DCT

2:26-cv-01869

Yeedi Technology Ltd v. Shenzhen Shermon Technology Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-01869, W.D. Wash., 05/29/2026
  • Venue Allegations: Venue is alleged to be proper because Defendant Shermon's enforcement actions were targeted at a Yeedi product sold and warehoused within the district. The complaint also alleges Shermon agreed to the jurisdiction of courts in Seattle in its submission to Amazon.
  • Core Dispute: Plaintiff Yeedi seeks a declaratory judgment that its robotic vacuum does not infringe Defendant Shermon's patent and/or that the patent is invalid, following Shermon's successful effort to have Yeedi's product removed from the Amazon marketplace for alleged patent infringement.
  • Technical Context: The technology at issue relates to combination wet-dry robotic vacuum cleaners, specifically the internal mechanisms for separating dry debris collection from wet mopping and sewage handling.
  • Key Procedural History: The complaint states this lawsuit was precipitated by Shermon's notice of infringement submitted to Amazon on or about April 29, 2026, through Amazon's Patent Evaluation Express ("APEX") procedure. This notice resulted in Amazon delisting Yeedi's product from its marketplace on May 22, 2026, prompting Yeedi to file this declaratory judgment action.

Case Timeline

Date Event
2020-03-26 '975 Patent Priority Date
2022-11-22 '975 Patent Issue Date
2026-04-29 Shermon submits infringement notice to Amazon
2026-04-30 Amazon notifies Yeedi of Shermon's notice
2026-05-22 Amazon delists the accused Yeedi product
2026-05-29 Complaint Filing Date

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

U.S. Patent No. 11,503,975 - "Dry-Wet Separation Cleaning Floor Brush," issued November 22, 2022

  • Patent Identification: U.S. Patent No. 11,503,975, "Dry-Wet Separation Cleaning Floor Brush," issued November 22, 2022.

The Invention Explained

  • Problem Addressed: The patent's background section describes issues with prior art cleaning robots that perform sweeping, vacuuming, and mopping simultaneously. These issues include the inability to automatically clean the mopping cloth, the failure to collect dirty water (sewage), and the problem of sewage being stored together with dry dust, which "makes the box easily blocked" (׳975 Patent, col. 1:24-32).
  • The Patented Solution: The invention proposes a floor brush assembly with an internal "partition plate" that divides the housing into two "disconnected" chambers. The first chamber contains a "stiff roller brush" for dry sweeping and vacuuming, while the second chamber contains a "soft roller brush" for mopping. This physical separation is designed to manage dry debris and wet sewage independently within the same cleaning head, thereby preventing the mixing and clogging problems of the prior art (׳975 Patent, abstract; ׳975 Patent, col. 2:50-65).
  • Technical Importance: This design purports to enhance the functionality and reliability of all-in-one cleaning devices by creating physically separate pathways for solid and liquid waste streams, potentially improving cleaning performance and simplifying maintenance (׳975 Patent, col. 2:57-62).

Key Claims at a Glance

  • The complaint identifies independent claims 1, 9, and 16 as being at issue Compl. ¶29
  • The essential elements of independent claim 1 include:
    • A dry-wet separation cleaning floor brush comprising a housing, a stiff roller brush and a soft roller brush
    • wherein the housing is provided with a partition plate dividing the inner part of the housing into a first storage chamber and a second storage chamber which are disconnected to each other
    • wherein the stiff roller brush is partially contained in the first storage chamber and is movably connected to the housing, and the stiff roller brush partially protrudes the housing
    • and the soft roller brush is partially contained in the second storage chamber and is movably connected to the housing, and the soft roller brush partially protrudes the housing

III. The Accused Instrumentality

Product Identification

The accused product is the "Yeedi M14 Plus White Robot Vacuum and Mop," identified by Amazon Standard Identification Number (ASIN) B0F187JZBJ Compl. ¶1 Compl. ¶19

Functionality and Market Context

  • The complaint identifies the accused product as a "Robot Vacuum and Mop" that was offered for sale on the Amazon marketplace prior to its removal Compl. ¶1 Compl. ¶6
  • The complaint's primary technical description of the product is a negative one, alleging that it "does not have 'a partition plate dividing the inner part of the housing into a first storage chamber and a second storage chamber which are disconnected to each other'" as required by the patent's claims Compl. ¶29 The complaint does not otherwise provide specific details on the technical operation of the accused product's cleaning mechanism.

IV. Analysis of Infringement Allegations

This lawsuit is a declaratory judgment action for non-infringement. The following table summarizes the plaintiff's (Yeedi's) argument that its product is not covered by the patent claims, as alleged in the complaint.

'975 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a partition plate dividing the inner part of the housing into a first storage chamber and a second storage chamber which are disconnected to each other The complaint alleges that the Yeedi M14 Plus Robot Vacuum and Mop product does not practice this claim element because it does not have the specified partitioned and disconnected chamber structure. ¶29 col. 2:50-56
the soft roller brush is partially contained in the second storage chamber and is movably connected to the housing The complaint also alleges non-infringement on the basis that the accused product does not meet this limitation as required by the claims. ¶29 col. 2:58-62

  • Visual Evidence: Exhibit A includes a screenshot from Defendant's commercial webpage showing various robotic vacuum cleaners it manufactures and sells, such as the "M30Pro Laser Robot Vacuum Cleaner," providing context for its market activities Compl. Ex. A, p. 14

  • Identified Points of Contention:

    • Technical Question: The primary factual question will be whether the Yeedi M14 Plus product contains an internal structure that performs the function of a "partition plate" creating "disconnected" chambers, even if it is not identical in form to the patent's figures. The analysis will require a detailed examination of the accused product's internal construction.
    • Scope Question: What is the required degree of separation for the two chambers to be considered "disconnected to each other"? The case may turn on whether any level of air or fluid communication between the dry and wet sections of the device is sufficient to place it outside the scope of the claim.

V. Key Claim Terms for Construction

  • The Term: "disconnected to each other"

    • Context and Importance: This term is central to the dispute, as Yeedi's non-infringement defense hinges on it Compl. ¶29 The definition will determine whether the chambers in the accused device must be hermetically sealed from one another or if a lesser degree of separation suffices.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The complaint does not point to specific evidence for a broader reading. A party seeking one might argue the term should be understood in the context of the overall function, meaning sufficiently disconnected to prevent the clogging problem described in the background, even if minor air passages exist.
      • Evidence for a Narrower Interpretation: The patent states the first chamber is for "vacuuming and sweeping" and the second is for "mopping" (׳975 Patent, col. 2:63-65). This functional division supports a narrower construction requiring a complete physical separation to prevent any mixing of dry dust and wet sewage, which is the stated objective of the invention.

  • The Term: "partition plate"

    • Context and Importance: The physical existence and character of this element in the accused product is a core point of contention Compl. ¶29 Its construction will define the structural requirements for infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue that the term is not limited to a single, discrete component and that any combination of internal walls or baffles that collectively divide the housing could meet the limitation.
      • Evidence for a Narrower Interpretation: The patent's figures depict the "partition plate" (11) as a distinct structural element that creates the two chambers (׳975 Patent, Fig. 1). The specification describes the housing as being "provided with a partition plate" (׳975 Patent, col. 2:51-52), which suggests a singular component rather than a collection of separate surfaces.

VI. Other Allegations

  • Indirect Infringement: The complaint is a declaratory judgment action filed by the accused infringer and does not contain sufficient information to analyze any specific theories of indirect infringement that Shermon may assert.
  • Willful Infringement: The complaint does not provide sufficient detail for analysis of any potential willful infringement theory that Shermon may eventually assert. The complaint notes that Shermon's infringement notice to Amazon initiated the dispute Compl. ¶16

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

  • A core issue will be one of definitional scope: can the term "disconnected to each other," as used to describe the two cleaning chambers, be construed to permit any degree of air or fluid communication, or does it require absolute separation? The outcome of this claim construction will be critical to the infringement analysis.
  • A second key question will be one of structural equivalence: does the internal architecture of the Yeedi M14 Plus product contain a "partition plate" that divides the housing as claimed? This will involve a fact-intensive comparison between the accused device's design and the patent's claims, as illustrated in its figures and described in the specification.
  • A third, parallel question is one of validity: can the '975 patent's claims to a separated dual-chamber cleaning brush withstand an invalidity challenge based on the four Chinese prior art references cited by Yeedi Compl. ¶36? The court will need to determine if these references, singly or in combination, teach or suggest the claimed invention.
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