DCT

2:25-cv-01202

Zhengzhou Letai Trading Co Ltd v. Towerstar Pets LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01202, W.D. Wash., 06/25/2025
  • Venue Allegations: Venue is based on Defendant's patent enforcement activities directed at Amazon.com, Inc., whose Seattle, Washington operations received the infringement takedown notice that forms the basis of the dispute.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its "Pet Feeding Products" do not infringe Defendant's patent related to a system for collecting and separating spilled pet food and water.
  • Technical Context: The technology addresses the common problem of messy pet eating by providing a feeding station designed to contain spills, separate liquid from solid waste, and keep the surrounding area clean.
  • Key Procedural History: The action was precipitated by Defendant submitting infringement reports to Amazon, which resulted in the removal of Plaintiff's products from the e-commerce platform and created the "actual controversy" necessary for a declaratory judgment action.

Case Timeline

Date Event
2008-10-03 '975 Patent Priority Date
2013-08-27 '975 Patent Issue Date
2025-04-29 Plaintiff receives infringement notice from Amazon
2025-06-25 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 8,516,975 - PET FEEDING SYSTEM AND METHOD FOR COLLECTING SPILLED FOOD AND WATER

  • Patent Identification: U.S. Patent No. 8,516,975, PET FEEDING SYSTEM AND METHOD FOR COLLECTING SPILLED FOOD AND WATER, issued August 27, 2013.

The Invention Explained

  • Problem Addressed: The patent's background describes the common problem of pets spilling food and water, which creates messes, can damage floors, and is inconvenient to clean (ʼ975 Patent, col. 1:30-39). It further identifies a shortcoming in prior art solutions that collect spilled food and water together, creating a "soggy, unsanitary mess" that is difficult to clean and prevents the reuse of spilled food (ʼ975 Patent, col. 2:55-59).
  • The Patented Solution: The invention is a pet feeding system designed to efficiently separate spilled food from spilled water. It generally consists of a housing with a sloped base that directs spilled water away from the bowl area and towards a collection region, which often features a grate or openings (ʼ975 Patent, Abstract). These openings are small enough to trap solid food pieces on the surface, where they remain accessible to the pet, while allowing water to pass through into a separate, underlying reservoir for later disposal (ʼ975 Patent, col. 7:36-56; Fig. 2).
  • Technical Importance: This design allows spilled food to remain relatively dry and edible while isolating spilled water, thereby improving sanitation, reducing food waste, and simplifying cleanup for the pet owner (ʼ975 Patent, col. 6:1-8).

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 2, 10, and 21 of the '975 Patent (Compl. ¶17). The right to assert non-infringement of dependent claims is also noted (Compl. ¶22).

  • Independent Claim 1, Essential Elements:

    • A housing with a bowl region and a collection region.
    • A base with a sloped surface to direct water.
    • A surrounding wall.
    • The bowl region has an opening surrounded by a "peripheral wall".
    • A bowl is received in the opening and rests on the "peripheral wall".
    • The surrounding wall is higher than the "peripheral wall".
    • A "channel" separates the surrounding wall and "peripheral wall", forming a "chute".

  • Independent Claim 2, Essential Elements:

    • A base with a descending slope and an opening surrounded by a "peripheral wall".
    • A barrier surrounding the base.
    • A trap at one end of the base.
    • A bowl extending through the opening and resting on the "peripheral wall".
    • The barrier is higher than the "peripheral wall".
    • A "channel" separates the barrier and "peripheral wall", forming a "chute".

  • Independent Claim 10, Essential Elements:

    • A base with a descending slope.
    • At least one bowl receptacle with an opening surrounded by a "peripheral wall".
    • A barrier surrounding the base.
    • A trap at one end of the base.
    • A bowl extending through the opening and resting on the "peripheral wall".
    • The barrier is higher than the "peripheral wall".
    • A "channel" separates the barrier and "peripheral wall", forming a "chute".

  • Independent Claim 21, Essential Elements:

    • A base with a descending slope and an opening surrounded by a "peripheral wall".
    • A barrier surrounding the base.
    • A trap at one end of the base.
    • A bowl extending through the opening and resting on the "peripheral wall".
    • The barrier is higher than the "peripheral wall".
    • A "channel" separates the barrier and "peripheral wall", forming a "chute".
    • A reservoir extending beneath the slope and trap.

III. The Accused Instrumentality

Product Identification

The complaint identifies Plaintiff’s “Pet Feeding Products,” specifically the product associated with Amazon Standard Identification Number (ASIN) B0DPFWZ3Z9 (Compl. ¶10).

Functionality and Market Context

The complaint describes the accused product as a pet feeder sold on Amazon, which constitutes Plaintiff’s primary sales channel in the United States (Compl. ¶11). The core of the non-infringement argument is based on functionality the product allegedly lacks. Plaintiff asserts its product does not have a “peripheral wall,” does not have a bowl that rests on such a wall, and does not have a “chute for conveying spilled water” as required by the claims of the ’975 Patent (Compl. ¶¶18-20). The complaint includes a photograph purporting to show the absence of the "peripheral wall" feature (Compl. p. 5).

IV. Analysis of Infringement Allegations

The complaint does not provide a formal claim chart but makes narrative arguments for non-infringement against all four asserted independent claims. The central arguments are summarized below in the context of representative Claim 1.

’975 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
the opening having a perimeter that is surrounded by a peripheral wall The accused product allegedly lacks a "peripheral wall." The complaint includes a photograph with arrows pointing to the edge of the bowl opening to support this assertion. The photo shows the top surface is flush with the opening. ¶18, p. 5 col. 24:12-13
the bowl region further comprising a bowl that is received in the opening and resting on the peripheral wall Because the product allegedly lacks a peripheral wall, the bowl cannot rest on one; instead, it rests directly on the product's main surface. ¶19 col. 24:14-15
the wall surrounding the contained feeding area and the peripheral wall being separated from one another by at least one channel...forming a chute... The accused product is alleged to not have the claimed "chute for conveying spilled water" from the bowl area into a trap. ¶20 col. 24:18-23

Plaintiff alleges that these same deficiencies (e.g., the lack of a "peripheral wall" and a "chute") result in non-infringement of corresponding limitations in independent claims 2, 10, and 21 (Compl. ¶¶18-20).

Identified Points of Contention

  • Definitional Question: The dispute centers on whether the structure at the edge of the accused product's bowl openings constitutes a "peripheral wall." The complaint's photograph suggests the product may have a simple edge or lip rather than a distinct, raised wall structure as depicted in the patent's figures (Compl. p. 5; '975 Patent, Fig. 8, item 32/33).
  • Technical Question: A factual dispute exists over whether the accused product’s design for water runoff meets the claim limitation of "forming a chute for conveying spilled water." The complaint alleges a complete absence of this feature, which raises the question of what structural and functional attributes are required to satisfy the "chute" limitation.

V. Key Claim Terms for Construction

The Term: "peripheral wall"

  • Context and Importance: This term is critical to the dispute, as Plaintiff's primary non-infringement theory is the complete absence of this structure in its product (Compl. ¶18). The term appears in all four asserted independent claims, making its construction potentially dispositive.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for infringement might contend that any raised structure or lip surrounding the opening meets the plain and ordinary meaning of "wall." The patent does not provide an explicit definition, potentially leaving the term open to a broader interpretation.
    • Evidence for a Narrower Interpretation: The patent specification describes the "peripheral wall" (32, 33) as a structure whose height "varies around its circumference to allow for the bowls to rest substantially parallel to the surface on which pet feeding system 10 rests" ('975 Patent, col. 15:3-8). Practitioners may focus on this language to argue that the term requires a structure that performs this specific leveling function on a sloped surface, not merely any edge or lip. The patent figures consistently show this as a distinct, raised ring separate from the main outer wall ('975 Patent, Fig. 1, 8).

The Term: "chute for conveying spilled water"

  • Context and Importance: This term describes the mechanism for transporting water, a key functional aspect of the invention. Plaintiff alleges its product lacks this element entirely (Compl. ¶20).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for infringement could assert that any sloped surface or groove that directs water flow constitutes a "chute."
    • Evidence for a Narrower Interpretation: The patent describes the "chute" as being formed by a "channel" (e.g., 70, 72, 74) that is bounded on one side by the "peripheral wall" and on the other by the main surrounding "barrier" or wall ('975 Patent, col. 16:35-56, col. 24:18-23). Practitioners may argue this requires a defined, bounded channel, rather than just an undifferentiated sloped surface.

VI. Other Allegations

  • Indirect Infringement: The complaint does not provide sufficient detail for analysis of any indirect infringement theories.
  • Willful Infringement: The complaint does not allege willful patent infringement. It does contain allegations related to "willful and malicious" conduct, but these are in support of a separate state law claim for tortious interference with business relationships (Compl. ¶31).

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

  1. A core issue will be one of definitional scope: can the term "peripheral wall," as described in the ’975 Patent with specific functional characteristics for leveling a bowl on a sloped surface, be construed to read on the simple edge of the bowl opening in the accused product? Or does the claim require a distinct, raised structure as depicted in the patent’s embodiments?

  2. The case will also present a key evidentiary question: does the accused product's general drainage design create a structure that meets the requirements of the claimed "chute," which the patent describes as a bounded "channel" separating the peripheral and outer walls? The determination will likely depend on factual evidence regarding the product's structure and how it compares to the specific architecture described in the patent.