Zhadanov v. Aqua Home Product Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Eli Zhadanov (New York)
  • Defendant: Aqua Home Product Inc. (New York)
  • Plaintiff’s Counsel: The Law Office of Jason B. Lattimore, Esq. LLC
• Case Identification: 1:26-cv-01020, E.D.N.Y., 02/20/2026
• Venue Allegations: Venue is based on Defendant being a New York corporation that resides in and conducts business within the Eastern District of New York.
• Core Dispute: Plaintiff alleges that Defendant’s handheld showerhead infringes a patent related to a showerhead with a secondary set of nozzles capable of producing two different types of cleaning sprays.
• Technical Context: The technology concerns multi-function showerheads that integrate standard showering capabilities with specialized, high-pressure cleaning jets for washing tub and tile surfaces.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other significant procedural events.

Case Timeline

Date	Event
2020-12-10	Priority Date for U.S. Patent No. 12,485,435
2025-12-02	U.S. Patent No. 12,485,435 Issues
2026-02-20	Complaint Filed

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. 12,485,435, "SHOWERHEAD HAVING SELECTOR FOR DIRECTING WATER FLOW IN INDEPENDENT DIRECTIONS," issued December 2, 2025 (the "’435 Patent").

The Invention Explained

• Problem Addressed: The patent's background section notes that showerheads designed for personal showering often have water pressure and spray patterns that are "undesirable for cleaning purposes," such as rinsing tiled walls or tubs (’435 Patent, col. 1:20-27).
• The Patented Solution: The invention is a handheld showerhead that combines a standard set of nozzles on its faceplate for showering with a separate, secondary set of nozzles located elsewhere on the head portion (’435 Patent, abstract). A user-operated "flow selector" can divert water away from the showering nozzles to the secondary nozzles, which are configured to produce two distinct types of cleaning sprays: one for broad rinsing (e.g., a "fan-shaped spray") and another for focused power-cleaning (e.g., a "jet stream") (’435 Patent, claim 1; ’435 Patent, claim 8). This selector mechanism routes water through different internal plenums to activate the desired nozzle set (’435 Patent, col. 5:1-58).
• Technical Importance: The invention aims to consolidate two functions—showering and high-pressure cleaning—into a single fixture, eliminating the need for separate cleaning tools while providing spray patterns specifically optimized for cleaning tasks (’435 Patent, col. 1:20-27).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 7-17 (’435 Patent, ¶24).
• Independent Claim 1 of the ’435 Patent recites the following essential elements:
  • A head portion and a handle.
  • A "plurality of first nozzles" for directing water in a first direction (i.e., for showering).
  • "At least one second nozzle" directing water in a second direction.
  • "At least one third nozzle" adjacent to the second, also directing water in a third direction.
  • A "flow selector" that is moveable between a first position (for the first nozzles), a second position (for the second nozzle), and a third position (for the third nozzle).
  • A requirement that the second and third directions are "substantially the same and transverse to the first direction."
  • A requirement that the second nozzle creates a "first type" of water flow and the third nozzle creates a "second type" of water flow "different from the first type."
  • A requirement that the flow selector can remain in any of its positions "without an external force continuously maintaining" it.
• The complaint reserves the right to assert additional claims (’435 Patent, ¶24).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as a showerhead sold by Defendant on Amazon under Model No. NY102022SH and ASIN B0BB5DV24G (the "Accused Product") (Compl. ¶15). The complaint provides an image identifying the Accused Product (Compl. p. 5).

Functionality and Market Context

• The Accused Product is a handheld showerhead that allegedly incorporates a "dual mode cleaning-jet feature" on its top portion (Compl. ¶¶18-19). The complaint alleges this feature provides two different cleaning spray patterns, which Defendant’s advertising refers to as "Wide Fan" and "Point Jet" (Compl. ¶18). A screenshot from Defendant's advertising illustrates these two distinct spray modes (Compl. p. 6).
• The complaint alleges the Accused Product is a "top selling showerhead[] on Amazon" and the "second-best-selling showerhead in the handheld showerhead category," placing it in direct competition with Plaintiff's own products (Compl. ¶¶16-17).

IV. Analysis of Infringement Allegations

’435 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a head portion; a handle extending from the head portion; a plurality of first nozzles configured to direct water flow in a first direction;	The Accused Product is a handheld showerhead with a head and handle, and it includes nozzles on its face that spray water in one direction for showering.	¶25	col. 4:1-3
at least one second nozzle disposed in the head portion and configured to direct water flow in a second direction;	The Accused Product has nozzles at the top that produce a "wider, flat stream" or "Wide Fan" spray for rinsing and cleaning.	¶26	col. 5:35-40
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 Product has a nozzle at the top that produces a "jet that emanates from the center nozzle" or "Point Jet" for cleaning.	¶26	col. 5:58-64
wherein the second direction and the third direction are substantially the same and transverse to the first direction,	The cleaning nozzles are located on the top of the showerhead and spray water in a direction that is "transverse to the flow of water emanating from the nozzles on the face of the showerhead." A provided image from Defendant's advertising depicts this transverse flow (Compl. p. 8).	¶25	col. 4:18-20
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 of the flow of water,	The cleaning nozzles allegedly provide "two different types of water flow streams": a "jet" and a "wider, flat stream," corresponding to the advertised "Point Jet" and "Wide Fan" modes.	¶26	col. 2:13-15
a flow selector moveable between a first position... a second position... and a third position...	The Accused Product allegedly "allows a user to control the flow of water through nozzles" on the face and the top of the showerhead.	¶25	col. 4:31-35
wherein the flow selector is configured to remain in one of the... position[s] without an external force continuously maintaining a desired position...	The complaint alleges that all limitations of claim 1 are present in the Accused Product but does not provide specific facts regarding the mechanical operation or stability of the selector switch.	¶24	col. 4:36-40

Identified Points of Contention

• Technical Questions: The complaint alleges the Accused Product's "Wide Fan" and "Point Jet" features map onto the claimed "second nozzle" and "third nozzle," respectively. A central question may be whether the physical structures and hydraulic operations of the accused nozzles meet the specific configurations required by the claims and described in the ’435 Patent's specification.
• Scope Questions: Analysis may focus on whether the Accused Product's mode-switching mechanism constitutes a "flow selector" as claimed. A further question is whether the complaint provides sufficient factual support for the limitation requiring that this selector can maintain its position without continuous external force, as no specific allegations address this mechanical property.

V. Key Claim Terms for Construction

The Term: "transverse to the first direction"

• Context and Importance: This term defines the geometric relationship between the standard showering spray and the specialized cleaning sprays. Its construction will determine whether a wide range of angles is covered or if a more specific orientation, such as perpendicularity, is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain meaning of "transverse" suggests "extending across," which does not inherently require a 90-degree angle. The patent claims use the term without further angular limitation (’435 Patent, claim 1).
  • Evidence for a Narrower Interpretation: The specification discloses that "In some embodiments, the second direction is perpendicular to the first direction" (’435 Patent, col. 4:20-21). A defendant may argue this statement informs or limits the scope of "transverse" to a generally perpendicular orientation.

The Term: "flow selector"

• Context and Importance: This term is central to the invention's operability. The dispute may turn on whether it is construed broadly to cover any user-operated switch for changing water flow, or more narrowly to encompass the specific mechanical structures disclosed in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is functional. Plaintiff may argue it should cover any component that performs the function of selecting water flow between the different nozzle sets.
  • Evidence for a Narrower Interpretation: The specification describes a specific embodiment in detail, including a "flow director 208" with a "ball-and-socket coupling 250," spring-loaded pins (254), and indentations (256) that enable the selector to "snap into one of the three positions" (’435 Patent, col. 5:9-16). A defendant may argue that these details are essential features of the claimed "flow selector."

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant has knowledge of the ’435 Patent and provides "instructions for use to consumers" that would allegedly result in direct infringement by users of the Accused Product (Compl. ¶29).
• Willful Infringement: The complaint alleges willful infringement based on Defendant's purported "knowing disregard of the ’435 Patent" and its engagement in infringing activities despite an "objectively high likelihood" of infringement (Compl. ¶¶30, 32).

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

• A core issue will be one of claim construction: will the term "flow selector" be interpreted broadly to cover any mechanism that switches between spray modes, or will it be narrowed to the specific mechanical implementation involving a ball-and-socket director and multiple plenums described in the patent's preferred embodiments?
• A key evidentiary question will be one of technical correspondence: does the Accused Product's "Wide Fan" and "Point Jet" functionality arise from nozzle structures that meet the distinct definitions of the "second nozzle" and "third nozzle" as required by claim 1, or is there a material difference in their configuration or operation?
• A potential litigation focus may be on sufficiency of allegations: the complaint makes a general allegation that all claim limitations are met, but a question remains whether sufficient factual detail has been provided for every element, particularly the functional requirement that the selector remains in a set position without continuous external force.