DCT

2:26-cv-02937

Youluoxihankeji Shenzhenyouxiangongsi v. Ad N Art Inc

Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-02937, W.D. Wash., 08/19/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because the defendant's enforcement of its patent rights on the Amazon.com platform, which is based in the district, caused the plaintiff's sales of its products into Washington to cease.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its insulated drink containers do not infringe the defendant's patent and/or that the defendant's patent is invalid and unenforceable.
  • Technical Context: The technology relates to insulated beverage containers, specifically systems using a detachable sleeve and a gripping ring to hold and insulate a separate fluid container, a common product category in the consumer housewares market.
  • Key Procedural History: This declaratory judgment action was initiated after the defendant, Ad-n-art Inc., accused the plaintiff's products of infringement through the Amazon Patent Evaluation Express (APEX) program, which resulted in the plaintiff's product sales being ceased on the platform.

Case Timeline

Date Event
2021-01-14 Earliest Priority Date for '926 Patent
2026-06-16 '926 Patent Issued
2026-07-XX Defendant initiates APEX complaint against Plaintiff
2026-08-19 Complaint for Declaratory Judgment Filed

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

  • Patent Identification: U.S. Patent No. 12,654,926, "Insulated Container Apparatuses and Devices," issued June 16, 2026.

The Invention Explained

  • Problem Addressed: The patent addresses challenges with consuming hot or cold beverages, including discomfort from holding containers at extreme temperatures, condensation on the outside of cold drink containers, and the risk of containers slipping from insulating mechanisms that do not provide a secure grip '926 Patent, col. 1:33-55 '926 Patent, col. 2:4-9
  • The Patented Solution: The invention is an apparatus with two main components: an "insulation sleeve" and a "flexible gripping ring" '926 Patent, abstract '926 Patent, claim 1 The ring first grips the "waist" of a beverage container (e.g., a glass) by friction, and the outer sleeve then couples to the ring, typically via screw threads, to provide insulation without obscuring the entire container '926 Patent, col. 5:1-20 '926 Patent, FIG. 1 This two-part system is designed to securely hold and insulate a standard, non-insulated container '926 Patent, col. 4:35-38
  • Technical Importance: The described solution aims to provide a secure, adaptable insulation system for various existing beverage containers, addressing both thermal transfer and grip stability issues common in the market '926 Patent, col. 2:10-14

Key Claims at a Glance

  • The complaint focuses on the allegations of infringement concerning Claim 1 Compl. ¶18 Compl. ¶24
  • Independent Claim 1 requires:
    • A fluid container with a "waist."
    • An insulation sleeve with at least one wall.
    • A "flexible gripping ring" with an inner surface to grip the container's waist by friction.
    • The gripping ring also has an outer surface that couples with the insulation sleeve, specifically where the sleeve has a "first screw thread" and the ring has a "second screw thread" for engagement.
  • The complaint does not explicitly reserve the right to assert dependent claims, as it is a declaratory judgment action seeking non-infringement of all claims Compl. prayer B

III. The Accused Instrumentality

Product Identification

  • The products at issue are Plaintiff's "insulated drink containers" sold under the storefront "Uluo" on Amazon.com, identified by several Amazon Standard Identification Numbers (ASINs), including B09JSYG5JN and B0B14VDCGB (collectively, the "Plaintiff Products") Compl. ¶8

Functionality and Market Context

  • The complaint describes the Plaintiff Products as "insulated drink container products" Compl. ¶8 It provides little technical detail but notes that photographs and a video demonstrating their operation were submitted as exhibits Compl. ¶9 Compl. ¶10 Photographs of the plaintiff's insulated drink containers from their Amazon product listings are referenced as Exhibit 2 Compl. ¶9 A video said to demonstrate the operation of the plaintiff's products is referenced as Exhibit 3 Compl. ¶10
  • The complaint alleges that prior to the defendant's enforcement action, the plaintiff enjoyed sales of these products on the Amazon.com platform, suggesting they are commercially active products Compl. ¶6

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement in response to the defendant's allegations made through the Amazon APEX program Compl. ¶¶12-14 It asserts that the Defendant has alleged infringement of at least Claim 1 Compl. ¶18 Compl. ¶24 However, the complaint itself does not provide a detailed, element-by-element mapping of how the Plaintiff Products allegedly infringe the patent claims. The following chart breaks down Claim 1 and notes the absence of specific infringement theories in the provided complaint.

'926 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a fluid container configured for containing fluids... the fluid container having a waist The complaint does not provide sufficient detail for analysis of this element. ¶¶18, 24 col. 9:40-44
an insulation sleeve having at least one wall The complaint does not provide sufficient detail for analysis of this element. ¶¶18, 24 col. 9:45-46
and a flexible gripping ring having: an inner surface configured to grip the waist of the fluid container by friction between its inner surface and the waist of the fluid container The complaint does not provide sufficient detail for analysis of this element. ¶¶18, 24 col. 9:47-52
and an outer surface configured to couple with an inner surface of the insulation sleeve, wherein the inner surface of the insulation sleeve comprises a first screw thread and the outer surface of the gripping ring comprises a second screw thread configured to couple with the first screw thread. The complaint does not provide sufficient detail for analysis of this element. ¶¶18, 24 col. 10:1-7
  • Identified Points of Contention:
    • Structural Questions: The core of the dispute will likely involve a direct comparison of the Plaintiff Products' structure against the specific elements of Claim 1. A key question will be whether the Plaintiff Products utilize a two-part system of a separate "flexible gripping ring" and a separate "insulation sleeve" that couple via screw threads, as claimed.
    • Scope Questions: The definition of "waist" may be a point of contention. The infringement analysis may turn on whether the Plaintiff's container has a feature that can be properly construed as a "waist" for the gripping ring to engage by friction.

V. Key Claim Terms for Construction

  • Term: "waist"

  • Context and Importance: This term is fundamental to the claimed structure, as it defines the part of the container that the gripping ring must engage by friction '926 Patent, claim 1 Practitioners may focus on this term because non-infringement could be argued if the plaintiff's container lacks a distinct, grip-able "waist," or if its components engage in a different manner.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification refers to the ring fitting the "waist of a container of different sizes," which may suggest the term is not limited to a specific shape or dimension '926 Patent, col. 4:35-36 It also refers to a "stepped waist" '926 Patent, col. 8:3-4, which could imply that any change in diameter constitutes a waist.
    • Evidence for a Narrower Interpretation: The figures consistently depict containers with a noticeable indentation or narrowing, such as a wine glass stem area or a stepped-in section of a tumbler '926 Patent, FIG. 2 '926 Patent, FIG. 8A This could support an argument that a "waist" requires a concave or significantly recessed profile, not just any slight variation in diameter.
  • Term: "flexible gripping ring"

  • Context and Importance: The "flexible" nature of the ring is a claimed feature '926 Patent, claim 1 The dispute may center on the degree of flexibility required and the materials used. Practitioners may focus on this term to determine if the corresponding component in the Plaintiff's Product, if one exists, meets the "flexible" limitation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term "flexible" is not explicitly defined with a required durometer or bending modulus. This may support a construction that covers any ring capable of being placed around a container.
    • Evidence for a Narrower Interpretation: The specification explicitly discloses that the ring is constructed from "soft flexible materials selected from a group consisting of one or more of polymer, rubber, silicone, and/or combinations thereof" '926 Patent, col. 6:35-39 This could support an argument that the term is limited to rings made of elastomeric or similarly pliable materials, as opposed to rigid or semi-rigid plastics.

VI. Other Allegations

The complaint does not allege indirect or willful infringement, as it is a declaratory judgment action filed by the accused infringer. Therefore, these sections are not applicable.

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

This case appears to be a direct response to a patent enforcement action on an e-commerce platform. The central questions for the court will likely be:

  1. A core question of claim construction: Can the term "waist", as used in the context of the '926 patent, be defined with sufficient breadth to read on the specific geometry of the Plaintiff's "Uluo" brand insulated drink containers?
  2. A dispositive factual question of infringement: Do the Plaintiff's Products actually incorporate the claimed two-part system of a "flexible gripping ring" that frictionally engages a container and a separate "insulation sleeve" that couples to the ring via screw threads, or do they achieve insulation through a different, non-infringing design?
  3. A question of validity: As raised in the complaint, are the claims of the '926 patent invalid as anticipated under 35 U.S.C. § 102 or obvious under § 103 in light of prior art in the crowded field of beverage insulators Compl. ¶¶20-21?
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