DCT
1:25-cv-01139
Shaanxi Yan Yu Meng Sheng Trading Co Ltd v. Cixi Bosheng Plastic Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shaanxi Yan Yu Meng Sheng Trading Co., Ltd. (People's Republic of China)
- Defendant: Cixi Bosheng Plastic Co., Ltd. (People's Republic of China)
- Plaintiff’s Counsel: Merchant & Gould P.C.
- Case Identification: 1:25-cv-01139, W.D. Tex., 07/21/2025
- Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the action occurred in the district, specifically Defendant's use of Amazon's patent enforcement process to target product listings accessible to consumers in Texas.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Mop and Bucket cleaning tools do not infringe Defendant’s patent related to a mop bucket for cleaning and squeezing a flat mop.
- Technical Context: The technology concerns mechanical cleaning tools, specifically mop and bucket systems that integrate mechanisms for both washing and wringing a flat mop head.
- Key Procedural History: This action was precipitated by a notice Plaintiff received from Amazon.com on July 3, 2025, indicating that Defendant had filed a report through the Amazon Patent Evaluation Express (APEX) program alleging that Plaintiff's products infringe the patent-in-suit. The APEX process creates the risk that Plaintiff's product listings will be removed from Amazon's platform, forming the basis for the declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2016-06-04 | Earliest Priority Date for ’900 Patent |
| 2024-09-24 | ’900 Patent Issue Date |
| 2025-07-03 | Plaintiff receives Amazon APEX notice from Defendant |
| 2025-07-21 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,096,900 B1 - MOP BUCKET FOR CLEANING AND SQUEEZING A FLAT MOP, issued September 24, 2024.
The Invention Explained
- Problem Addressed: The patent describes prior art methods for squeezing flat mops as suffering from several drawbacks. These include the complexity and high cost of foot-operated or centrifugal rotation systems, and the strenuous, inconvenient, and less effective nature of manual push-and-pull squeezing mechanisms (’900 Patent, col. 1:26-2:8).
- The Patented Solution: The invention provides an integrated cleaning tool that combines a cleaning function and a squeezing function within a single mop bucket, aiming for a more convenient and labor-saving user experience (’900 Patent, col. 2:15-24). The system uses a bucket with physically separate cleaning and squeezing water sections, each fitted with a squeezing device. When the user inserts the flat mop head into a section, the squeezing device presses against and scrapes a wiper on the mop head to clean or dry it (’900 Patent, Abstract; col. 9:26-36).
- Technical Importance: The invention seeks to provide a simplified and more ergonomic all-in-one solution for flat mops, addressing the usability gaps left by more complex or physically demanding prior art designs (’900 Patent, col. 2:15-24).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1.
- The essential elements of independent claim 1 include:
- A cleaning tool comprising a flat mop, a mop bucket, and a squeezing device at the top of the bucket.
- The flat mop has a mop rod, a mop head, and a wiper on a back surface of the head.
- The mop bucket has a cleaning section and a squeezing water section that are "physically independent and separated."
- The squeezing device has a frame and a squeezer, with the frame having a "squeezing port" to receive the mop.
- Functionally, the mop head is rotated to align with the rod, and is "capable of moving up and down" in the squeezing section "to squeeze water out of the wiper."
- Functionally, the flat mop moves down until the mop head touches the bucket bottom, where "a length of the mop head is matched with a height from the bottom of the mop bucket touching the mop head to the squeezer," so the wiper is "fully cleaned or squeezed."
- The complaint notes that dependent claims 2-16 are not infringed because they depend on claim 1 (Compl. ¶27).
III. The Accused Instrumentality
Product Identification
- The "Mop and Bucket" cleaning tools sold by Plaintiff on Amazon.com, identified by ASINs B0DPWDQKLS and B0DPWGYKK3 (Compl. ¶1).
Functionality and Market Context
- The accused products consist of a mop bucket with a "cleaning section" and a "squeezing water section" (Compl. ¶16). A single monolithic frame sits atop the bucket, holding two squeezers, one for each section (Compl. ¶17).
- The complaint alleges a specific mode of operation for the squeezers. When the mop moves downward, the squeezer applies pressure to wring out water (Compl. ¶19). However, when the mop is lifted upward, the squeezer allegedly "rotates upward, increasing the width of the squeezing port," which "releases pressure on the mop" (Compl. ¶20). This one-way squeezing action is central to the plaintiff's non-infringement argument.
- Figure 1 in the complaint provides an annotated top view of the accused bucket, identifying the cleaning and squeezing sections and the monolithic frame (Compl. p. 6).
IV. Analysis of Infringement Allegations
The complaint alleges non-infringement. The following table summarizes the Plaintiff's contentions as to why its products do not meet specific limitations of claim 1.
’900 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| during squeezing, the mop head and the mop rod is inserted into the squeezing port, and the flat mop is capable of moving up and down into squeezing water section through the squeezing port to squeeze water out of the wiper by the squeezer; | The accused product's squeezer allegedly applies pressure only when the mop moves downward. On upward movement, the squeezer is alleged to rotate away and release pressure, thus not squeezing on the upstroke. | ¶25, p. 11 | col. 22:15-22 |
| during squeezing or cleaning, the flat mop moves down until the mop head touching a bottom of the mop bucket, a length of the mop head is matched with a height from the bottom of the mop bucket touching the mop head to the squeezer, so that when the flat mop is inserted into the squeezing port ... the wiper will be fully cleaned or squeezed. | The length of the accused product's mop head allegedly does not match the specified height. The complaint states there is a 1-2 cm gap, causing the mop head to extend beyond the squeezer and preventing the mop from being blocked or jammed. | ¶22, ¶25, pp. 12-13 | col. 22:22-28 |
Identified Points of Contention
- Scope Questions:
- The dispute raises the question of whether the claim language "capable of moving up and down... to squeeze" requires that the squeezing action occurs during both the upward and downward motions. The Plaintiff contends its product only squeezes in one direction (Compl. p. 11). Figure 2B in the complaint is presented as evidence that upward movement releases the squeezer (Compl. p. 8).
- Another scope question is whether the term "matched with a height" requires dimensional equality or if it can be interpreted to cover a configuration with a small, functional gap as alleged in the accused product. Figure 3 in the complaint shows the mop head touching the bottom of the bucket, which Plaintiff uses to argue the height does not match (Compl. p. 9, 13).
- Technical Questions:
- What evidence will be required to demonstrate that the accused squeezer "rotates away and widens the port to release pressure" during upward movement, as alleged? (Compl. p. 11).
- What is the functional significance of the alleged 1-2 cm height mismatch, and does it prevent the accused product from achieving the claimed result of the wiper being "fully cleaned or squeezed"? (Compl. ¶22, ¶24).
V. Key Claim Terms for Construction
The Term: "capable of moving up and down into squeezing water section ... to squeeze water out of the wiper"
- Context and Importance: The interpretation of this phrase is central to the dispute. Plaintiff's primary non-infringement argument is that its product only squeezes on the downward stroke, not "up and down." Practitioners may focus on whether "to squeeze" modifies the entire "up and down" movement, implying a bilateral action, or if it simply states the purpose of the squeezing section where a unilateral (downward) squeeze occurs.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes that "the mop head 4 moves up and down in its axial direction" to generate "relative movement... between the mop head 4 and the squeezing device 7 for cleaning or squeezing" (’900 Patent, col. 11:51-58). This language could be argued to describe the general motion required, not that squeezing must occur on both strokes.
- Evidence for a Narrower Interpretation: The claim links the compound "up and down" movement directly to the function "to squeeze." Plaintiff may argue this requires the function to be performed during the entirety of the described action. The repeated action of scraping is also mentioned: "the squeezing device 7 presses against the wiper on the mop head 4 and scrapes the wiper on the mop head 4 repetitively" (’900 Patent, col. 9:33-36), which may suggest a back-and-forth scraping action.
The Term: "a length of the mop head is matched with a height from the bottom of the mop bucket... to the squeezer"
- Context and Importance: This term is the basis for Plaintiff's second non-infringement argument. The case may turn on whether "matched with" requires near-exact dimensional correspondence or allows for some tolerance.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A patentee might argue "matched" means "proportioned" or "corresponding" in a functional sense, rather than being strictly equal. The stated purpose is that "the wiper will be fully cleaned or squeezed" (’900 Patent, col. 22:23-28), and if the accused product achieves this result despite a small gap, it could fall within the claim's scope.
- Evidence for a Narrower Interpretation: Plaintiff argues for a strict, literal meaning, contending its product's 1-2 cm gap proves the dimensions are not "matched" (Compl. ¶22). The claim links the "matched" height directly to the functional outcome ("so that... the wiper will be fully cleaned or squeezed"), suggesting the dimensional relationship is a specific requirement for the invention to work as claimed.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration of non-infringement for indirect infringement (inducement and contribution) in addition to direct infringement (Compl. ¶30). The factual basis for this request rests on the primary allegation that there can be no indirect infringement without an underlying act of direct infringement by a user of the product.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim scope: does the limitation requiring the mop to be "capable of moving up and down... to squeeze" necessitate a bilateral squeezing action on both strokes, as the Plaintiff contends is absent from its product, or does it merely describe the location where a unilateral squeezing action occurs?
- A second dispositive question will be one of dimensional correspondence: can the term "matched with a height," which the patent links to achieving a "fully cleaned or squeezed" wiper, be construed to read on a product that has an alleged 1-2 cm dimensional gap between the mop head and the squeezer when the mop touches the bucket floor?