2:24-cv-10910
Curelife Co Ltd v. Ideavillage Products Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Curelife Co., Ltd. (Republic of Korea) and Cogent Global, Inc. (New Jersey)
- Defendant: Ideavillage Products Corp. (New Jersey)
- Plaintiff’s Counsel: Rivkin Radler LLP; Sughrue Mion PLLC
- Case Identification: 2:24-cv-10910, D.N.J., 12/04/2024
- Venue Allegations: Venue is asserted in the District of New Jersey on the basis that Defendant is incorporated in the state and therefore "resides" in the district.
- Core Dispute: Plaintiffs allege that Defendant’s Helio Airbroom product line infringes a patent related to the structural design of cleaning devices that integrate a rigid frame with a flexible scraper.
- Technical Context: The lawsuit concerns the market for manual cleaning tools, specifically lightweight brooms or squeegees that use a flexible blade instead of traditional bristles.
- Key Procedural History: The complaint certifies that this action is related to a prior case, Ideavillage Products Corp. v. Yang, Civil Action No. 2:24-cv-07657 (D.N.J.), suggesting a pre-existing dispute between the parties. The complaint also alleges Defendant received notice of infringement from Amazon.com approximately six months before the suit was filed.
Case Timeline
| Date | Event |
|---|---|
| 2018-12-19 | Priority Date for U.S. Patent No. 11,219,348 |
| 2022-01-11 | U.S. Patent No. 11,219,348 Issued |
| 2023-06-01 | Alleged initial market introduction of Accused Products (approx.) |
| 2024-06-11 | Alleged date Defendant was notified of infringement by Amazon.com |
| 2024-12-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,219,348 - Cleaning Device with Auxiliary Cleaner
- Patent Identification: U.S. Patent No. 11,219,348, issued January 11, 2022.
The Invention Explained
The patent background describes issues with conventional broom-type cleaning devices, noting that their hairs are difficult to clean and ineffective on liquids (U.S. Patent No. 11,219,348, col. 1:31-43). It also identifies a problem with prior art integrated scraper designs where the main cleaner does not "firmly support the auxiliary cleaner when sweeping a floor" and can be "cumbersome to clean" (U.S. Patent No. 11,219,348, col. 1:56-60).
The invention is a cleaning device with a rigid "main cleaner" (a frame structure) and a flexible "auxiliary cleaner" (a scraper blade). The two components are integrally coupled, where a "coupler" extending from the rigid frame is inserted into and surrounded by the material of the auxiliary cleaner during a two-step injection molding process (’348 Patent, col. 5:11-19, col. 6:31-40). This construction is intended to create a durable, twist-resistant head, while the auxiliary cleaner features protrusions designed to remove dirt from uneven surfaces and contain debris (’348 Patent, col. 6:1-19, 6:25-31).
The patented design purports to offer a more robust and effective manual cleaning tool by combining the structural rigidity of a molded frame with the cleaning flexibility of a rubber blade in a single, integrated unit manufactured via a specific molding process (’348 Patent, col. 7:1-8).
Key Claims at a Glance
- The complaint asserts independent Claim 1.
- The essential elements of Claim 1 are:
- A bar-shaped grip coupled to a tubular housing at a bottom.
- A rigid main cleaner including the tubular housing and a plurality of frames connected to a bottom of the tubular housing.
- An auxiliary cleaner coupled to a coupler extending from the bottom of the frames.
- The coupler is inserted into an inside of the auxiliary cleaner such that the auxiliary cleaner surrounds the coupler.
- The auxiliary cleaner includes a plate-shaped scraper, a plurality of main protrusions on the scraper, and auxiliary protrusions in the form of a wall alongside the main protrusions.
- The complaint alleges infringement of "one or more claims" of the patent, which may suggest an intent to assert dependent claims later in the litigation (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are the "Helio Airbroom™ broom" and the "Helio™ mini broom" (Compl. ¶14).
Functionality and Market Context
The complaint describes the accused products as a "type of lightweight broom having a flexible rubber blade that allows it to sweep up debris and dust more effectively than traditional plastic or wooden brooms" (Compl. ¶14). They are allegedly promoted and sold through national "As Seen On TV" campaigns and distributed through major online and mass retail channels, including Amazon.com, Kohl's, Wal-Mart, and Target (Compl. ¶15). The complaint alleges the products have achieved "significant sales" since their introduction in June 2023 (Compl. ¶18). An annotated image from the defendant's website shows the product in use, with a callout identifying the "Auxiliary cleaner" portion of the device (Compl. p. 7).
IV. Analysis of Infringement Allegations
Claim Chart Summary
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a bar-shaped grip coupled to a tubular housing at a bottom | The product comprises a handle identified as a "bar-shaped grip" connected to a "tubular housing" at the top of the broom head. An annotated image on page 8 of the complaint depicts these components. | ¶26 | col. 4:16-18 |
| a rigid main cleaner including the tubular housing and a plurality of frames connected to a bottom of the tubular housing | The product includes a "rigid main cleaner" composed of the housing and multiple structural "frames" extending from it. An annotated image on page 9 of the complaint depicts these features. | ¶27 | col. 4:21-26 |
| the auxiliary cleaner coupled to a coupler extending from the bottom of the frames | The product's flexible blade ("auxiliary cleaner") is alleged to be coupled to a "coupler" that extends from the bottom of the rigid frame. An annotated photograph of a purchased product on page 10 highlights these parts. | ¶29 | col. 5:8-13 |
| wherein the coupler is inserted into an inside of the auxiliary cleaner such that the auxiliary cleaner surrounds the coupler | The complaint alleges the product is manufactured such that the flexible auxiliary cleaner surrounds the coupler extending from the rigid frame. | ¶29 | col. 6:35-40 |
| a plate-shaped scraper connected to a bottom of the main cleaner | The flexible blade of the product is identified as the claimed "plate-shaped scraper." An annotated image on page 12 of the complaint shows this component. | ¶30 | col. 5:56-62 |
| a plurality of main protrusions arranged along a longitudinal direction of the scraper and protruding from both lower surfaces of the scraper | The scraper allegedly includes multiple "main protrusions" running along its length. A close-up image on page 13 of the complaint identifies these features. | ¶31 | col. 6:1-4 |
| auxiliary protrusions protruding in the form of a wall in a longitudinal direction of the scraper from at least one side of a top and a bottom of the main protrusions | The scraper allegedly includes "auxiliary protrusions" that form a wall-like structure alongside the main protrusions. An annotated image on page 14 of the complaint points to these features. | ¶32 | col. 6:20-24 |
Identified Points of Contention
- Structural Questions: A central technical question will be whether the accused product's method of joining its rigid frame and flexible blade meets the claim limitation "wherein the coupler is inserted into an inside of the auxiliary cleaner such that the auxiliary cleaner surrounds the coupler." The litigation may require detailed evidence, such as product cross-sections or manufacturing specifications, to determine if the accused structure corresponds to the claimed overmolding configuration.
- Scope Questions: The interpretation of "auxiliary protrusions protruding in the form of a wall" may be a key point of dispute. The court will need to determine if the raised ridges on the accused product, as shown in the complaint's photograph (Compl. p. 14), are sufficient to constitute a "wall" as that term is used in the patent, which describes the feature as serving to "collect dust and dirt" and "prevent the dust and dirt from escape" ('348 Patent, col. 6:25-31).
V. Key Claim Terms for Construction
The Term: "coupler"
Context and Importance
This term is central to the claimed invention's structural integrity and method of manufacture. The patent describes the "coupler" as the specific component extending from the rigid main cleaner that becomes embedded within the auxiliary cleaner during a second molding step ('348 Patent, col. 5:11-19). The construction of this term will be critical for determining whether the connection mechanism in the accused product infringes.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claims state the coupler "extend[s] from the bottom of the frames," which could potentially encompass any structural element that serves to join the frame to the blade (’348 Patent, col. 8:12-13).
- Evidence for a Narrower Interpretation: The specification describes the coupler as a specific plate-like structure extending from the "second reinforcing frame 232" and including features like "coupling grooves 270" and "coupling protrusions 280" to enhance the bond with the overmolded auxiliary cleaner (’348 Patent, col. 5:37-52). This detailed description of a specific embodiment may be used to argue for a narrower definition.
The Term: "auxiliary protrusions protruding in the form of a wall"
Context and Importance
Practitioners may focus on this term because it defines a specific functional feature of the cleaning blade. The complaint alleges that ridges on the accused product meet this limitation (Compl. ¶32). The infringement analysis will depend on whether "in the form of a wall" requires a continuous, solid barrier or can read on a series of distinct ridges.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language requires the protrusions to be "in the form of a wall," which could be argued to describe the general shape or arrangement rather than requiring a solid, uninterrupted structure (’348 Patent, col. 8:22).
- Evidence for a Narrower Interpretation: The specification states that the "auxiliary protrusions 330 may act to prevent the dust and dirt from escape the scraper 310 behind the scraper 310" ('348 Patent, col. 6:28-31). This functional language implies a containing or confining structure, which might support an argument that disconnected ridges do not constitute a "wall."
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced infringement under § 271(b) and contributory infringement under § 271(c) (Compl. ¶¶36, 37). The contributory infringement claim is based on the allegation that the accused brooms are material components of the claimed apparatus, are especially made or adapted for an infringing use, and have no substantial non-infringing uses (Compl. ¶37). The complaint does not plead specific facts supporting inducement, such as references to instructional materials.
Willful Infringement
Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint makes a specific factual allegation that "Defendant was aware of the '348 Patent since at least June 11, 2024, when Amazon.com notified Defendant that the Helio Airbroom™ broom was believed to infringe at least one claim of the '348 Patent" (Compl. ¶38). It further alleges that Defendant continues to infringe without a good faith belief of invalidity or non-infringement (Compl. ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural correspondence: Does the physical interface between the Helio Airbroom's rigid frame and flexible blade meet the specific claim requirement of a "coupler" that is "inserted into an inside of the auxiliary cleaner such that the auxiliary cleaner surrounds" it, or is there a fundamental difference in the product's construction compared to the patented design?
- A second key issue will be one of definitional scope: Can the term "protruding in the form of a wall," described in the patent as preventing the escape of debris, be construed to cover the series of ridges on the accused product's blade, or does the claim require a more continuous, confining structure?
- Finally, a critical factual question for willfulness and damages will be the impact of pre-suit notice: Given the specific allegation of notice from Amazon.com, the court will likely examine what investigative steps, if any, the Defendant took in response, which will be central to determining whether any continued infringement was objectively reckless.