Goodegg Stuff LLC v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GoodEgg Stuff LLC (Delaware)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A (People's Republic of China, on information and belief)
  • Plaintiff’s Counsel: AVEK IP, LLC
• Case Identification: 6:25-cv-00339, W.D. Tex., 08/05/2025
• Venue Allegations: Venue is alleged to be proper because each defendant directs business to U.S. consumers, including those in Texas, through interactive e-commerce stores that ship to the state and accept payment in U.S. dollars.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of certain poultry product tools infringe a patent for an egg washing brush.
• Technical Context: The technology relates to handheld cleaning devices specifically contoured for cleaning individual eggs, aimed at hobby farmers and individual consumers rather than large-scale commercial operations.
• Key Procedural History: The complaint asserts that the patent-in-suit was assigned to the Plaintiff on the date of its issuance. The complaint also devotes significant attention to justifying the joinder of numerous unidentified defendants as a "swarm of foreign counterfeiters" whose products are the "same in all respects relevant to the patent."

Case Timeline

Date	Event
2023-04-11	Priority Date for ’567 Patent (from Provisional App. 63/495,363)
2023-11-01	Approximate launch of Plaintiff's "GoodEgg Products"
2024-09-17	U.S. Patent No. 12,089,567 Issues
2025-08-05	Complaint Filed

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

• Patent Identification: U.S. Patent No. 12,089,567, Apparatus and Method for Egg Washing Brush, issued September 17, 2024 (’567 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section notes that hobby egg farmers and individual consumers often resort to using brushes designed for other purposes or flat devices that are not "compatible with the contours of an egg" (’567 Patent, col. 1:29-33). This creates a need for a cleaning tool specifically designed for the task.
• The Patented Solution: The invention is a deformable, "half egg-shaped shell" made of a flexible material like silicon, which forms an "egg washing cavity" (’567 Patent, col. 1:56-62). Inside this cavity, a network of "bristle bands" with inwardly-extending "bristle protrusions" is configured to contact and scrub the surface of an egg when it is placed inside and rotated (’567 Patent, Abstract; col. 3:51-55). The design aims to provide an abrasive surface sufficient to clean the egg without damaging the shell.
• Technical Importance: The invention provides a purpose-built apparatus for individual egg cleaning that is contoured to the object being cleaned, in contrast to the general-purpose tools previously available (’567 Patent, col. 1:39-44).

Key Claims at a Glance

• The complaint asserts infringement of at least Claim 1 (’567 Patent, col. 4:47-57; Compl. ¶28).
• The essential elements of independent Claim 1 are:
  • a half egg-shaped shell comprising a flexible material
  • a plurality of bristle bands at least two of which intersect each other, the plurality of bristle bands defining an egg washing cavity
  • a plurality of bristle protrusions extending inward from the bristle bands and configured to contact an egg
• The complaint does not explicitly reserve the right to assert dependent claims, but the infringement count is directed to the patent generally.

III. The Accused Instrumentality

Product Identification

• The accused products are identified as "poultry product tools" and "the Infringing Products," which are sold by Defendants through various online e-commerce stores (’567 Patent, ¶3).

Functionality and Market Context

• The complaint alleges the accused products are "the same in all respects relevant to the ’567 Patent" and that they are sold by a "swarm of foreign counterfeiters" who take advantage of online anonymity (’567 Patent, ¶6). The complaint provides a representative figure from the patent to illustrate the configuration of the product. The complaint provides a representative figure from the patent, depicting a cutaway perspective view of the egg washing brush's interior structure, including the bristle bands and protrusions (Compl. ¶10, FIG. 1). However, the complaint relies on an external "Schedule A-1" to show a comparison of the accused products to the claims, and this schedule was not included with the complaint document (Compl. ¶6). The complaint does not provide sufficient detail for an independent analysis of the accused products' specific functionality.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendants infringe at least Claim 1 of the ’567 Patent (’567 Patent, ¶28). The following table summarizes the infringement theory based on the complaint's general allegations, as a detailed element-by-element comparison is not provided in the body of the complaint.

’567 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a half egg-shaped shell comprising a flexible material	The complaint alleges the accused products have the unique configuration claimed in the patent and are the same in all relevant respects, which would include the claimed shell structure.	¶6, 10	col. 4:50-51
a plurality of bristle bands at least two of which intersect each other, the plurality of bristle bands defining an egg washing cavity	The complaint makes a general allegation that the accused products infringe Claim 1, which contains this limitation. A specific comparison is said to be shown in an unprovided schedule.	¶6, 28	col. 4:52-55
a plurality of bristle protrusions extending inward from the bristle bands and configured to contact an egg	The complaint’s general infringement allegation encompasses this feature. The representative figure provided in the complaint shows these protrusions extending from the bands.	¶10, 28	col. 4:56-57

• Identified Points of Contention:
  • Evidentiary Questions: A central issue will be the presentation of evidence. The complaint makes broad allegations that the accused products are "the same" as the patented invention but relies on external schedules not filed with the pleading. The primary question will be whether discovery shows the accused products, once obtained and analyzed, actually meet every limitation of Claim 1.
  • Scope Questions: The infringement analysis will depend on the interpretation of claim terms. A key question is whether the configuration of the accused products' cleaning elements constitutes "bristle bands at least two of which intersect each other," or if they are arranged in a non-intersecting pattern (e.g., purely radial) that might fall outside the scope of the claim.

V. Key Claim Terms for Construction

• The Term: "half egg-shaped shell"

• Context and Importance: This term defines the overall structure of the apparatus. The dispute may focus on how closely a product must conform to a literal "half egg" shape to infringe. Practitioners may focus on this term to determine if products with more generally ovoid, hemispherical, or other curved cavity shapes fall within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is not rigidly defined with geometric precision in the specification, which may support an interpretation covering a range of generally concave, ovoid shapes suitable for receiving an egg.
  • Evidence for a Narrower Interpretation: The patent consistently uses the specific phrase "half egg-shaped" and not more general terms like "cup-shaped" or "concave" (’567 Patent, col. 1:56, 4:50). The provided figures (FIG. 1, 2) depict a specific ovoid, rather than spherical, semi-shape, which could be argued to limit the term to that particular geometry.

• The Term: "bristle bands"

• Context and Importance: This term is critical as it describes the structures that hold the cleaning protrusions. Infringement may depend on whether the accused products have distinct "bands" or another structure, such as a uniform field of bristles.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification does not define a required width or height for a "band," potentially allowing the term to cover any linear grouping of bristles.
  • Evidence for a Narrower Interpretation: The detailed description and figures show "bristle bands" as discrete, raised structures that are distinct from the main shell, upon which protrusions are located (’567 Patent, col. 3:51-66; FIG. 1). One could argue a "band" must be a separately identifiable structural feature, not merely a line of bristles on a flat surface.

• The Term: "intersect each other"

• Context and Importance: This limitation, which applies to at least two of the bristle bands, is a specific structural requirement. Whether infringement is found could turn on the geometric arrangement of the cleaning elements in the accused product.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term could be construed to mean any joining or meeting of the bands, such as at a central point or hub from which they radiate.
  • Evidence for a Narrower Interpretation: The ordinary meaning of "intersect" suggests a crossing over/under. The specification states that "Bristle bands 106 sometimes intersect other bristle bands 106 at various angles," which, in conjunction with Figure 1, may support an interpretation requiring a physical crossing rather than simply terminating at a common junction (’567 Patent, col. 4:3-5).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain a formal count for indirect infringement under 35 U.S.C. § 271(b) or (c). The prayer for relief, however, requests an injunction against "aiding, abetting, contributing to, or otherwise assisting anyone" in infringing (’567 Patent, Prayer for Relief ¶A(2)). The body of the complaint lacks specific factual allegations regarding intent to induce or the sale of non-staple components that would be required to support such a claim.
• Willful Infringement: The complaint alleges that Defendants' infringement has been "knowing[] and willfully" (’567 Patent, ¶22, 23, 27). The basis for this allegation appears to be the alleged nature of Defendants' business model—operating as a "swarm of foreign counterfeiters" using fictitious names and other tactics to evade enforcement—rather than any specific allegation of pre-suit knowledge of the ’567 Patent itself (’567 Patent, ¶6, 17-21).

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

• A primary procedural question will be one of joinder and personal jurisdiction: The complaint targets a collection of allegedly related but unidentified online sellers. A threshold issue for the court will be to determine if Plaintiff's allegations that Defendants operate as a coordinated "swarm" are sufficient to join them in a single action under 35 U.S.C. § 299 and to establish personal jurisdiction over each foreign entity.
• A core issue will be one of definitional scope: The infringement analysis will likely turn on the construction of key claim terms. A central question for the court will be whether the limitation requiring bristle bands to "intersect each other" can be read to cover arrangements where bands may simply radiate from a central point, a design that may be common in competing products.
• A key evidentiary question will be one of technical proof: The complaint makes conclusory allegations of infringement, relying on unprovided schedules for a direct comparison. The case will depend on Plaintiff’s ability to obtain the accused products and demonstrate, with competent evidence, that their physical structures meet every element of the asserted claim as construed by the court.