DCT
2:25-cv-02742
Shenzhen Yuansanding Technology Co Ltd v. Flip It Cap LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Yuansanding Technology Co., Ltd. (People's Republic of China)
- Defendant: Flip It Cap LLC (Massachusetts)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02742, W.D. Wash., 12/30/2025
- 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 a proceeding against Plaintiff’s Amazon listing, which foreseeably caused actions by Amazon personnel located in Seattle.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "pack bottle emptying cap" product does not infringe Defendant's design patent for a "Fitment Adaptor."
- Technical Context: The dispute concerns the ornamental design of consumer product accessories used as adaptors or caps for bottles.
- Key Procedural History: The complaint states this action was precipitated by Defendant causing Amazon to remove Plaintiff's product listing based on a report of infringement of the patent-in-suit. This enforcement action created the "actual case or controversy" required for a declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-17 | D'668 Patent Application (Priority) Date |
| 2015-07-21 | D'668 Patent Issue Date |
| 2025-11-25 | Amazon Notifies Plaintiff of Product Listing Removal |
| 2025-12-30 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D734,668 S - *"Fitment Adaptor"*
The patent-in-suit is U.S. Design Patent No. D734,668 S, "Fitment Adaptor," issued July 21, 2015 (the "'668 Patent"). (Compl. ¶13; '668 Patent, p. 1).
The Invention Explained
- Problem Addressed: As a design patent, the '668 Patent does not describe a technical problem or functional solution; rather, it protects the novel, non-obvious, and ornamental appearance of an article of manufacture. (D'668 Patent, Claim). The patent is directed to the specific aesthetic appearance of a fitment adaptor.
- The Patented Solution: The patent claims "The ornamental design for a fitment adaptor, as shown." ('668 Patent, p. 1). The claimed design, illustrated in five figures, consists of a generally annular, ring-like object. (D'668 Patent, Figs. 1-5). Key ornamental features include a ridged or geared texture on the upper portion of the exterior cylindrical surface, a series of uniform horizontal ribs on the lower portion of the exterior, and a smooth, unadorned interior surface. (D'668 Patent, Figs. 1, 3, 4). The top and bottom views depict a clean, circular profile with concentric rings. (D'668 Patent, Figs. 2, 5).
- Technical Importance: The design provides a specific ornamental appearance for what the complaint identifies as a "pack bottle emptying cap," a common type of consumer product accessory. (Compl. ¶8).
Key Claims at a Glance
- The single claim of the '668 Patent is asserted: "The ornamental design for a fitment adaptor, as shown." (Compl. ¶23; '668 Patent, p. 1).
- The essential ornamental features that constitute the claimed design include:
- The overall proportions and ring-like profile.
- The combination of a ridged upper exterior and a ribbed lower exterior.
- The unadorned, smooth appearance of the top, bottom, and interior surfaces.
- The specific visual relationship between these features as depicted in the patent figures.
III. The Accused Instrumentality
Product Identification
Plaintiff’s "pack bottle emptying cap" (the "Accused Product"). (Compl. ¶23).
Functionality and Market Context
The Accused Product is designed, sourced, and sold by Plaintiff on Amazon.com and other e-commerce channels. (Compl. ¶8). The complaint alleges that Amazon is Plaintiff's "primary sales channel in the United States" for the product. (Compl. ¶12). The dispute arose after Defendant initiated an infringement report that resulted in the removal of Plaintiff's Amazon product listing. (Compl. ¶9).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, arguing that the Accused Product and the patented design are not substantially the same from the perspective of an ordinary observer. (Compl. ¶¶ 18, 20). The plaintiff's theory of non-infringement centers on several alleged visual differences between its product and the patented design.
No probative visual evidence provided in complaint.
'668 Patent Non-Infringement Allegations
| Patented Design Feature (from '668 Patent) | Plaintiff's Alleged Different Feature in Accused Product | Complaint Citation | Patent Citation |
|---|---|---|---|
| A clean, continuously annular, predominantly circular overall appearance and proportions. | An overall perimeter presentation and proportions that differ from the patented design. | ¶21 | Figs. 1-5 |
| A clean, unadorned top surface appearance. | A top view that reflects a "more structurally articulated interior appearance." | ¶21 | Fig. 5 |
| A clean, unadorned bottom surface appearance. | A bottom view that includes "conspicuous molded surface markings." | ¶21 | Fig. 2 |
| A streamlined, uniform ring-like side profile. | A side profile that appears "thicker and more heavily articulated." | ¶21 | Figs. 3, 4 |
- Identified Points of Contention:
- Scope Questions: The central question for the court will be whether the combination of alleged differences in proportion, surface articulation, and profile is sufficient to create an overall visual impression in the mind of an ordinary observer that is plainly dissimilar from the patented design.
- Technical Questions: A key factual question will be how the specific visual features of the Accused Product (e.g., "structurally articulated interior," "molded surface markings") compare to the clean lines depicted in the '668 Patent's figures. The analysis will depend on the visual evidence presented, which the complaint references in an unattached exhibit. (Compl. ¶18, Ex. C).
V. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action will likely center on the single, holistic test for design patent infringement. The key questions for the court are:
- A core issue will be one of holistic visual comparison: When viewed as a whole, do the alleged differences in the Accused Product's proportions, surface details, and profile create a distinct overall ornamental appearance, or would an ordinary observer be deceived into believing the Accused Product is the same as, or substantially the same as, the design claimed in the '668 Patent?
- A related evidentiary question will concern the impact of prior art: How will the landscape of prior art designs for bottle caps and fitment adaptors inform the perspective of the ordinary observer? The scope of protection afforded to the '668 Patent's design may be narrowed if the prior art is crowded, making the alleged differences in the Accused Product appear more significant.