DCT
2:25-cv-02586
Sanmingshi Sanyuanqu Chiyu Baihuo Shanghang v. Goodegg Stuff LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Sanmingshi Sanyuanqu Chiyu Baihuo Shanghang (People's Republic of China)
- Defendant: Goodegg Stuff LLC (Delaware)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02586, W.D. Wash., 12/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant purposefully directed patent enforcement activities into the district by initiating an Amazon "Patent Evaluation Express" process, 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 for an egg washing brush and/or that the patent is invalid.
- Technical Context: The technology concerns a simple, hand-held manual cleaning device, typically made of silicone, designed specifically for washing individual poultry eggs, a niche market for hobby farmers and small-scale producers.
- Key Procedural History: This declaratory judgment action was precipitated by Defendant's enforcement of its patent through Amazon's "Patent Evaluation Express" (APEX) program, which threatened the removal of Plaintiff's product listings. The complaint also notes a potential inconsistency between the patent owner identified in USPTO records (Goodegg Stuff LLC) and the owner named in the APEX submission (Tim Rowberry).
Case Timeline
| Date | Event |
|---|---|
| 2017-09-06 | "Bakerpan Listing" (alleged prior art) first available on Amazon |
| 2023-04-11 | ’337 Patent Priority Date |
| 2023-12-26 | ’337 Patent Filing Date |
| 2025-10-28 | ’337 Patent Issue Date |
| 2025-12-03 | Amazon notifies Plaintiff of Defendant's infringement report |
| 2025-12-16 | Complaint for Declaratory Judgment Filed |
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 (’337 Patent).
The Invention Explained
- Problem Addressed: The patent's background section notes that hobby egg farmers and individual consumers often lack cleaning tools specifically contoured for eggs, forcing them to use brushes designed for other purposes or flat devices that are not well-suited to the task ('337 Patent, col. 1:24-34).
- The Patented Solution: The invention is a hand-operable egg washing brush comprising a deformable, half egg-shaped shell made of a flexible material like silicone. The shell defines an interior washing cavity and features a plurality of inwardly-extending protrusions (bristles) that scrub the egg's surface when the egg is rotated inside. The design may also include drainage windows and a scraping ridge. ('337 Patent, Abstract; col. 2:50-65).
- Technical Importance: The patented design purports to provide a simple, effective, and easy-to-clean tool specifically adapted to the contours of an egg, overcoming shortcomings of general-purpose brushes in this application ('337 Patent, col. 1:35-42).
Key Claims at a Glance
- The complaint seeks a declaration of non-infringement and invalidity of the ’337 Patent, including at least independent claims 1, 10, 19, and 20 (Compl. ¶22). The APEX proceeding initiated by Defendant identified Claim 1 for evaluation (Compl. ¶37).
- Independent Claim 1 (Apparatus):
- A hand-held egg washing brush apparatus to clean an individual poultry egg;
- comprising an isolated half egg-shaped shell, which includes a perimeter rim defining an access opening to a fixed egg washing cavity;
- the shell is made of an integral and inherently deformable material;
- the shell includes a plurality of protrusions extending inward from the washing cavity, configured to contact an egg; and
- the apparatus has no hinges or mechanical parts and is self-contained and operable by hand.
III. The Accused Instrumentality
Product Identification
- The "Accused Product" is Plaintiff's "Egg Washer" product, sold on Amazon.com and other e-commerce channels (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" (Compl. ¶24). This shape includes raised external 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, because its comb is a "separately molded component that is attached (e.g., glued) onto the main body" (Compl. ¶25).
- Plaintiff states that the Amazon marketplace is its "primary sales channel in the United States," making the threatened removal of its listings a significant commercial risk (Compl. ¶14).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The table below summarizes Plaintiff's arguments for why its Accused Product does not meet the limitations of claim 1.
- '337 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an isolated half egg-shaped shell... comprising a perimeter rim defining an access opening to a fixed egg washing cavity | The Accused Product has the overall contour of a "cartoon chicken head" with external features (eyes, beak, comb) that "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 not integral because its comb is a "separately molded component that is attached (e.g., glued) onto the main body." | ¶25 | col. 4:44-45 |
- Identified Points of Contention:
- Scope Questions: The primary dispute raises the question of definitional scope: does the claim term "isolated half egg-shaped shell" read on a product with significant, non-functional external ornamentation like a "cartoon chicken head"? (Compl. ¶24). A related question is whether "integral" requires a unitary, single-piece construction or if it can encompass multiple components permanently affixed together (Compl. ¶25).
- Technical Questions: A key factual question will be whether the Accused Product's "protruding comb geometry and fixed attachment" physically "prevent the Accused Product from being inverted," as required by other asserted claims like claim 19 (Compl. ¶28).
V. Key Claim Terms for Construction
The Term: "isolated half egg-shaped shell"
- Context and Importance: Plaintiff's primary non-infringement argument is that its product's "cartoon chicken head" shape is not "half egg-shaped" (Compl. ¶24). The construction of this term is therefore central to determining literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the apparatus functionally, as being "contoured to contact and clean the surface of an individual egg," which could suggest that any generally concave shape sufficient to perform this function falls within the scope ('337 Patent, col. 1:30-31).
- Evidence for a Narrower Interpretation: The claim language itself is geometrically specific. The patent's figures depict a smooth, unadorned, symmetrical half-egg shape ('337 Patent, Fig. 1). The term "isolated" could be argued to mean the shell is structurally separate and free from additional external features like those on the accused product.
The Term: "integral"
- Context and Importance: Plaintiff alleges non-infringement based on its product's comb being a separately molded and attached piece, arguing this violates the "integral" limitation (Compl. ¶25).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition. An argument could be made that "integral" refers to the final product operating as a single, non-articulating unit, which could be true even if components are permanently bonded during manufacturing.
- Evidence for a Narrower Interpretation: The common technical meaning of "integral" implies a single, unitary piece formed from the same material in one process. The patent's description of the shell comprising an "integral and inherently deformable material" supports this, suggesting a single piece of material, not an assembly ('337 Patent, col. 4:44-45). The complaint explicitly argues for this interpretation (Compl. ¶25).
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any basis for indirect infringement, asserting that the Accused Product is a "staple article of commerce suitable for substantial non-infringing uses" and that Plaintiff has not instructed or encouraged any infringing use (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "isolated half egg-shaped shell," which is described and depicted with a simple geometric form, be construed to cover a product featuring significant external ornamentation that results in a "cartoon chicken head" shape?
- A second key claim construction question will be one of structural composition: does the term "integral" require a unitary, single-piece construction, thereby excluding a product with a separately molded and permanently affixed component, or can it be interpreted more broadly to mean a non-articulated final assembly?
- Beyond infringement, a central validity question will be one of anticipation and obviousness: does the alleged prior art, including a 2017 product listing for a "Silicone Vegetable Scrubber... [and] Egg Cleaner," disclose every element of the asserted claims, or would combining prior art references have rendered the claimed invention obvious to a person of ordinary skill? (Compl. ¶¶40, 43-44).