DCT
2:25-cv-01300
Shenzhen Huajing Intl Trade Co Ltd v. Grease Box LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Huajing International Trade Co., Ltd. (China)
- Defendant: The Grease Box LLC (Arizona)
- Plaintiff’s Counsel: Alight Law P.C.
- Case Identification: 2:25-cv-01300, W.D. Wash., 07/10/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant purposefully directed its conduct at Washington by filing a patent infringement complaint with Amazon, which is headquartered in Seattle. The complaint further alleges that the agreement governing Amazon’s enforcement program, which Defendant voluntarily used, requires participants to agree to venue in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its grease bucket products do not infringe Defendant's patent related to grease containment systems for outdoor cookers, and further alleges tortious interference and bad faith patent assertion.
- Technical Context: The technology concerns safety enclosures for grease collection buckets used with outdoor cooking devices like pellet grills, a market segment for consumer cooking accessories.
- Key Procedural History: The dispute arose after Defendant filed a patent infringement complaint against Plaintiff via Amazon's Patent Evaluation Express (APEX) program, resulting in the removal of Plaintiff's products from the platform. Plaintiff alleges it provided Defendant with a detailed non-infringement analysis and requested withdrawal of the Amazon complaint, but Defendant refused.
Case Timeline
| Date | Event |
|---|---|
| 2020-08-04 | '895 Patent Priority Date |
| 2023-11-14 | '895 Patent Issue Date |
| 2024-11-01 | Defendant submitted APEX complaint against Plaintiff (approx.) |
| 2025-02-03 | Plaintiff’s Accused Products removed from Amazon |
| 2025-02-10 | Defendant allegedly listed its own competing product on Amazon |
| 2025-02-18 | Plaintiff sent non-infringement analysis to Defendant |
| 2025-07-10 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,812,895 - "Grease containment systems", issued November 14, 2023
The Invention Explained
- Problem Addressed: The patent’s background section identifies safety and convenience issues with standard, open-top grease collection buckets used for outdoor grills. These issues include the risk of spills, burns from accidental contact with the hot bucket, the collection of rainwater which can cause overflows, and the potential for hot grease to ignite ('895 Patent, col. 1:12-36).
- The Patented Solution: The invention is a multi-part enclosure that houses the grease bucket. It is designed to securely mount to the drain of an outdoor cooker, provide a thermal buffer to prevent burns, and contain spills. A key feature is a separable two-part construction (an upper and lower portion) that allows for easy access to and removal of the internal grease receptacle for cleaning ('895 Patent, Abstract; col. 2:42-47).
- Technical Importance: The system purports to enhance the safety, stability, and cleanliness associated with managing hot grease runoff from popular outdoor cooking devices like pellet smokers ('895 Patent, col. 2:5-9).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1 and 16 (Compl. ¶¶ 29, 32).
- Independent Claim 1 recites a system for catching fluid drainage, the essential elements of which include:
- A receptacle to collect fluid
- An enclosure to house the receptacle
- The enclosure comprises an upper portion (with top and side walls) and a separable lower portion (with bottom and side walls)
- The enclosure also comprises "at least one receptacle support" within the lower portion, and a "mount" to attach the enclosure to the cooking device's drain
- The enclosure includes "at least one insulation layer" between the receptacle and the side walls
- Independent Claim 16 recites a system comprising the outdoor cooking device itself and an enclosure with similar structural limitations to Claim 1, but adds requirements for:
- "at least one thermal vent" to vent heat
- "at least one damper" to control airflow through the vent
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are grease bucket products sold by Plaintiff Shenzhen Huajing on Amazon under the brand name "VattaFrast," identified by ASINs B0DJFNG1DP, B0DNSP3TFJ, B0DSVQ4SND, and B0DJBB85FK (Compl. ¶¶ 15, 16).
Functionality and Market Context
- The complaint describes the Accused Products as accessories for outdoor cooking devices designed to collect grease (Compl. ¶ 8). The central non-infringement argument is based on the products' alleged construction: the grease receptacle is supported directly by the enclosure's bottom surface, not by a separate internal support structure (Compl. ¶ 29). The complaint alleges the Accused Products compete directly with products sold by the Defendant on Amazon (Compl. ¶ 20).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiff’s non-infringement contentions for the asserted claims.
'895 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least one receptacle support within the lower portion of the enclosure, the at least one receptacle support structured and arranged to support said at least one receptacle | The receptacle is supported directly by the bottom of the enclosure; there is no separately structured internal component serving as a receptacle support. The complaint's FIG. 1 visually contrasts the patent's distinct support (375) with the accused product's integrated bottom. | ¶29 | col. 11:58-62 |
| an upper portion comprising a top and side walls | The accused product's upper portion consists of only a top without any side walls and therefore does not meet the claim's requirement. This structural difference is depicted in the complaint's FIG. 2. | ¶30 | col. 11:54 |
| at least one insulation layer between said receptacle and the side walls | There is no insulation layer present; the receptacle is in direct contact with the enclosure's bottom surface and is not separated from the side walls by a dedicated layer. The complaint's FIG. 3 illustrates this alleged direct contact. | ¶31 | col. 11:66-12:2 |
'895 Patent Infringement Allegations (Claim 16)
| Claim Element (from Independent Claim 16) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| wherein at least one wall of said walls comprises at least one thermal vent structured and arranged to vent heat from the fluid collected... | The Accused Products do not include a thermal vent. | ¶33 | col. 13:11-14 |
| wherein said at least one thermal vent comprises at least one damper structured and arranged to dampen air flow through said enclosure | The Accused Products do not include a damper. | ¶33 | col. 13:15-18 |
Identified Points of Contention
- Scope Questions: The primary dispute appears to center on claim construction. A key question is whether the term "receptacle support" requires a structure separate and distinct from the "bottom" of the enclosure, as Plaintiff argues by citing the principle that claim terms listed separately are presumptively distinct components (Compl. ¶ 34). Another question is whether the term "insulation layer" can be construed to read on an incidental air gap between a bucket and an enclosure wall, or if it requires a deliberately designed feature.
- Technical Questions: A factual question for the court will be whether the Accused Products are constructed exactly as the complaint alleges and depicts. For example, evidence will be needed to confirm that the Accused Products lack any structure that could be characterized as "side walls" on the upper portion or any feature that functions as a "thermal vent" or "damper."
V. Key Claim Terms for Construction
The Term: "receptacle support"
- Context and Importance: This term is central to the non-infringement argument for both asserted claims. The case may turn on whether the bottom surface of the accused enclosure can be construed as meeting this limitation, or if a separate, distinct component is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the function generally as a structure that "suspends a receptacle" or is "arranged to support" it ('895 Patent, col. 8:31-33). Defendant may argue that any structure performing this function, including an integrated bottom, meets the limitation.
- Evidence for a Narrower Interpretation: Claim 1(c) separately lists "a lower portion comprising a bottom and side walls" and "at least one receptacle support within the lower portion." This suggests the two are not the same structure. The patent's figures consistently depict the "receptacle support" (375) as a distinct flange or shelf separate from the "bottom" (285) of the enclosure, providing strong evidence for requiring a separate component ('895 Patent, FIG. 3, FIG. 4B).
The Term: "insulation layer"
- Context and Importance: Plaintiff alleges the Accused Products lack this feature entirely. The dispute will likely focus on what constitutes a "layer" and whether any incidental air space between the grease bucket and the enclosure wall meets the definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Dependent claim 12 specifies that the "insulation layer comprises at least one air gap" ('895 Patent, col. 12:41-43). Defendant could argue this informs the term's meaning and that any air gap, even if not explicitly designed as a feature, constitutes an "insulation layer."
- Evidence for a Narrower Interpretation: The specification describes creating a "safety buffer" and shows the insulation as a significant "lower cavity" (520) between the receptacle and the enclosure walls ('895 Patent, col. 5:20; FIG. 5). Plaintiff may argue this implies a deliberately engineered separation, not an incidental space, is required to meet the "layer" limitation.
VI. Other Allegations
Indirect Infringement
- The complaint seeks a declaratory judgment of non-infringement of "any valid and enforceable claim," which includes direct, induced, and contributory infringement, but provides no specific factual analysis related to indirect infringement beyond a general denial (Compl. ¶¶ 28, 36).
Willful Infringement
- Willful infringement is not at issue in this declaratory judgment complaint. However, Plaintiff makes related allegations of "bad faith assertions of patent infringement" against Defendant under Washington state law, based on Defendant's alleged refusal to withdraw its Amazon APEX complaint after being presented with a non-infringement analysis (Compl. ¶¶ 50-54).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can claim terms such as "receptacle support" and "insulation layer" be interpreted broadly to cover integral or incidental features of an enclosure, or do the patent's own text and figures limit them to the separate, distinct structural components depicted? Plaintiff’s non-infringement case appears to rely heavily on the latter interpretation.
- A second central question relates to commercial conduct: beyond the technical patent issues, the court will address claims of bad faith assertion under Washington's Patent Troll Prevention Act. This will turn on whether Defendant's enforcement activity through Amazon's APEX program, and its alleged refusal to withdraw its complaint, constituted a bad faith action rather than a legitimate effort to enforce its patent rights.