DCT
1:25-cv-06235
Jiujiang Xiangmojin Trading Co Ltd v. Interlink Products Intl Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Jiujiang Xiangmojin Trading Co., Ltd., et al. (China/New York)
- Defendant: Interlink Products International, Inc. (New Jersey) and Eli Zhadanov (New York)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 1:25-cv-06235, E.D.N.Y., 11/28/2025
- Venue Allegations: Plaintiffs allege venue is proper because Defendants previously moved to transfer the case to the Eastern District of New York and thereby waived any objections to venue.
- Core Dispute: Plaintiffs, a group of showerhead sellers, seek a declaratory judgment that their products do not infringe U.S. Patent No. 11,992,850 and that the patent is invalid.
- Technical Context: The dispute centers on the internal fluid-directing mechanisms of multi-function handheld showerheads, a mature consumer product category.
- Key Procedural History: This action was initiated in response to infringement allegations made by the Defendants through Amazon’s Neutral Patent Evaluation (APEX) Program, which can lead to the removal of accused product listings from Amazon's marketplace.
Case Timeline
| Date | Event |
|---|---|
| 2020-12-10 | ’850 Patent Priority Date |
| 2024-05-28 | ’850 Patent Issue Date |
| 2024-11-21 | Defendants initiate Amazon APEX complaint |
| 2025-11-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,992,850: "Showerhead Having Selector for Directing Water Flow in Independent Directions" (Issued May 28, 2024)
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional showerheads designed for personal showering often provide insufficient water pressure or an unsuitable spray pattern for cleaning tasks like rinsing tiled walls or tubs (’850 Patent, col. 1:5-20).
- The Patented Solution: The invention is a handheld showerhead with multiple, functionally distinct sets of nozzles. In addition to standard nozzles on the main faceplate for showering, it includes separate nozzles on another side of the head designed for cleaning, capable of producing a high-pressure jet stream or a wide, fan-shaped spray (’850 Patent, col. 3:25-34, col. 5:39-49). A key component is an internal "flow director" mechanism that a user can manipulate to selectively channel water from a single handle inlet to one of several "plenums," with each plenum feeding a different nozzle set (’850 Patent, Abstract; col. 4:33-40).
- Technical Importance: The design aims to integrate distinct showering and high-pressure cleaning functionalities into a single, user-selectable device, obviating the need for separate cleaning tools (’850 Patent, col. 3:5-9).
Key Claims at a Glance
The complaint asserts non-infringement of independent claims 1, 9, and 14 (Compl. ¶24).
Independent Claim 1:
- A showerhead comprising: a head portion and a handle with a first channel.
- A faceplate with a plurality of first nozzles.
- A second nozzle separate from the faceplate.
- A third nozzle separate from the faceplate and adjacent to the second nozzle.
- A first, second, and third plenum within the head portion, fluidly coupled to the first, second, and third nozzles, respectively.
- A flow director with a second channel, moveable between three positions to selectively couple the first channel (from the handle) to either the first, second, or third plenum.
Independent Claim 9:
- A showerhead with similar head, handle, faceplate, and first/second/third nozzle elements as claim 1.
- A first, second, and third plenum coupled to the respective nozzle sets.
- A flow director moveable between three positions to selectively direct water to one of the plenums.
- Requires the second and third nozzles to direct water in a second direction through a second plane, which is transverse to the first plane of the first nozzles.
III. The Accused Instrumentality
Product Identification
The complaint identifies a range of showerhead products sold by the Plaintiffs on Amazon.com, identified by their Amazon Standard Identification Numbers (ASINs) (Compl. ¶15, p. 4 table). The technical arguments focus on a representative device referred to as "Plaintiffs' Product 1" (Compl. ¶30).
Functionality and Market Context
- The complaint describes "Plaintiffs' Product 1" as a multi-function showerhead that uses a "rotatable disc" set within the head portion to switch between different water spray functions (Compl. ¶¶30, 32). The complaint provides an image showing the disassembled product, including the head portion, a "rotatable disc 22," and a "cover plate 21" (Compl. p. 8).
- The complaint alleges that the accused product's structure is "entirely different" from the patented invention, specifically asserting that it does not contain any "plenum" or a "flow director" as described in the patent (Compl. ¶¶30-33). The complaint alleges the Plaintiffs are popular sellers of these showerheads on Amazon.com (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' arguments for why their product features do not meet the patent's claim limitations.
’850 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Contrasted Product Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first plenum disposed within the head portion and fluidly coupled to the first nozzles | Plaintiffs' product "has no plenum, cannot have a plenum, and has no need for a plenum." | ¶30 | col. 8:3-5 |
| a second plenum disposed within the head portion and fluidly coupled to the second nozzle | The product's internal structure is alleged to lack the claimed plenum. The complaint describes a system of cavities and grooves covered by a rotatable disc. | ¶¶30, 31 | col. 8:6-8 |
| a third plenum disposed within the head portion and fluidly coupled to the third nozzle | The product's internal structure is alleged to lack the claimed plenum. | ¶¶30, 31 | col. 8:9-11 |
| a flow director having a second channel fluidly coupled to the first channel and moveable between a first position... a second position... and a third position to selectively direct a flow of water | The product is alleged to use a "rotatable disc" to switch water paths, which is described as structurally and functionally distinct from the claimed "flow director." | ¶31 | col. 8:12-23 |
- Identified Points of Contention:
- Structural Questions: The core of the dispute appears to be a structural mismatch. The complaint alleges the accused product uses a rotating disc to cover and uncover different water channels, as shown in an annotated photograph (Compl. p. 8), while the patent claims a system of three distinct plenums fed by a pivoting flow director. A key question for the court will be whether the internal cavities and channels of the accused product can be characterized as the claimed "plenums."
- Functional Questions: The complaint argues the accused "rotatable disc" is fundamentally different from the claimed "flow director," which is described in the patent as having a "ball-and-socket coupling" that allows it to pivot ('850 Patent, col. 4:59-62). The complaint also presents diagrams to argue that the accused product's nozzles direct water in different directions than what is required by the claims, further suggesting a functional mismatch (Compl. p. 9).
V. Key Claim Terms for Construction
The Term: "plenum"
Context and Importance: This term appears in all asserted independent claims (1, 9, and 14) and is central to the non-infringement argument. The Plaintiffs' core assertion is that their product "has no plenum" (Compl. ¶30). The definition of this term will determine whether the internal water-routing cavities of the accused product fall within the scope of the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves define a plenum by its function: a structure "disposed within the head portion and fluidly coupled to" a set of nozzles (’850 Patent, col. 8:3-11). A party could argue this requires only a chamber that serves this purpose, regardless of its specific shape or form.
- Evidence for a Narrower Interpretation: The specification consistently refers to three distinct and separate plenums ("first plenum 212a," "second plenum 212b," and "third plenum 212c") as part of a "flow distribution chamber 500" (’850 Patent, col. 4:56-58, col. 5:54-57; Fig. 2C). The use of separate reference numbers for each plenum may suggest they must be structurally distinct chambers, not merely different outlets of a single channel selected by a rotating disc.
The Term: "flow director"
Context and Importance: Plaintiffs distinguish their product's "rotatable disc" from the claimed "flow director" (Compl. ¶31). The construction of this term is critical to determining if the mechanism that switches between spray modes in the accused product is equivalent to the one claimed in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language describes the flow director's function as being "moveable between a first position... a second position... and a third position to selectively direct a flow of water" (’850 Patent, col. 8:15-23). An argument could be made that any mechanism performing this selective direction function, including a rotating disc, meets the claim limitation.
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the flow director (208) is a component that "pivot[s] about an axis" using a "ball-and-socket coupling" (250) to connect a channel from the handle to one of three separate plenum inlets (’850 Patent, col. 4:33-40, 59-62; Figs. 2B, 5A). This detailed description of a pivoting, rather than rotating, mechanism could be used to argue for a narrower scope that excludes the accused product's rotating disc.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to hinge on fundamental questions of claim scope and technical operation. The central issues for the court will likely be:
- Structural Interpretation: Is the accused product's architecture, which allegedly uses a rotating disc to select water paths from internal cavities, structurally equivalent to the patent's claimed system of three discrete "plenums" served by a pivoting "flow director"? This question will require a detailed comparison of the physical components and their interaction.
- Definitional Scope: Can the term "plenum," as used in the patent, be construed broadly enough to read on the internal water channels of the accused product, or does the patent's specification limit the term to the specific, separate chamber structures shown in the embodiments? The outcome of claim construction for this term may be dispositive.