DCT
2:23-cv-00069
Hanchett Entry Systems Inc v. Camden Marketing Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hanchett Entry Systems, Inc. (Arizona)
- Defendant: Camden Marketing Inc. d/b/a Camden Door Controls (Canadian)
- Plaintiff’s Counsel: Woods Oviatt Gilman LLP
- Case Identification: 2:23-cv-00069, D. Ariz., 01/11/2023
- Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation, which may be sued in any judicial district, and has allegedly committed acts of infringement within the District of Arizona.
- Core Dispute: Plaintiff alleges that Defendant’s Series 1500 Electric Strikes infringe two utility patents and one design patent related to adjustable and high-reliability electric door strike mechanisms.
- Technical Context: Electric strikes are electromechanical locking devices installed in door frames that work with a lockset to control access, a foundational technology in the security and access control industry.
- Key Procedural History: The complaint alleges that Defendant received pre-suit notice of U.S. Patent No. D794,416 in 2017, and of U.S. Patent Nos. 10,563,427 and 10,794,088 in 2020, which may form the basis for allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-04-14 | Earliest Priority Date ('427, '088, '416 Patents) |
| 2017-08-15 | '416 Patent Issued |
| 2017 | Defendant Notified of '416 Patent |
| 2020-02-18 | '427 Patent Issued |
| 2020 | Defendant Notified of '427 Patent |
| 2020-10-06 | '088 Patent Issued |
| 2020 | Defendant Notified of '088 Patent |
| 2022-07 | Alleged Launch of Accused Products |
| 2023-01-11 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,563,427, "Integrated Adjustable Keeper Shim for an Electric Strike," issued February 18, 2020
The Invention Explained
- Problem Addressed: The patent describes the problem of an improper gap between a door's latch and the electric strike's keeper, which can be caused by initial installation inaccuracies or by door sagging and component wear over time (’427 Patent, col. 2:11-20). A gap that is too large causes the door to rattle and can compromise security, while a negative gap (pre-load) can prevent the door from latching at all (’427 Patent, col. 1:59-col. 2:10).
- The Patented Solution: The invention is a keeper assembly featuring an integrated keeper shim that is adjustably mounted to the keeper itself (’427 Patent, Abstract). An adjustment mechanism, such as set screws, allows an installer to precisely position the shim to "minimize a gap" in the field, after which a separate fastener secures the shim in place, providing a durable and re-adjustable solution to a common installation and maintenance issue (’427 Patent, col. 7:31-48; Figs. 11-13).
- Technical Importance: This technology allows for fine-tuning the strike-to-latch fit in the field, improving the security and long-term reliability of the locking mechanism without requiring the replacement of fixed-size shims (’427 Patent, col. 8:6-14).
Key Claims at a Glance
- The complaint asserts independent claims 1, 9, 16, and 20 (Compl. ¶¶14, 43).
- The essential elements of independent claim 1 include:
- A keeper assembly with a keeper rotatably mounted to a housing, the keeper including a keeper base.
- A keeper shim mounted to the keeper base, with an outer face for contacting the latch.
- An adjustment mechanism configured to selectively adjust the position of the shim's outer face relative to the keeper base to minimize a gap.
- A fastener that couples the shim to the keeper after the position is set by the adjustment mechanism.
- The complaint asserts numerous dependent claims (Compl. ¶43).
U.S. Patent No. 10,794,088, "Adjustable Strike Keeper Face and Method of Adjusting," issued October 6, 2020
The Invention Explained
- Problem Addressed: The patent addresses the issue of improper latching in doors that use both a main spring latch and a secondary dead latch, particularly when the door is misaligned or sags over time (’088 Patent, col. 13:26-30). If the dead latch contacts the strike's housing before the main latch is properly seated, the door can be prevented from latching securely (’088 Patent, col. 13:1-15).
- The Patented Solution: The invention is an electric strike with a keeper that features a specially designed ramp element with a contoured surface that "extends beyond the front profile of the housing" (’088 Patent, col. 16:23-29). This forward-projecting ramp ensures that the tapered face of the door's main latch makes contact first and is properly guided into the strike, allowing for correct sequencing and retraction of both the latch and dead latch before the dead latch can interfere with the housing (’088 Patent, Abstract; Fig. 3).
- Technical Importance: This geometric configuration increases the reliability of the locking mechanism by accommodating greater door-to-frame misalignment, a common problem that can compromise security.
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶59).
- The essential elements of independent claim 1 include:
- An actuator-controlled electric strike with a housing defining an entry chamber and having a "front profile."
- A rotatable keeper disposed in the entry chamber, which includes a keeper base and a "ramp element."
- The ramp element includes a "contoured surface" for contacting the latch's tapered face.
- Crucially, the contoured surface of the ramp element "extends beyond said front profile of said housing" when the keeper is locked, to prevent the latch from contacting the housing's front profile as the door closes.
- The complaint asserts dependent claims 2 through 13 (Compl. ¶59).
Multi-Patent Capsule: U.S. Design Patent No. D794,416, "Electric Strike," issued August 15, 2017
- Patent Identification: U.S. Patent No. D794,416, "Electric Strike," issued August 15, 2017 (Compl. ¶24).
- Technology Synopsis: The patent claims the novel, non-obvious, and ornamental design for an electric strike as depicted in its figures (’416 Patent, Claim). It protects the specific visual appearance of the product, not its utilitarian features or method of operation (’416 Patent, Figs. 1-7).
- Asserted Claims: Claim 1 (the sole claim) is asserted (Compl. ¶¶71-72).
- Accused Features: The complaint alleges that the overall ornamental appearance of Defendant's "Series 1500 Electric Strikes" is "substantially similar" to the design claimed in the '416 Patent (Compl. ¶73).
III. The Accused Instrumentality
Product Identification
The accused products are Defendant’s "Series 1500 Electric Strikes" (Compl. ¶41). The complaint identifies "a Model CX-ED1500-L2" as "the Examined Model" upon which its infringement allegations are based (Compl. ¶42, ¶58).
Functionality and Market Context
The complaint alleges that the accused products are electric strikes that are made, used, sold, and imported into the United States (Compl. ¶41, ¶57). It asserts that an "examination" of the accused model revealed that it practices each element of the asserted claims of the patents-in-suit (Compl. ¶42, ¶58, ¶71). The complaint does not provide specific technical details about the operation of the accused products, instead making conclusory allegations of infringement.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
'427 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a keeper rotatably mounted to the housing, wherein said keeper includes a keeper base... | The complaint alleges the Examined Model includes a keeper assembly with a rotatably mounted keeper. | ¶¶10, 42 | col. 9:23-30 |
| a keeper shim mounted to said keeper base of said keeper, wherein said keeper shim includes an outer face contactable by the latch... | The complaint alleges the Examined Model includes a keeper shim mounted to the keeper base. | ¶¶11, 42 | col. 9:31-34 |
| an adjustment mechanism... configured to selectively adjust the position of said outer face of said keeper shim relative to said keeper base... to minimize a gap... | The complaint alleges the Examined Model includes an adjustment mechanism for selectively adjusting the shim's position. | ¶¶12, 42 | col. 9:35-43 |
| a fastener that couples said keeper shim to said keeper after the position of the keeper shim... is set by said adjustment mechanism. | The complaint alleges the Examined Model includes a fastener that couples the shim to the keeper after its position is set. | ¶¶13, 42 | col. 9:44-48 |
- Identified Points of Contention:
- Technical Questions: A central factual question will be whether the accused product contains the two-step, two-component system recited in claim 1: a distinct "adjustment mechanism" for setting the position and a separate "fastener" for subsequently locking it down. The complaint does not provide any evidence (e.g., product photos, diagrams, or technical manuals) to substantiate this allegation.
'088 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing defining an entry chamber... said first and second side walls include respective edges comprising a front profile... | The complaint alleges the Examined Model includes a housing with the claimed features. | ¶¶19, 58 | col. 16:1-8 |
| a keeper rotatably disposed in said entry chamber... | The complaint alleges the Examined Model includes a rotatable keeper. | ¶¶20, 58 | col. 16:9-15 |
| said keeper includes a keeper base and a ramp element. The ramp element includes a contoured surface that is contactable by the tapered contact face of the latch... | The complaint alleges the Examined Model's keeper has a ramp element with a contoured surface. | ¶¶21, 58 | col. 16:16-22 |
| The contoured surface of the ramp element extends beyond said front profile of the housing when the keeper is in the locked position to prevent the tapered face of the latch from contacting said front profile of the housing... | The complaint alleges the Examined Model's contoured surface extends beyond the housing's front profile to prevent latch contact with it. | ¶¶21, 58 | col. 16:23-29 |
- Identified Points of Contention:
- Scope Questions: The dispute may center on the scope of "extends beyond said front profile." The question for the court will be whether the accused product's geometry satisfies this specific spatial relationship.
- Technical Questions: A key factual question will be what evidence demonstrates that the accused product's keeper surface projects forward of the housing face and that this projection functions to prevent the latch from contacting that face, as required by the claim.
V. Key Claim Terms for Construction
For the '427 Patent:
- The Term: "adjustment mechanism"
- Context and Importance: This term is at the heart of the '427 patent's asserted novelty. The construction of this term, especially in relation to the subsequent "fastener" limitation, will be critical. Practitioners may focus on this term because if it is construed broadly to include a single screw that both adjusts and fastens, the claim may be easier to find invalid over prior art; a narrower construction requiring two distinct components may be harder to prove infringed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes "an adjustment mechanism... configured for setting the position of the keeper shim" without strictly limiting its form (’427 Patent, col. 12:4-6).
- Evidence for a Narrower Interpretation: The claim language recites "a fastener that couples said keeper shim... after the position... is set by said adjustment mechanism," which suggests a sequence involving two distinct elements (’427 Patent, col. 9:44-48). The patent's preferred embodiment reinforces this, showing set screws (104) as the "adjustment mechanism" and a separate hex screw (110) as the "fastener" (’427 Patent, Fig. 13; col. 7:31-48).
For the '088 Patent:
- The Term: "extends beyond said front profile of said housing"
- Context and Importance: This phrase defines the specific geometric relationship that allegedly provides the invention's functional benefit over the prior art. Infringement of claim 1 will likely depend entirely on whether the accused product meets this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue that any portion of the keeper's contoured surface projecting forward of the housing's front plane, regardless of how small, satisfies the plain meaning of "extends beyond."
- Evidence for a Narrower Interpretation: The specification explicitly links this extension to the function of preventing the latch from contacting the housing (’088 Patent, col. 16:23-29). The figures illustrate this with a clear, functionally significant projection labeled as distance "A" (’088 Patent, Fig. 3; col. 14:38-44). A defendant could argue this context requires more than a de minimis or functionally irrelevant extension.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for the '427 and '088 patents. For inducement, it alleges Defendant took active steps with specific intent by marketing, contracting for distribution, and publishing installation instructions for its products (Compl. ¶¶44-45, 60-61). For contributory infringement, it alleges the accused products are specially made for infringement and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶48, 62).
- Willful Infringement: Willfulness is alleged for all three patents. The allegations are based on Defendant's alleged continued infringement after receiving pre-suit notice of the patents in 2017 (for the '416 patent) and 2020 (for the '427 and '088 patents) (Compl. ¶¶51, 54, 64, 67, 77, 80).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of factual proof: As the complaint provides only conclusory allegations without supporting evidence, a key question is what evidence Plaintiff will produce to show that the accused "Series 1500 Electric Strikes" actually incorporate the specific structural and functional features required by the asserted claims, such as the '427 patent's distinct adjustment mechanism and fastener, and the '088 patent's forward-projecting keeper.
- The case may also turn on a question of claim construction: For the '427 patent, can the limitation "an adjustment mechanism" followed by "a fastener" be met by a single component, or does the claim language and specification require two separate and sequentially-used components?
- Finally, for the '416 design patent, the central question will be the application of the ordinary observer test: Is the overall visual appearance of the accused Camden strike "substantially the same" as the patented design, such that it would deceive an ordinary purchaser?