DCT
2:25-cv-02585
Datian Jianchang Trading Co Ltd v. Goodegg Stuff LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Datian Jianchang Trading Co., Ltd. (People's Republic of China)
- Defendant: Goodegg Stuff LLC (Delaware)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02585, W.D. Wash., 12/16/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon "Patent Evaluation Express" (APEX) proceeding against Plaintiff's product listings, which involved communications with Amazon personnel located in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Egg Washer" products do not infringe Defendant's patent related to a hand-held egg washing brush, and/or that the patent is invalid.
- Technical Context: The technology at issue pertains to simple, manually-operated cleaning devices specifically designed for washing individual poultry eggs, a niche market catering to hobby farmers and small-scale producers.
- Key Procedural History: The complaint states this action was precipitated by Defendant's use of Amazon’s APEX process to accuse Plaintiff’s products of infringement, threatening removal of the product listings. The complaint also highlights a potential discrepancy between the patent owner of record with the USPTO (Goodegg Stuff LLC) and the "Patent Owner" identified in the APEX submission (an individual, Tim Rowberry).
Case Timeline
| Date | Event |
|---|---|
| 2023-04-11 | '337 Patent Priority Date |
| 2023-12-26 | '337 Patent Filing Date |
| 2025-10-28 | '337 Patent Issue Date |
| 2025-12-01 | Defendant's APEX submission date |
| 2025-12-03 | Amazon notification to Plaintiff |
| 2025-12-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,453,337 - APPARATUS AND METHOD FOR EGG WASHING BRUSH
- Patent Identification: U.S. Patent No. 12,453,337, APPARATUS AND METHOD FOR EGG WASHING BRUSH, issued October 28, 2025. (Compl. ¶15-16; ’337 Patent, cover).
The Invention Explained
- Problem Addressed: The patent's background section identifies a need for a cleaning tool specifically adapted to the contours of an individual egg, noting that hobby farmers and consumers often must use generic brushes or flat devices not designed for this purpose. (’337 Patent, col. 1:24-34).
- The Patented Solution: The invention is a hand-held, deformable, half egg-shaped shell made of a flexible material like silicon. (’337 Patent, col. 1:51-56, col. 4:51-53). It features internal "bristle bands" with protrusions that make contact with the egg to scrub its surface, and includes drainage windows to allow debris and water to pass through. (’337 Patent, Abstract; col. 1:56-62).
- Technical Importance: The patented design aims to provide an effective, convenient, and easy-to-clean manual tool that is specifically contoured for cleaning individual eggs, addressing a perceived gap in the market for small-scale poultry keepers. (’337 Patent, col. 1:35-41).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 10, 19, and 20. (Compl. ¶22).
- Independent Claim 1 (Apparatus):
- A hand-held egg washing brush apparatus to clean an individual poultry egg;
- comprising an isolated half egg-shaped shell, the shell comprising a perimeter rim defining an access opening to a fixed egg washing cavity;
- the shell comprising an integral and inherently deformable material and a plurality of protrusions extending inward from the washing cavity configured to contact an egg; and
- the apparatus comprising no hinges or mechanical parts and being self-contained and operable by hand. (’337 Patent, col. 4:39-50).
- The complaint also addresses dependent claims. (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- Plaintiff's "Egg Washer" products, sold on Amazon.com and other e-commerce platforms. (Compl. ¶9, 23).
Functionality and Market Context
- The complaint alleges the Accused Product has an "overall contour of a cartoon chicken head rather than an egg-shaped shell," which includes raised external ornamental features such as eyes, a beak, and a comb. (Compl. ¶24).
- It is further alleged that the product is not of integral, single-piece construction; specifically, the complaint states on information and belief that the comb is a "separately molded component that is attached (e.g., glued) onto the main body." (Compl. ¶25).
- Plaintiff asserts that the Amazon marketplace is its primary sales channel in the United States and that Defendant's enforcement actions threaten to remove its products from that channel. (Compl. ¶14).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint seeks a declaratory judgment of non-infringement. The table below summarizes Plaintiff's primary arguments for why its Accused Product does not meet the limitations of the asserted claims.
’337 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (Plaintiff's Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| an isolated half egg-shaped shell | The Accused Product possesses the overall contour of a "cartoon chicken head," with external features (eyes, beak, comb) that allegedly "materially alter the claimed half egg-shaped configuration." | ¶24 | col. 4:41-43 |
| the isolated half egg-shaped comprising an integral and inherently deformable material | The Accused Product is allegedly not "integral" because its comb is a separately molded component that is attached to the main body, rather than being formed as a single piece. | ¶25 | col. 4:44-46 |
- Identified Points of Contention:
- Scope Questions: The core of the dispute appears to center on claim construction. A primary question will be whether the term "isolated half egg-shaped shell" is limited to a simple geometric shape or if it can be construed to read on a device with a generally similar cavity but with additional, ornamental external features like those of a "cartoon chicken head." (Compl. ¶24, 30). Another key question is whether the term "integral" requires a monolithic, single-piece construction or can encompass a device made of multiple components permanently affixed together. (Compl. ¶25, 30).
- Technical Questions: A functional dispute is raised regarding claims 19 and 20. The complaint alleges that the Accused Product's "protruding comb geometry and fixed attachment" prevent the device from being inverted as required by those claims. (Compl. ¶28-29). This raises the factual question of whether the physical structure of the Accused Product actually precludes it from performing a claimed function.
V. Key Claim Terms for Construction
The Term: "isolated half egg-shaped shell"
Context and Importance: This term is central to the non-infringement argument, as Plaintiff contends its "cartoon chicken head" product does not have a "half egg-shaped shell." (Compl. ¶24). The construction of this term may determine whether the overall shape of the accused device falls within the literal scope of the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the shell as being "sized for the type of egg to be washed," which could suggest the "egg-shape" is primarily functional—i.e., shaped to effectively hold and clean an egg—rather than being strictly limited to a specific geometric form. (’337 Patent, col. 5:7-8).
- Evidence for a Narrower Interpretation: The patent's title, abstract, and summary consistently and repeatedly use the phrase "half egg-shaped shell." (’337 Patent, Abstract; col. 1:54). Figure 1 depicts a simple, unadorned semi-ovoid shape. A party could argue these consistent descriptions, combined with the figure, define the invention's structure as being free of material external alterations like those on the Accused Product.
The Term: "integral"
Context and Importance: Plaintiff's non-infringement position relies on its product not being "integral" because a comb element is allegedly attached separately. (Compl. ¶25). The definition of this term will be critical to determining if a multi-component but functionally unified product infringes.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly define "integral." An argument could be made that the term, in context, means the final apparatus is a single, self-contained unit without separable components during use, which could include permanently bonded parts.
- Evidence for a Narrower Interpretation: The phrase "comprising an integral and inherently deformable material" could be interpreted to mean that the entire shell is formed from a single, continuous piece of that material, implying a monolithic construction (e.g., via a single mold). (’337 Patent, col. 4:44-46). The specification does not describe any process of joining separate components, which may lend support to a single-piece construction being contemplated.
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any indirect infringement, asserting that Plaintiff has not instructed or encouraged any infringing use and that the Accused Product is a "staple article of commerce suitable for substantial non-infringing uses." (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "isolated half egg-shaped shell," which describes a simple geometric form in the patent, be construed to cover the accused product’s "cartoon chicken head" contour with added ornamental features?
- A second key issue will be one of structural interpretation: does the claim term "integral" require a monolithic, single-piece construction, or can it read on a product assembled from multiple, permanently-affixed components, such as the accused product's allegedly attached comb?
- A central functional question will be whether the accused product's external geometry, specifically its protruding comb, physically prevents it from being "inverted" in the manner required by the patent’s method claims, thereby creating a non-infringing mismatch in technical operation.