DCT

4:25-cv-01412

Ruian Fengqiu Bathroom Sanitary Ware Co Ltd v. Ryuwanku

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01412, E.D. Tex., 12/18/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants are not residents of the United States and may therefore be sued in any judicial district. The complaint also alleges Defendants target business activities toward consumers in Texas through interactive stores on Amazon.com.
  • Core Dispute: Plaintiff, as the exclusive licensee, alleges that Defendants’ bathroom faucets sold on Amazon.com infringe a utility patent related to a method for manufacturing a faucet shell from non-cast components.
  • Technical Context: The patent relates to manufacturing faucet bodies from cut tubing and punched sheet metal, a method intended to reduce costs and complexity compared to traditional metal casting techniques common in the plumbing fixture industry.
  • Key Procedural History: The complaint states that Plaintiff RFBS is the exclusive licensee of the patent-in-suit via an agreement with the assignee, Wenzhou Yisheng Sanitary Ware Co., Ltd., that became effective on October 21, 2025.

Case Timeline

Date Event
2021-08-31 '865 Patent Priority Date
2024-07-02 '865 Patent Issue Date
2025-10-21 Plaintiff's Exclusive License Agreement Active
2025-12-18 Complaint Filing Date

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

U.S. Patent No. 12,024,865 - "FAUCET SHELL AND FAUCET MADE OF SUCH SHELL"

  • Patent Identification: U.S. Patent No. 12,024,865, "FAUCET SHELL AND FAUCET MADE OF SUCH SHELL," issued July 2, 2024.

The Invention Explained

  • Problem Addressed: The patent's background section describes conventional faucet shells as being produced from solid castings, a process that consumes large quantities of material, requires complicated and costly production steps, and involves extensive follow-up processing such as polishing and electroplating ('865 Patent, col. 1:19-30).
  • The Patented Solution: The invention discloses a faucet shell constructed from simpler, separately manufactured components that are welded together. The main body is a "cylinder body" formed by cutting a standard "tubular profile" (e.g., a stainless steel pipe), and the top is a "cover" created by "punching from sheet plate." A separate "valve element mounting cylinder" is then welded to this cover to house the faucet's internal valve mechanism ('865 Patent, col. 1:40-48; Fig. 3). This modular approach is designed to replace the single-piece casting process.
  • Technical Importance: This manufacturing method was intended to reduce material waste, simplify production, and lower costs compared to the casting processes traditionally used for faucet bodies ('865 Patent, col. 2:1-4).

Key Claims at a Glance

  • The complaint asserts infringement of the '865 Patent generally without specifying claims, but practitioners would focus on the single independent claim.
  • Independent Claim 1: The essential elements include:
    • A cylinder body formed by cutting a tubular profile.
    • A cover formed by punching from sheet plate, which is welded to the cylinder body.
    • A "welding cylinder" formed from the material of a through-hole in the cover.
    • A "valve element mounting cylinder" that is welded to the welding cylinder and contains internal components like inlet pipes and a water outlet.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • "Bathroom Faucets" sold by Defendants Ryuwanku US, FRANSITON, and VOTON through their storefronts on Amazon.com (Compl. ¶¶1, 15-16). Specific Amazon Standard Identification Numbers (ASINs) are identified: B09654KMWZ, B09YD9JWND, and B08HV9PZGK (Compl. ¶16).

Functionality and Market Context

  • The complaint does not provide a technical description of the accused products' construction or internal functionality. The allegations are based on the products being sold as "Bathroom Faucets" that are available for purchase and shipping to consumers in the United States, including Texas (Compl. ¶¶3, 16-17). The complaint characterizes the Defendants as an "interrelated group of foreign partnerships" operating on Amazon (Compl. ¶7). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an "Exemplary Claim Chart" in its Exhibit 4, but this exhibit was not included in the provided court filing (Compl. ¶22). In its absence, the narrative infringement theory is presented.

The complaint alleges that Defendants' products directly infringe the '865 Patent (Compl. ¶22). However, the pleading advances this allegation using language typically associated with design patent infringement, stating that "the design of the Infringing Products appear substantially similar to the claimed design of the '865 Patent to the eye of an ordinary observer" (Compl. ¶23). The '865 Patent is a utility patent, not a design patent, and its claims cover a specific structure and method of manufacture, not an ornamental design. The complaint does not contain factual allegations detailing how the accused faucets are constructed or how that construction meets the specific structural limitations of Claim 1 of the '865 Patent.

  • Identified Points of Contention:
    • Pleading Standard Question: A primary legal question is whether the complaint's allegations, which invoke the "eye of an ordinary observer" test for design patents, are sufficient to state a plausible claim for infringement of the asserted utility patent, which requires element-by-element satisfaction of its structural claims.
    • Technical Question: The central factual dispute will concern the manufacturing process of the accused products. Does the evidence show the accused faucets are constructed from a "cylinder body formed by cutting tubular profile" and a "cover formed by punching from sheet plate," as required by Claim 1, or are they manufactured using a different method, such as conventional casting, that would fall outside the claim scope?

V. Key Claim Terms for Construction

  • The Term: "cylinder body formed by cutting tubular profile"

    • Context and Importance: This term defines the core component of the patented faucet shell and distinguishes it from bodies made by traditional casting. The infringement analysis will hinge on whether the accused products' main bodies are made from pre-existing tubing.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the term is not limited to a single material, giving examples of "tubular profiles such as stainless-steel pipe and aluminum pipe" ('865 Patent, col. 2:49-50).
      • Evidence for a Narrower Interpretation: The figures consistently depict a simple, straight, uniform cylinder (e.g., '865 Patent, Fig. 1, element 10). A defendant may argue the term is limited to such simple geometries and does not cover faucet bodies with more complex or tapered shapes.

  • The Term: "cover formed by punching from sheet plate"

    • Context and Importance: This limitation defines the manufacturing method for the top component of the faucet shell. Proving infringement requires showing the accused product's cover is made via this specific process. Practitioners may focus on this term because "punching" is a specific metalworking operation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification lists multiple materials, including "stainless steel plate, aluminum plate or other plates," suggesting breadth in material type ('865 Patent, col. 2:51-52).
      • Evidence for a Narrower Interpretation: A party could argue that "punching" refers to a specific metal-forming process distinct from other methods like stamping, casting, or machining, potentially limiting the claim's scope to products made with that exact technique.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead facts to support a claim for either induced or contributory infringement.
  • Willful Infringement: The complaint alleges that Defendants' infringement is willful "at least as of the filing of this amended complaint, if not earlier" (Compl. ¶19). This allegation appears to be based on post-suit knowledge derived from the complaint itself, as no facts suggesting pre-suit knowledge of the patent are alleged.

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

  • A threshold issue will be one of legal sufficiency: can the complaint's reliance on infringement language and standards applicable to design patents ("ornamental design," "eye of an ordinary observer") state a valid claim for infringement of the asserted utility patent, which requires meeting specific structural and manufacturing-process limitations?
  • The central evidentiary question will be one of technical construction: does discovery show that the accused faucets are assembled from components made via the claimed methods—a body cut from tubing and a cover punched from sheet metal—or are they produced through conventional casting, which would likely place them outside the patent's claimed scope?