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: Shaanxi Yan Yu Meng Sheng Trading Co., Ltd. v. Cixi Bosheng Plastic Co., Ltd., 1:25-cv-1139, W.D. Tex., 11/11/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because a substantial part of the events giving rise to the action occurred in the District, specifically Defendant's enforcement activities targeting Plaintiff's product listings on Amazon, which are accessible to consumers in Texas.
• Core Dispute: Plaintiff seeks a declaratory judgment that its mop and bucket products do not infringe Defendant’s patent and that the patent is unenforceable due to inequitable conduct.
• Technical Context: The technology relates to consumer cleaning tools, specifically mop and bucket systems designed to both clean and wring out flat mops efficiently.
• Key Procedural History: The action was precipitated by Defendant's enforcement of its patent through the Amazon Patent Evaluation Express (APEX) program, which created a risk that Plaintiff’s products would be removed from the Amazon platform, thereby establishing a justiciable controversy for a declaratory judgment action. The complaint also includes a significant allegation of inequitable conduct during patent prosecution, asserting that Defendant knowingly and with deceptive intent misrepresented the true inventorship of the patent-in-suit to the USPTO.

Case Timeline

Date	Event
2016-06-04	’900 Patent Priority Date
2024-09-24	’900 Patent Issue Date
2025-07-03	Plaintiff receives notice from Amazon of Defendant's infringement report via APEX
2025-11-11	Complaint Filing Date

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

U.S. Patent No. 12,096,900 - "MOP BUCKET FOR CLEANING AND SQUEEZING A FLAT MOP"

• Patent Identification: U.S. Patent No. 12,096,900, “MOP BUCKET FOR CLEANING AND SQUEEZING A FLAT MOP,” issued September 24, 2024 (the “’900 Patent”).

The Invention Explained

• Problem Addressed: The patent's background section describes prior art methods for squeezing flat mops as suffering from several drawbacks, including complex and costly mechanisms (e.g., foot-pedals, centrifugal spinners) or requiring strenuous, impractical user operations (e.g., manual push-pull squeezing) (’900 Patent, col. 1:26-col. 2:11).
• The Patented Solution: The invention is a mop bucket that integrates both a cleaning section and a squeezing water section into a single unit (’900 Patent, col. 2:15-21). A squeezing device is disposed inside the bucket; when a user inserts the flat mop head, the device "presses against the wiper on the mop head and scrapes the wiper" to either clean it or wring it out (’900 Patent, Abstract). This design aims to provide a convenient, labor-saving, and effective cleaning and squeezing experience in one tool (’900 Patent, col. 2:21-24).
• Technical Importance: The claimed solution consolidates cleaning and squeezing functions for flat mops into a single, mechanically simple device, aiming to improve upon prior art that required separate, complex, or physically demanding systems (’900 Patent, col. 6:41-56).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 (Compl. ¶14).
• Essential elements of independent claim 1 include:
  • A cleaning tool comprising a flat mop, a mop bucket, and a squeezing device.
  • The mop bucket has a cleaning section and a squeezing water section that are "physically independent and separated."
  • The squeezing device comprises a frame and a squeezer, with the squeezer provided in a side of a squeezing port.
  • During cleaning, the flat mop is capable of moving "up and down into the cleaning section ... to squeeze for cleaning the wiper."
  • During squeezing, the flat mop is capable of moving "up and down into squeezing water section ... to squeeze water out of the wiper."
  • During either operation, the 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," such that the wiper will be "fully cleaned or squeezed."
• The complaint notes that dependent claims 2-16 are not infringed because they depend on claim 1 (Compl. ¶37).

III. The Accused Instrumentality

Product Identification

• The "Mop and Bucket" products sold on Amazon.com under ASINs B0DPWDQKLS and B0DPWGYKK3 (Compl. ¶1).

Functionality and Market Context

• The accused product is a cleaning tool consisting of a mop and a bucket with two distinct sections: a cleaning section and a squeezing water section (Compl. ¶16). A single monolithic frame sits atop the bucket, containing two squeezers, one for each section (Compl. ¶17). Figure 1 in the complaint depicts this top-down view of the bucket with its distinct sections and squeezers (Compl. p. 6).
• Functionally, the squeezer for the squeezing section applies pressure only when the mop moves downward (Compl. ¶19). When the mop is lifted upward, the squeezer allegedly "rotates away and widens the port to release pressure," ceasing the squeezing action (Compl. ¶¶20, 35). The complaint alleges the product is sold through Plaintiff's Amazon storefront (Compl. ¶1).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following chart summarizes Plaintiff's primary non-infringement arguments for Claim 1 of the ’900 Patent.

• ’900 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
...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 does not squeeze the mop during upward movement. The squeezer applies pressure only when the mop moves downward; it rotates away to release pressure during upward movement.	¶35	col. 22:15-20
...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...	The length of the mop head in the Accused Product does not match the specified height. There is an alleged gap of approximately 1-2 cm, which causes the mop head to extend beyond the squeezer when at the bottom of the bucket.	¶¶22, 35	col. 22:21-27
...so that when the flat mop is inserted into the squeezing port to squeeze for cleaning the wiper or squeeze water out of the wiper, the wiper will be fully cleaned or squeezed.	As a result of the height mismatch, the wiper is allegedly not "fully cleaned or squeezed." The complaint states the height difference ensures the mop is not blocked or jammed when pulled up. Figure 3 illustrates the mop head in contact with the bucket bottom (Compl. p. 9).	¶¶22, 35, 36	col. 22:25-29

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern the interpretation of "moving up and down... to squeeze." The question is whether this language requires the squeezing function to occur during both upward and downward strokes, or if it merely describes the general motion within a section where squeezing takes place.
  • Technical Questions: A key factual question relates to the term "matched." The analysis will require determining whether the approximately 1-2 cm gap between the top of the squeezer and the top of the mop head (when at the bottom of the bucket) means the dimensions are not "matched" as required by the claim (Compl. ¶22). The complaint provides a photograph, Figure 3, showing the mop inserted in the bucket to support this contention (Compl. p. 9).

V. Key Claim Terms for Construction

• The Term: "moving up and down... to squeeze water out of the wiper"

  • Context and Importance: This term is critical because Plaintiff's primary non-infringement theory is that its product only squeezes on the downstroke, not during both "up and down" movements (Compl. ¶35). The definition will determine if a one-directional squeeze meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "moving up and down" simply describes the general path of the mop within the squeezing section, and "to squeeze" states the purpose of that section, not that squeezing must occur in both directions of travel.
    • Evidence for a Narrower Interpretation: The patent states, "the mop head 4 moves up and down in its axial direction... so that the wiper on the mop head 4 moves in relative to and against the squeezer... for cleaning or squeezing" (’900 Patent, col. 11:51-58). This language, which Plaintiff cites (Compl. p. 14), could be used to argue that the claimed squeezing action is tied to the reciprocal "up and down" motion.

• 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: Plaintiff alleges its product does not meet this limitation because there is a 1-2 cm height difference, meaning the lengths are not "matched" (Compl. ¶22). The construction of "matched"—whether it means exact correspondence or functional approximation—is therefore central to infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "matched" does not require precise dimensional equality but rather a functional correspondence sufficient to achieve the claim's ultimate goal of making the wiper "fully cleaned or squeezed."
    • Evidence for a Narrower Interpretation: The claim links the "matched" dimension directly to the functional outcome that "the wiper will be fully cleaned or squeezed" (’900 Patent, col. 22:25-29). Plaintiff argues that its intentional height mismatch is designed to prevent jamming, suggesting that a precise match is what the patent contemplates and what its product avoids (Compl. ¶¶22, 35).

VI. Other Allegations

• Inequitable Conduct: The complaint makes a detailed allegation of inequitable conduct, which, if proven, would render the ’900 Patent unenforceable (Compl. ¶¶23-32). Plaintiff alleges that Defendant knew the named inventor was not the true or sole inventor of the claimed subject matter, having learned of the technical solution from a third-party design company before filing the priority application (Compl. ¶¶27-28). The complaint further alleges that Defendant acted with deceptive intent by falsely representing inventorship to the USPTO, a misrepresentation considered material to the patent's issuance (Compl. ¶¶29, 31).

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

This case presents three central questions for the court:

• A core issue will be one of claim scope: does the limitation requiring the mop to move "up and down... to squeeze" necessitate a squeezing action during both upward and downward movement, or does a product that squeezes in only one direction still fall within the claim's ambit?
• A second key question will be one of definitional precision: how much deviation, if any, is permitted by the term "matched" as it relates to the mop head length and the bucket-to-squeezer height? This will require construing the term in light of the patent's specification and the functional goal of fully cleaning the wiper.
• A dispositive threshold question will be one of enforceability: did the patentee commit inequitable conduct by intentionally misrepresenting inventorship to the USPTO, as the plaintiff alleges? A finding of inequitable conduct could resolve the case entirely, regardless of the infringement analysis.