Good Life Wholesale LLC v. Rico Jiao

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Good Life Wholesale LLC (Arizona)
  • Defendant: Rico Jiao (Virginia)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 2:25-cv-02099, W.D. Wash., 10/24/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because the Defendant purposefully directed patent enforcement activities at Amazon.com personnel located in Seattle, Washington.
• Core Dispute: Plaintiff seeks a declaratory judgment that its Laundry Pedestal products do not infringe Defendant's patent related to a laundry pedestal system, and/or that the patent is invalid.
• Technical Context: The dispute concerns laundry room accessories, specifically pedestals designed to elevate washing machines and dryers while providing additional storage and functionality.
• Key Procedural History: The action arises from Defendant's extra-judicial enforcement of the patent-in-suit through Amazon's Patent Evaluation Express (APEX) process, which Plaintiff alleges threatens removal of its product listings and has created a justiciable controversy between the parties.

Case Timeline

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

U.S. Patent No. 12,404,623 - "Laundry Pedestal System"

• Patent Identification: U.S. Patent No. 12,404,623, "Laundry Pedestal System," issued September 2, 2025 (’623 Patent).

The Invention Explained

• Problem Addressed: The patent describes several problems with traditional laundry room setups, including water leakage from machines causing floor damage, user discomfort from bending to load and unload appliances, instability and vibration during machine operation, and suboptimal use of storage space in existing pedestals (’623 Patent, col. 1:12-61).
• The Patented Solution: The invention is a "universal laundry pedestal system" designed to solve these problems by providing an elevated frame with an upper support surface that includes a built-in drainage hole to manage leaks (’623 Patent, col. 2:10-20). The space beneath this surface is configured as an open-ended storage bay to house a "custom-fitted laundry hamper," which is provided as part of the system (’623 Patent, col. 2:21-26). The structure also includes features for vibration damping, such as welded cross bars underneath the upper support surface and high-friction leg stand mats (’623 Patent, col. 2:48-52).
• Technical Importance: The invention aims to consolidate multiple laundry accessories (pedestal, drain pan, hamper) into a single, universal product that improves safety, ergonomics, and space efficiency in the laundry room (’623 Patent, col. 2:56-60).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claim 1 (Compl. ¶21).
• Essential elements of independent claim 1 include:
  • A drawer-shaped laundry hamper
  • A universal laundry pedestal with a frame, four legs, an upper support surface with a drainage hole, and a lower support surface
  • The lower support surface forms an open-ended storage space shaped to accommodate the hamper and is raised above floor level
  • A set of welded cross bars underneath the upper support surface to provide additional support and reduce vibration
• The complaint notes that the patent includes eleven dependent claims (claims 2-12) and asserts non-infringement of these as well (Compl. ¶¶17, 26).

III. The Accused Instrumentality

Product Identification

• Plaintiff’s "Laundry Pedestal" products (Compl. ¶22).

Functionality and Market Context

• The complaint describes the Accused Product as a stand-alone pedestal that features a "pull-out/extendable shelf that can hold a user's external basket" and a "closed lower cabinet for supplies" (Compl. ¶23). It alleges that the product is designed for non-infringing uses such as elevating a machine and storing supplies (Compl. ¶25). The Amazon marketplace is identified as the Plaintiff's "primary sales channel" in the United States, making the threat of delisting due to Defendant's enforcement activities a significant commercial risk (Compl. ¶14).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

• Claim Chart Summary: The complaint is for a declaratory judgment of non-infringement. The following table summarizes the Plaintiff's asserted distinctions between the Accused Product and the elements of claim 1 of the ’623 Patent.

’623 Patent Infringement Allegations

• Identified Points of Contention: The core of the non-infringement dispute appears to center on structural and functional differences between the claimed invention and the Accused Product.
  • Scope Questions: The case may turn on whether a "pull-out/extendable shelf" that holds a user-supplied basket can be considered equivalent to the claimed "drawer-shaped laundry hamper." The Plaintiff argues that treating it as such would "vitiate express limitations" of the claim (Compl. ¶24).
  • Technical Questions: A factual question may arise regarding the structure of the Accused Product's lower portion. The complaint's description of a "closed lower cabinet for supplies" suggests a different configuration and purpose than the claimed "open-ended storage space" specifically "shaped and sized to accommodate the laundry hamper" (Compl. ¶23).

V. Key Claim Terms for Construction

• The Term: "drawer-shaped laundry hamper"

  • Context and Importance: This term is central to the non-infringement argument, as Plaintiff alleges its product lacks this claimed component entirely, instead providing a shelf for an external basket (Compl. ¶23). The construction will determine if the claim requires a specific, integrated component or if it can read on a more general-purpose feature.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the hamper as something that "can be pulled out like a drawer," which might suggest the primary characteristic is its mode of operation rather than its specific form (’623 Patent, col. 2:25-26).
    • Evidence for a Narrower Interpretation: The claim itself requires the hamper to be "drawer-shaped." The specification refers to it as a "custom-fitted laundry hamper" that is "provided as part of the kit," implying it is an integral and specifically designed part of the system, not a generic shelf for a third-party item (’623 Patent, col. 2:23-25).

• The Term: "open-ended storage space"

  • Context and Importance: Plaintiff contrasts this claimed feature with its Accused Product's alleged "closed lower cabinet" (Compl. ¶23). The definition of "open-ended" will be critical to determining if the Accused Product's storage area falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term could be interpreted to mean any storage area that is accessible from at least one side (i.e., the front).
    • Evidence for a Narrower Interpretation: The claim requires the space to be "shaped and sized to accommodate the laundry hamper," linking its characteristics directly to the hamper element (’623 Patent, col. 6:1-2). The figures show a bay defined by upper and lower support surfaces and legs, which is structurally distinct from what may be understood as a "closed... cabinet" (’623 Patent, Fig. 1).

VI. Other Allegations

• Indirect Infringement: The complaint preemptively denies claims of indirect infringement. It alleges that the Accused Product is a staple article of commerce suitable for substantial non-infringing uses (e.g., elevating an appliance) and that Plaintiff has not encouraged or instructed any infringing activity (Compl. ¶25).

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

The resolution of this declaratory judgment action will likely depend on the court's interpretation of several key technical and legal issues.

• A core issue will be one of definitional scope: can the claim term "drawer-shaped laundry hamper," which the patent describes as a "custom-fitted" part of the system, be construed to cover a general-purpose "pull-out/extendable shelf" designed to hold a user's own basket?
• A second key issue will be structural interpretation: does the Accused Product's alleged "closed lower cabinet for supplies" meet the claim limitation of an "open-ended storage space shaped and sized to accommodate the laundry hamper," or is there a fundamental structural and functional distinction?
• Finally, should the non-infringement arguments fail, the case will turn on an invalidity analysis: do the prior art references cited in the complaint, individually or in combination, disclose or render obvious every element of the asserted claims, particularly features like the integrated hamper bay and welded cross-bar reinforcements?