DCT

6:25-cv-01628

Screenco Systems, LLC v. Jean

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:25-cv-01628, N.D. Ala., 09/24/2025
  • Venue Allegations: Venue is alleged to be proper because Defendants reside in the district, have a regular and established place of business in the district, and have committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s septic receiving station infringes a design patent covering the ornamental appearance of Plaintiff's own wastewater filtration product.
  • Technical Context: The technology at issue involves industrial equipment for filtering trash and debris from wastewater, specifically at septic receiving stations.
  • Key Procedural History: The complaint outlines a series of events preceding the lawsuit, beginning with a request for cost estimates from the City of Cordova, Alabama, to the Plaintiff. The dispute arose after the City initiated a formal bidding process that specifically mentioned Plaintiff's product, but ultimately awarded the contract to Defendants, who then allegedly fabricated and delivered a "Replica System."

Case Timeline

Date Event
2015-02-23 D757,889 Patent Priority Date
2016-05-31 D757,889 Patent Issue Date
2021-01-XX City of Cordova approaches Screenco for cost estimates
2021-02-XX Screenco provides cost estimates to City of Cordova
2021-02-11 City of Cordova issues formal Bid Notice mentioning Screenco’s product
2021-02-22 Defendants allegedly submit a bid with drawings of a "substantial copy"
2021-03-09 City of Cordova accepts Defendants' bid
2021-03-09 to 2021-07-06 Defendants allegedly fabricate the accused "Replica System"
2021-07-06 Defendant Jean Field Services, LLC is formed
2021-07-20 Defendants allegedly deliver the "Replica System" to the City of Cordova
2025-09-24 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Design Patent No. D757,889 - "Septic Receiving Station With Screen"

The patent-in-suit is U.S. Design Patent No. D757,889, issued May 31, 2016 (the "'889 Patent").

The Invention Explained

  • Problem Addressed: Unlike a utility patent, which addresses a functional problem, a design patent protects the novel, non-obvious, and ornamental (i.e., non-functional) appearance of an article of manufacture (D'889 Patent, Claim). The ’889 Patent does not describe a technical problem but rather claims a specific visual design for a septic receiving station.
  • The Patented Solution: The patent protects the overall ornamental design of the receiving station as depicted in its seven figures (D'889 Patent, Figs. 1-7). Key ornamental features include the combination of a large, open-top rectangular basin; a V-shaped screen element set within the basin; a perforated back plate; an angled discharge chute extending from one side; and a specific configuration of support legs and external piping (D'889 Patent, Fig. 1). The claim covers the visual impression created by this combination of shapes and configurations.
  • Technical Importance: The complaint alleges Screenco is a "market leader" in systems for wastewater filtration, suggesting the commercial significance of its product designs in this industrial sector (Compl. ¶2).

Key Claims at a Glance

Design patents have a single claim. The asserted claim is: "The ornamental design for a septic receiving station with screen, as shown and described" (D'889 Patent, Claim). This claim incorporates all seven figures of the patent.

III. The Accused Instrumentality

Product Identification

The accused product is a septic receiving station referred to in the complaint as the "Replica System" (Compl. ¶21).

Functionality and Market Context

The complaint alleges Defendants fabricated and sold the Replica System to the City of Cordova after participating in a bidding process that initially sought Plaintiff's patented "Maxi Screen 400" product (Compl. ¶¶19, 21). Plaintiff alleges that the bid submitted by Defendants included drawings of a station that was a "substantial copy" of a Screenco product (Compl. ¶23). The complaint includes several photographs of the delivered Replica System as evidence (Compl. ¶35, Exhibit 3). One photograph shows the accused Replica System installed outdoors on a concrete pad (Compl. ¶39, Exhibit 3, p. 1).

IV. Analysis of Infringement Allegations

The complaint alleges infringement based on the "ordinary observer" test, which is the standard for design patent infringement. This test assesses whether an ordinary observer, in the context of the prior art, would be deceived into believing the accused design is the same as the patented design. Rather than a traditional element-by-element claim chart, the complaint presents its infringement theory through a series of side-by-side visual comparisons.

The complaint provides a top-down visual comparison between Figure 6 of the ’889 Patent and a photograph of the accused Replica System, highlighting the similar V-shaped screen and overall basin shape (Compl. ¶37). It also provides a second, similar top-down comparison from a slightly different angle (Compl. ¶38). To demonstrate similarity in the overall configuration, the complaint presents an isometric view from Figure 1 of the ’889 Patent alongside a photograph of the Replica System taken from a similar perspective, showing the basin, legs, and discharge chute (Compl. ¶39). The core of the infringement allegation is that the "overall appearance" of the Replica System is "substantially the same" as the design protected by the ’889 Patent (Compl. ¶36).

Identified Points of Contention

  • Scope Questions: The central question will be whether the visual differences between the accused Replica System and the patented design are minor enough that an ordinary observer would find the designs "substantially the same." The analysis will focus on the overall visual impression rather than on a dissection of individual features.
  • Technical Questions: A potential point of contention may arise if Defendants argue that certain similarities are dictated by the function of a septic receiving station and are therefore not protectable ornamental features. The court would then need to determine which aspects of the design are ornamental and which are purely functional.

V. Other Allegations

Willful Infringement

The complaint alleges that Defendants' infringement was "willful, deliberate, malicious, and in bad faith" (Compl. ¶49). To support this, Plaintiff alleges that Defendants had knowledge of the ’889 Patent at the time of the infringing activities. The alleged factual basis for knowledge includes: (1) the City of Cordova’s Bid Notice, which Defendants responded to, specifically identified Screenco’s patented "Maxi Screen 400" product (Compl. ¶¶19, 21); (2) Screenco’s website, at the time, allegedly identified its products as being protected by the ’889 Patent (Compl. ¶17); and (3) Defendants’ bid was allegedly based on an "analysis of one or more of Screenco's products shown and described on Screenco's website" (Compl. ¶29).

VI. Analyst’s Conclusion: Key Questions for the Case

The resolution of this dispute will likely depend on the court's determination of two primary issues:

  • A core issue will be one of visual identity: Applying the ordinary observer test, is the overall ornamental appearance of the Defendants' "Replica System" substantially the same as the design claimed in the ’889 Patent, such that a potential purchaser would be deceived? This will involve a holistic comparison of the designs, not a simple accounting of differences and similarities.
  • A key question for damages will be one of intent: Does the evidence, particularly the Bid Notice that explicitly named Screenco's product and the alleged copying from Screenco's patent-marked website, demonstrate that Defendants knew of the patent and engaged in conduct egregious enough to support a finding of willful infringement?