Telebrands Corporation v. Winston Products LLC

CourtDistrict Court, N.D. Ohio
DecidedJune 3, 2025
Docket1:23-cv-00631
StatusUnknown

This text of Telebrands Corporation v. Winston Products LLC (Telebrands Corporation v. Winston Products LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Telebrands Corporation v. Winston Products LLC, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION TELEBRANDS CORP., ) CASE NO. 1:23-CV-631 ) Plaintiff, ) JUDGE BRIDGET MEEHAN BRENNAN ) v. ) ) WINSTON PRODUCTS LLC, ) MEMORANDUM OPINION ) AND ORDER Defendant. ) This matter is before the Court upon the request of the parties to resolve a dispute over the construction of patent claim terms pursuant to Markman v. Westview Instruments, 517 U.S. 370, 116 S.Ct. 1384, 134 L.Ed.2d 577 (1996). Plaintiff Telebrands Corp. (“Telebrands”) and Defendant Winston Products LLC (“Winston”) filed opening claims construction briefs. (Docs. 39, 40.) Both parties filed reply briefs. (Docs. 41, 42.) On July 24, 2024, the Court held a Markman hearing. (Doc. 45.) For the reasons below, the Court finds no construction is necessary for the disputed patent claim terms. I. BACKGROUND Telebrands owns U.S. Patent Nos. 10,174,870 (‘870 Patent), 10, 890,278 (‘278 Patent), and 11,608,915 (‘915 Patent) (collectively, the “Asserted Patents”). Telebrands sued Winston asserting patent infringement of various claims in the Asserted Patents. Specifically, Telebrands alleges Winston infringed on the following claims:  Claims 1, 3, 5-7, 10, 12, 13, and 15 of the ‘870 Patent  Claims 1, 3, 5-7, 10, and 12-14 of the ‘278 Patent  Claims 1, 2, 4-6, 9, and 11-13 of the ‘915 Patent (Doc. 40 at 1161-62.)' The Asserted Patents relate to an “Expandable and Contractible Garden Hose” product that automatically expands when water is turned on and contracts when water is turned off. (Doc. 39 at 638.) The design and configuration allows the hose to be coiled and compact when not in use, but fully expandable like a regular hose when in use. (/d.) As shown in Figures 1 and 8 below, a hollow flexible outer tube (12) is positioned around a hollow flexible inner tube (14), both of which are secured to a coupler (18) that can be connected to a source of pressurized water. (Doc. 39-1 at 668.) Both the outer tube (12) and inner tube (14) are also secured to a second coupler (16) which can be connected to a nozzle. The outer tube (12) and inner tube (14) are unsecured between the two couplers to allow for expansion. (/d.) The outer tube restricts expansion after a certain point, containing the inner tube’s expansion. (Doc. 39 at 639.)

FIG. 8 FIG. 1 -10 27 AY , |

The parties’ claims construction dispute is primarily limited to two sets of terms used in four groupings throughout the Asserted Patents. These disputed claim terms are: “secured”/“securing’’/“unsecured” and “to couple’/“coupled to.” (Doc. 39 at 636; Doc. 40 at 1163.) For example, Claim 1 of the ‘278 Patent and ‘915 Patent contains the following language (disputed terms in bold):

' For ease and consistency, record citations are to the electronically stamped CM/ECF document and PageID# rather than any internal pagination.

A garden hose comprising . . . a flexible elongated outer tube . . . a flexible elongated elastic inner tube . . . a first coupler secured to said first end of said inner and said outer tubes, said first coupler constructed to couple said hose to a source of pressurized liquid . . . a second coupler secured to said second end of said inner and said outer tubes, said inner and outer tubes unsecured between said first and second ends so that said outer tube is not held in frictional contact with said inner tube so that said outer tube can move freely along said inner tube[.] (Doc. 39-2 at 697; Doc. 39-3 at 716.) Claim 5 of those same patents contains the following language: The garden hose of claim 1 including a first restrictor sleeve secured to said first end of said inner and said outer tubes, and a second restrictor sleeve secured to said second end and said inner and said outer tubes[.] (Doc. 39-2 at 697; Doc. 39-3 at 716.) II. CLAIMS CONSTRUCTION STANDARD Claims construction is a matter of law. Teva Pharms. USA, Inc. v. Sandoz, Inc., 574 U.S. 318, 326, 135 S.Ct. 831, 135 L.Ed.2d 719 (2015); Markman v. Westview Instruments, Inc., 517 U.S. 370, 372, 116 S.Ct. 1384, 134 L.Ed.2d 577 (1996). “It is a ‘bedrock principle’ of patent law that the ‘claims of a patent define the invention to which the patentee is entitled the right to exclude.’” Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2005) (en banc) (quoting Innova/Pure Water, Inc. v. Safari Water Filtration Sys., Inc., 381 F.3d 1111, 1115 (Fed. Cir. 2004)). “The purpose of claim construction is to determin[e] the meaning and scope of the patent claims asserted to be infringed.” O2 Micro Int’l Ltd. v. Beyond Innovation Tech. Co., 521 F.3d 1351, 1360 (Fed. Cir. 2008) (citation and quotation omitted). “[C]laim construction must begin with the words of the claims themselves.” Allergan Sales, LLC v. Sandoz, Inc., 935 F.3d 1370, 1373 (Fed. Cir. 2019) (quoting Amgen Inc. v. Hoechst Marion Roussel, Inc., 457 F.3d 1293, 1301 (Fed. Cir. 2006)). “Words of a claim are generally given their ordinary and customary meaning, which is the meaning a term would have to a person of ordinary skill in the art [POSITA] after reviewing the intrinsic record at the time of the invention.” O2 Micro, 521 F.3d at 1360 (citing Phillips, 415 F.3d at 1312-13). Absent an express intent to the contrary, patentees are presumed to have intended ordinary and customary meaning of a claim term. York Prods., Inc. v. Cent. Tractor Farm & Fam. Ctr., 99 F.3d 1568, 1572 (Fed. Cir. 1996). A court’s review of a claim term begins with the intrinsic record, “including the written

description, the drawings, and the prosecution history[.] Allergan Sales, 935 F.3d at 1373. Claims “must be read in view of the specification, of which they are a part.” Phillips, 415 F.3d at 1315. “In some cases, the ordinary meaning of claim language as understood by a [POSITA] may be readily apparent even to lay judges, and claim construction in such cases involves little more than the application of the widely accepted meaning of commonly understood words.” Id. at 1314. Claims “must be read in view of the specification, of which they are a part.” Id. at 1315. In fact, the specification “is always highly relevant to the claim construction analysis. Usually, it is dispositive; it is the single best guide to the meaning of a disputed term.” Id. “In most

situations, an analysis of the intrinsic evidence alone will resolve any ambiguity in a disputed claim term.” Vitronics Corp. v. Conceptronic, Inc., 90 F.3d 1576, 1580 (Fed. Cir. 1996). A court may also consider extrinsic evidence, which “is generally of less significance than the intrinsic record.” Allergan Sales, 935 F.3d at 1373 (quoting Wi-LAN, Inc. v. Apple Inc., 811 F.3d 455, 462 (Fed. Cir. 2016)).

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Telebrands Corporation v. Winston Products LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/telebrands-corporation-v-winston-products-llc-ohnd-2025.