Wang v. Manna Pro Products LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Daoli Wang (China)
  • Defendant: Manna Pro Products, LLC. (Missouri)
  • Plaintiff’s Counsel: Lance Liu, Esq.
• Case Identification: 7:24-cv-03592, S.D.N.Y., 05/09/2024
• Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendant allegedly disrupted Plaintiff’s e-commerce sales to consumers in the district by filing an Amazon complaint based on the patent-in-suit.
• Core Dispute: Plaintiff seeks a declaratory judgment that its egg incubator product does not infringe Defendant's patent and that certain patent claims are invalid, while also bringing claims for tortious interference and illegal monopolization based on Defendant's enforcement actions on the Amazon platform.
• Technical Context: The lawsuit concerns automated egg incubators for small-scale or residential use, a market where precise and automated control of temperature and humidity is critical for successful hatching.
• Key Procedural History: The complaint states this action was precipitated by Defendant filing a complaint with Amazon (No. 15137256341) alleging that Plaintiff's product infringes the patent-in-suit. Plaintiff also introduces a 2017 YouTube video as prior art that allegedly anticipates and invalidates certain claims of the patent.

Case Timeline

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

U.S. Patent No. 10,863,725, Poultry and Game Bird Egg Incubator, issued December 15, 2020

The Invention Explained

• Problem Addressed: The patent’s background section describes challenges with conventional low-cost incubators, such as imprecise humidity levels that result from manually refilling water trays, which requires opening the incubator and disrupting the internal climate. It also notes that basic incubators often lack automated egg-turning mechanisms. ('725 Patent, col. 2:20-42).
• The Patented Solution: The invention is a compact egg incubator designed to improve environmental control. It features a base with multiple, distinct water troughs that can be filled independently via external water ports, allowing for staged humidity adjustments without opening the main chamber. The design also includes a low-profile, motorized egg turner and a control panel to manage temperature and humidity. ('725 Patent, Abstract; col. 3:12-21).
• Technical Importance: The described technology aims to provide a more reliable and automated solution for small-scale bird hatching, potentially improving hatch rates by maintaining a more stable and precisely controlled incubation environment than was available in prior low-cost models. ('725 Patent, col. 2:7-10).

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement and invalidity concerning independent claims 1, 10, and 20.
• Independent Claim 1 recites an egg incubator comprising:
  • A base assembly with a base tray and a first water trough
  • A window removably coupled to the base assembly
  • A lid assembly enclosing a main incubation chamber, which includes a heating element, a circulation fan, a control panel, and a humidity sensor
  • The control panel further includes an "indicator configured to receive an alert signal and generate a visual alert" when humidity is outside a predetermined range
• Independent Claim 10 recites a base for an egg incubator comprising:
  • A housing defining a lower boundary of the incubation chamber
  • A "first water trough disposed on the interior of the housing... approximately at a geometric center"
  • A "second water trough disposed on the interior of the housing... and... around the first water trough"
• The complaint notes that dependent claims 2-9 and 11-19 incorporate all limitations of their respective independent claims. (Compl. ¶10).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the product as "Plaintiff's Incubator," an egg hatching incubator sold by Plaintiff on the Amazon e-commerce platform. (Compl. ¶1).

Functionality and Market Context

• The complaint describes Plaintiff's Incubator as being "substantially different" from the device claimed in the '725 Patent. (Compl. ¶13). Specific allegations of non-infringement focus on the product lacking certain features, including a specific type of humidity alert indicator, a centrally located water trough, and particular air deflector components. (Compl. ¶¶14, 16, 19). The complaint provides an exploded-view diagram of the Plaintiff's Incubator to contrast its construction with the patented embodiment. (Compl. ¶12). This visual, a side-by-side comparison of the patented embodiment and the Plaintiff's Incubator, highlights the alleged structural differences between the two products. (Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following tables summarize the Plaintiff's allegations as to why its product does not meet the limitations of the asserted claims.

'725 Patent Infringement Allegations

'725 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: A primary factual dispute concerns whether the Plaintiff's Incubator contains the specific components recited in the claims. For Claim 1, the question is whether the accused device's control panel performs the function of receiving an "alert signal" and generating a "visual alert" for out-of-range humidity. For Claim 10, the dispute centers on the physical structure of the water troughs. The complaint includes a three-panel image comparing the trough design of the patent, an alleged prior art reference, and the Plaintiff's Incubator, suggesting the Plaintiff's design is structurally different from what is claimed. (Compl. ¶17).
  • Scope Questions: The case raises questions about the scope of key claim terms. The meaning of "indicator configured to... generate a visual alert" will be critical. The court may need to decide if this requires a specific, event-triggered alarm (e.g., a flashing light) or if a continuously updated numerical display could suffice. Similarly, the term "approximately at a geometric center" will require construction to determine the allowable deviation from a perfect central position.

V. Key Claim Terms for Construction

• The Term: "indicator configured to receive an alert signal and generate a visual alert" (Claim 1)

  • Context and Importance: This term is central to the non-infringement argument for Claim 1, as Plaintiff alleges its incubator "does not have any indicator to receive an alert" or "generate any visual alert." (Compl. ¶14). The construction of this term will determine whether the accused product's display functionality falls within the claim's scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses a "control panel 132" that may "initiate, for example, audible or visual alerts to a user." ('725 Patent, col. 8:49-51). This general language could be argued to encompass various forms of visual notification.
    • Evidence for a Narrower Interpretation: The claim language recites a sequence: the indicator must "receive an alert signal" and then "generate a visual alert." This may suggest a specific, event-triggered function distinct from a simple, continuous digital readout. The claim requires the alert to indicate the humidity is "outside a predetermined range," which supports an interpretation of a conditional, triggered alarm rather than a constant display. ('725 Patent, col. 12:61-65).

• The Term: "disposed approximately at a geometric center" (Claim 10)

  • Context and Importance: This spatial limitation is a key element for both Plaintiff's non-infringement defense and its invalidity argument against Claim 10. Practitioners may focus on this term because its definition will determine whether both the accused product and the alleged prior art read on the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "approximately" inherently allows for some deviation from a precise location, and a party could argue it should be interpreted functionally rather than with geometric precision.
    • Evidence for a Narrower Interpretation: The specification explicitly links this term to a specific embodiment, stating that "water trough 602... is disposed approximately at the geomteric center of interior 612." ('725 Patent, col. 7:8-10). The accompanying FIG. 6A depicts a distinct, circular trough located centrally within the base, which could be used to argue for a narrower construction tied to this depicted structure.

VI. Other Allegations

The complaint includes counts beyond the patent dispute, alleging business torts and antitrust violations.

• Tortious Interference with Business Relationship: Plaintiff alleges that Defendant knew or should have known that the '725 Patent was not infringed by Plaintiff's Incubator but proceeded to file a "fraudulent" complaint with Amazon to stop Plaintiff's sales. (Compl. ¶¶29-30). This conduct is alleged to constitute wrongful and malicious interference with Plaintiff's business relationship with Amazon. (Compl. ¶32).
• Illegal Monopolization (Walker Process Claim): Plaintiff alleges that Defendant's enforcement of the '725 Patent through the Amazon complaint constitutes patent misuse intended to gain an illegal monopoly in the market for egg hatching incubators. (Compl. ¶¶34, 36). This allegation invokes the doctrine from Walker Process Eqpt., Inc. v. Food Machinery Corp., which allows for antitrust liability based on the bad-faith enforcement of a patent known to be invalid or not infringed.

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

The resolution of this case will likely depend on the court’s findings on three central issues:

1. A core issue will be one of claim construction: Can the phrase "indicator configured to receive an alert signal and generate a visual alert" be interpreted to read on a device that may display humidity but allegedly lacks a specific, triggered alarm for out-of-range conditions?
2. A second issue will be a factual and technical comparison: Does the physical structure of the Plaintiff's Incubator, particularly its water trough system, fall within the scope of the patent's claims requiring a "first water trough... approximately at a geometric center" and a "second water trough... disposed around the first"?
3. The case presents a significant validity question: Does the "YouTube Publication" cited by the Plaintiff constitute prior art under 35 U.S.C. §102 that discloses every element of Claim 10, thereby rendering the claim invalid as anticipated?