Judge Paul A. Engelmayer (S.D.N.Y.) recently construed claim terms at issue in a patent litigation between Plaintiffs Trove Brands, LLC, d/b/a The BlenderBottle Company, and Runway Blue, LLC (collectively, “Trove”) and Defendant Jia Wei Lifestyle, Inc. (“Jia Wei”). Slip Op. at 2. Trove alleges that Jia Wei infringes both U.S. Patent No. 8,695,830 and U.S. Design Patent No. D696,551. Id. Both patents “concern the lid component of a product called ‘BlenderBottle,’ a shaker bottle that mixes liquids with dietary supplements.” Id.
The court construed multiple disputed terms, addressed an indefiniteness challenge, and considered challenges to the design patent claim. On the constructions, the court gave “handle” its plain and ordinary meaning—“[a] part that is designed to be held, carried, or controlled.” Id. at 4-5. It construed “handle pivot” as “[t]he fulcrum upon which the handle turns, oscillates, or rotates about a fixed axis.” Id. at 5-6. “[F]lip top pivot” was construed similarly to “handle pivot,” as “[t]he fulcrum upon which the flip top turns, oscillates, or rotates about a fixed axis.” Id. at 6. Finally, the court construed “first protrusion” and “second protrusion” as “[a] physical extension that stretches from or through a structure. The numerical designations ‘first’ and ‘second’ denote which side of the object the protrusion appears on, the ‘first’ occupying the position closest to the user, and the ‘second’ occupying the position furthest from the user.’” Id. at 8-9.
In addition to construing terms, the court considered Jia Wei’s argument that the terms “first receiving portion” and “second receiving portion” were indefinite. Id. at 6-8. Jia Wei argued that the “specification . . . does not make clear which components are ‘receiving portions,’ because the specification uses the terms ‘receiving portions’ and ‘openings’ interchangeably whereas the terms refer to separate elements.” Id. The Court, however, disagreed. It found that “Claim one states that the ‘first receiving portion’ connects the ‘first handle pivot’ to the ‘first post of the mount’ . . . And the specification further states that, ‘[a]s shown in Fig. 2, handle 102 is attached to mount 104 by inserting handle pivots 102b into openings 104b or receiving portions in posts 104a of mount 104.’ The function of the receiving portion, in context, is clear: it attaches and secures the handle pivot to the mount.” Id. at 7. The Court then adopted a construction agreed upon at the claim construction hearing—“[t]he receiving portion is a part that is capable, by snap fit, pins, hook, clip, or other means, of supporting an attachment. The numerical designations ‘first’ and ‘second’ denote which side of the object the receiving portion appears on, the ‘first’ occupying the position closest to the user, and the ‘second’ occupying the position furthest from the user.’” Id. at 8.
Finally, the court addressed “the Design Patent, Titled ‘Bottle Lid Having Integrated Handle.” Jia Wei “ask[ed] the Court to determine which elements are (1) functional or (2) found in prior art, and to exclude them.” Id. The Court declined because the issues “are fact-sensitive inquiries that should not be undertaken until discovery is complete.” Id. The Court also declined to provide “a detailed verbal construction of the Design Patent,” noting that “the Federal Circuit has instructed district courts not to ‘attempt to ‘construe’ a design patent claim by providing a detailed verbal description of the claimed design.” Id.
The case is Trove Brands LLC v. Jia Wei Lifestyle Inc., No. 24 Civ. 3050 (PAE) (S.D.N.Y. May 15, 2025).
