- Independent Claim 3 requires, among other elements:
- 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 outlets.
- Two valve seats within the casing.
- A controlling means that includes a rotatable valve stem.
- The valve stem must contain a compartment holding a "spring-biased valve member" designed to engage with the valve seats to control water flow.
- Independent Claim 11 requires, among other elements:
- A housing with an inlet, outlets, and an internal casing and valve stem.
- A "knob" secured to the valve stem to allow for rotation.
- The knob must include a "barrel" attached to the valve stem and "at least one rib extended therein and coupled to said barrel, for reinforcing said barrel."
- The complaint notes that the accused products embody "all of the limitations of at least one claim," suggesting the right to assert other claims is reserved (Compl. ¶20).
III. The Accused Instrumentality
Product Identification
The accused products are numerous "combo showerhead" models sold to major U.S. retailers, including "Walmart Combos" (MAINSTAYS® brand), "Home Depot Combos" (GLACIER BAY® brand), and "Lowe's Combos" (AQUASOURCE® and PROJECT SOURCE® brands) (Compl. ¶¶12, 16, 18).
Functionality and Market Context
The complaint describes the accused products as dual showerhead systems that include a fixed showerhead, a handheld sprayer, and a "combined water diverter and handheld shower holder" (Compl. ¶9). This central "diverter-holder" component is alleged to have an inlet for water, two outlets for the showerheads, a knob-operated valve for directing water flow, and a holder for the handheld sprayer (Compl. ¶9).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint. The complaint's infringement allegations are based on the assertion that the accused products' "diverter-holder" possesses the "same structural elements" as those claimed in the ’510 Patent (Compl. ¶¶13, 15, 17, 19).
Claim Chart Summary: ’510 Patent, Independent Claim 3
The following table synthesizes the allegations for 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 include a "diverter-holder" with an inlet that attaches to the shower pipe and two outlets for a fixed showerhead and a handheld sprayer. | ¶9 | col. 3:13-25 |
| and including 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 complaint alleges the accused products have the same structural elements as the claimed invention, which would include an internal casing and chamber. | ¶13, ¶15 | col. 3:37-43 |
| said housing including 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 complaint's general allegation that the accused products embody all limitations of the claim implies the presence of two internal valve seats to control flow to the respective outlets. | ¶13, ¶15 | col. 4:35-39 |
| means for controlling the water to flow out... said controlling means including a valve stem rotatably attached in said chamber of said casing... | The accused products include a valve controlled by a knob, which allegedly functions as the claimed controlling means with a rotatable valve stem. | ¶9 | col. 4:21-27 |
| and said valve stem including a compartment formed therein, and a spring-biased valve member received in said compartment of said valve stem, to engage with either of said valve seats of said housing... | The complaint's broad allegation of structural identity suggests the internal valve mechanism of the accused products includes a spring-biased member within the valve stem. | ¶13, ¶15 | col. 4:32-38 |
Identified Points of Contention
- Technical Questions: A key question for the court will be factual: does the internal mechanism of the accused products' diverter valve actually operate using a "spring-biased valve member" that engages with two distinct "valve seats" as required by Claim 3? The complaint does not provide specific evidence, such as product teardowns or diagrams, to substantiate this structural correspondence.
- Scope Questions: The infringement analysis for Claim 11 will raise the question of whether the internal construction of the accused products' control knob includes a "barrel" and a "rib... for reinforcing said barrel." The litigation may focus on whether the accused knobs, which may be of a different construction (e.g., solid molded plastic), fall within the scope of this specific structural language.
V. Key Claim Terms for Construction
Term: "a spring-biased valve member received in said compartment of said valve stem" (Claim 3)
- Context and Importance: This term defines the core operational component of the patented diverter. Infringement of Claim 3 hinges on whether the accused products contain this specific internal arrangement. Practitioners may focus on this term because many alternative valve technologies exist (e.g., ceramic disc cartridges) that may not meet this structural definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the objective is to provide a "controlling device for controlling the water to selectively flow" (’510 Patent, col. 2:13-15). Plaintiff may argue that the claim term should be interpreted functionally to cover any spring-loaded component within a valve stem that achieves this purpose.
- Evidence for a Narrower Interpretation: The patent provides a detailed depiction of this arrangement, showing valve member (44) pushed by spring (45) inside compartment (43) of the valve stem (40) to seal against valve seats (46, 47) (’510 Patent, col. 4:32-38; Figs. 3, 5-7). A defendant would likely argue the claim is limited to this disclosed structure or a close equivalent.
Term: "at least one rib extended therein and coupled to said barrel, for reinforcing said barrel" (Claim 11)
- Context and Importance: This limitation describes a specific method of constructing the control knob. Its interpretation is critical for Claim 11, as the accused products may use knobs with different internal structures.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The language "for reinforcing" describes the purpose of the rib. Plaintiff may argue this functional language allows the term to read on any internal structural element that strengthens the knob's barrel, regardless of its specific shape.
- Evidence for a Narrower Interpretation: The specification explicitly shows "ribs 54 extended therein and coupled to the barrel 51, for reinforcing the barrel 51" (’510 Patent, col. 5:17-19; Fig. 4). A defendant could argue that the term requires a distinct, rib-like structure as depicted, not merely a thicker or solid-molded section of the knob.
VI. Other Allegations
Indirect Infringement
The complaint alleges that Defendant induces infringement by supplying the accused products to purchasers, who then import, use, distribute, and sell them in an infringing manner (Compl. ¶22).
Willful Infringement
The willfulness allegation is based on alleged pre-suit knowledge of infringement. The complaint cites a notice letter sent to Defendant on April 6, 2023, and alleges that Defendant's "continued sale of the Infringing Products" after receiving this notice constitutes willful and knowing disregard of Plaintiff's patent rights (Compl. ¶¶23-24).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural correspondence: Do the internal mechanics of the accused products' diverter valves and control knobs contain the specific, detailed structures recited in the independent claims—such as a "spring-biased valve member" (Claim 3) and a "rib... for reinforcing" a knob's barrel (Claim 11)—or do they employ different, potentially non-infringing designs? The complaint's conclusory allegations will require substantial evidentiary support during discovery.
- The case will also turn on a question of claim scope: Will the court construe the key structural terms narrowly, limiting them to the specific embodiments shown in the patent's figures, or more broadly, allowing them to cover a wider range of functionally similar but structurally different valve and knob constructions? The outcome of claim construction will likely be dispositive for the infringement analysis.