DCT
1:24-cv-00894
Shenzhen Wan Rong Technology Co Ltd v. ADR Products LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Liantronics Co Ltd and Shenzhen Long Chi Auto Services Co. Ltd. (People's Republic of China)
- Defendant: ADR Products LLC (Wyoming)
- Plaintiff’s Counsel: Kovach Law Firm, LLC; Ni Wang & Massand PLLC
- Case Identification: 1:24-cv-00894, N.D. Ohio, 05/20/2024
- Venue Allegations: Venue is asserted as proper in the Northern District of Ohio on the basis that Defendant ADR Products, LLC maintains its principal place of business within the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their indoor dryer vent products do not infringe Defendant's patent related to a lint catching system.
- Technical Context: The technology concerns indoor filtration systems designed to capture lint from clothes dryer exhaust, a market segment influenced by the growth of e-commerce platforms like Amazon.
- Key Procedural History: The complaint states this action was precipitated by an infringement report filed by Defendant on Amazon against Plaintiffs' products in or around April 2024. This report was made through the Amazon Patent Evaluation Express (APEX) program, creating a threat of the products being delisted from the marketplace.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-28 | Earliest Priority Date for U.S. Patent No. 11,479,904 |
| 2022-10-25 | U.S. Patent No. 11,479,904 Issued |
| 2024-04-01 | Approximate Date of Defendant's Infringement Report on Amazon |
| 2024-05-20 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,479,904 - Lint Catching System and Exhaust Assembly, issued October 25, 2022
The Invention Explained
- Problem Addressed: The patent's background section describes the shortcomings of prior indoor dryer venting systems. Conventional methods can increase indoor humidity, spread allergens, and rely on filters that either clog inefficiently or allow lint to pass through. Some systems use water traps that can become moldy, while others have poor airflow characteristics that reduce filtration effectiveness. (’904 Patent, col. 1:37-col. 2:57).
- The Patented Solution: The invention proposes a lint catching system with a specially shaped filter housing that generates a circulating airflow pattern. This is intended to improve the deposition of lint onto a filter material. A central feature is a "cover element" over an exhaust port that is designed to act as a pressure-sensitive indicator. When the filter becomes sufficiently clogged with lint, the resulting back-pressure forces the cover element to open, providing a clear visual signal to the user that the filter requires maintenance or replacement. (’904 Patent, Abstract; col. 7:1-col. 8:24).
- Technical Importance: The design seeks to enhance the efficiency and reliability of indoor lint filtration by combining improved airflow dynamics with a built-in mechanical indicator for filter obstruction. (’904 Patent, col. 11:5-21).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 12 as not being infringed (Compl. ¶31).
- Independent Claim 1 recites a lint catching system comprising:
- A filter housing with an interior chamber defined by front, back, and curved end panel walls
- A filter housing inlet and outlet
- An exhaust aperture element in the curved end panel wall
- A cover element rotatably connected to the curved end panel wall, configured to cover the aperture at a first air pressure and uncover it at a second, higher pressure
- Independent Claim 12 recites a similar lint catching system comprising:
- A filter housing with an inlet, outlet, and an exhaust aperture element
- A cover element configured to operate between a closed condition (impeding airflow) and an open condition
- The open condition is "generated by an obstructed condition of a filtration material," allowing exhaust air to flow through the aperture
- The complaint requests a declaration of non-infringement for "any presumably valid claim of the '904 Patent," thereby reserving the right to contest dependent claims as well (Compl. ¶29).
III. The Accused Instrumentality
Product Identification
- The complaint identifies indoor dryer vents sold under the brand "FUNMAS," specifically referencing Amazon Standard Identification Number (ASIN) B095KG5FPT (Compl. ¶16).
Functionality and Market Context
- The Accused Products are described as having a "three-in-one filtration design" that includes a stainless steel screen filter, a polyester filter, and a "water drawer system" (Compl. ¶17). An exploded-view diagram in the complaint illustrates these components as distinct parts of the filtration process. (Compl. p. 5, "3-in-1 Indoor Dryer Vent" figure). The complaint alleges this design captures lint, filters air, and can increase room humidity (Compl. ¶17).
- Plaintiffs state that the Amazon Marketplace is their "primary sales channel into the United States," making the threat of delisting due to the infringement report a significant commercial concern (Compl. ¶19).
IV. Analysis of Infringement Allegations
As this is a declaratory judgment action, the following summarizes the Plaintiffs' stated reasons for non-infringement.
’904 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an exhaust aperture element disposed in said curved end panel wall to communicate with said interior chamber | The complaint alleges the Accused Products do not comprise an "exhaust aperture element" and do not have the corresponding structure described in the patent specification. | ¶31 | col. 8:26-36 |
| a cover element rotatably connected to said curved end panel wall to overlay an external surface..., said cover element configured to cover said exhaust aperture element when exhaust air...comprises a first amount of pressure, and uncover said exhaust aperture element when...exhaust air...comprises a second amount of pressure which urges said cover element away... | The complaint alleges the Accused Products do not comprise a "cover element" and do not have the corresponding structure described in the patent specification. The complaint's visual evidence suggests a multi-stage filtration system without a component that functions as a pressure-activated, rotatable cover. (Compl. p. 5). | ¶31 | col. 8:26-36 |
- Identified Points of Contention:
- Legal Question: The complaint asserts that the terms "an exhaust aperture element" and "a cover element" are subject to means-plus-function treatment under 35 U.S.C. § 112(f) (Compl. ¶31). A central dispute will be whether these terms, as used in the claims, are purely functional (triggering § 112(f)) or connote sufficient structure to be construed under their plain and ordinary meaning.
- Scope Questions: Assuming the terms are not means-plus-function, a question remains whether any part of the Accused Product's "3-in-1" system, which includes a water drawer and multiple filters, can be considered "an exhaust aperture element" and a "cover element" as those terms would be understood by a person of ordinary skill in the art.
- Technical Questions: What evidence exists that any component of the FUNMAS product performs the claimed function of the cover element—namely, automatically moving from a closed to an open position in response to a specific increase in air pressure caused by filter obstruction? The complaint's theory of non-infringement suggests no such function is performed.
V. Key Claim Terms for Construction
- The Term: "cover element"
- Context and Importance: This term is the lynchpin of the non-infringement argument advanced in the complaint. Its construction will likely determine the outcome of the infringement analysis. Practitioners may focus on this term because the Plaintiffs have explicitly argued it should be treated as a means-plus-function limitation under 35 U.S.C. § 112(f), which would significantly narrow its scope to the specific structures disclosed in the patent and their equivalents (Compl. ¶31).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the claim language itself—"a cover element rotatably connected to said curved end panel wall"—provides sufficient structure to avoid § 112(f) construction. The term "cover" and the phrase "rotatably connected" may be argued to have well-understood structural meanings to one of skill in the art, independent of the specific embodiments.
- Evidence for a Narrower Interpretation: The specification provides a detailed description of the "cover element (57)," including its relationship with pivot elements, a weight element, and magnets, and its function as a visual indicator of filter blockage (’904 Patent, col. 9:46-col. 10:54; Figs. 11A-12E). A party arguing for § 112(f) treatment would point to this detailed description as the required "corresponding structure" for the claimed function, asserting that any accused device lacking this structure or its equivalents cannot infringe.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a judicial declaration of non-infringement both directly and indirectly (Compl. ¶29). However, it does not plead specific facts relating to indirect infringement beyond the foundational argument that no direct infringement occurs.
- Willful Infringement: This section is not applicable as this is a declaratory judgment action filed by the accused infringer, and no allegation of willfulness by the patentee is present in the complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: are the terms "exhaust aperture element" and "cover element" means-plus-function limitations under 35 U.S.C. § 112(f), thereby restricting their scope to the specific embodiments shown in the patent? Or do they carry a broader, plain and ordinary meaning?
- A central evidentiary question will be one of technical and functional comparison: does any part of the accused FUNMAS "3-in-1" dryer vent, with its water drawer and multiple filters, perform the specific function of the patented "cover element"—acting as a pressure-sensitive valve that opens to provide a visual indicator of filter obstruction? The case may turn on whether there is a fundamental mismatch in the structure and technical operation between the accused product and the patented invention.