DCT

1:26-cv-09396

Shenzhen Jollysun Technology Co Ltd v. Diedrichsen

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Name: Shenzhen JollySun Technology Co., Ltd. v. Diedrichsen
  • Case Identification: 1:26-cv-09396, N.D. Ill., 08/06/2026
  • Venue Allegations: Venue is asserted based on Defendants' prior patent enforcement lawsuits filed in the Northern District of Illinois and the sale of Plaintiffs' accused products to customers in Illinois, which were impacted by Defendants' enforcement actions.
  • Core Dispute: Plaintiffs seek a declaratory judgment that their poultry feeder port products do not infringe Defendants' U.S. Patent No. 12,419,280, and that the patent is invalid and unenforceable.
  • Technical Context: The dispute concerns the design of modular feeder ports for poultry, which attach to containers to allow animal access to feed while aiming to prevent contamination by pests.
  • Key Procedural History: The action was precipitated by Defendants' submission of a patent infringement complaint to Amazon, which resulted in the removal of Plaintiffs' product listings. The complaint highlights that the inventor-defendant holds a separate patent allegedly covering the specific design used by Plaintiffs, which Plaintiffs argue demonstrates that the asserted patent does not cover their products. The complaint also references a history of patent enforcement by Defendants in the same district concerning related design patents.

Case Timeline

Date Event
2020-05-26 Earliest Priority Date for '280 Patent (via Design Application)
2025-03-17 '280 Patent Application Filing Date
2025-09-23 '280 Patent Issue Date
2026-07-23 Defendants allegedly submit infringement complaint to Amazon
2026-08-03 Plaintiffs' counsel sends demand letter to Defendants
2026-08-06 Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 12,419,280 - Feeder Port

('280 Patent)

The Invention Explained

  • Problem Addressed: The patent's background describes the long-standing problem of pests, rodents, and insects contaminating livestock feeders. This contamination poses health risks to the animals and causes economic loss for farmers. The patent notes that many existing solutions to this problem can be expensive and difficult to implement. '280 Patent, col. 1:48-60
  • The Patented Solution: The invention is a feeder port designed to be inserted into an aperture in a container, such as a bucket, to create a controlled access point for feed. The port comprises a tubular body with an entry portion, an exit portion, a collar, and external threading. A key feature is the arrangement where a bushing can be screwed onto the external threading to secure the port to the container wall, with a waterproof seal potentially positioned between the collar and the threading to prevent contamination. '280 Patent, abstract '280 Patent, col. 4:7-21
  • Technical Importance: The design provides a modular and potentially cost-effective method for converting standard containers into more hygienic and efficient feeders, restricting pest access while maintaining feed access for poultry. '280 Patent, col. 2:7-10

Key Claims at a Glance

  • The complaint asserts non-infringement of independent claims 1 and 12. Compl. ¶20
  • Independent Claim 1 recites the core feeder port device with the following essential elements:
    • 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 configured to provide a downward-facing exit.
    • A "collar that protrudes around the tubular body between the entry portion and the exit portion."
    • "external threading on the tubular body between the collar and the exit portion," configured to receive a bushing. Compl. ¶21 '280 Patent, col. 9:28 - col. 10:1
  • Independent Claim 12 recites a system comprising the feeder port of claim 1 and a "trough" to which the feeder port is detachably coupled. Compl. ¶22 '280 Patent, col. 10:12-16

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two lines of "poultry feeder port products" sold by Plaintiffs: the "New Model" and the "Old Model." Compl. ¶26

Functionality and Market Context

  • Plaintiffs' products are poultry feeder ports sold on Amazon, some together with a feed container. Compl. ¶26 The complaint alleges that the fundamental design of these products differs from the '280 Patent's claims. Specifically, it contends that the external threading on all accused products is located on the entry side of the product's flange, which is opposite to the location required by the claims. Compl. ¶4 Compl. ¶27 The complaint further alleges that the "New Model" products additionally lack a "collar" and an "outwardly flared lip" as required by the claims. Compl. ¶¶28-29 The complaint includes a diagram contrasting the claimed arrangement of the '280 Patent with the alleged "reverse" arrangement of the Plaintiffs' "New Model" product. Compl. p. 10, Fig. 4

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' arguments for why their products do not meet specific limitations of the asserted claims.

'280 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Non-Infringing Functionality Complaint Citation Patent Citation
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 The complaint alleges the "New Model" lacks this feature, describing its entry as a "plain cylinder, constant diameter" with "no outward flare." A side-by-side comparison of a patent figure and a product photo is provided to support this contention. ¶28; p. 12, Fig. 8 col. 3:35-38
a collar that protrudes around the tubular body between the entry portion and the exit portion The complaint alleges the "New Model" lacks a collar entirely. For the "Old Model," it argues that even if its annular flange is construed as the claimed "collar," its location relative to the threading does not match the claim. ¶27; ¶29 col. 4:7-9
external threading on the tubular body between the collar and the exit portion This is the central non-infringement argument. The complaint alleges that on all accused products, the external threading is on the entry side of the flange, not between the flange/collar and the exit portion as required by the claim. ¶4; ¶27; ¶36 col. 4:10-14
  • Identified Points of Contention:
    • Locational Mismatch: The primary dispute centers on the relative positions of the collar, threading, and exit portion. The core question is whether the accused products' configuration-with threading allegedly on the entry side of the flange-can be read to meet the claim language requiring threading "between the collar and the exit portion." The complaint's use of diagrams comparing the claimed versus accused arrangements underscores this as the main point of contention. Compl. p. 7, Fig. 1
    • Structural Mismatch: A secondary dispute involves whether the accused products contain the structures required by the claims at all. Questions include: (1) Does the "annular flange" on the accused products qualify as the claimed "collar"? and (2) Does the "New Model" possess an "outwardly flared lip"? An exploded view of the "New Model" accused product is included to label its component parts for this analysis. Compl. p. 9, Fig. 2

V. Key Claim Terms for Construction

  1. The Term: "between the collar and the exit portion"

    • Context and Importance: The interpretation of this phrase is central to the dispute. The Plaintiffs' core non-infringement theory is that their products' threading is located on the opposite side of the collar/flange from what is claimed. Compl. ¶4 Compl. ¶37 The complaint alleges that the inventor-defendant separately patented the "opposite" arrangement, which may suggest the patentee viewed the two locations as distinct and that this term should be narrowly construed. Compl. ¶4 Compl. ¶25
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A defendant might argue that the term should be interpreted functionally in the context of securing the device to a container wall, rather than in a strictly linear, geometric sense.
      • Evidence for a Narrower Interpretation: The patent figures consistently depict a linear arrangement of entry portion -> collar -> threading -> exit portion. '280 Patent, Figs. 1-4 The plain meaning of "between" supports a narrow interpretation. The glossary defines the collar as preventing the port from moving through an aperture, and the threading as receiving a bushing, suggesting a specific mechanical relationship that may support a narrow, literal reading. '280 Patent, col. 3:29-33 '280 Patent, col. 3:51-54

  2. The Term: "collar"

    • Context and Importance: The complaint alleges the "New Model" lacks a "collar" entirely. Compl. ¶29 Therefore, determining whether the accused products' "annular flange" constitutes a "collar" is critical to the infringement analysis.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's glossary provides a functional definition: "a component of the feeder port that surrounds the tubular structure ... to prevent it from moving entirely through an aperture." '280 Patent, col. 3:29-33 A defendant could argue any structure performing this function, such as a flange, meets the definition.
      • Evidence for a Narrower Interpretation: The patent drawings consistently show the collar as a distinct, protruding ring separate from the main contours of the entry or exit portions. '280 Patent, Fig. 1, element 130 '280 Patent, Fig. 2, element 240 A plaintiff could argue that this structural depiction limits the term to something more than just an integral flange.

VI. Other Allegations

  • Allegations of Bad-Faith Enforcement: The complaint does not contain a claim for willful infringement against the Plaintiffs. Instead, it alleges that Defendants engaged in "bad-faith enforcement" of the '280 Patent. Compl. ¶¶51-52 The basis for this allegation is the assertion that Defendants knew their infringement claim was baseless because the inventor-defendant had previously secured a separate patent (the '252 Patent) that allegedly claims the very "entry-side" threading arrangement used in Plaintiffs' products. Compl. ¶4 Compl. ¶57 This alleged knowledge, combined with Defendants' refusal to withdraw the Amazon complaint after receiving a detailed non-infringement notice, is presented as evidence of subjective and objective bad faith, forming the basis for Plaintiffs' request for attorneys' fees under 35 U.S.C. § 285. Compl. ¶33 Compl. ¶58 Compl. ¶H, p. 21

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

  1. Claim Construction and Estoppel: A central issue will be one of definitional scope: can the phrase "between the collar and the exit portion" be construed to cover the accused products' alleged "entry-side" threading arrangement? The existence of Defendants' separate patent for the "opposite" configuration raises significant questions of claim differentiation and may limit the scope of the asserted claim.
  2. Factual Infringement: The case will involve key evidentiary questions regarding the structure of the accused products. The court will need to determine, as a matter of fact, whether the "New Model" possesses structures that meet the construed definitions of a "collar" and an "outwardly flared lip."
  3. Patentee Conduct: The litigation will likely scrutinize the patentee's enforcement activities. A critical question will be whether asserting the '280 Patent against products that allegedly embody a design separately patented by the same inventor constitutes bad-faith enforcement, potentially making this an "exceptional case" and exposing the Defendants to liability for attorneys' fees.