BHRS Group LLC v. Ez Inventions LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: BHRS Group, LLC (New Jersey)
  • Defendant: EZ Inventions LLC dba Filter 123 (Delaware); Brilliant Initiatives LLC (New York); and Shimon Oestreicher (New York)
  • Plaintiff's Counsel: Lombard & Geliebter LLP
• Case Identification: 1:26-cv-02460, E.D.N.Y., 07/21/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of New York based on Defendants' residence, places of business, substantial business contacts, and commission of infringing acts within the district, including in Kings County.
• Core Dispute: Plaintiff alleges that Defendants' aftermarket replacement water filters infringe a patent related to a secure bayonet-type filter connection, in addition to claims of trade dress infringement and false advertising.
• Technical Context: The lawsuit concerns the market for replacement water filters for bottleless water coolers, where mechanical compatibility and the integrity of the connection interface are critical for functionality.
• Key Procedural History: The complaint alleges that Plaintiff previously notified Defendants of infringement related to an earlier product version via Amazon's Patent Evaluation Express (APEX) process. Following this notice and a denial from Defendants, Defendants allegedly launched a new version of their product with modified features, which is the subject of the current infringement claim.

Case Timeline

Date	Event
2017-12-11	First use of BHRS's "Water Filter Mark" alleged
2018-06-11	U.S. Patent No. 11,123,667 Priority Date
2021-09-21	U.S. Patent No. 11,123,667 Issue Date
2025-05-22	BHRS informs EZ Inventions of infringement by "Old Accused Product"
2025-06-18	EZ Inventions responds to BHRS, denying infringement
Early 2026	Defendants allegedly debut the "New Accused Product"
2026-03-XX	BHRS initiates APEX proceeding regarding the "New Accused Product"
2026-07-21	First Amended Complaint Filing Date

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

U.S. Patent No. 11,123,667 - "Water Cooler Filter With Secure Bayonet-type Connection"

• Patent Identification: U.S. Patent No. 11123667 ("Water Cooler Filter With Secure Bayonet-type Connection"), issued September 21, 2021 (the "'667 Patent"). Compl. ¶28

The Invention Explained

• Problem Addressed: The background of the patent notes that for some applications, the interlock mechanism of conventional bayonet-type water filters is not sufficiently secure. U.S. Patent No. 11,123,667, col. 2:1-5
• The Patented Solution: The invention proposes an enhanced dual-interlock system for connecting a filter to a water cooler housing. In addition to a standard bayonet connection (elongated protrusions on the filter neck engaging channels in the housing), the patent describes a second interlock. This second lock consists of protrusions on an inclined portion of the filter's base that must align with and be received by corresponding recesses in the housing surface. This alignment can only occur after the filter is rotated, a design intended to create a more secure, leak-proof connection that ensures the filter is fully and correctly seated before water can flow. U.S. Patent No. 11,123,667, abstract U.S. Patent No. 11,123,667, col. 2:9-38 The complaint highlights a key part of this system as a "teeth mechanism" on the filter neck. Compl. ¶96
• Technical Importance: This design provides a more robust and secure connection for replacement filters, aiming to prevent improper installation, leaks, and potential damage to the water cooler system. U.S. Patent No. 11,123,667, col. 2:13-15

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 of the '667 Patent. Compl. ¶152
• The essential elements of independent claim 1 include:
  • A filter for a water cooler comprising a housing with a cavity and cavity ports, said filter comprising: an end and an axis;
  • A cylindrical base with a base surface;
  • A filter neck extending from the base, with specific geometry including a bottom section, a smaller upper top section, and a lower top section;
  • The upper top section comprising a planar step that forms first and second teeth extending outward from the center;
  • The teeth having parallel edges offset from the center;
  • The side surface of the neck comprising an elongated protrusion;
  • The base surface comprising an inclined surface portion with one or more protrusions;
  • The filter end being configured for bayonet-type reception in the housing. Compl. ¶152 '667 Patent, col. 9:45-col. 10:14
• The complaint alleges infringement of "one or more claims" of the patent, which may include the assertion of dependent claims. Compl. ¶145

III. The Accused Instrumentality

Product Identification

• The primary accused product is the "New Accused Product," identified as Model No. RIVERPURE-1500 (Amazon ASIN B0FQ4GYPZZ). Compl. ¶92

Functionality and Market Context

• The RIVERPURE-1500 is an aftermarket replacement water filter marketed as being compatible with BHRS's Avalon brand bottleless water coolers. (Compl. ¶¶1; Compl. ¶106) The complaint alleges that an earlier version of the product, the "Old Accused Product," was incompatible and would "obstruct the flow of water." Compl. ¶98 The complaint further alleges that the "New Accused Product" was purposefully modified to include features, specifically a "teeth mechanism," to overcome these compatibility issues, thereby making it functional with the Avalon coolers. Compl. ¶¶97-99 A side-by-side image in the complaint illustrates the alleged addition of "Teeth" to the filter head of the New Accused Product, which were absent on the Old Accused Product. Compl. ¶97

IV. Analysis of Infringement Allegations

The complaint alleges that the "New Accused Product" infringes at least claim 1 of the '667 Patent. The complaint provides annotated images to map features of the accused product to claim limitations. Compl. ¶¶161-165

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A filter for a water cooler comprising a housing with a cavity and cavity ports...	The New Accused Products are filters for water coolers and are used with a housing containing a cavity and ports.	¶156	col. 9:45-47
a filter neck extending from said base surface... said neck having a bottom section, a lower top section extending upward... an upper top section extending upward... and dimensionally smaller than the lower top section...	The New Accused Product's neck has a bottom section, a lower top section, and an upper top section that is dimensionally smaller.	¶161	col. 9:55-63
said upper top section comprising a planar step extending upward from the first planar surface and wherein the planar step forms first and second teeth extending outward from a center of the upper top section,	The upper top section has a planar step forming first and second teeth (two rectangular sections) extending outward, which the complaint alleges were added to overcome compatibility issues. A close-up image in the complaint highlights these "Teeth." Compl. ¶163	¶163	col. 10:1-5
said first and second teeth comprising a first and second edge, wherein said first and second edges are parallel to each other and offset from the center of the upper top section,	The first and second teeth have two edges that are parallel and offset from the center. An annotated image in the complaint points to these "Edges." Compl. ¶164	¶164	col. 10:6-9
said side surface of said neck comprising an elongated protrusion extending in a direction parallel to said axis,	The New Accused Product is inserted into the housing in a "bayonet-type fashion," which relies on such protrusions to engage with channels in the housing.	¶166	col. 10:10-11
said base surface comprising an inclined surface portion having one or more protrusions extending from said inclined surface portion,	The accused product's base surface includes an inclined surface portion with a protrusion described as a "stepped up ridge."	¶165	col. 10:12-14

Identified Points of Contention

• Scope Questions: A central dispute will likely concern whether the features added to the "New Accused Product" meet the specific limitations of the claims. For example, does the accused "planar step" and its associated "teeth" and "edges" have the same structure and orientation (e.g., "upward," "outward from a center," "parallel") as required by the claim language?
• Technical Questions: The complaint alleges the "Old Accused Product" was non-functional and that the "New Accused Product" was modified to overcome this issue. (Compl. ¶98; Compl. ¶99). This raises the technical question of whether the functionality of the added "teeth" in the accused product is the same as the function described in the patent-namely, engaging with "tooth stops" in the housing to ensure proper rotational alignment and a secure interlock. (See'667 Patent, col. 8:11-19).

V. Key Claim Terms for Construction

"planar step ... forms first and second teeth"

• Context and Importance: This term appears to be the central point of the infringement dispute. The complaint alleges Defendants specifically added this "teeth mechanism" after being put on notice of the patent and realizing their prior product was incompatible. (Compl. ¶96; Compl. ¶97; Compl. ¶98; Compl. ¶99). Practitioners may focus on this term because Defendants' pre-suit communication expressly denied the presence of this "claim-critical" feature on their old product, making its alleged appearance on the new product a focal point for willfulness. Compl. ¶96
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff may argue that the term should be interpreted functionally to cover any structures on the filter neck that engage with corresponding stops in the housing to control rotation, as this is the described purpose. The specification describes the teeth as extending "outward from a center" to engage with "tooth stops" in the housing. '667 Patent, col. 7:16-17 '667 Patent, col. 8:11-19
  • Evidence for a Narrower Interpretation: Defendants may argue the term is limited to the specific embodiment shown, where the teeth are formed by a "planar step extending upward" and have "planar surfaces" that are "parallel." '667 Patent, col. 7:14-21 '667 Patent, col. 10:1-9 Any deviation in the accused product from this specific geometric configuration could be argued as grounds for non-infringement.

"inclined surface portion having one or more protrusions"

• Context and Importance: This describes the second part of the patented dual-interlock system. Its construction is critical because infringement of claim 1 requires a finding that the accused product contains this element in addition to the "teeth."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification suggests this feature can be quite varied, stating the protrusions may form "geometric shapes, symbols, characters... words, logos, designs and the like," including the word "AVALON." '667 Patent, col. 3:57-64 '667 Patent, col. 6:1-3 Plaintiff may argue that the "stepped up ridge" on the accused product Compl. ¶165 is a "protrusion" that serves the claimed purpose of interacting with the housing.
  • Evidence for a Narrower Interpretation: The function of the "inclined surface" is explicitly described as causing the filter to move away from the housing during rotation to allow the protrusions and recesses to align. '667 Patent, col. 6:7-11 Defendants may argue that their product's "stepped up ridge" does not function in this specific manner or that its base surface is not "inclined" as taught by the patent, thus distinguishing it from the claimed invention.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is alleged based on Defendants directing contract manufacturers to build the infringing products and marketing and selling the products to end-users for their intended infringing use. Compl. ¶149 Compl. ¶155
• Willful Infringement: The complaint makes a detailed case for willfulness. It alleges that Defendants had pre-suit knowledge of the '667 Patent as of May 2025. Compl. ¶96 More significantly, it alleges that after denying infringement by pointing to the absence of the patented "teeth mechanism," Defendants then launched a new product that specifically incorporated this very feature to overcome compatibility problems. (Compl. ¶96; Compl. ¶97; Compl. ¶98; Compl. ¶99) This narrative suggests intentional and deliberate copying in the face of a known patent.

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

• A core issue will be one of definitional scope and copying: The complaint frames a potent narrative: Defendants were notified of a patent, identified the "teeth mechanism" as a key missing element in their non-functional product, and then allegedly added that exact feature to their new product. The central legal and factual question will be whether the features added to the "New Accused Product" are technically the same as the "first and second teeth" required by the claim, or if Defendants can establish a good-faith, technically-supported argument that their new design, while functional, still falls outside the patent's scope.
• A key evidentiary question will be one of intent: Given the allegation that Defendants' own pre-suit letter identified the key patented feature, the case may turn on what evidence Defendants can produce to demonstrate a good-faith belief of non-infringement when designing the "New Accused Product." The plausibility of their non-infringement defense will be weighed against the strong circumstantial evidence of deliberate copying alleged in the complaint.