Shenzhen Juxinli Technology Co Ltd v. Interlink Products Intl Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Shenzhen Juxinli Technology Co., Ltd. (People's Republic of China)
  • Defendant: Interlink Products International, Inc. (New Jersey) and Eli Zhadanov (New York)
  • Plaintiff's Counsel: Glacier Law LLP
• Case Identification: 2:25-cv-02732, W.D. Wash., 03/16/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendants directed patent enforcement activities at Amazon's Washington-based platform, including initiating an Amazon Patent Evaluation Express (APEX) proceeding, which constitutes a substantial part of the events giving rise to the action.
• Core Dispute: Plaintiff seeks a declaratory judgment that its rain shower head products do not infringe two of Defendants' patents and/or that the patents are invalid.
• Technical Context: The dispute concerns multi-function handheld showerheads capable of directing water flow to different nozzle groups to produce varied spray patterns, such as standard shower sprays, high-pressure jets, or fan-shaped sprays for cleaning.
• Key Procedural History: The complaint states this action arises from Defendants' enforcement of the '435 Patent against Plaintiff's products on Amazon.com through the APEX process. It also notes that Defendants have asserted the '850 Patent against similar products in separate litigation in the Eastern District of New York, creating a continuing controversy between the parties.

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

The Invention Explained

• Problem Addressed: The patent addresses the shortcomings of conventional showerheads when used for cleaning purposes (e.g., rinsing tiled walls) US 12,485,435 B2, col. 1:19-27 It notes that typical showerhead spray patterns may have insufficient pressure or coverage for effective cleaning US 12,485,435 B2, col. 3:28-41
• The Patented Solution: The invention is a showerhead with a selector mechanism that directs water flow to different sets of nozzles US 12,485,435 B2, col. 2:1-16 In addition to the standard faceplate nozzles for showering, it includes separate nozzles on another part of the head, such as a "second nozzle" that creates one type of flow (e.g., a fan-shaped spray) and a "third nozzle" that creates a different type (e.g., a jet stream), with these flows being transverse to the main shower direction US 12,485,435 B2, abstract US 12,485,435 B2, col. 4:13-33
• Technical Importance: This design provides a single device that combines a standard shower function with specialized high-pressure or wide-coverage spray functions tailored for cleaning tasks.

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement of the '435 Patent, focusing on independent claim 1 Compl. ¶27
• Independent Claim 1 Elements:
  • A showerhead with 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 disposed in the head portion, configured to direct water in a second and third direction substantially the same as each other and 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 flow (e.g., fan-shaped spray) and the third nozzle creates a different, second type of flow (e.g., jet stream).
• The complaint does not explicitly reserve the right to assert dependent claims but references "any claim of the '435 Patent" Compl. ¶27

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

The Invention Explained

• Problem Addressed: As the parent patent, the '850 Patent addresses the same problem as the '435 Patent: the inadequacy of conventional showerheads for cleaning tasks due to suboptimal water pressure or spray patterns US 11,992,850 B2, col. 3:5-24
• The Patented Solution: The '850 Patent discloses a similar showerhead structure but claims it with an emphasis on the internal fluid pathways US 11,992,850 B2, abstract The solution involves a "flow director" that moves between positions to couple a main water channel to one of three separate "plenums." Each plenum is fluidly coupled to a distinct set of nozzles (e.g., the faceplate nozzles, a fan-spray nozzle, or a jet-stream nozzle), allowing the user to select the desired output US 11,992,850 B2, col. 4:56-61 US 11,992,850 B2, col. 8:3-10
• Technical Importance: This approach provides a specific internal mechanical structure for reliably partitioning and directing water flow to functionally distinct nozzle arrays within a single showerhead.

Key Claims at a Glance

• The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 9, and 14 Compl. ¶51
• Independent Claim 1 Elements:
  • A showerhead with a head portion, handle, and faceplate with first nozzles.
  • A second nozzle and a third nozzle separate from the faceplate.
  • 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 a first, second, and third position to selectively couple a water channel to the first, second, or third plenum, respectively.
• The complaint does not explicitly reserve the right to assert other claims but references "any claim of the '850 Patent" Compl. ¶50

III. The Accused Instrumentality

Product Identification

• Plaintiff's "rain shower head" products sold on Amazon.com, identified by ASINs including B0FH1577WQ, B0DQHFG94H, and others Compl. ¶¶10, 22 Compl. ¶24

Functionality and Market Context

• The complaint describes the Accused Product as employing a "rotatable disc/faceplate mechanism" to select different water outlets Compl. ¶28
• This mechanism is alleged to operate in "multiple discrete positions" to route water through internal passageways Compl. ¶28
• Crucially, the plaintiff states the Accused Product includes an "additional 'off' position in which no water is discharged from any nozzle" Compl. ¶28
• For the '850 Patent, the plaintiff alleges the Accused Product has "no plenum" and no need for one Compl. ¶51
• The complaint alleges that Amazon is Plaintiff's "primary sales channel in the United States," making the threatened removal of its product listings a source of immediate and irreparable harm Compl. ¶15 Compl. ¶18

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'435 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The primary dispute may concern the scope of the term "flow selector moveable between a first position, a second position, and a third position." A question for the court is whether the accused product's "rotatable disc" with an "off" setting is structurally and functionally equivalent to the claimed three-position selector, or if it represents a distinct, non-infringing design.
• Technical Questions: A factual question is whether the accused product's water routing scheme, which allegedly directs water to "side outlets and to selected subsets of faceplate nozzles" Compl. ¶28, corresponds to the patent's more discrete routing to one of three distinct nozzle groups as claimed.

'850 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: The case will likely turn on the construction of the term "plenum." A question for the court is how to define this term based on the patent's specification and whether any internal chamber or passageway within the accused device meets that definition, even if not explicitly labeled as a "plenum."
• Technical Questions: An evidentiary question will be whether the internal structure of the accused product contains chambers that perform the claimed function of the three separate plenums-receiving water from the flow director and distributing it to a specific nozzle group-thereby meeting the claim limitation, or if its internal fluidics operate on a fundamentally different principle.

V. Key Claim Terms for Construction

The Term: "flow selector moveable between a first position... a second position, and a third position" ('435 Patent, Claim 1)

• Context and Importance: This term is central because the plaintiff's non-infringement defense for the '435 Patent rests on the argument that its "rotatable disc/faceplate mechanism" with an "off" position is materially different Compl. ¶28 The definition will determine whether the accused mechanism is captured by the claim language.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the selector more broadly as a device "that enables the user to selectively direct the flow of water to the desired nozzle(s)" US 11,992,850 B2, col. 4:44-52, which could support arguing that the specific form (e.g., switch vs. rotating disc) is not limiting.
  • Evidence for a Narrower Interpretation: The patent figures consistently depict a sliding switch-style "flow selector 116" that moves linearly through a slot US 11,992,850 B2, Fig. 2A US 11,992,850 B2, Fig. 2B This specific embodiment, along with the discrete "first," "second," and "third" positions, could be used to argue for a narrower construction that excludes a continuously rotatable mechanism with an "off" position.

The Term: "plenum" ('850 Patent, Claim 1)

• Context and Importance: The plaintiff's entire non-infringement argument for the '850 Patent is that its product lacks the three claimed "plenums" Compl. ¶51 The construction of this term is therefore dispositive for the '850 Patent infringement analysis.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "plenum." A party might argue for the ordinary meaning of a chamber designed to contain a fluid at a pressure higher than its surroundings before distribution. Under such a broad definition, any internal cavity that serves this purpose could potentially be considered a "plenum."
  • Evidence for a Narrower Interpretation: The specification describes the "first plenum 212a," "second plenum 212b," and "third plenum 212c" as distinct, separate chambers, each fluidly coupled to a specific nozzle group and selectively fed by the flow director US 11,992,850 B2, col. 4:56-61 The clear depiction of these as separate structural components US 11,992,850 B2, Fig. 2C may support a narrower construction requiring three physically distinct chambers, which the accused product allegedly lacks.

VI. Other Allegations

Indirect Infringement

• The complaint preemptively denies indirect infringement for both patents. It alleges Plaintiff has not encouraged or intended for customers to practice the claimed invention, and that the Accused Product is a staple article of commerce suitable for substantial non-infringing uses Compl. ¶30 Compl. ¶52

Willful Infringement

• Willful infringement is not alleged by the defendants in this complaint, as the plaintiff is seeking declaratory judgment. The plaintiff does, however, characterize the defendants' enforcement activities as "baseless" Compl. ¶31 Compl. ¶53

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

This declaratory judgment action presents focused questions of claim scope and technical implementation for the court's determination.

• A core issue will be one of definitional scope: can the term "plenum", which the patent illustrates as three distinct internal chambers, be construed to read on the internal fluid pathways of the accused product, which the plaintiff alleges contains no such structures?
• A second key question will be one of structural equivalence: does the accused product's "rotatable disc" selector, which allegedly includes an "off" position, fall within the scope of the claimed "flow selector moveable between... three positions," or is it a materially different and non-infringing design?
• Finally, the litigation context itself raises a procedural question: whether this declaratory judgment action in Washington or the defendants' infringement action in New York is the proper forum to resolve the dispute, a common issue in multi-front patent conflicts.