DCT
2:26-cv-02717
Shenzhen Huajing Intl Trade Co Ltd v. Grease Box LLC
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Huajing International Trade Co., Ltd. (People's Republic of China)
- Defendant: The Grease Box LLC (Arizona)
- Plaintiff's Counsel: LawMay P.C.
- Case Identification: 2:26-cv-02717, D. Ariz., 04/19/2026
- Venue Allegations: Venue is alleged to be proper in the District of Arizona because the Defendant, The Grease Box LLC, is domiciled and resides in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its products do not infringe Defendant's patent for grease containment systems, and further alleges tortious interference and bad faith patent assertions by the Defendant related to product delistings on Amazon.
- Technical Context: The technology relates to safety enclosures for grease collection buckets used with outdoor cooking devices like grills and smokers, designed to prevent spills, burns, and fires.
- Key Procedural History: The complaint follows Defendant's submission of a patent infringement complaint via Amazon's Patent Evaluation Express (APEX) program, which resulted in the removal of Plaintiff's products. Plaintiff previously filed a related action in the Western District of Washington, which was dismissed for lack of personal jurisdiction, leading to this refiling in Defendant's home district of Arizona.
Case Timeline
| Date | Event |
|---|---|
| 2020-08-04 | '895 Patent Application Filing Date |
| 2023-11-14 | '895 Patent Issue Date |
| 2024-11-01 | (Approx.) Defendant submitted APEX complaint to Amazon |
| 2025-02-03 | Plaintiff's products delisted from Amazon |
| 2025-02-10 | (Approx.) Defendant allegedly listed its own corresponding product on Amazon |
| 2025-02-17 | Plaintiff's counsel contacted Defendant with non-infringement analysis |
| 2026-04-19 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,812,895 - "Grease containment systems"
- Patent Identification: U.S. Patent No. 11,812,895, "Grease containment systems," issued November 14, 2023.
The Invention Explained
- Problem Addressed: The patent's background section identifies several problems with simple, open-top grease collection buckets used for outdoor cookers: they can be easily spilled, creating messes and slipping hazards; the hot grease poses a burn risk, especially to children and pets; collected water can cause overflow; and hot air from the cooker's drain can pose a fire risk '895 Patent, col. 1:7-34
- The Patented Solution: The invention is a safety system comprising an enclosure that surrounds the grease bucket '895 Patent, abstract This enclosure is designed to create a "thermal buffer," securely mount to the cooker's drain for stability, and provide features like ventilation to cool the collected grease '895 Patent, abstract The enclosure consists of a separable upper and lower portion, includes a specific support structure for the receptacle (bucket) within the lower portion, and features an insulation layer between the receptacle and the enclosure's side walls '895 Patent, col. 11:40 - col. 12:2
- Technical Importance: The invention aims to improve the safety of a common accessory for outdoor cooking by addressing multiple hazards-spills, burns, and fire-through a single, integrated mechanical enclosure '895 Patent, col. 1:35-37
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1 and 16 Compl. ¶¶26-30
- Independent Claim 1 recites a system for catching fluid drainage, with key elements including:
- a receptacle to collect fluid;
- an enclosure to enclose the receptacle, itself comprising:
- an "upper portion" comprising a top and side walls;
- a "lower portion" comprising a bottom and side walls, separable from the upper portion;
- "at least one receptacle support" within the lower portion, structured to support the receptacle;
- a mount with a mounting flange to attach the enclosure to the cooker's drain;
- "at least one insulation layer" between the receptacle and the side walls.
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement for "any valid or enforceable claim" of the patent Compl. ¶33
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "grease bucket products" sold by the Plaintiff on its Amazon storefront under the brand name VattaFrast Compl. ¶3 Compl. ¶5 The complaint identifies specific products by their Amazon Standard Identification Numbers (ASINs): B0DJFNG1DP, B0DNSP3TFJ, B0DSVQ4SND, and B0DJBB85FK Compl. ¶13
Functionality and Market Context
- The complaint describes the Accused Products as grease buckets for use with outdoor cooking devices Compl. ¶12 The functionality at issue is how the product's two-part structure holds a grease receptacle. The complaint alleges these products are key to Plaintiff's U.S. business operations and that their delisting from Amazon caused significant disruption Compl. ¶12 Compl. ¶16 The complaint further alleges that the Defendant sells competing grease-collection products on Amazon under the brand name THE GREASE BOX Compl. ¶17
IV. Analysis of Infringement Allegations
The complaint argues for non-infringement by presenting several structural differences between the Accused Products and the requirements of the patent claims.
The complaint includes a side-by-side visual comparison arguing that the Accused Product's receptacle rests directly on the bottom of the enclosure, which it alleges is distinct from the claimed "receptacle support" Compl. FIG. 1
The complaint provides a visual to support its argument that the top part of the Accused Product has no side walls, and therefore cannot be the claimed "upper portion" Compl. FIG. 2
A third visual provided in the complaint aims to show that the Accused Product lacks the claimed "insulation layer" because the receptacle is in direct contact with the bottom of the enclosure Compl. FIG. 3
'895 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an upper portion comprising a top and side walls | The complaint alleges the upper portion of the Accused Products consists of only a top without any side walls. | ¶27 | col. 11:53-54 |
| a lower portion comprising a bottom and side walls surrounding the at least one receptacle | The complaint alleges the Accused Products lack this element, but does not specify the structural deficiency beyond what is shown in its figures. | ¶26 | col. 11:55-58 |
| at least one receptacle support within the lower portion of the enclosure, the at least one receptacle support structured and arranged to support said at least one receptacle | The complaint alleges the Accused Products lack a separate, dedicated "receptacle support," stating the receptacle is instead supported directly by the bottom of the enclosure itself. | ¶26 | col. 8:30-34 |
| wherein said enclosure comprises at least one insulation layer between said receptacle and the side walls | The complaint alleges the Accused Products have no insulation layer, as the receptacle is in direct contact with the enclosure. | ¶28 | col. 9:24-34 |
Identified Points of Contention
- Scope Questions: The dispute raises the question of whether the "bottom" of the enclosure can also serve as the claimed "receptacle support," or if the claim requires two structurally distinct components. The complaint cites case law to support the latter interpretation Compl. ¶31
- Technical Questions: A central factual question is whether the Accused Product's upper component, which allegedly lacks vertical walls, can meet the claim limitation of "an upper portion comprising a top and side walls." Similarly, the court may need to determine if direct contact between the receptacle and the enclosure forecloses the presence of an "insulation layer" as construed from the patent.
V. Key Claim Terms for Construction
The Term: "at least one receptacle support"
- Context and Importance: The complaint's primary non-infringement argument hinges on this term Compl. ¶26 Plaintiff argues its product lacks this element entirely, asserting the receptacle simply rests on the "bottom" of the enclosure. The case may turn on whether the "bottom" can also be the "receptacle support," or if the claim requires a separate structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any surface that holds the receptacle up, including the bottom of the enclosure, functions as a "support."
- Evidence for a Narrower Interpretation: The complaint argues that because Claim 1 recites a "bottom" and a "receptacle support" as separate elements of the lower portion, they must be structurally distinct Compl. ¶31 The patent specification describes and illustrates the "receptacle support" (375) as a distinct flange structure that "suspends" the receptacle (370) within the lower portion, separate from the "bottom" (285) '895 Patent, FIG. 3 '895 Patent, col. 8:30-34
The Term: "upper portion comprising a top and side walls"
- Context and Importance: Plaintiff alleges its product does not meet this limitation because its upper component is just a "top without any side walls" Compl. ¶27 The definition of what constitutes "side walls" in the context of the patent will be critical to this infringement question.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any vertical or angled surface descending from the top, however short, could be considered a "side wall."
- Evidence for a Narrower Interpretation: The patent figures consistently show the upper portion (200) with distinct, substantial vertical side walls (230) that are separate from the top (280) '895 Patent, FIG. 2 '895 Patent, FIG. 3 This may suggest that minor lips or flanges are insufficient to meet the limitation.
VI. Other Allegations
Tortious Interference & Bad Faith Assertions
The complaint alleges that Defendant's infringement assertions to Amazon were made in bad faith and constituted tortious interference with Plaintiff's business relationships Compl. ¶¶34-45 The factual basis for these allegations includes:
- Defendant's alleged failure to conduct a substantive pre-assertion analysis, given the clear structural differences between the Accused Products and the patent's claims Compl. ¶9 Compl. ¶41
- Defendant's refusal to withdraw the Amazon complaint after being presented with a detailed non-infringement analysis by Plaintiff's counsel Compl. ¶19
- The timing of Defendant allegedly listing its own competing product on Amazon approximately one week after Plaintiff's products were removed Compl. ¶52
Arizona Statutory Claims
The complaint alleges that this same conduct violates the Arizona Patent Troll Prevention Act (PTPA) and Arizona Consumer Fraud Act (ACFA) Compl. ¶¶46-55 The complaint argues Defendant's actions constitute a "bad faith assertion of patent infringement" under the PTPA Compl. ¶50
VII. Analyst's Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: must the "receptacle support" be a structurally distinct component from the "bottom" of the enclosure, as the patent figures and separate recitation in the claim might suggest, or can a single surface satisfy both limitations?
- A second key question will be factual infringement: does the accused product's upper component, which the plaintiff alleges is merely a flat "top," possess structure that can be considered "side walls" within the meaning of the claim, and does the direct contact between the receptacle and enclosure preclude the existence of the claimed "insulation layer"?
- Finally, the case presents a question of commercial conduct: did the patent owner's use of the Amazon APEX platform to delist a competitor's product, and its subsequent refusal to withdraw the complaint, constitute a bad faith assertion and tortious interference, particularly in light of the specific non-infringement arguments raised?
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