Dailyfarm Equipment Co Ltd v. Erik Diedrichsen

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dailyfarm Equipment Co., Limited (Hong Kong)
  • Defendant: Erik Diedrichsen (Massachusetts)
  • Plaintiff's Counsel: ScienBiziP, P.C.; Tabet Divito & Rothstein LLC
• Case Identification: 1:26-cv-08546, N.D. Ill., 07/20/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because the Defendant is actively enforcing patents from the same "Diedrichsen Poultry Feeder Patent Family" in that district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its chicken feeder port product does not infringe U.S. Patent No. 12,642,252 and that the patent is invalid, following Defendant's accusation of infringement via Amazon's patent enforcement procedure.
• Technical Context: The technology relates to feeder ports for poultry, designed to allow chickens access to feed within a container while preventing waste and contamination from pests.
• Key Procedural History: The lawsuit was precipitated by Defendant Erik Diedrichsen invoking Amazon's Patent Evaluation Express (APEX) procedure, alleging Plaintiff's product infringes the patent-in-suit. The complaint notes that Defendant is also enforcing other patents from the same family in the same judicial district. The Plaintiff raises invalidity arguments based on prior art, including its own alleged prior sales and a U.S. design patent.

Case Timeline

Date	Event
2020-05-26	Priority Date for '252 Patent (originating U.S. App. 29/735,857)
2022-01-01	Alleged first offer for sale of Plaintiff's similar products
2023-06-06	U.S. Design Patent D988,614 ('D614 Patent') issued
2025-03-17	U.S. Patent Application 19/081,558 filed
2025-04-24	U.S. Patent Application 19/189,221 filed
2025-08-21	U.S. Patent Application 19/306,643 (for '252 Patent) filed
2026-06-02	U.S. Patent No. 12,642,252 ('252 Patent) issued
2026-06-26	Defendant executes Amazon APEX Agreement
2026-06-30	Plaintiff receives APEX Notice from Amazon
2026-07-20	Complaint for Declaratory Judgment filed

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

• Patent Identification: U.S. Patent No. 12,642,252, "Feeder Port," issued June 2, 2026.

The Invention Explained

• Problem Addressed: The patent's background describes the long-standing challenge of feeding livestock from containers, which are often susceptible to contamination and feed loss from rodents, pests, and insects accessing the feed through large openings ʼ252 Patent, col. 1:57-65 Existing solutions are described as potentially expensive and difficult to implement ʼ252 Patent, col. 2:3-6
• The Patented Solution: The patent proposes a "feeder port" with a specific tubular body geometry intended to be installed into a container like a bucket or trough ʼ252 Patent, abstract The solution involves a structure with an entry portion for the animal, an exit portion dispensing feed, and features like a collar and external threading for secure, sealed mounting ʼ252 Patent, col. 4:6-14 ʼ252 Patent, col. 4:24-34 The design aims to provide easy access for the intended animal (e.g., poultry) while limiting access for pests ʼ252 Patent, col. 2:18-22
• Technical Importance: The invention purports to offer a method for improving livestock health and feeding efficiency by creating a more controlled, cleaner, and less wasteful feeding system ʼ252 Patent, col. 2:10-16

Key Claims at a Glance

• The complaint specifically identifies Claim 1 as being asserted by the Defendant Compl. ¶11
• Independent Claim 1 of the '252 Patent recites:
  • A tubular body with an internal cavity, a first base, and a second base.
  • An entry portion at the first base with an outwardly flared lip.
  • An exit portion perpendicular to the second base providing a downward facing exit.
  • A collar protruding around the tubular body between the entry and exit portions.
  • External threading on the tubular body between the collar and the entry portion, configured to receive a bushing.
• The complaint's prayer for relief seeks a declaration of non-infringement for "any valid and enforceable claim of the '252 Patent," suggesting a potential dispute over other claims, although only Claim 1 is explicitly mentioned in the factual allegations Compl. ¶31 Compl. Prayer B

III. The Accused Instrumentality

Product Identification

The complaint identifies the Accused Product by its Amazon Standard Identification Number (ASIN) B0DMR88XMX Compl. ¶4 The product listing title is "No Waste Chicken Feeders, DIY Automatic Poultry Feeder - 4 Ports Orange | Buckets Barrels Bins Troughs-mountable Design for common Breeds of Chicken Flock with Hole Saw" Compl. ¶18

Functionality and Market Context

The Accused Product is described as a port designed to be installed by the end-user into a container (e.g., a bucket or barrel) to create a DIY poultry feeder Compl. ¶18 The complaint includes a printout of the Amazon product listing, which displays the port and a hole saw, reinforcing its role as a component for a user-assembled system Compl. ¶18 Compl. Ex. C The Plaintiff, Dailyfarm Equipment Co., sells the product on Amazon under its "ZenxyHoC" storefront Compl. ¶17 The dispute's initiation through the Amazon APEX procedure indicates the commercial significance of the Amazon marketplace for these products Compl. ¶4 Compl. ¶10

IV. Analysis of Infringement Allegations

This action is for a declaratory judgment of non-infringement. The table below summarizes the Plaintiff's position that its product does not meet the claim limitations asserted by the Defendant.

'252 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
A feeder port with a tubular body including: a tubular body including: an internal cavity that extends through the tubular body, wherein the tubular body has a first base and a second base;	The complaint does not contest that the Accused Product is a feeder port with a tubular body, but denies infringement of any valid claim Compl. ¶20	¶20	col. 11:1-4
an entry portion at the first base of the tubular body with an outwardly flared lip that provides access into the internal cavity of the tubular body,	Plaintiff explicitly alleges the Accused Product does not meet the limitation of "an entry portion at the first base of the tubular body with the outwardly flared lip" Compl. ¶21 Compl. ¶28	¶21; ¶28	col. 11:5-8
an exit portion that is perpendicular to the second base configured to provide a downward facing exit out of the internal cavity of the tubular body...	The complaint makes a general denial of infringement and does not provide specific allegations regarding this element Compl. ¶20	¶20	col. 11:9-14
a collar that protrudes around the tubular body between the entry portion and the exit portion;	The complaint makes a general denial of infringement and does not provide specific allegations regarding this element Compl. ¶20	¶20	col. 11:15-17
and external threading on the tubular body between the collar and the entry portion, wherein the external threading is configured to receive a bushing.	The complaint makes a general denial of infringement and does not provide specific allegations regarding this element Compl. ¶20	¶20	col. 11:18-22

• Identified Points of Contention:
  • Scope Questions: The complaint's primary non-infringement argument centers on the "outwardly flared lip" limitation Compl. ¶21 Compl. ¶28 This raises the question of how broadly or narrowly the term "outwardly flared lip" will be construed and whether the Accused Product's entry portion falls within that scope.
  • Technical Questions: A central evidentiary question will be a direct comparison of the Accused Product's physical structure to the claim language. The dispute will require a factual determination of whether the geometry of the Accused Product's entry point constitutes an "outwardly flared lip" as described and claimed in the '252 Patent.

V. Key Claim Terms for Construction

The complaint specifically singles out one term, indicating it will be a focus of the dispute.

• The Term: "outwardly flared lip"
• Context and Importance: This term is critical because the Plaintiff has identified it as a specific feature that its Accused Product allegedly lacks, forming the basis of its non-infringement argument Compl. ¶21 Compl. ¶28 The definition of what constitutes an "outwardly flared lip" will be central to determining infringement. Practitioners may focus on this term because it is the only element-specific argument for non-infringement presented in the complaint.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the flared lip in functional terms as something that "provides access into the internal cavity of the tubular body" ʼ252 Patent, col. 4:15-18 A party might argue this functional language supports a broader definition that includes any structure at the entry port that facilitates access.
  • Evidence for a Narrower Interpretation: The patent figures, such as Figure 1 (element 115) and Figure 4 (element 460), depict a very specific, pronounced, and smoothly curved flare. A party could argue these specific embodiments define the term, limiting it to structures that closely resemble the drawings rather than any feature that merely "provides access" ʼ252 Patent, Fig. 1 ʼ252 Patent, Fig. 4 The use of the term "lip" itself may suggest a distinct, projecting edge, potentially narrowing the scope.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaration of non-infringement both directly and indirectly Compl. Prayer B, but provides no specific factual allegations related to indirect infringement theories like inducement or contributory infringement.
• Willful Infringement: Willful infringement is not alleged by the Defendant in the complaint, as this is a declaratory judgment action initiated by the accused infringer.

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

The resolution of this dispute, as framed by the complaint, appears to rest on two primary questions for the court:

• A question of claim construction and infringement: What is the proper scope of the term "outwardly flared lip"? The case may turn on whether the specific geometry of the Plaintiff's product entry port is found to meet this limitation, a determination that will follow the court's construction of the term.
• A question of validity based on prior art: Is Claim 1 of the '252 Patent invalid as anticipated? The Plaintiff raises two distinct prior art challenges: anticipation by the D614 design patent Compl. ¶36 and anticipation by public use or sale of similar products offered on Amazon as early as 2022, well over a year before the patent's effective filing date Compl. ¶35 This second challenge invokes the "on-sale bar" under 35 U.S.C. § 102.