DCT
2:25-cv-02743
Datian County Qicai Clothing Shop v. Goodegg Stuff LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Datian County Qicai Clothing Shop d/b/a DATIANSOFU (China)
- Defendant: Goodegg Stuff LLC (Delaware)
- Plaintiff’s Counsel: Glacier Law LLP
- Case Identification: 2:25-cv-02743, W.D. Wash., 12/30/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant directed patent enforcement activities into the district by initiating an Amazon patent-enforcement proceeding, which foreseeably caused actions by Amazon personnel located in Seattle, Washington.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Egg Washer" product does not infringe Defendant's patent related to an egg washing brush, and/or that the patent is invalid.
- Technical Context: The technology concerns manual cleaning devices specifically designed with a contoured shape and internal bristles for washing individual eggs, a product category relevant to hobby farmers and home consumers.
- Key Procedural History: The dispute arose after Defendant submitted a patent-infringement report to Amazon, which resulted in the temporary removal of Plaintiff's product listing. Although Amazon later reinstated the listing following an appeal by Plaintiff, Plaintiff asserts that the ongoing threat of enforcement creates a justiciable controversy.
Case Timeline
| Date | Event |
|---|---|
| 2023-04-11 | ’567 Patent Priority Date |
| 2024-09-17 | ’567 Patent Issue Date |
| 2024-12-20 | Defendant initiates Amazon patent enforcement, causing removal of Plaintiff's product |
| 2025-02-07 | Amazon reinstates Plaintiff's product listing |
| 2025-12-30 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,089,567 - *"APPARATUS AND METHOD FOR EGG WASHING BRUSH"*
- Patent Identification: U.S. Patent No. 12,089,567, "APPARATUS AND METHOD FOR EGG WASHING BRUSH," issued September 17, 2024 (the "’567 Patent"). (Compl. ¶15-16).
The Invention Explained
- Problem Addressed: The patent's background section identifies a lack of suitable tools for hobby farmers or individual consumers to clean eggs, noting they often must use "brushes created for other purposes" or flat devices that are not "compatible with the contours of an egg" (’567 Patent, col. 1:26-30).
- The Patented Solution: The invention is a "deformable half egg-shaped shell" containing a network of "bristle bands" with inwardly-facing "protrusions" that create a cavity for holding and scrubbing an egg (’567 Patent, Abstract; col. 1:53-59). This design allows the apparatus to conform to the egg's surface for more effective and convenient cleaning, as illustrated in the internal view provided in Figure 1.
- Technical Importance: The invention provides a purpose-built, ergonomic tool for a common but underserved task, aiming to improve cleaning effectiveness over generic brushes (’567 Patent, col. 1:40-44).
Key Claims at a Glance
- The complaint challenges independent claims 1 (apparatus) and 10 (method) (Compl. ¶21).
- Claim 1 (Apparatus) Elements:
- A half egg-shaped shell comprising a flexible material
- A plurality of bristle bands, at least two of which intersect each other
- The bristle bands define an egg washing cavity
- A plurality of bristle protrusions extending inward from the bristle bands and configured to contact an egg
- Claim 10 (Method) Elements:
- Providing the apparatus of Claim 1
- Inserting an egg into the egg washing cavity
- Optionally providing a cleaning agent
- Introducing the cleaning agent into the cavity
- Rotating the egg within the cavity to contact the protrusions
- The complaint states that Plaintiff denies infringement of any dependent claims as well (Compl. ¶21, 25, 27).
III. The Accused Instrumentality
Product Identification
- Plaintiff’s "Egg Washer" products sold on Amazon.com (Compl. ¶22).
Functionality and Market Context
- The complaint alleges the Accused Product has an "overall external contour of a cartoon chicken head, with raised surface features such as eyes, a beak, and a comb" (Compl. ¶23). It is further alleged that the product's internal structure is different from that claimed in the ’567 Patent, asserting that it "does not form strip- or rib-like bristle bands" (Compl. ¶24). Plaintiff identifies Amazon as its primary sales channel in the United States, positioning the product for the e-commerce market (Compl. ¶14). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment of non-infringement, the following table summarizes the Plaintiff's asserted distinctions between the patent claims and the Accused Product.
- ’567 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a half egg-shaped shell comprising a flexible material | The Accused Product has the external contour of a "cartoon chicken head" with raised surface features, rather than a smooth, continuous "half egg-shaped shell." | ¶23 | col. 3:52-53 |
| a plurality of bristle bands at least two of which intersect each other | The Accused Product allegedly "does not include bristle bands as claimed" and instead has a "different structural configuration that does not form strip- or rib-like bristle bands" that intersect. | ¶24 | col. 4:3-5 |
- Identified Points of Contention:
- Scope Questions: The dispute raises a question of claim scope regarding whether the term "half egg-shaped shell," depicted in the patent as a simple geometric form, can be interpreted to read on a novelty shape like a "cartoon chicken head" that serves a similar function.
- Technical Questions: A central technical question is whether the Accused Product's internal structure contains elements that meet the claim limitations of "a plurality of bristle bands" and their "intersect[ion]," or if its configuration is, as the complaint alleges, fundamentally different from the claimed "strip- or rib-like" structure (Compl. ¶24).
V. Key Claim Terms for Construction
The Term: "half egg-shaped shell"
- Context and Importance: This term is central to the non-infringement argument, as Plaintiff's primary defense is that its "cartoon chicken head" product does not have a "half egg-shaped shell" (Compl. ¶23). The construction of this term may be dispositive of literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the shell as "deformable," which could suggest that its precise geometric shape is less critical than its function of cupping an egg (’567 Patent, col. 3:52).
- Evidence for a Narrower Interpretation: The claim language itself is geometrically specific. Further, the patent's figures consistently depict a smooth, semi-ovoid structure, and the detailed description repeatedly refers to the "deformable half egg-shaped shell 102" in reference to these drawings (’567 Patent, FIG. 1-2; col. 3:52).
The Term: "bristle bands"
- Context and Importance: Plaintiff alleges its product lacks the claimed "bristle bands," describing them as "strip- or rib-like" structures that its product does not possess (Compl. ¶24). The definition of what constitutes a "band" will be critical to determining if the accused internal structure infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "band," which could allow for an interpretation covering any raised linear structure from which bristles protrude.
- Evidence for a Narrower Interpretation: The patent figures depict "bristle bands 106" as distinct, rib-like structures that "radiate from the top center" or are "spaced around the circumference," suggesting discrete elements rather than a more integrated or uniform bristled surface (’567 Patent, FIG. 1; col. 4:1-5). Plaintiff’s characterization in the complaint suggests it will advocate for this narrower construction.
VI. Other Allegations
- Indirect Infringement: Plaintiff denies any allegation of indirect infringement, including inducement or contributory infringement under 35 U.S.C. § 271(b) or (c) (Compl. ¶29). The complaint does not provide further factual detail on this denial.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on three fundamental questions for the court:
- A core issue will be one of definitional scope: can the term "half egg-shaped shell," which is rooted in a specific geometric description and consistent visual depictions in the patent, be construed broadly enough to cover the Accused Product’s functionally similar but aesthetically distinct "cartoon chicken head" design?
- A second key issue will be one of structural interpretation: does the Accused Product's internal cleaning surface contain structures that meet the claim requirement of "a plurality of bristle bands, at least two of which intersect," or is its configuration, as alleged, technically distinct from the "strip- or rib-like" arrangement disclosed in the patent?
- Independent of the infringement analysis, a dispositive question will be obviousness: do the prior art references cited in the complaint, which allegedly teach a half egg-shaped shell, intersecting bristle strips, and one-piece flexible molding, render the asserted claims of the ’567 Patent invalid as obvious to a person of ordinary skill in the art?