Zhang v. Individuals Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Yongchang Zhang (China)
  • Defendant: The Individuals, Partnerships, and Unincorporated Associations Identified on Schedule A
  • Plaintiff’s Counsel: Law Office of Bole Yuan, Esq.
• Case Identification: 2:25-cv-03944, E.D. Pa., 07/25/2025
• Venue Allegations: Plaintiff alleges venue is proper because a substantial part of the events giving rise to the claims occurred in the district and because Defendants target consumers in the district through online stores.
• Core Dispute: Plaintiff alleges that Defendants’ foldable pet water basins infringe a patent related to a reinforced, polygonal, one-piece water basin design.
• Technical Context: The technology relates to portable, foldable water basins, primarily for washing pets, within the consumer e-commerce market for pet supplies.
• Key Procedural History: The complaint does not mention any prior litigation, post-grant proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2021-12-31	U.S. Patent No. 11,786,079 Priority Date
2023-10-17	U.S. Patent No. 11,786,079 Issue Date
2025-07-25	Complaint Filing Date

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

U.S. Patent No. 11,786,079 - "Polygonal One-piece Foldable Water Basin"

• Patent Identification: U.S. Patent No. 11,786,079, "Polygonal One-piece Foldable Water Basin," issued October 17, 2023 (the “’079 Patent”).

The Invention Explained

• Problem Addressed: The patent describes a problem with existing one-piece foldable water basins made of flexible materials like PVC. When filled with water, the load causes the inner wall to stretch and the outer wall to incline or split, limiting the practical size and durability of the basin (’079 Patent, col. 1:15-30).
• The Patented Solution: The invention is a foldable water basin with walls reinforced by an outer tarpaulin layer. This tarpaulin contains a "high strength square mesh" made of "inelastic materials" (’079 Patent, col. 2:28-39; ’079 Patent, col. 4:30-32). This inelastic mesh, enclosed within the tarpaulin, prevents the basin walls from deforming under the weight of the water, which allows the basin to be made "infinitely large" and overcome the size limitations of prior art designs (’079 Patent, col. 2:35-39; ’079 Patent, col. 4:35-39).
• Technical Importance: The use of an inelastic mesh reinforcement addresses a key structural failure point in large, flexible, non-supported water containers, potentially enabling the creation of more durable and larger-capacity portable products (Compl. ¶¶17-18).

Key Claims at a Glance

• The complaint asserts infringement of dependent claims 2, 3, 4, and 5 (’50; Compl. ¶51). These claims depend on independent claim 1.
• Independent Claim 1 requires:
  • A polygonal one-piece foldable water basin comprising a water basin body
  • At least one water outlet on the body
  • A supporting frame at an inner wall of the outlet
  • An elongated rod penetrating and slidably engaging the supporting frame
  • A circular plate fixed to an end of the rod
  • A water feeding mechanism at a top surface of the body
  • The water basin body is made of terylene
  • A PTFE film on an outer surface of the body
  • A tarpaulin on an outer side of the body
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The accused products are "polygonal one-piece pet water basin products" sold by Defendants through various online storefronts, such as on Amazon.com (Compl. ¶¶7, 35). An exemplary product is identified as being sold by Defendant JoyinDirect under the brand name "SLOOSH" (Compl. p. 9, Diagram 4).

Functionality and Market Context

• The accused products are alleged to feature "reinforced basin walls with mesh enclosed in the tarpaulin" (Compl. ¶36). The complaint includes a marketing image from an accused product listing that depicts a "5-layer reinforced pool wall" structure, which includes a "Strong mesh layer" positioned between layers of "Thickened PVC" and a "5mm PP board" (Compl. p. 9, Diagram 4). This image illustrates the folding process of the accused product for "easy travel" (Compl. p. 9, Diagram 4).
• The complaint alleges that Defendants are an "interconnected group" of online sellers who use "common or similar tactics" to sell infringing products while concealing their identities (Compl. ¶¶8-9).

IV. Analysis of Infringement Allegations

’079 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A polygonal one-piece foldable water basin, comprising a water basin body...	The accused products are described as "polygonal one-piece pet water basin[s]" that pack "down small for easy travel." A photograph of an exemplary infringing product depicts a polygonal, foldable basin.	¶36; ¶37; p. 9, Diagram 4; p. 10, Diagram 5	col. 5:1-2
...a tarpaulin is provided at an outer side of the water basin body.	The accused products are alleged to have "reinforced basin walls" and are depicted with a "5-layer reinforced pool wall" that includes a "Strong mesh layer" and outer layers of PVC.	¶36; p. 9, Diagram 4	col. 5:5-7
...the water basin body is made of terylene...	The complaint does not provide sufficient detail for analysis of this element.		col. 5:4
...a PTFE film is provided on an outer surface of the water basin body...	The complaint does not provide sufficient detail for analysis of this element.		col. 5:4-5
...at least one water outlet is provided at the water basin body, a supporting frame is provided at an inner wall of the at least one water outlet...an elongated rod is provided...a circular plate is fixed at an end of the elongated rod...	The complaint does not provide sufficient detail for analysis of the specific water outlet structure claimed.		col. 5:2-4
...a water feeding mechanism is provided at a top surface of the water basin body...	The complaint does not provide sufficient detail for analysis of this element.		col. 5:3-4

Note: The complaint’s central infringement theory appears to rely on the limitations of dependent claim 2, which requires that the "tarpaulin comprises a mesh and a base cloth and the mesh is enclosed in the base cloth" (’079 Patent, col. 5:8-11). The complaint’s visual evidence, showing a "Strong mesh layer" inside the wall, directly supports this allegation (Compl. p. 9, Diagram 4).

Identified Points of Contention

• Evidentiary Questions: The complaint focuses heavily on the reinforced wall structure (the "tarpaulin" with "enclosed mesh") but provides no specific allegations or evidence mapping the accused products to other, distinct limitations of independent claim 1. Key questions for the court may include whether the accused products contain the specific "water outlet" assembly (including a "supporting frame" and "elongated rod"), the "water feeding mechanism," the "terylene" body, and the "PTFE film" as required by the independent claim on which the asserted dependent claims rely.
• Scope Questions: A potential dispute may arise over whether the "5-layer reinforced pool wall" shown in the accused product's marketing materials (Compl. p. 9, Diagram 4) constitutes a "tarpaulin" as that term is used and defined in the patent.

V. Key Claim Terms for Construction

The Term: "tarpaulin"

• Context and Importance: This term is central to the patent’s point of novelty and the core of the infringement allegation. Its construction will determine whether the multi-layer wall of the accused product falls within the scope of the claims. The complaint alleges the accused products have "mesh enclosed in the tarpaulin" (Compl. ¶36). Practitioners may focus on this term because the patent’s specification provides a specific definition that could be used to narrow the claim scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 itself only requires "a tarpaulin is provided at an outer side of the water basin body," which could suggest any reinforcing outer fabric layer (’079 Patent, col. 5:5-7).
  • Evidence for a Narrower Interpretation: The specification defines the tarpaulin as comprising "a mesh 13 and a base cloth 14" and states the base cloth is made from "high strength terylene or chinlon" and "coated with PVC paste" (’079 Patent, col. 3:23-27; ’079 Patent, col. 4:23-24). This language could support a narrower construction limited to this specific multi-component structure.

The Term: "supporting frame" (at the water outlet)

• Context and Importance: This is a required element of independent claim 1. Since the complaint provides no evidence showing this feature on the accused products, its presence or absence is a critical factual question. The definition of "supporting frame" will be important if Defendants argue their products use a standard drain plug that lacks such a structure.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language requires only "a supporting frame is provided at an inner wall of the at least one water outlet adjacent to an edge thereof" (’079 Patent, col. 6:64-66), which could be argued to read on any internal structure that reinforces the outlet opening.
  • Evidence for a Narrower Interpretation: Figure 3 of the patent depicts the "supporting frame" (3) as a distinct component through which the "long pole" (4) passes (’079 Patent, Fig. 3). The description explains its interaction with the "long pole" and "circular plate" to clear the drain (’079 Patent, col. 3:24-30). This could support a construction requiring this specific structural arrangement.

VI. Other Allegations

Indirect Infringement

• The complaint does not plead a separate count for indirect infringement. While the prayer for relief requests an injunction against "Assisting, aiding, or abetting" infringement (Compl. ¶(1)(b)), the factual allegations in the body of the complaint focus on direct infringement under 35 U.S.C. § 271(a) and on Defendants "working in active concert" to sell the accused products (Compl. ¶40; Compl. ¶54).

Willful Infringement

• The complaint alleges willful infringement based on Defendants having "actual and constructive knowledge" of the ’079 Patent and acting with "reckless disregard or willful blindness" to the Plaintiff's rights (Compl. ¶¶45-47, 53, 55).

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

• A central issue will be one of evidentiary completeness: can the Plaintiff demonstrate that the accused products meet every limitation of independent claim 1? The complaint provides visual evidence for the core reinforcing-mesh technology but is silent on other claimed elements, such as the specific water outlet assembly ("supporting frame," "elongated rod") and material compositions ("terylene," "PTFE film"), creating a potential gap between the allegations and the full scope of the asserted claims.
• A second key question will be one of definitional scope: does the accused product's "5-layer reinforced pool wall" (Compl. p. 9, Diagram 4) meet the definition of a "tarpaulin" as that term is construed in light of the patent's specification? The case may turn on whether the term is given a broad, functional meaning or is limited to the specific materials and structure described in the patent’s preferred embodiments.