Goclips LLC v. Tools for Trade LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: GoClips LLC (Florida); Z Keepers LLC (Florida)
  • Defendant: Tools for the Trade, LLC (Arizona)
  • Plaintiff's Counsel: Fennemore Craig, P.C.
• Case Identification: 2:26-cv-06291, D. Ariz., 09/02/2026
• Venue Allegations: Venue is asserted based on the Defendant regularly conducting business in the District of Arizona, a substantial part of the events giving rise to the action occurring in the district, and the commission of infringing acts within the district.
• Core Dispute: Plaintiff alleges that Defendant's "Sun Clips" sink anchors infringe a patent related to mechanical clamps for undermounting sinks to hard countertops.
• Technical Context: The technology involves mechanical hardware used in the home construction and remodeling industry to securely fasten undermount sinks to materials like granite or stone.
• Key Procedural History: The complaint alleges that after Plaintiffs sent a cease-and-desist letter regarding the sale of accused "Sun Clips," Defendant promised to stop and entered into a distribution agreement to sell Plaintiffs' authentic products, only to secretly continue selling the accused products, creating a significant issue regarding willful infringement.

Case Timeline

Date	Event
2014-12-10	'754 Patent Priority Date
2014-12-13	Plaintiffs' first alleged use of "GoClips" trademark
2015-05-19	Plaintiffs' "GoClips" trademark registration date
2017-11-28	'754 Patent Issue Date
2024-04-17	Date of invoice allegedly showing Defendant "palming off" accused products
2026-09-02	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

• Patent Identification: U.S. Patent No. 9,828,754 ("Sink Clamp and Methods"), issued November 28, 2017.

The Invention Explained

• Problem Addressed: The patent's background describes conventional methods for attaching undermount sinks to hard-surface countertops as time-consuming, difficult to perform in confined under-sink spaces, and prone to failure (Compl. ¶9, Compl. ¶27; '754 Patent, Compl. ¶¶col. 1:10-24). Existing methods often require drilling into the countertop, applying two-part epoxies, or building wooden support cradles, all of which are described as labor-intensive and risk damaging the materials '754 Patent, col. 1:10-65
• The Patented Solution: The invention is a one-piece clamping device that simplifies installation by using a pre-cut slot in the underside of the countertop rather than a drilled hole '754 Patent, col. 2:36-41 A "binding lip" on the clamp is inserted into the slot, and a screw mechanism is tightened against the sink's rim '754 Patent, Fig. 1 This tightening action causes the device to pivot, making the binding lip grip the inside of the slot and securely clamp the sink to the countertop '754 Patent, col. 4:3-9 This design is intended to allow for quick, tool-free (other than a grinder to make the slot), one-handed installation '754 Patent, col. 6:53-61
• Technical Importance: The patented method and device offer a faster and less-invasive way to install undermount sinks, which gained a foothold with professionals and DIY consumers by reducing labor time and the risk of damaging expensive countertops Compl. ¶19 Compl. ¶27

Key Claims at a Glance

• The complaint asserts that the accused products "embody each of the claims of the '754 patent" Compl. ¶31 The key independent claims appear to be Claim 1 (a system claim including the sink) and Claim 11 (a device claim for the clamp itself).
• Essential elements of independent claim 11 (the device claim) include:
  • A clamp body.
  • An "insertable end" configured for insertion into a slot in a countertop.
  • A "clamping spring" connected to the body, which has a "deflectable portion" extending at an upward angle.
  • The deflectable portion is configured to contact the sink and transmit an "upward clamping spring force" when deflected.
  • The clamping spring has a hole and is connected to the clamp body by a "fastener horizontally offset from the insertable end."
• The complaint does not specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

• The accused products are sink anchoring clamps referred to by Defendant as "Sun Clips" Compl. ¶22

Functionality and Market Context

• The complaint alleges that the "Sun Clips" are "knockoff devices" that are "identical in appearance, form, and function to authentic GoClips® sink anchoring clips" Compl. ¶5 They are imported, marketed, and sold for the same purpose: to undermount sinks to hard countertop surfaces Compl. ¶2 Compl. ¶5 The complaint alleges Defendant sourced these products from a manufacturing facility in China and marketed them to the same customers as Plaintiffs Compl. ¶20 Compl. ¶33 An image of the accused "Sun Clips" shows a metal clamp with a screw and a spring-like component, appearing structurally similar to Plaintiffs' product Compl. ¶22, p. 8

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Sun Clips" infringe all claims of the '754 Patent Compl. ¶31 The analysis below focuses on independent claim 11, a device claim, as representative of the core infringement theory.

'754 Patent Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a clamping device for mounting a sink to a countertop comprising: a clamp body;	The accused "Sun Clips" are described as sink anchoring clamps possessing a main structural body.	¶22	col. 3:12-18
an insertable end of the clamp body, said insertable end being configured for insertion in an upward insertion direction into a slot in a bottom surface of a countertop...	The accused device includes a flat tab designed to be inserted into a slot cut into the countertop underside, which the complaint alleges functions identically to the patented invention.	¶5	col. 3:32-37
a clamping spring connected to the clamp body, the clamping spring in a relaxed state including a deflectable portion extending at an upward angle...	The accused "Sun Clip" includes a separate, spring-like metal component connected to the body that extends at an upward angle, as depicted in a photograph.	¶22	col. 7:50-54
...the deflectable spring portion in said relaxed state configured to contact a portion of the sink... to transmit an upward clamping spring force to the portion of the sink when the insertable end is further inserted into said slot...	The complaint alleges the accused device functions identically to Plaintiffs' product, which uses this principle to clamp the sink against the countertop when a screw is tightened. An invoice shows the device sold as a "GoClips Standard" for this purpose.	¶5; ¶23	col. 4:3-9
...wherein the clamping spring has a hole and the clamping spring is connected to the clamp body by a fastener horizontally offset from the insertable end.	A photograph of the accused product appears to show the spring component is attached to the clamp body with a fastener (e.g., a rivet) that is located away from the insertable tab end.	¶22	col. 7:60-65

• Identified Points of Contention:
  • Factual Question: The central dispute appears to be factual rather than a complex issue of claim interpretation. The primary question is whether the accused "Sun Clips" are, as the complaint alleges, structurally and functionally identical to the claimed invention. Any subtle differences in the materials, geometry, or mechanical operation of the accused device's "clamping spring" could become a focus for a non-infringement defense.
  • Scope Question: A potential point of contention could arise over the term "clamping spring". A defense argument may question whether the accused product's angled lever component meets the functional requirements of a "spring" that is "deflected" to "transmit an upward clamping spring force," or if it achieves its clamping function through a different mechanical principle.

V. Key Claim Terms for Construction

• The Term: "clamping spring"

• Context and Importance: This term is central to the device's claimed mechanism of action. The infringement analysis depends on whether the component on the accused "Sun Clips" that contacts the sink functions as a "clamping spring." Practitioners may focus on this term because the defense could argue their component is merely a rigid lever and does not rely on the elastic, force-transmitting properties implied by "spring."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent specification refers to this component not just as a "spring" but also as a "binding or clamping tab," which may suggest a broader meaning that is not limited to a traditional spring (e.g., a coil or leaf spring) '754 Patent, col. 3:14
  • Evidence for a Narrower Interpretation: The claims consistently describe the component's function in terms of being "deflected" to "transmit an upward clamping spring force" ('754 Patent, claims 1, 11). This functional language, combined with the clear depiction of a leaf-spring-like part in the patent's figures, could support a narrower construction requiring specific elastic properties '754 Patent, Fig. 1

• The Term: "fastener horizontally offset from the insertable end"

• Context and Importance: This limitation defines the specific geometry of the clamp's assembly. Its construction is important because if the accused product's spring-like component is attached in a different configuration (e.g., not "horizontally offset"), it may fall outside the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent figures consistently show the fastener connecting the spring to the clamp body at a location separate and distinct from the "insertable end," along the main axis of the device '754 Patent, Fig. 1 '754 Patent, Fig. 4 This may support an interpretation where any clear spatial separation along the device's length meets the "horizontally offset" requirement.
  • Evidence for a Narrower Interpretation: A defendant could argue that "horizontally offset" implies a specific orientation relative to the countertop or a minimum distance of separation that its product does not satisfy. The term is not explicitly defined, leaving its precise geometric meaning open to debate.

VI. Other Allegations

• Willful Infringement: The complaint makes specific allegations supporting willfulness Compl. ¶42 It claims Defendant had pre-suit knowledge of the '754 patent via a cease-and-desist letter Compl. ¶24 The complaint further alleges that after receiving notice, Defendant promised to stop infringing and entered into a distribution agreement for Plaintiffs' authentic products, only to then "in secret willfully and intentionally" continue selling counterfeit "SunClips" Compl. ¶25 Compl. ¶29 The complaint includes an invoice allegedly showing Defendant supplying the accused products to a customer who had ordered authentic "GoClips," an act described as "palming off" Compl. ¶23

VII. Analyst's Conclusion: Key Questions for the Case

1. A central issue will be one of factual identity: Can Plaintiffs establish that the accused "Sun Clips" are structurally and functionally indistinguishable from the device claimed in the '754 Patent, or will Defendant be able to demonstrate a material technical difference in its product's design, materials, or mechanism of action that avoids infringement?
2. A second key question will concern willfulness and intent: Given the allegations that Defendant promised to cease infringing conduct and then secretly resumed selling accused products while acting as an authorized distributor for Plaintiffs, the case will likely turn on the evidence presented regarding Defendant's knowledge and intent, which could significantly impact potential damages.