Trove Brands LLC v. Jia Wei Lifestyle Inc

Background

Trove Brands LLC, doing business as The BlenderBottle Company, and Runway Blue, LLC sued Jia Wei Lifestyle Inc. The amended complaint asserts patent-infringement, trade-dress-infringement, trademark-infringement, and state-law unfair-competition claims. This order concerns claim construction—the court’s determination of what disputed patent language means—not whether Jia Wei ultimately infringed.

The patents concern the lid of the BlenderBottle shaker bottle. The utility patent is U.S. Patent No. 8,695,830, titled “Container Lid Having Independently Pivoting Flip Top and Handle.” The design patent is U.S. Design Patent No. D696,551, titled “Bottle Lid Having Integrated Handle.” The parties initially disputed 13 terms in the utility patent and the sole claim of the design patent, but by the April 8, 2025 hearing their dispute had narrowed to seven utility-patent terms and the design-patent claim.

Utility-patent constructions

The court adopted these constructions for the disputed terms in the ’830 Patent:

- “Handle”: “A part that is designed to be held, carried, or controlled.” The court rejected Jia Wei’s proposed requirement that the part be designed to be operated by hand and declined to add Jia Wei’s list of examples. - “Handle pivot”: “The fulcrum upon which the handle turns, oscillates, or rotates about a fixed axis.” - “Flip top pivot”: “The fulcrum upon which the flip top turns, oscillates, or rotates about a fixed axis.” - “First receiving portion” and “second receiving portion”: “The receiving portion is a part that is capable, by snap fit, pins, hook, clip, or other means, of supporting an attachment.” The terms “first” and “second” identify the side of the object: the first is closest to the user, and the second is furthest from the user. - “First protrusion” and “second protrusion”: “A physical extension that stretches from or through a structure.” Again, “first” identifies the position closest to the user and “second” identifies the position furthest from the user.

Jia Wei argued that the receiving-portion terms were indefinite, meaning that the patent did not explain their scope with reasonable certainty. The court rejected that argument, finding that the patent made sufficiently clear that the receiving portion is located in a post of the mount and must be capable of receiving or securing an attachment such as a handle.

Design patent

The design patent has one claim: “The ornamental design for a bottle lid with an integrated handle, as shown and described.” Jia Wei asked the court to identify functional or prior-art elements and exclude them from consideration. The court declined to do so at this stage because those inquiries are fact-sensitive and should occur after discovery is complete. The court also declined to provide a detailed verbal construction of the design, explaining that the design is better represented by the patent’s illustrations.

Disposition and next steps

The court construed the disputed utility-patent terms as stated above and declined Jia Wei’s requested functional, prior-art, and detailed verbal constructions for the design patent. Judge Paul A. Engelmayer ordered that fact discovery be completed by September 25, 2025, expert discovery by January 8, 2026, and held a telephonic case-management conference for October 28, 2025. The order did not decide infringement or the ultimate validity of the patents. The clerk was also directed to terminate the motion pending at Docket 181; the opinion does not identify that motion’s subject in the text provided.