DCT
2:25-cv-02732
Shenzhen Juxinli Technology Co Ltd v. Interlink Products Intl Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Juxinli Technology Co., Ltd. d/b/a BOZYBO Official (China)
- Defendant: Interlink Products International, Inc. (New Jersey)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02732, W.D. Wash., 12/30/2025
- Venue Allegations: Plaintiff asserts 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 and transmitting enforcement communications to Amazon personnel located in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its rain shower head products do not infringe Defendant’s patent related to multi-function showerheads and/or that the patent is invalid.
- Technical Context: The technology at issue involves showerheads with user-selectable modes that direct water through different sets of nozzles to create varied spray patterns, including standard shower sprays and specialized cleaning sprays.
- Key Procedural History: The complaint states that this action was precipitated by Defendant’s accusation of infringement made through Amazon’s APEX program, which created a threat that Plaintiff’s product listings would be removed from the e-commerce platform.
Case Timeline
| Date | Event |
|---|---|
| 2020-12-10 | ’435 Patent Priority Date |
| 2025-12-02 | ’435 Patent Issue Date |
| 2025-12-12 | Amazon notifies Plaintiff of Defendant's infringement report |
| 2025-12-30 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,485,435 - *Showerhead Having Selector For Directing Water Flow In Independent Directions*
- Patent Identification: U.S. Patent No. 12,485,435, Showerhead Having Selector For Directing Water Flow In Independent Directions, issued December 2, 2025 (’435 Patent). (Compl. ¶15).
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional showerheads, designed primarily for showering, may provide undesirable water pressure or spray patterns for ancillary tasks like cleaning shower walls or tubs. (’435 Patent, col. 1:16-27).
- The Patented Solution: The invention is a showerhead with a selector mechanism that allows a user to direct water flow through different, independent sets of nozzles. In addition to conventional nozzles on the main faceplate for showering, the device includes separate nozzles, located elsewhere on the head, which can produce different spray types, such as a focused "jet stream" or a wide "fan-shaped spray," better suited for cleaning. (’435 Patent, Abstract; col. 4:12-41). The key concept is the ability to switch between functionally distinct and independently located nozzle groups.
- Technical Importance: This design consolidates multiple functions into a single fixture, offering both a conventional showering experience and specialized, higher-pressure cleaning capabilities. (’435 Patent, col. 1:21-27).
Key Claims at a Glance
- The complaint’s non-infringement count focuses exclusively on independent Claim 1. (Compl. ¶¶21-22).
- Claim 1 of the ’435 Patent recites the following essential elements for a showerhead:
- A head portion and a handle.
- A plurality of first nozzles for directing water in a first direction.
- At least one second nozzle in the head portion for directing water in a second direction.
- At least one third nozzle adjacent to the second nozzle for directing water in a third direction, where the second and third directions are substantially the same and transverse to the first direction.
- A flow selector moveable between a first position (directing water to the first nozzles), a second position (directing water to the second nozzle), and a third position (directing water to the third nozzle).
- The second and third nozzles are configured to create different types of water flow (e.g., fan-shaped spray vs. jet stream).
- The flow selector is configured to remain in a selected position without continuous external force.
- Plaintiff alleges that dependent claims are not infringed because they incorporate all limitations of Claim 1. (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- Plaintiff’s "rain shower head" sold on Amazon.com under various ASINs, including B0FH1577WQ and B0DQHFG94H (the Accused Product). (Compl. ¶¶9, 23; Compl. ¶¶5-6).
Functionality and Market Context
- The complaint describes the Accused Product as employing a "rotatable disc/faceplate mechanism" that operates in "multiple discrete positions." (Compl. ¶27).
- This mechanism is alleged to route water through different internal passageways to various outlets, including "side outlets" and "selected subsets of faceplate nozzles." (Compl. ¶27).
- The complaint notes that the Accused Product's selector includes an "off" position where no water is discharged, a feature Plaintiff contends is not recited in Claim 1. (Compl. ¶27).
- Plaintiff identifies the Amazon marketplace as its primary sales channel in the United States, positioning the threatened removal of its product listings as a significant commercial harm. (Compl. ¶¶13-14).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiff’s allegations regarding how its Accused Product does not meet the limitations of Claim 1 of the ’435 Patent.
’435 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flow selector moveable between a first position... a second position... and a third position... | The Accused Product uses a "rotatable disc/faceplate mechanism" with "multiple discrete positions" and an additional "off" position. | ¶¶23, 27 | col. 9:12-18 |
| ...in which water flow is directed through the plurality of first nozzles... | The Accused Product's selector routes water to "selected subsets of faceplate nozzles," rather than the entire plurality of first nozzles. | ¶27 | col. 9:14-15 |
| wherein the second nozzle is configured to create a first type of the flow of water, and the third nozzle is configured to create a second type of the flow of water different from the first type... | The complaint does not provide sufficient detail for analysis of the specific flow types created by the nozzles of the Accused Product. | N/A | col. 9:21-25 |
| wherein the flow selector is configured to remain in one of the first position, the second position, or the third position without an external force... | The complaint does not directly address whether the Accused Product's selector remains in position without external force, but describes a mechanism with "discrete positions," which may imply such a feature. | ¶27 | col. 9:26-30 |
- Identified Points of Contention:
- Scope Questions: A primary dispute may arise over the term "a flow selector moveable between a first position... a second position... and a third position." The question for the court will be whether the Accused Product's "rotatable disc" with "multiple discrete positions" and an "off" setting falls within the scope of this limitation, or if it represents a materially different structure. (Compl. ¶¶23-24).
- Technical Questions: The complaint raises a factual question of correspondence. Does routing water to "selected subsets of faceplate nozzles," as the Accused Product allegedly does, satisfy the claim requirement of directing flow "through the plurality of first nozzles"? (Compl. ¶27). This suggests a potential mismatch between the operation of the accused device and the specific functional outcomes required by the claim.
V. Key Claim Terms for Construction
- The Term: "a flow selector moveable between a first position ... a second position ... and a third position"
- Context and Importance: This term is central to the dispute, as Plaintiff alleges its "rotatable disc/faceplate mechanism" is a "materially different flow-selection structure." (Compl. ¶23). The construction of this term will determine whether the accused mechanism, with its multiple positions and "off" state, can be read upon by the claim language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is functional, describing movement between positions that result in different water flows. Plaintiff (the patentee in a counterclaim) may argue this language covers any mechanism capable of selecting between at least three specified flow paths, regardless of its specific mechanical implementation. The specification describes a "flow selector 116" that is "configured to allow the user to move the flow director to a desired one of the first position, the second position, and the third position." (’435 Patent, col. 2:10-13).
- Evidence for a Narrower Interpretation: The specification and figures disclose a specific embodiment: a pivoting lever-type selector that actuates a flow director using a ball-and-socket joint and is retained in position by spring-loaded pins engaging with indentations. (’435 Patent, col. 5:8-21; Figs. 2C, 5A). Defendant (the DJ Plaintiff) will likely argue that the term should be construed more narrowly in light of these specific disclosures, distinguishing it from a "rotatable disc."
VI. Other Allegations
- Indirect Infringement: The complaint preemptively denies any indirect infringement, stating that Plaintiff "has not encouraged or intended that customers practice every limitation of any asserted claim" and that the Accused Product is a "staple article of commerce suitable for substantial non-infringing uses." (Compl. ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on fundamental questions of claim scope and technical operation. The key issues for the court will likely be:
- A core issue will be one of structural and functional correspondence: Does the accused "rotatable disc/faceplate mechanism," which allegedly features multiple positions including an "off" state, constitute the "flow selector moveable between a first... second... and a third position" as required by Claim 1, or is it a non-equivalent design?
- A key evidentiary question will be one of operational fidelity: Does the Accused Product's method of routing water to "selected subsets of faceplate nozzles" satisfy the claim limitation requiring water to be "directed through the plurality of first nozzles," or does this represent a material deviation in function that avoids infringement?