Ning Bo Ta Cu Shang Mao You Xian Gong Si v. Cyclone Filter Tools LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Ning Bo Ta Cu Shang Mao You Xian Gong Si (People's Republic of China)
  • Defendant: Cyclone Filter Tools LLC (Tennessee)
  • Plaintiff's Counsel: West Atlantic Law Firm, PLLC
• Case Identification: 1:26-cv-09806, N.D. Ill., 08/14/2026
• Venue Allegations: Plaintiff alleges venue is proper because the Defendant is deemed to reside in the district where it is subject to personal jurisdiction. Personal jurisdiction is asserted based on Defendant's use of Amazon's nationwide APEX enforcement program, which purposefully targeted Plaintiff's product listing and thereby affected recurring sales to customers in Illinois.
• Core Dispute: Plaintiff seeks a declaratory judgment that its pool filter cleaner stand does not infringe Defendant's patent related to a portable pool filter cleaning system.
• Technical Context: The technology concerns mechanical devices designed to hold and spin a cylindrical pool filter cartridge, using a spray of water to dislodge debris from the filter's pleats through centrifugal force.
• Key Procedural History: The dispute arose after Defendant Cyclone Filter Tools LLC initiated an Amazon Patent Evaluation Express (APEX) proceeding, accusing Plaintiff's product of infringing Claim 19 of the asserted patent. This action by Plaintiff is a direct response, seeking a court declaration of non-infringement to prevent the removal of its product from Amazon's marketplace.

Case Timeline

Date	Event
2020-10-03	'369 Patent - Earliest Priority Date
2025-08-05	'369 Patent - Issue Date
2026-07-28	Defendant executes Amazon APEX Agreement
2026-07-31	Amazon notifies Plaintiff of APEX proceeding
2026-08-14	Complaint for Declaratory Judgment filed

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

U.S. Patent No. 12,377,369 - "Portable Pool Filter Cleaning System and Method of Cleaning a Pool Filter"

• Patent Identification: U.S. Patent No. 12,377,369, "Portable Pool Filter Cleaning System and Method of Cleaning a Pool Filter," issued August 5, 2025 (the "'369 Patent").

The Invention Explained

• Problem Addressed: The patent's background section identifies cleaning cartridge-style pool filters as a "messy and difficult job" '369 Patent, col. 1:27-28 It notes that prior spinning devices are often not easily secured on varied surfaces, and that water collecting inside the filter during cleaning can make it heavy and prevent it from spinning effectively '369 Patent, col. 1:35-41
• The Patented Solution: The invention is a portable apparatus that holds a pool filter on a central support rod for cleaning '369 Patent, col. 1:18-21 The core concept involves a bottom filter retainer, upon which the filter rests, that is equipped with a bearing to allow for low-friction rotation around the support rod '369 Patent, abstract This allows a stream of water to spin the filter, using centrifugal force to eject debris. The design also incorporates drainage features to prevent water accumulation, ensuring the filter remains light enough to spin freely '369 Patent, col. 2:1-5
• Technical Importance: The invention aims to provide a versatile and effective cleaning method by enabling stable, low-friction rotation on different surfaces, such as a lawn or a concrete pool deck '369 Patent, col. 1:23-26

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement specifically as to independent Claim 19 Compl. ¶2
• The essential elements of Claim 19 are:
  • A support rod extending between a top end and a bottom end.
  • A bottom filter retainer that is "rotationally journaled on said support rod" and configured to extend into a pool filter's aperture.
  • A bearing "disposed between said bottom filter retainer and said support rod," which allows a pool filter engaged with the retainer to freely rotate about the support rod.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The accused product is a "pool filter cleaner stand" sold by Plaintiff on Amazon under ASIN B0GJQ6DXGK Compl. ¶2 Defendant's brand for its own product is identified as "CYCLONE FILTER CLEANER" Compl. ¶25

Functionality and Market Context

• The complaint alleges the Accused Product uses a different structural design than that claimed in the patent Compl. ¶¶20-24 It is described as having two vertical support tubes connected by a horizontal bottom cross beam Compl. ¶20 A lower filter adapter and bearing assembly are mounted at the center of this cross beam via a "separate threaded fastener" Compl. ¶22
• According to the complaint, any rotation of the filter on the Accused Product occurs around this central fastener, not around either of the two vertical support tubes Compl. ¶21 Compl. ¶23 The product is sold to consumers in Illinois and elsewhere through Plaintiff's Amazon storefront Compl. ¶7 Compl. ¶12

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

This action is for a declaratory judgment of non-infringement. The following chart summarizes the Plaintiff's arguments for why its product does not meet the limitations of Claim 19.

'369 Patent Infringement Allegations

Claim Element (from Independent Claim 19)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
a support rod extending between top end and a bottom end	The Accused Product allegedly lacks a single "support rod." It instead uses two vertical support tubes connected by a cross beam, with a separate fastener providing the axis of rotation.	¶22; ¶33	col. 5:27-29
a bottom filter retainer rotationally journaled on said support rod...	The Accused Product's lower filter adapter is allegedly not "rotationally journaled on" either of the two vertical support tubes. Instead, it is mounted to a central cross beam.	¶21	col. 8:56-65
a bearing disposed between said bottom filter retainer and said support rod...	The Accused Product's bearing is allegedly disposed at the center of a horizontal cross beam and rotates about a separate fastener, not between the retainer and a singular "support rod" as claimed.	¶22; ¶23	col. 8:47-51

• Identified Points of Contention:
  • Scope Questions: The central issue is whether the term "support rod" can be construed to cover the Accused Product's multi-component frame, which consists of two vertical tubes, a horizontal cross beam, and a central fastener Compl. ¶33 The plaintiff argues that treating these separate structures collectively as the claimed "support rod" would impermissibly "eliminate the express relational limitations recited in Claim 19" Compl. ¶33
  • Technical Questions: A key factual question is whether the Accused Product contains the specific structural relationship required by the claim. The claim requires a bearing to be disposed between the retainer and the support rod, with the retainer "rotationally journaled on said support rod." The complaint asserts that in the Accused Product, these components are arranged differently, lacking the direct, coaxial relationship between the support rod, bearing, and retainer taught in the patent Compl. ¶24

V. Key Claim Terms for Construction

• The Term: "support rod"
• Context and Importance: The definition of "support rod" is fundamental to the dispute. Plaintiff's non-infringement case rests on the argument that its two-tube frame with a central fastener is structurally distinct from the "support rod" recited in Claim 19 Compl. ¶22 Compl. ¶24 Practitioners may focus on this term because its construction will likely determine whether the accused product's architecture falls within the claim's scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A patentee might argue for a functional definition, suggesting "support rod" means any structure that provides a vertical axis for the filter to spin around. Language describing the purpose of the rod, such as enabling the filter to "spin or rotate about the support rod when sprayed with a stream of water," could be cited to support the view that the specific form is less important than the function '369 Patent, col. 5:41-43
  • Evidence for a Narrower Interpretation: The plaintiff will likely point to the patent's consistent depiction of the "support rod" (element 20) as a single, unitary, elongated member that directly holds the filter retainers and provides the axis of rotation '369 Patent, Fig. 1 '369 Patent, col. 5:27-29 The argument would be that the claim requires a single component to serve as both the primary vertical support and the direct axle for the bearing and retainer, a structural relationship the Accused Product allegedly lacks Compl. ¶23

VI. Other Allegations

• Indirect Infringement: The complaint makes a conclusory denial of indirect infringement but provides no specific factual analysis, as the primary focus is on the absence of direct infringement Compl. ¶34

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

The resolution of this declaratory judgment action will likely depend on the court's interpretation of the claim language in light of the accused product's specific design. The key questions for the case are:

• A question of claim construction: Will the term "support rod" be construed narrowly to mean a single, unitary component that serves as both the main structural support and the direct axis of rotation, as consistently depicted in the '369 Patent's embodiments? Or will it be given a broader, functional definition that could encompass the accused product's multi-part assembly of tubes, a cross-beam, and a fastener?
• A question of structural infringement: Does the accused product's design-where a filter adapter rotates on a fastener mounted to a cross-beam, which is itself supported by two separate vertical tubes-meet the claim limitation requiring a "bottom filter retainer rotationally journaled on said support rod" with a "bearing disposed between said bottom filter retainer and said support rod"? This raises the core issue of whether the accused device contains the specific physical and functional relationships between components as mandated by the claim language.