Zhadanov v. Homewerks Worldwide LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Eli Zhadanov (New York)
  • Defendant: Homewerks Worldwide, LLC (Delaware)
  • Plaintiff's Counsel: BISHOP & DIEHL, LTD.; Jason B. Lattimore, Esq LLC
• Case Identification: 1:26-cv-8661, N.D. Ill., 07/21/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendant Homewerks Worldwide, LLC resides in the district and has an established place of business where it has committed acts of infringement.
• Core Dispute: Plaintiff alleges that Defendant's "Nevis" line of showerheads infringes two patents related to handheld showerheads that incorporate secondary nozzles for high-pressure cleaning functions.
• Technical Context: The technology adds a secondary "power wash" function to a standard handheld showerhead, using separate nozzles to create specialized spray patterns (e.g., jet stream, fan spray) intended for cleaning the tub and shower area.
• Key Procedural History: The complaint alleges that the Plaintiff provided Defendant with written notice of infringement for both patents-in-suit, including detailed preliminary claim charts, on or about March 5, 2026, and May 6, 2026, prior to filing the lawsuit.

Case Timeline

Date	Event
2020-12-10	Priority Date for '850 and '435 Patents
2024-05-28	U.S. Patent No. 11,992,850 Issued
2025-12-02	U.S. Patent No. 12,485,435 Issued
2026-03-05	First pre-suit notice of infringement sent to Defendant
2026-05-06	Second pre-suit notice of infringement sent to Defendant
2026-07-21	Complaint Filing Date

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

U.S. Patent No. 12,485,435 - "Showerhead Having Selector for Directing Water Flow in Independent Directions"

• Patent Identification: U.S. Patent No. 12485435, "Showerhead Having Selector for Directing Water Flow in Independent Directions," issued December 2, 2025.

The Invention Explained

• Problem Addressed: The patent's background section notes that conventional showerheads are designed primarily for showering and that the resulting water pressure and spray patterns may be undesirable or ineffective for cleaning shower areas like tiled walls and tubs '435 Patent, col. 1:20-26
• The Patented Solution: The invention is a handheld showerhead that adds a secondary set of nozzles, separate from the main shower face, which are optimized for cleaning '435 Patent, abstract A user-operated "flow selector" allows switching between the standard showering nozzles and the cleaning nozzles, which can produce different spray types, such as a focused jet stream or a wide fan-shaped spray '435 Patent, col. 4:33-41 This creates a dual-purpose device for both personal bathing and bathroom cleaning.
• Technical Importance: This design integrated a new utility-targeted, high-pressure cleaning-into a common household fixture without requiring a separate tool '435 Patent, col. 3:1-4

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶25
• Claim 1 claims a showerhead comprising:
  • A plurality of "first nozzles" for directing water in a first direction.
  • At least one "second nozzle" for directing water in a second direction, transverse to the first.
  • At least one "third nozzle" adjacent to the second nozzle, also directing water in the second direction.
  • A "flow selector" movable between positions to direct water through either the first nozzles, the second nozzle, or the third nozzle.
  • The second nozzle creates a "first type of the flow of water" and the third nozzle creates a "second type of the flow of water different from the first type."
• The complaint also asserts dependent claims 8-17 Compl. ¶25

U.S. Patent No. 11,992,850 - "Showerhead Having Selector for Directing Water Flow in Independent Directions"

• Patent Identification: U.S. Patent No. 11992850, "Showerhead Having Selector for Directing Water Flow in Independent Directions," issued May 28, 2024.

The Invention Explained

• Problem Addressed: The patent identifies the same problem as its continuation ('435 Patent): conventional showerheads are not well-suited for the task of cleaning the shower enclosure itself '850 Patent, col. 1:12-20
• The Patented Solution: The patent describes a showerhead with a handle, a faceplate with standard shower nozzles, and a set of at least two additional nozzles located separately from the faceplate (e.g., on the top edge of the showerhead) '850 Patent, abstract The core of the invention is a "flow director" mechanism with distinct internal plenums that allows a user to selectively route water to the showering nozzles, a first cleaning nozzle, or a second cleaning nozzle, which can provide different spray patterns '850 Patent, col. 4:35-42 '850 Patent, FIG. 2C
• Technical Importance: The invention provides a mechanical solution for adding distinct, selectable, high-pressure spray functions to a handheld showerhead for enhanced utility '850 Patent, col. 3:25-35

Key Claims at a Glance

• The complaint alleges infringement of the "claims of the '850 Patent," with a notice letter referencing at least claims 10 and 16 Compl. ¶53 Compl. ¶70 Independent claim 1 is representative.
• Claim 1 claims a showerhead comprising:
  • A head portion, handle, and faceplate with a plurality of "first nozzles".
  • A "second nozzle" and a "third nozzle" disposed in the head portion separate from the faceplate.
  • A "first plenum" coupled to the first nozzles, a "second plenum" coupled to the second nozzle, and a "third plenum" coupled to the third nozzle.
  • A "flow director" movable between three positions to selectively couple a water channel to one of the three plenums.
  • The second and third nozzles direct flow in a direction "transverse" to the first nozzles.
• The complaint reserves the right to assert other claims Compl. ¶53

III. The Accused Instrumentality

• Product Identification: The "Accused Products" are the "Nevis" line of showerheads supplied by Homewerks and sold at Lowe's under the "Allen + Roth" brand Compl. ¶14 Compl. ¶15 This includes stand-alone handheld models and "combo" models that pair the handheld unit with a fixed showerhead Compl. ¶15 Compl. ¶16
• Functionality and Market Context: The complaint alleges the Accused Products feature a "2-Mode Power Wash" function that is their central selling point Compl. ¶19 This feature uses nozzles on the top of the showerhead to provide two different cleaning streams: a "jet spray" and a "wide fan spray" Compl. ¶27 The complaint includes a screenshot from a promotional video on Lowes.com that describes the handheld showerhead "turn[ing] into a pressure washer" Compl. ¶19 These products are alleged to be sold on the same shelves and in direct competition with the Plaintiff's own products Compl. ¶18

IV. Analysis of Infringement Allegations

'435 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a plurality of first nozzles configured to direct water flow in a first direction	The Accused Products have nozzles on the face of the showerhead for normal showering.	¶26	col. 4:1-4
at least one second nozzle... configured to direct water flow in a second direction... transverse to the first direction	The Accused Products have nozzles at the top of the head that direct water transversely to the main shower flow. The complaint alleges one provides a "wider, flat stream."	¶26; ¶27	col. 4:12-24
at least one third nozzle disposed adjacent to the at least one second nozzle and configured to direct water flow in a third direction	The Accused Products have a center nozzle at the top of the head, adjacent to the other cleaning nozzles, which provides a "jet that emanates from the center nozzle."	¶27	col. 4:12-24
wherein the second nozzle is configured to create a first type of the flow of water, and the third nozzle is configured to create a second type of the flow of water different from the first type	The Accused Products allegedly provide two different cleaning streams: a wide, flat stream (first type) and a jet stream (second type). This is shown in a promotional video for the product.	¶27; ¶19	col. 9:22-26
a flow selector moveable between a first position..., a second position..., and a third position	The Accused Products allegedly allow a user to control the flow of water between the main shower nozzles and the two different types of cleaning nozzles.	¶26	col. 4:33-41

'850 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a faceplate disposed at a first side of the head portion; a plurality of first nozzles extending through the faceplate	The Accused Products have a conventional shower face with multiple nozzles for showering.	¶26	col. 3:42-44
a second nozzle disposed in the head portion separate from the faceplate; a third nozzle disposed in the head portion separate from the faceplate adjacent to the second nozzle	The Accused Products feature three nozzles located at the top of the showerhead, separate from the main face, for cleaning functions.	¶26	col. 4:1-9
a first plenum... a second plenum... a third plenum	The complaint does not explicitly detail the internal plenum structure but alleges that the product's function requires the elements of the claims.	¶53	col. 1:32-35
a flow director having a second channel... and moveable between a first position... a second position... and a third position... to selectively direct a flow of water	The Accused Products allow a user to select between the standard shower spray and the two different cleaning sprays ("jet" and "fan"), implying an internal flow-directing mechanism.	¶26; ¶27	col. 4:35-49

• Identified Points of Contention:
  • Structural Equivalence Question: The complaint focuses on the external features and functions of the Accused Products (e.g., jet spray, fan spray). A central question for the court will be whether the internal mechanics of the Accused Products contain the specific multi-"plenum" and "flow director" architecture recited in the claims, or if they achieve a similar external function through a different, non-infringing internal design.
  • Evidentiary Question: The complaint's allegations regarding the internal structure (plenums, flow director) are made on information and belief. The case may hinge on evidence discovered regarding the actual construction of the Accused Products to determine if they meet these structural limitations.

V. Key Claim Terms for Construction

• The Term: "flow director"

• Context and Importance: This term appears in the independent claims of both patents and describes the core switching mechanism. Its definition is critical, as it dictates what internal structures will be found to infringe. Practitioners may focus on this term because the patents disclose a specific ball-and-socket embodiment '850 Patent, FIG. 2C, 250, and the dispute will likely concern whether the term is limited to such structures or can cover any valve or manifold that performs the same function.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims themselves describe the "flow director" functionally as being "moveable between" positions to "selectively direct a flow of water" '850 Patent, col. 8:11-22, which may support a construction covering any component that performs this function.
  • Evidence for a Narrower Interpretation: The specification heavily details a specific ball-and-socket coupling with spring-loaded pins and indentations '850 Patent, col. 4:58-67 A defendant may argue that this detailed description limits the scope of "flow director" to the disclosed embodiment or equivalents thereof.

• The Term: "plenum"

• Context and Importance: The claims require multiple, distinct "plenums", each fluidly coupled to a different set of nozzles '850 Patent, claim 1 Infringement depends on the Accused Product having a corresponding number of separate internal chambers.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term is not explicitly defined, suggesting it could be given its plain and ordinary meaning in fluid mechanics (a chamber for distributing flow).
  • Evidence for a Narrower Interpretation: The patent figures depict the plenums as physically separate compartments within a "flow distribution chamber" '850 Patent, FIG. 5A A defendant could argue this implies a requirement for distinct physical separation, which might not be present in a more integrated manifold design.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Homewerks actively induces infringement by its customers (Lowe's) and end-users Compl. ¶¶38-41 This is based on allegations of Homewerks entering into supply agreements, manufacturing the products for private-label resale, providing marketing materials that highlight the infringing use (the promotional video), and including instructions on how to use the infringing features Compl. ¶19 Compl. ¶40 Compl. ¶41
• Willful Infringement: The complaint alleges willful infringement based on Defendant's continued sales after receiving specific notice of infringement Compl. ¶30 Compl. ¶56 The basis for pre-suit knowledge is two alleged notice letters, sent on March 5 and May 6, 2026, which the complaint states included "detailed preliminary claim charts demonstrating how the Nevis showerheads meet each and every limitation" of asserted claims Compl. ¶¶44-46 Compl. ¶¶69-71

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

• A Structural vs. Functional Question: The core of the case appears to be a dispute over internal structure versus external function. Does the accused "Nevis" showerhead, which functionally mimics the patented invention by providing selectable "jet" and "fan" cleaning sprays, also incorporate the specific internal architecture of a multi-position "flow director" and separate "plenums" as required by the claims? The case will likely depend on whether discovery reveals a structural match, not just a functional one.
• A Claim Scope Question: Will the term "flow director" be interpreted broadly to cover any mechanism that switches between water paths, or will it be narrowed to the specific ball-and-socket embodiment detailed in the patent's figures? The answer to this claim construction question may determine whether the Accused Product's internal valve system, whatever its design, falls within the scope of the patents.
• An Evidentiary Question of Willfulness: Plaintiff has alleged specific pre-suit communications, including the provision of claim charts. A key question will be whether these communications put Defendant on sufficient notice to make its subsequent conduct-continuing to sell the Accused Products-objectively reckless, thereby exposing it to enhanced damages for willful infringement.