Telebrands Corp. v. Guangzhoulingyedianzishangwuyouxiangongsi d/b/a Zezz

Background

Telebrands Corp. sued several online sellers over expandable garden hoses. Telebrands owns U.S. Patent No. 9,581,272, which covers an expandable and contractible garden hose. The opinion focuses on Claim 13, including a design in which an elastic inner tube expands under water pressure and an outer tube helps the inner tube contract when the pressure is removed.

Telebrands alleged that the defendants sold infringing hoses through Amazon storefronts. It purchased an accused hose from the defendant doing business as Sicily and submitted photographs, product information, declarations, and a claim chart. The court found that the Sicily product matched each element of Claim 13 for purposes of the preliminary-injunction motion.

The court had issued a temporary restraining order against all defendants on October 16, 2025. The order also restrained Amazon and the defendants’ financial institutions from facilitating transactions. The court later converted the temporary restraining order into an injunction for the defendants who did not appear. Sicily appeared, submitted an opposition, and participated in the November 13, 2025 hearing.

Service and Preliminary-Injunction Analysis

The court held that electronic service on Sicily was authorized by Article 15 of the Hague Convention because the circumstances involved urgency and a likelihood of irreparable harm to Telebrands’ brand, business interests, and reputation. The court therefore rejected Sicily’s challenge to electronic service.

For a preliminary injunction, the court considered whether Telebrands showed a likelihood of success, likely irreparable harm without an injunction, a favorable balance of hardships, and consistency with the public interest.

On likely success, the court found that Telebrands had shown that Sicily’s hose met every element of Claim 13. Sicily disputed whether its product satisfied the claim’s requirement that the outer tube “catches on” to the elastic inner tube. The court disagreed, finding that the product appeared to use the same inner-and-outer-tube mechanism described in the patent.

The court also rejected Sicily’s challenges to the patent’s validity based on indefiniteness and lack of written description. It concluded that the “catches on” mechanism was adequately described and taught in the patent. The court therefore found that Telebrands had shown a likelihood of success on its infringement claim.

The court found likely irreparable harm because Sicily’s products directly competed with Telebrands’ products and were offered at a significantly lower price. It concluded that the balance of hardships favored Telebrands and that the public interest favored enforcing the patent.

Asset Attachment

Although the court found that Telebrands was entitled to injunctive relief, it rejected Telebrands’ request to attach or restrain Sicily’s assets. The court held that Federal Rule of Civil Procedure 65 did not provide authority for the requested asset restraint and analyzed the request under Rule 64 and New York attachment law.

The court found that Telebrands had not provided specific allegations or evidence showing that Sicily would likely be unable to satisfy a later judgment. Evidence concerning avoidance of judgments by similar sellers did not specifically concern Sicily. The court also considered that Sicily had appeared and represented that it was willing to participate in further proceedings.

Disposition

The court granted in part and denied in part Telebrands’ motion for a preliminary injunction. The preliminary injunctive relief against Sicily was granted, with the specific terms issued in a separate order. The requested order of attachment was denied without prejudice, and the court did not at that time restrain financial institutions or websites from allowing Sicily’s assets to move freely. The court also stated that injunctive relief issued against the non-appearing defendants under a separate order.