Zhadanov v. Xiamen Huangyudu Cosmetics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Eli Zhadanov (New York); Interlink Products International, Inc. (New Jersey)
  • Defendant: Xiamen Huangyudu Cosmetics Co., Ltd. (China); Huian County Mubing E-commerce Co., Ltd. (China); Decomax Technology Inc. (New York); Xiantao Wensheng Technology Co., Ltd. (China); and Aqua Home Product Inc. (New York)
  • Plaintiff's Counsel: The Law Office of JASON B. LATTIMORE, ESQ. LLC
• Case Identification: 1:26-cv-01027, E.D.N.Y., 04/03/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of New York because certain defendants reside and conduct business in the district, and all defendants are alleged to have directed their infringing and deceptive sales activities to consumers in New York.
• Core Dispute: Plaintiffs allege that Defendants' handheld showerheads infringe two patents related to multi-mode showerheads that feature distinct nozzles for both standard showering and high-pressure cleaning functions.
• Technical Context: The technology at issue resides in the consumer plumbing fixtures market, specifically focusing on handheld showerheads that offer enhanced utility beyond personal bathing, such as cleaning tub and tile surfaces.
• Key Procedural History: The complaint alleges a history of disputes between the parties, including Plaintiffs' use of the Amazon Patent Evaluation Express (APEX) program to report infringement. In response to these reports, certain Defendants previously filed declaratory judgment actions for noninfringement in the Western District of Washington, which were subsequently transferred to the Eastern District of New York.

Case Timeline

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 Invention Explained

• Problem Addressed: The patent's background section notes that conventional showerheads are designed primarily for showering, and their water pressure and spray patterns are often "undesirable for cleaning purposes," such as rinsing tiled walls or tubs '435 Patent, col. 1:19-27
• The Patented Solution: The invention is a showerhead with two independent sets of nozzles: a standard set on the faceplate for showering and a separate set, typically on the top or back of the head, designed specifically for cleaning '435 Patent, abstract A user-operated "flow selector" internally directs water to either the showering nozzles or the cleaning nozzles, which can produce different spray types, such as a concentrated jet stream or a wide, fan-shaped spray '435 Patent, col. 4:26-55 '435 Patent, Fig. 1B This allows a single device to serve both functions effectively without compromising performance.
• Technical Importance: This design provides enhanced utility by integrating specialized, high-pressure cleaning functions into a standard handheld showerhead, addressing a practical limitation of conventional designs '435 Patent, col. 1:19-27

Key Claims at a Glance

• The complaint asserts independent claim 1 and several dependent claims '435 Patent, col. 9:1-28 Compl. ¶47
• Claim 1 recites a showerhead comprising:
  • A head portion and a handle.
  • A plurality of "first nozzles" configured to direct water in a "first direction".
  • At least one "second nozzle" and at least one "third nozzle" configured to direct water in a second and third direction, respectively, where these directions are "transverse to the first direction".
  • A "flow selector" moveable between a first position (directing water to the first nozzles), a second position (directing water to the second nozzle), and a third position (directing water to 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 asserts claims 1 and 7-17 Compl. ¶47

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

• Patent Identification: U.S. Patent No. 11,992,850, "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 the '435 Patent: conventional showerheads are ill-suited for cleaning tasks due to their spray patterns and pressure levels '850 Patent, col. 1:8-20
• The Patented Solution: The patented solution is a showerhead with an internal "flow director" that selectively routes water to different nozzle sets via distinct plenums '850 Patent, abstract This mechanism allows a user to switch between standard showering nozzles on the faceplate and a separate set of nozzles that project water in a transverse direction for cleaning tasks '850 Patent, col. 4:32-52 The patent describes specific cleaning sprays, including a fan-shaped spray and a jet stream '850 Patent, col. 5:17-24 '850 Patent, col. 5:41-47
• Technical Importance: The invention provides a structural mechanism for a multi-function showerhead, enabling it to perform both showering and high-pressure cleaning functions from a single device '850 Patent, col. 1:8-20

Key Claims at a Glance

• The complaint asserts independent claim 9 and several dependent claims '850 Patent, col. 9:1-22 Compl. ¶61
• Claim 9 recites a showerhead comprising:
  • A head portion and a handle.
  • A plurality of "first nozzles" directing water in a "first direction through a first plane".
  • A "second nozzle" and a "third nozzle" directing water in a "second direction through a second plane", with the second plane being "transverse to the first plane".
  • A "first plenum", "second plenum", and "third plenum" fluidly coupled to the respective nozzle sets.
  • A "flow director" moveable between three positions to selectively couple a main water channel to one of the three plenums.
• The complaint asserts claims 9-13 Compl. ¶61

III. The Accused Instrumentality

Product Identification

• The "Accused Products" are handheld showerheads manufactured by Xiamen Galenpoo Kitchen & Bathroom Technology Co., Ltd. and sold by the Defendants under various brand names (e.g., Besaquo, Pavezo, Razime, VKZK) and Amazon ASINs as detailed in the complaint's tables Compl. ¶26 Compl. ¶28 Compl. pp. 8-9

Functionality and Market Context

• The complaint alleges that the Accused Products are handheld showerheads featuring a "2-Mode Power Wash" function Compl. ¶33 This function is enabled by cleaning jets located on the top portion of the showerhead that provide two distinct spray patterns for cleaning Compl. ¶32 Defendants' advertising materials are cited to show these modes, identified as "Power Jet" and "Wide range," which are alleged to be a central selling feature distinguishing the products from competitors Compl. ¶32 Compl. p. 10 Another advertisement highlights "3 Modes + 2 Washing Jets + 8 Hand Sprays," further underscoring the multi-mode functionality Compl. p. 14

IV. Analysis of Infringement Allegations

'435 Patent Infringement Allegations

'850 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the '435 Patent may be whether the Accused Product's "flow selector" is capable of moving to distinct second and third positions that isolate the different cleaning sprays (e.g., fan spray vs. jet spray), as suggested by the claim language "directed through the at least one second nozzle" and "directed through the at least one third nozzle." The complaint alleges two different stream types but is not specific as to whether they can be selected independently.
• Technical Questions: For both patents, a key factual issue will be the internal mechanism of the Accused Products. What evidence does the complaint provide that the products contain the claimed system of a moveable "flow director" and distinct first, second, and third "plenums"? The allegations are based on external observation and marketing materials, which may not be sufficient to prove the internal structure required by the claims.

V. Key Claim Terms for Construction

'435 Patent, Claim 1

• The Term: "flow selector moveable between... a second position... and a third position"
• Context and Importance: This term is critical because infringement may depend on whether the Accused Products' selector can independently activate the "wide stream" and the "jet stream" cleaning nozzles. If the selector has only one "cleaning mode" that activates both types of top nozzles simultaneously, it may not meet this limitation. Practitioners may focus on this term to determine if the claim requires three discrete, user-selectable output modes.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim requires the selector to be "moveable between" the positions, which a party might argue is met by any selector that passes through these functional states, even if it does not rest in all of them.
  • Evidence for a Narrower Interpretation: The specification explicitly describes and illustrates discrete selector positions corresponding to each nozzle set. Figures 3A-3B show a distinct second position coupling the water channel to the second plenum for the fan-spray nozzles, while Figures 4A-4B show a distinct third position coupling the channel to the third plenum for the jet nozzle '435 Patent, col. 5:8-19 '435 Patent, col. 5:30-41 This supports a construction requiring three separate, stable selector positions.

'850 Patent, Claim 9

• The Term: "flow director"
• Context and Importance: The patent uses this specific term for the internal water-routing mechanism. The infringement analysis will depend on whether the accused device contains a structure that meets the definition of a "flow director" as described and depicted in the patent, or if the term can be construed more broadly to cover any valve or switch.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that "flow director" should be given its plain and ordinary meaning, covering any component that directs the flow of water within the showerhead.
  • Evidence for a Narrower Interpretation: The specification provides substantial detail on a specific embodiment of the "flow director 208", including a "ball-and-socket coupling 250", "spring loaded pins 254" that engage with "indentations 256" to hold it in position, and a specific shape with arms ("505a", "505b") '850 Patent, col. 4:58-67 '850 Patent, Fig. 5A A defendant may argue this detailed disclosure limits the scope of the term to a structure with these or equivalent features.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendants induced infringement by selling the Accused Products with knowledge of the patents and providing "instructions for use to consumers" that would result in infringement Compl. ¶52 Compl. ¶64 The advertising materials showing the multi-mode functionality may be used as evidence of encouraging infringing use Compl. p. 10 Compl. p. 14
• Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge of the patents. The complaint asserts that Plaintiffs previously initiated Amazon's APEX enforcement process and that certain Defendants filed declaratory judgment actions in response, allegedly establishing knowledge of the patents and the infringement allegations prior to this lawsuit Compl. ¶¶37-39 Compl. ¶¶54-55 Compl. ¶¶66-67

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

• A core issue will be one of claim scope and functionality: Does the claim language requiring a "flow selector moveable between... a second position... and a third position" necessitate three discrete, independently selectable output modes (e.g., shower, fan-spray, jet-spray)? The case may turn on whether the Accused Products' selector provides this level of control or combines the cleaning functions into a single mode.
• A key evidentiary question will be one of internal structure: Does discovery reveal that the Accused Products contain the internal architecture claimed in the patents, specifically the system of a moveable "flow director" and multiple, distinct "plenums" that route water to the different nozzle sets? The complaint's allegations are based on external function, and proof of the claimed internal mechanism will be central to the infringement analysis.