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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION

MAYBORN (UK) LIMITED, MAYBORN 

USA, INC., MAYBORN GROUP LIMITED, 

Plaintiffs, 

v. 

NUTRITS, LTD., 

Defendant. 

No. _____________________ 

JURY TRIAL DEMANDED

COMPLAINT 

Plaintiffs hereby bring this complaint for patent infringement against Defendant Nutrits, 

Ltd. (“Nutrits”), and alleges as follows: 

NATURE OF THIS ACTION 

1. This is a civil action for patent infringement under the patent laws of the United 

States, 35 U.S.C. § 1, et seq. 

2. Nutrits has infringed (literally and/or under the doctrine of equivalents) and 

continues to infringe, contribute to the infringement of, and/or actively induce others to infringe 

U.S. Patent No. 11,730,680 (“the ’680 patent”). 

3. A true and correct copy of the ’680 patent is attached as Exhibit A. 

PARTIES 

4. Mayborn USA, Inc. is a corporation organized under the laws of the State of New 

York with a principal place of business at 1010 Washington Boulevard, Stamford, Connecticut 

06901. 

5. Mayborn (UK) Limited is a corporation organized and existing under the laws of 

England with a principal place of business at Balliol Business Park, Benton Lane, Newcastle upon 

Tyne, United Kingdom, NE12 8EW. 

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6. Mayborn Group Limited is a corporation organized and existing under the laws of 

England with a principal place of business at Balliol Business Park, Benton Lane, Newcastle upon 

Tyne, United Kingdom, NE12 8EW. 

7. Mayborn USA, Inc., Mayborn (UK) Limited, and Mayborn Group Limited are 

collectively referred to herein as “Mayborn.” 

8. Upon information and belief, Defendant Nutrits is a company organized and 

existing under the laws of Israel with a principal place of business at 3 Sdeneot, Herzliya, Israel 

4672830. 

JURISDICTION AND VENUE 

9. This is a civil action for patent infringement arising under the patent laws of the 

United States, 35 U.S.C. § 1 et seq. Jurisdiction is conferred on this Court pursuant to 28 U.S.C. 

1331 and 1338(a). 

10. The Court has personal jurisdiction over Nutrits. 

11. The personal jurisdiction inquiry is three-part: (1) whether Nutrits has committed 

an act constituting business in Texas under Texas statute; (2) whether the claim arises out of that 

act; and (3) whether asserting jurisdiction comports with due process and does not offend 

traditional notions of fair play and substantial justice. 

12. Under the first prong of the jurisdiction inquiry, Nutrits has committed an act 

constituting business in Texas. Under Texas law, conducting business includes “commit[ting] a 

tort in whole or in part in [the] state.” V.T.C.A. §17.042. 

13. Nutrits’s Plastic Breastmilk Baby Bottle and Flexy Silicone Baby Bottle marketed 

and sold under Nutrits-owned trademark, Nanobebe, and substantially similar products and 

components thereof constitute the “Accused Products” in this action. 

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14. On information and belief, the Accused Products in this action are marketed under 

the trademarked name “Nanobebe” and sold in national retailers such as Walmart and Amazon, 

including online sales with shipping available in Texas. 

15. On information and belief, the Accused Products in this action suit are sold at 

brick-and-mortar stores within Texas, including brick-and-mortar sales within this district. 

16. Exhibit B is a true and correct copy of a printout from the webpage of 

Walmart.com, showing Accused Products available for pickup at a Walmart in Tyler, Texas. 

17. Nutrits owns the intellectual property associated with the marketing and sales of 

the Accused Products under the Nanobebe brand. 

18. Nutrits’s ownership includes the trademark “Nanobebe” itself. 

19. On information and belief, Ayal Lanternari is Chairman of Nutrits. 

20. On information and belief, Ayal Lanternari is Chairman of Nanobebe US Inc., 

which is Nutrits’s wholly-owned US subsidiary. 

21. On information and belief, Nutrits and Nanobebe US Inc. share other executives 

in addition to Ayal Lanternari. 

22. Nutrits, through its Chairman Ayal Lanternari, submitted a sworn declaration to 

the USPTO that Nutrits “is using” the Nanobebe mark in connection with the US sales and 

distribution of baby bottles and nipples “by applying it to goods or using it in advertising.” 

23. Exhibit C is a true and accurate copy of the Statement of Use filed by Nutrits 

during the prosecution of its trademark “NANOBÉBÉ,” including a declaration signed by Ayal 

Lanternari. 

24. Thus, the Accused Products here are sold and advertised in Texas using Nutritsowned trademarks, and Nutrits has sworn to the USPTO that Nutrits “is using” the Nanobebe 

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trademark in U.S. commerce in connection with baby bottles and nipples by affixing the mark to 

the Accused Products and using the mark in advertising of the Accused Products. 

25. Moreover, on information and belief, the overlap of executives and interconnection between Nutrits and Nanobebe US Inc. is such that even if Nanobebe US Inc. purports 

to be the seller of the Accused Products in the United States, Nutrits has injected these products 

into the stream of commerce, knowing and intending that they will be sold in the United States, 

and has active involvement and direction in those sales such that Nutrits is committing the tort of 

patent infringement in Texas. 

26. Under the second prong of the jurisdiction inquiry, Mayborn’s patent infringement 

claim here arises from the tort of patent infringement described above and serves as the basis for 

Mayborn’s patent infringement suit. 

27. Finally, under the third prong of the personal jurisdiction inquiry, this Court’s 

exercise of personal jurisdiction over Nutrits comports with the requirements of due process. 

28. Nutrits has injected the Accused Products into the Texas market. 

29. Nutrits has advertised the Accused Products in Texas. 

30. In Huchel v. Sybron Corp.,

1

 the court remarked that “it is not within the 

contemplation of the concepts of fairness and due process to allow a wrongdoing manufacturer 

to insulate himself from the long arm of the courts by using an intermediary or by professing 

ignorance of the ultimate destination of his products.” Additionally, in Phibro-Tech, Inc. v. 

1 Huchel v. Sybron Corp., No. H-79-2047, 1980 WL 30343, at *2 (S.D. Tex. Oct. 17, 1980) 

(quoting Honeywell, Inc. v. Metz Apparatewerke, 509 F.2d 1137, 1143, 184 USPQ 387, 

392 (7th Cir. 1975)) 

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Osmose Holdings, Inc.,

2

 the court held that the defendant, a foreign parent corporation, directed 

the infringing activities of its American subsidiary entity, and therefore found that the parent 

corporation had minimum contacts with the state. 

31. On information and belief, Nutrits has similarly concocted a scheme through its 

wholly-owned subsidiary, Nanobebe US Inc., whereby Nutrits manufactures the Accused 

Products, and directs the infringing activities of its U.S. subsidiary while attempting to avoid 

liability for their importation into, distribution, and sales throughout the United States. 

32. In view of the foregoing, all three prongs of the personal jurisdiction inquiry are 

satisfied and this Court has personal jurisdiction over Nutrits. 

33. Venue is proper in this district because Nutrits is a foreign entity. 28 U.S.C. § 

1391(c).

BACKGROUND 

34. Mayborn has been in the business of creating, making, and selling baby products 

and delighting parents for nearly 60 years, starting with the original Tommee Tippee no-spill cup 

in the mid-sixties. Since then, Mayborn’s push for innovation to solve real issues faced by real 

parents the world over has made Tommee Tippee the #1 baby brand in the United Kingdom and 

Australia, and in the decade since the brand was launched in the United States, Tommee Tippee 

became a major player and continues to be a growing baby brand in the United States. 

35. A shining example of Mayborn’s innovation is the Closer to Nature (“CTN”) 

line of baby bottles. The CTN bottles revolutionized the baby industry by being the first to 

have a real breast-like shape. 

2 Phibro-Tech, Inc. v. Osmose Holdings, Inc., No. 5:06-CV-77-DF, 2006 WL 8441241, at *3 (E.D. 

Tex. Dec. 5, 2006) 

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38. The ’680 patent is a reflection of the breadth of Mayborn’s dedication and 

investment in the technology and development of innovative products that support and delight 

parents in the rollercoaster ride of raising a baby. 

39. The ’680 patent is a continuation of a patent family that claims priority to June 29, 

2004. 

40. On August 22, 2023, the ’680 patent was duly and legally issued and titled “Baby 

Bottle With Flexible Nipple Regions.” 

41. Mayborn (UK) Limited owns the entire right, title, and interest to the ’680 patent. 

42. Pursuant to 35 U.S. Code § 287, Mayborn marks its products to provide notice of 

Mayborn’s patent rights in the ’680 patent to the public. 

43. On information and belief, without license or permission from Mayborn, Nutrits 

has infringed, literally and/or under the doctrine of equivalents, and continues to infringe, the ’680 

patent by engaging in acts constituting infringement under 35 U.S.C. § 271, including but not 

necessarily limited to one or more of making, using, selling and offering to sell, in the United 

States, and importing into the United States, baby bottles having Mayborn’s breast-like shape, 

design, and functionality. 

44. In particular, Nutrits’s Plastic Breastmilk Baby Bottle and Flexy Silicone Baby 

Bottle marketed and sold under the Nutrits-owned trademark, Nanobebe, and substantially similar 

products and components thereof (the “Accused Products”) infringe at least claim 1 of the ’680 

patent. 

45. In the declaration signed by Ayal Lanternari in his capacity as Chairman of Nutrits, 

Mr. Lanternari swore to the USPTO that Nutrits “is using” the Nanobebe mark in connection with 

baby bottles and nipples “by applying it to goods or using it in advertising.” See Exhibit C. 

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46. On information and belief, Nutrits is the shipper, wholesaler, and the manufacturer 

of Accused Products shipped to the United States. See Exhibit D (the “Panjiva Data”). 

47. On information and belief, Nutrits directly infringes the ’680 patent. 

48. First, Nutrits admits in the aforementioned declaration to the USPTO that Nutrits 

is selling and offering to sell Nanobebe-branded baby bottles and nipples in the United States, 

which includes the Accused Products. Selling and offering to sell the Accused Products in the 

United States is an act of direct infringement. See 35 U.S.C. 271(a). 

49. Second, on information and belief, Nutrits imports the Accused Products to the 

United States. This is evidenced by the aforementioned Panjiva Data. Nutrits’s declaration to the 

USPTO is also evidence that Nutrits is the importer of the Accused Products, as Nutrits has 

admitted therein to being the seller. Importing the Accused Products into the United States is also 

an act of direct infringement. See 35 U.S.C. 271(a). 

50. Third, on information and belief, Nutrits is liable for Nanobebe US Inc.’s actions 

under an agency or veil piercing theory of liability. 

51. On information and belief, Nutrits (a) has admitted to selling and offering the 

Accused Products for sale, (b) has imported Accused Products into the United States, (c) has a 

direct financial interest in Nanobebe US Inc. as a wholly-owned subsidiary of Nutrits, (d) 

manufactures and/or wholesales the Accused Products, and ships the products to Nanobebe US 

Inc., (e) owns the intellectual property rights in the trademarks and copyrights associated with the 

Accused Products, (f) shares at least one corporate officer with Nanobebe, and (g) is aligned with 

Nanobebe on strategy for the sale of the Accused Products. These facts more than constitute a 

“continuing connection in regard to the infringing activity.” Nutrits’s involvement in any 

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infringement by Nanobebe U.S., Inc. therefore extends far beyond the traditional parent-subsidiary 

relationship and into the realm of agency. 

52. Here, Nanobebe U.S. Inc. (a) is wholly-owned by Nutrits, (b) shares at least one 

corporate officer and may in fact share other executives, (c) has no ownership of the intellectual 

property associated with Nanobebe’s products, including the very name “Nanobebe” itself. On 

information and belief, corporate formalities and separation between the companies is minimal 

or non-existent. Thus, Nutrits is liable for the acts of Nanobebe under a veil piercing theory. 

53. On information and belief, Nutrits induces and continues to induce infringement 

of the ’680 patent by others. For example, Nutrits takes active steps to promote and encourage 

the sale of the Accused Products by Nanobebe U.S. Inc. and third parties. 

54. Nutrits takes specific steps to actively induce others—such as, for example, 

retailers and customers—to use and sell the Accused Products. For example, and without 

limitation, on information and belief, Nutrits actively induces direct infringement of the ’680 

patent by others by promoting, instructing, offering, and encouraging others to use and sell the 

Accused Products. Furthermore, Nutrits also actively promotes the breast-like nature of the 

Accused Products including, for example and without limitation, by way of authorized retailers, 

customer service and sales representatives, and/or its internet sales websites. Furthermore, Nutrits 

also actively promotes the breast-like nature of the Accused Products including, for example and 

without limitation, by way of authorized retailers, customer service and sales representatives, 

and/or its internet sales websites. Such active promotion includes advertising that the Accused 

Products feature a “natural mom-like feel” and “smooth transitions between breast and bottle” 

and promoting that “[b]aby instinctively connects to the bottle’s breast shape.” And, on 

information and belief, Nutrits knows or should know that such sales and promotions actively 

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induce others to directly infringe at least claim 1 of the ’680 patent, including for example, by 

prompting them to sell or use the Accused Products in an infringing manner. 

55. As another example, Nutrits provides and/or authorizes the providing of 

instruction manuals, product manuals, and other materials (e.g., with the sale of a product and/or 

offered on its website) for customers and other users of the Accused Products that show how to 

assemble the Accused Products. On information and belief, Nutrits knows or should know that 

such materials and instructions actively induce others to directly infringe at least claim 1 of the 

’680 patent including by instructing them to use the Accused Products. 

56. Furthermore, Nutrits and/or its authorized retailers operate stores throughout the 

United States, such as Walmart and Target. These stores include a Walmart in this District, that 

upon information and belief, sells, promotes, and instructs the use of the Accused Products. 

57. On information and belief, Nutrits is aware of the ’680 patent either by 

constructive notice as a competitor in the baby products industry, due to Mayborn’s marking of 

its patents to the public, or at least as of August 22, 2023, when the ’680 patent issued following 

notice to Nutrits of the pending issuance earlier that month. 

58. Finally, on information and belief, the acts alleged in paragraphs 1-57 are 

continuing in nature such that Nutrits is subject to jurisdiction and liable for infringement now 

and throughout the pendency of this action. 

COUNT ONE 

(Infringement of U.S. Patent No. 11,730,680) 

59. Mayborn incorporates by reference the allegations set forth in the preceding 

paragraphs as though fully set forth herein. 

60. In violation of 35 U.S.C. § 271, Nutrits has infringed, induced others to infringe, 

and/or contributed to the infringement of one or more claims of the ’680 patent, including but not 

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limited to claim 1, literally and/or under the doctrine of equivalents, by among other things, 

making, using, offering for sale, selling, and/or importing into the United States unlicensed 

products in a manner that infringes the ’680 patent. Such unlicensed products include the Accused 

Products. On information and belief, Nutrits continues to ship Accused Products to the United 

States, advertise and sell Accused Products using Nutrits’s trademark, and maintain its Nanobebe 

trademark. Therefore, Nutrits continues to infringe and induce infringement of the ’680 patent 

despite prior notice to Nutrits of the issue date and claims of the ’680 patent. 

61. Claim 1 of the ’680 patent recites: A baby bottle comprising: a) a vessel with an 

opening comprising a rim; and b) an assembly configured to mount and seal over the vessel 

comprising: i) a collar configured to removably couple to a nipple and mount over the vessel 

opening; and ii) a nipple having a teat with an aperture, a base, an areola portion between the teat 

and the base, and a flange configured to seal over the vessel rim, iii) wherein the flange extends 

from a substantially cylindrical lower portion of the base to define the outermost nipple 

circumference, and iv) wherein an air vent projects internally into the nipple interior below the 

teat, and v) wherein the nipple and collar together define a breast shape comprising a teat projecting 

from a domed configuration that extends outwardly and downwardly to a widest circumferential 

edge of the collar. 

62. The Accused Products are marketed and sold as baby bottles. 

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Screenshot from https://www.amazon.com/Nanobebe-Silicone-Bottles-Anti-Colic-NonCollapsing/dp/B08C5K4XTD/ref=sr_1_5?crid=2PEAGYF4ISOQ4&keywords=nanobebe 

+ bottles&qid=1692561831&sprefix=%2Caps%2C289&sr=8-5 

Screenshot from https://www.amazon.com/ Breastmilk-Innovation-BreastfedBreastfeeding-Newborn-Breast-Breast-Milk/dp/B07CXSBNM4/ 

ref=sr_1_6?crid=2PEAGYF4ISOQ4 

&keywords=nanobebe+bottles&qid=1692561831&sprefix=%2Caps%2C289&sr=8-6.

63. The Accused Products have a vessel with an opening comprising a rim and an 

assembly configured to mount and seal over the vessel comprising a collar configured to 

removably couple to a nipple and mount over the vessel opening. 

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Flexy Silicone Bottle – Instruction Manual at https://www.nanobebe.com/pages/productinstruction-manuals. 

Breastmilk Bottle – Instruction Manual at https://www.nanobebe.com/pages/productinstruction-manuals. 

64. The nipple of the Accused Products has a teat with an aperture, a base, an areola 

portion between the teat and the base, and a flange configured to seal over the vessel rim, wherein 

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the flange extends from a substantially cylindrical lower portion of the base to define the 

outermost nipple circumference. 

65. The Accused Products include an air vent that projects internally into the nipple 

interior below the teat. 

66. The nipple and collar of the Accused Products together define a breast shape 

comprising a teat projecting from a domed configuration that extends outwardly and downwardly 

to a widest circumferential edge of the collar. 

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67. On information and belief, Nutrits has had knowledge of the issuance of the ’680 

patent and that its activities would infringe the ’680 patent before the filing of this action. Nutrits 

received such notice in connection with ongoing litigation between Mayborn and Nanobebe. 

68. Mayborn repeatedly informed Nanobebe and Mr. Lanternari of the pending 

issuance ’680 patent, including most recently an August 10, 2023, notice through Nanobebe US 

Inc.’s counsel of the issue date and claims of the ’680 patent, accompanied by claim charts 

detailing infringement of the Accused Products. 

69. As Chairman of Nutrits, Mr. Lanternari’s knowledge of the ’680 patent can be 

attributed to Nutrits. 

70. On information and belief, in addition to direct infringement, Nutrits takes active 

steps to induce infringement of the ’680 patent by others, including its retailers, distributors, and 

customers, and Nutrits takes such active steps knowing that those steps will induce, encourage, and 

facilitate direct infringement by others. Such active steps include, but are not limited to, 

encouraging, advertising (including by internet websites, YouTube videos, print advertisements, 

etc.), promoting, and instructing others to use and/or how to use the Accused Products. 

71. On information and belief, Nutrits knows or should know that such activities 

induce others to directly infringe the ’680 patent, including for example, by prompting them to 

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assemble the Accused Products in an infringing manner. As such, Nutrits has knowingly induced 

and continues to induce direct infringement of the ’680 patent by its retailers, distributors, and 

consumers. 

72. On information and belief, Nutrits also contributes to the infringement of the ’680 

patent by others, including its customers. Acts by Nutrits that contribute to the infringement of 

others include, but are not limited to, the sale, offer for sale, and/or import by Nutrits of the 

components of Accused Products, including but not limited to, replacement nipples. 

73. The components are not suitable for substantial noninfringing use. 

74. On information and belief, Nutrits knows such components are especially adapted 

to infringe by use with other components to assemble the Accused Products. 

75. Nutrits knew of the pending issuance and claims of the ’680 patent prior to the 

filing of this Complaint. 

76. Nutrits knew of the issuance of the ’680 patent and yet performs and continues to 

perform acts that it knows, or should know, induces and/or contributes to the direct infringement 

of the ’680 patent by third parties. 

77. Nutrits continues to undertake its egregious infringing actions with knowledge of 

the ’680 patent and despite an objectively high likelihood that such activities infringe the ’680 

patent, which has been duly issued by the USPTO and is presumed valid. 

78. For example, since the date it received notice of the pending issuance and 

infringement of the ’680 patent, Nutrits has been aware of an objectively high likelihood that 

continuing its actions with regard to the Accused Products will constitute and continue to 

constitute infringement of the ’680 patent and that the ’680 patent is valid. 

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79. Nutrits could not reasonably or subjectively believe that its actions do not 

constitute infringement of the ’680 patent, nor could it reasonably or subjectively believe that the 

patent is invalid. 

80. Despite that knowledge and subjective belief, and the objectively high likelihood 

that its continued actions constitute infringement, Nutrits has continued its activities despite the 

issuance of the ’680 patent. 

81. Nutrits’s infringement of the ’680 patent is willful. 

82. Nutrits’s infringement of the ’680 patent has caused and continues to cause 

damage to Mayborn and Mayborn is entitled to recover from Nutrits compensation as a result of 

Nutrits’s wrongful acts, including but not limited to a reasonable royalty and/or lost profits, and 

such other relief as may be appropriate. 

83. Nutrits’s infringement of the ’680 patent is exceptional and entitles Mayborn to 

attorneys’ fees and costs incurred in prosecuting this action under 35 U.S.C. § 285.

JURY DEMAND 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands a trial by 

jury on all issues triable as such. 

PRAYER FOR RELIEF 

WHEREFORE, Plaintiff demands judgment for itself and against Defendant as follows: 

a) That at least claim 1 of the Asserted Patent has been and continues to be 

infringed by Nutrits; 

b) That Nutrits’s infringement of the ’680 patent has been willful; 

c) That the ’680 patent is enforceable, eligible for patent protection, and not 

invalid; 

d) An award of damages adequate to compensate Mayborn for the patent 

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infringement that has occurred, together with pre-judgment interests and costs and postjudgement interests and costs; 

e) Lost profits to compensate Mayborn for Nutrits’s infringement; 

f) A permanent injunction preventing further infringement; 

g) If a permanent injunction is not awarded, then an award of ongoing royalty 

for Nutrits’s post-verdict infringement, payable on each product offered and/or imported by 

Nutrits that is found to infringe one or more of the Asserted Patents, and on all future products 

that are not colorably different from those found to infringe; 

h) An award of all other damages permitted by 35 U.S.C. § 284, including 

increased damages up to three times the amount of compensatory damages found; 

i) A finding that this action is an exceptional case under 35 U.S.C. § 285 and an 

award to Mayborn of its costs and attorneys’ fees incurred in this action; and 

j) Further relief as the Court may deem just and proper. 

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Dated: August 22, 2023 Respectfully submitted, 

FISH & RICHARDSON P.C. 

By: /s/ Matthew A. Colvin 

 Matthew A. Colvin 

Texas Bar No. 24087331 

1717 Main Street, Suite 5000 

Dallas, Texas 75201 

Telephone: 214-747-5070 

Facsimile: 214-747-2091 

Email: colvin@fr.com 

John S. Goetz (pro hac vice forthcoming) 

Maggie L. LaPoint (pro hac vice forthcoming) 

7 Times Square Tower, 20th Floor 

New York, NY 10036 

Tel: (212) 765-5070 

Fax: (212) 258-2291 

Email: goetz@fr.com 

Email: lapoint@fr.com 

ATTORNEYS FOR PLAINTIFFS 

MAYBORN (UK) LIMITED, 

MAYBORN USA, INC. and 

MAYBORN GROUP LIMITED 

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