Zhadanov v. Shenzhen Juxinli Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Eli Zhadanov and Interlink Products International, Inc. (New Jersey)
  • Defendant: Shenzhen Juxinli Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: The Law Office of JASON B. LATTIMORE, ESQ. LLC
• Case Identification: 1:26-cv-01011, E.D.N.Y., 02/20/2026
• Venue Allegations: Venue is based on Defendant allegedly conducting business in New York, deriving substantial revenue from sales in the state, and causing injury to Plaintiff Zhadanov, who resides in Brooklyn, New York.
• Core Dispute: Plaintiffs allege that Defendant’s handheld showerheads infringe two patents related to showerheads featuring both standard showering nozzles and a separate, user-selectable set of nozzles for cleaning tasks that provide different spray patterns.
• Technical Context: The technology concerns multi-function showerheads that integrate conventional spray nozzles with specialized high-pressure jet or wide-fan spray nozzles, selectable by the user, to provide distinct functionalities for personal showering and utility cleaning within a single device.
• Key Procedural History: The complaint notes a pre-suit history involving Amazon's Patent Evaluation Express (APEX) program. Plaintiffs allege they submitted an APEX complaint against Defendant, and that Defendant, in response, filed a declaratory judgment action in the Western District of Washington, which Plaintiffs characterize as a "loophole" to avoid the APEX process and continue selling the accused products.

Case Timeline

Date	Event
2020-12-10	Priority Date for U.S. Patent No. 11,992,850
2020-12-10	Priority Date for U.S. Patent No. 12,485,435
2024-05-28	U.S. Patent No. 11,992,850 Issues
2025-12-02	U.S. Patent No. 12,485,435 Issues
2025-12-10	Interlink submits complaint under Amazon APEX program
2025-12-30	Defendant files declaratory judgment action in W.D. Wash.
2026-01-22	Defendant serves Interlink with Washington complaint
2026-02-20	Complaint Filed in E.D.N.Y.

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

The Invention Explained

• Problem Addressed: The patent addresses the issue that conventional showerheads are designed primarily for showering, and their resulting water pressure and spray patterns may be "undesirable for cleaning purposes," such as rinsing tiled walls or tubs (U.S. Patent No. 12,485,435, col. 1:21-27).
• The Patented Solution: The invention is a showerhead with two distinct sets of nozzles. A primary set of "first nozzles" on the main faceplate provides a standard shower spray in a "first direction" ('435 Patent, col. 4:11-20). A secondary set of nozzles, located separately on the head portion (e.g., on the top edge), is configured to spray water in a "transverse" direction for cleaning ('435 Patent, col. 4:11-20). This secondary set includes at least a "second nozzle" that creates a "first type" of flow (e.g., a fan spray) and a "third nozzle" that creates a "second type" of flow different from the first (e.g., a jet stream) ('435 Patent, col. 2:13-16). A "flow selector" allows a user to switch between these three modes (showering, cleaning-type-1, cleaning-type-2) ('435 Patent, abstract).
• Technical Importance: This design integrates optimized functions for both personal showering and utility cleaning into a single fixture, addressing a common limitation of showerheads that are only effective for one purpose.

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 7-17 (Compl. ¶36).
• The essential elements of independent claim 1 include:
  • A head portion and handle.
  • A plurality of "first nozzles" directing water in a "first direction."
  • At least one "second nozzle" directing water in a "second direction."
  • At least one "third nozzle" adjacent to the second, directing water in a "third direction."
  • A "flow selector" moveable between three positions to direct water through the first, second, or third nozzles respectively.
  • The second and third directions are "substantially the same and transverse to the first direction."
  • 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 flow selector is configured to remain in a selected position without continuous external force.

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

The Invention Explained

• Problem Addressed: As with its continuation ('435 Patent), this patent's background describes the undesirable effects of using conventional showerheads, which are optimized for showering, for cleaning tasks ('850 Patent, col. 3:5-14).
• The Patented Solution: The patent describes the internal architecture for a multi-mode showerhead. It claims a structure comprising three separate plenums (water distribution chambers) inside the showerhead head portion ('850 Patent, col. 9:1-5). A "first plenum" is coupled to the standard showering nozzles, a "second plenum" is coupled to a first cleaning nozzle, and a "third plenum" is coupled to a second cleaning nozzle ('850 Patent, col. 9:1-5). A moveable "flow director" inside the showerhead channels water from the handle into only one of the three plenums at a time, allowing the user to select the desired spray function ('850 Patent, col. 9:6-15).
• Technical Importance: This patent focuses on the specific internal mechanical structure (the system of plenums and a flow director) that enables the selective operation of different nozzle sets for distinct functions.

Key Claims at a Glance

• The complaint asserts claims 9-13 (Compl. ¶51).
• The essential elements of independent claim 9 include:
  • A head portion, handle, and faceplate.
  • A plurality of "first nozzles" extending through the faceplate.
  • A "second nozzle" separate from the faceplate.
  • A "third nozzle" separate from the faceplate and adjacent to the second nozzle.
  • A "first plenum" coupled to the first nozzles.
  • A "second plenum" coupled to the second nozzle.
  • A "third plenum" coupled to the third nozzle.
  • A "flow director" moveable between three positions to couple a water channel from the handle to the first, second, or third plenum, respectively.
  • The first nozzles direct water in a first direction, while the second and third nozzles direct water in a second direction that is "transverse to the first."

III. The Accused Instrumentality

Product Identification

The complaint identifies handheld showerheads sold on Amazon under Model/Part Nos. 460311 and 2331, referred to collectively as the "Accused Products" (Compl. ¶21; Compl. p. 7). The complaint includes images of the various finishes available for these models (Compl. p. 7).

Functionality and Market Context

The Accused Products are described as having a standard shower spray function from the main face, as well as a "central feature" of a cleaning jet on the top portion (Compl. ¶24). This cleaning feature allegedly provides two distinct spray patterns: a "Point Jet to blast away stubborn grime" and a "Wide Fan to rinse off soap scum" (Compl. ¶24). A screenshot from the Defendant's advertising illustrates these two cleaning modes (Compl. p. 8). The complaint alleges these products are among the "top selling showerheads on Amazon" and compete directly with Plaintiffs' products (Compl. ¶22; Compl. ¶23).

IV. Analysis of Infringement Allegations

U.S. Patent No. 12,485,435 Infringement Allegations

Claim Element	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 handheld showerhead that provide a standard shower spray (Compl. ¶37).	¶37	col. 4:11-13
at least one second nozzle disposed in the head portion and configured to direct water flow in a second direction... transverse to the first direction	The Accused Products have nozzles located near the top of the showerhead that direct water in a direction transverse to the flow from the face nozzles (Compl. ¶37). These nozzles provide a "wider, flat stream" for cleaning (Compl. ¶38).	¶37; ¶38	col. 4:14-20
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 showerhead, adjacent to the side nozzles, which provides a "jet" stream for cleaning (Compl. ¶38). This direction is also transverse to the main shower flow (Compl. ¶37).	¶37; ¶38	col. 4:14-20
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 side nozzles at the top of the showerhead create a "wider, flat stream" (a "Wide Fan"), while the center nozzle creates a "jet" stream (a "Point Jet"), constituting two different types of water flow streams (Compl. ¶38). This is depicted in advertising materials (Compl. p. 8).	¶38	col. 2:13-16
a flow selector moveable between a first position..., a second position..., and a third position...	The Accused Products allow a user to control and select the flow of water through the face nozzles or through the different top-mounted cleaning nozzles (Compl. ¶37). An advertising image shows "3 Modes + 2 Washing Jets + 8 Hand Sprays" (Compl. p. 11).	¶37	col. 4:16-20

U.S. Patent No. 11,992,850 Infringement Allegations

Claim Element	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a plurality of first nozzles extending through the faceplate	The Accused Products possess standard nozzles on the showerhead face for showering (Compl. ¶37).	¶37	col. 3:42-45
a second nozzle disposed in the head portion separate from the faceplate... [and] a third nozzle disposed in the head portion separate from the faceplate adjacent to the second nozzle	The Accused Products have three nozzles on the top portion, separate from the faceplate, which provide cleaning sprays. One is a center jet nozzle and two are side nozzles for a flat stream (Compl. ¶37; Compl. ¶38).	¶37; ¶38	col. 3:62-67
a first plenum... fluidly coupled to the first nozzles; a second plenum... fluidly coupled to the second nozzle; a third plenum... fluidly coupled to the third nozzle	The complaint alleges that all limitations are met, which implies the existence of internal water channels (plenums) that separately feed the face nozzles, the side cleaning nozzles, and the center cleaning nozzle (Compl. ¶50).	¶50	col. 4:56-62
a flow director... moveable between a first position..., a second position..., and a third position... to selectively direct a flow of water through a corresponding one of the first nozzles, the second nozzle, or the third nozzle	A user can control the flow of water to select between the showering mode and the two different cleaning modes, which suggests an internal mechanism (flow director) for channeling the water as claimed (Compl. ¶37; Compl. ¶38).	¶37; ¶38	col. 4:32-46

Identified Points of Contention

• Structural Equivalence: For the ’850 Patent, a central question will be whether the internal mechanism of the Accused Products contains the specific "first plenum," "second plenum," and "third plenum" architecture as claimed. The complaint does not provide evidence of the products' internal construction, creating a potential dispute over whether the accused water channels meet the structural requirements of the claims.
• Definitional Scope: For the ’435 Patent, the analysis may focus on whether the "Point Jet" and "Wide Fan" sprays constitute two distinct "types of the flow of water." A dispute could arise over whether a difference in spray pattern alone is sufficient to meet this limitation, or if a more fundamental difference (e.g., pulsating vs. continuous) is required.

V. Key Claim Terms for Construction

'435 Patent: "a second type of the flow of water different from the first type"

• Context and Importance: The infringement theory hinges on the "Wide Fan" and "Point Jet" functions of the Accused Products satisfying the requirement for two different "types" of flow. The construction of this term will determine whether a difference in spray pattern (fan vs. jet) is legally sufficient to meet the claim limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes embodiments where one set of nozzles is "configured to create a fan-shaped spray" and another nozzle is "configured to create a jet stream of water," treating these as distinct configurations ('435 Patent, col. 2:13-16). This language may support an interpretation where different spray patterns constitute different "types" of flow.
  • Evidence for a Narrower Interpretation: The patent does not explicitly define the term "type." A defendant may argue that "type" refers to more fundamental hydraulic properties, such as a steady stream versus a pulsating flow, and that both the accused fan and jet sprays are of the same "type" (i.e., a steady stream).

'850 Patent: "plenum"

• Context and Importance: This term defines a key structural element of the claimed invention. As the complaint lacks details on the internal construction of the Accused Products, infringement of the '850 Patent's claims will depend heavily on whether the internal water-directing chambers of the accused device can be characterized as the claimed "plenums."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent uses the term consistent with its general technical meaning of a distribution chamber. The figures depict distinct chambers (e.g., 212a, 212b, 212c) that receive water from the flow director and feed it to a corresponding set of nozzles ('850 Patent, Fig. 2C). This may support a broad construction covering any chamber that performs this function.
  • Evidence for a Narrower Interpretation: A defendant could argue that the term should be limited to the specific embodiments shown in the patent's drawings, potentially arguing that simpler internal conduits in its product do not rise to the level of the claimed "plenum" structures.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents, stating that Defendant acts with knowledge and provides "instructions for use to consumers" that would result in infringement of the patented methods (Compl. ¶41; Compl. ¶54).
• Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It asserts that Plaintiffs notified Defendant of infringement of the '435 Patent prior to the lawsuit via an Amazon APEX complaint (Compl. ¶7; Compl. ¶27). The complaint further alleges that Defendant's subsequent filing of a declaratory judgment action was because it "believes the Accused Products infringe the '435 Patent" (Compl. ¶30).

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

• A core issue will be one of structural infringement: What are the specific internal mechanics of the accused showerheads? Discovery will be required to determine if they contain the distinct, multi-plenum architecture required by the claims of the '850 Patent, or if they use a different mechanism to achieve a similar functional result.
• A key question of claim scope will be central to the '435 Patent analysis: Can the term "different type of the flow of water" be construed to mean that a jet stream and a fan-shaped spray are legally distinct types? The outcome of this construction will likely determine infringement for that patent.
• The case presents a question of intent and willfulness rooted in pre-suit conduct: How will the court view Defendant's decision to file a declaratory judgment action in a different district in response to an Amazon APEX notice? This procedural history will be a focal point for Plaintiffs' allegations of willful infringement.