Link to Dao Health v. Shenzhen Lutejiacheng Technology Co., Ltd., No. 23 C 4885 (N.D. Ill. Dec. 12, 2025) (Durkin, J.) Dao Health v. Shenzhen Lutejiacheng Technology Co., Ltd., No. 23 C 4885 (N.D. Ill. Dec. 12, 2025) (Durkin, J.)
Judge Durkin construed seven disputed terms across three patents involving a hands-free breast milk collection device and a related valve, rejecting indefiniteness challenges and clarifying several scope disputes in this patent matter.
Of particular note, the Court held as follows:
- “External suction source” – Construed with reference to the reservoir, not the bra. The pump must be external to the reservoir’s internal volume but need not be external to the bra. The Court relied on the claim’s juxtaposition of “within” (for the adaptor) and “external” (for the suction source), harmonized with the specification and prosecution history.
- “A reduced volume … formed within said drip tube” – Not indefinite. The drip tube constitutes a reduced volume within the reservoir that can be closed via a valve to generate vacuum. The Court found the physical configuration coherent and comprehensible to a POSITA.
- “A valve assembly” – Construed as “an assembly of multiple parts forming a valve,” consistent with the specification’s description of multiple components (e.g., valve body, valve cap, valve flap) and embodiments including overflow chamber and baffle or an alternative bladder design.
- “A valve assembly disposed between and surrounded by the adaptor and the reservoir” – Given its plain meaning, “between” and “surrounded by” are not contradictory.
- Distal-end aperture – The phrase “a distal end of said drip tube having an aperture adjacent the distal end” carries its plain meaning; no need to add “structure” to force a closed-end reading.
- Functional “cyclical application and relief” and antecedent issues – The Court treated “said” before “vacuum pressure” and “cycle portion” as typographical errors; read in light of the specification, a POSITA would understand the pump supplies the alternating vacuum.
- “Through said interior chamber” – Any antecedent issue resolved by context from claim 2 and the surrounding claim language; sufficiently definite.
Collectively, the Court favored text-anchored, specification-consistent readings and was reluctant to find indefiniteness where a POSITA could readily understand the claims in context.