DCT

1:26-cv-08474

Lekele Guangzhou Technology Co Ltd v. Diedrichsen

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-08474, N.D. Ill., 07/17/2026
  • Venue Allegations: Plaintiffs allege venue is proper in the Northern District of Illinois because Defendants have purposefully directed patent enforcement activities to the district, including filing prior patent lawsuits, and because the current dispute arises from these activities and threatens commerce in Illinois.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their poultry feeder port product does not infringe the Defendants' patent and/or that the patent is invalid, filed in response to Defendants' assertion of infringement in an Amazon Patent Evaluation Express (APEX) proceeding.
  • Technical Context: The technology involves feeder ports for animal feed containers, designed to allow access for poultry while restricting access for pests like rodents and insects, thereby reducing contamination and feed loss.
  • Key Procedural History: The action was precipitated by Defendants' initiation of an Amazon APEX proceeding asserting infringement of U.S. Patent No. 12,642,252. The complaint also notes that Defendants have previously filed at least three patent enforcement actions in the same district concerning related design patents for their "Poultry Pro Feeder" product line. Plaintiffs explicitly dispute that the asserted patent is entitled to its claimed priority date, which could impact the scope of applicable prior art.

Case Timeline

Date Event
2020-05-26 Earliest Priority Date (''252 Patent)
"Since at least 2024" Plaintiffs' sales of Accused Product begin
2026-06-02 ''252 Patent Issued
2026-06-29 Defendants initiate Amazon APEX Proceeding
2026-07-17 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,642,252 - "Feeder Port"

  • Patent Identification: U.S. Patent No. 12,642,252, titled "Feeder Port," issued June 2, 2026 (the "'252 Patent").

The Invention Explained

  • Problem Addressed: The patent's background describes a common challenge with conventional animal feeders: their openings are often accessible to rodents, pests, and insects, which can lead to feed contamination, disease transmission, and economic loss '252 Patent, col. 1:56-65
  • The Patented Solution: The invention is a specially designed port that can be installed into a feed container (e.g., a bucket). It comprises a tubular body with a distinct entry portion and a downward-facing exit portion, allowing an animal like a chicken to access feed '252 Patent, Fig. 8 A collar prevents the port from falling completely into the container, while external threading and a corresponding bushing are used to secure it in place through a hole in the container wall '252 Patent, col. 4:38-54 '252 Patent, abstract
  • Technical Importance: This design seeks to provide controlled access to feed for intended livestock while creating a barrier against pests, thereby improving feeder sanitation, reducing feed waste, and lowering costs for farmers '252 Patent, col. 2:7-16

Key Claims at a Glance

  • The complaint seeks a declaratory judgment of non-infringement and invalidity with respect to Claim 1 of the '252 Patent Compl. ¶¶37-47
  • Independent Claim 1 of the '252 Patent recites:
    • A feeder port with a tubular body.
    • The tubular body includes an internal cavity, a first base, and a second base.
    • An "entry portion" at the first base with an "outwardly flared lip" provides access.
    • An "exit portion" that is "perpendicular to the second base" provides a "downward facing exit."
    • A "collar" protrudes around the body between the entry and exit portions.
    • "External threading" is located on the tubular body "between the collar and the entry portion."
    • The external threading is configured to receive a "bushing."

III. The Accused Instrumentality

Product Identification

  • The accused instrumentality is a "poultry feeder port product" identified by Amazon Standard Identification Number (ASIN) B09BDB4DNS Compl. ¶3

Functionality and Market Context

  • The complaint, being for declaratory judgment of non-infringement, does not provide a technical description of the Accused Product's functionality. It states that Plaintiffs offer and sell the product through Amazon storefronts to customers in Illinois and nationwide Compl. ¶8 Compl. ¶9 Compl. ¶19 The dispute centers on the Defendants' assertion that this product infringes Claim 1 of the '252 Patent, an assertion which Plaintiffs deny Compl. ¶2 Compl. ¶31

IV. Analysis of Infringement Allegations

The complaint is an action for declaratory judgment of non-infringement and, as such, does not contain allegations mapping the Accused Product to the claim elements. Instead, Plaintiffs make a general assertion that the Accused Product "does not satisfy every limitation of Claim 1 of the '252 Patent, either literally or under the doctrine of equivalents" Compl. ¶31 Compl. ¶39 Therefore, a detailed claim chart cannot be constructed from the complaint.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A significant question arises from the claim language itself. Claim 1 explicitly requires the "external threading" to be located "between the collar and the entry portion" '252 Patent, col. 11:10-12 However, the patent's own figures and detailed description appear to show the threading located between the collar and the exit portion '252 Patent, Fig. 4 '252 Patent, col. 4:25-29 This discrepancy raises the question of whether the claim, as written, reads on a product that follows the patent's own diagrams.
    • Technical Questions: The complaint's blanket denial of infringement suggests potential factual disputes over whether the Accused Product contains each specific structural element recited in Claim 1. This includes whether the product has an "outwardly flared lip," a "downward facing exit," a "collar," and the specifically located "external threading." The case may turn on evidence comparing the physical structure of the Accused Product to these claimed features.

V. Key Claim Terms for Construction

  • The Term: "between the collar and the entry portion"

  • Context and Importance: This term defines the required location of the "external threading" used to secure the port. Its construction is critical because the patent's own exemplary embodiments appear to depict the threading in a different location (between the collar and the exit portion). Practitioners may focus on this term because if it is construed strictly, it could provide a straightforward path to a non-infringement finding for any product that places the threading on the exit side, including one that mirrors the patent's own figures.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A patentee might argue that the term should be interpreted in light of the overall invention and that a drafting error should not vitiate the claim. However, the claim language is unambiguous, and there is little intrinsic evidence to support a reading contrary to its plain meaning.
    • Evidence for a Narrower Interpretation: An accused infringer will point to the plain and ordinary meaning of the words "between," "collar," and "entry portion." They may also use the doctrine of claim differentiation, noting that if the inventor intended a different location, they could have claimed it. The clear conflict with the figures '252 Patent, Fig. 4 '252 Patent, Fig. 9 could be used to argue that the claim language must be strictly enforced as written, or that the claim is invalid for lack of written description support under 35 U.S.C. § 112.

  • The Term: "downward facing exit"

  • Context and Importance: This term describes the orientation of the opening from which an animal retrieves feed. The definition will determine what structures meet this limitation. The dispute could center on whether any orientation below horizontal suffices, or if a more specific shape or angle is required.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patentee could argue that the term's plain meaning encompasses any exit oriented to direct feed downwards, promoting gravity-assisted feeding and preventing spillage, without being limited to a specific geometry.
    • Evidence for a Narrower Interpretation: Plaintiffs might argue that the term should be limited by the consistent depiction in the patent's figures of a curved, hooded exit that directs feed in a specific manner '252 Patent, Fig. 4 '252 Patent, Fig. 7 This could support a narrower construction that excludes simple, angled-cut tubes.

VI. Other Allegations

The complaint, being a declaratory judgment action filed by the accused infringers, does not contain counts for indirect or willful infringement.

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

  1. A core issue will be one of claim scope versus specification disclosure: Can Claim 1, which explicitly requires external threading "between the collar and the entry portion," be enforced against a product where the threading is located elsewhere, such as the location depicted in the patent's own figures (between the collar and the exit portion)? This discrepancy will likely fuel arguments of both non-infringement and patent invalidity under 35 U.S.C. § 112.

  2. A second central question will concern the patent's effective priority date. Plaintiffs expressly contest the patent's entitlement to the filing date of earlier design patent applications Compl. ¶¶26-27 The resolution of this priority dispute is critical, as it will determine which prior art references are available for Plaintiffs' obviousness challenge under 35 U.S.C. § 103 Compl. ¶44, potentially deciding the ultimate validity of the asserted claim.

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