DCT

2:25-cv-04063

Soons Co Ltd v. Ajs Innovations LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-04063, D. Ariz., 10/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Arizona because Defendant has committed acts of infringement and maintains a regular and established place of business, specifically a showroom, in Phoenix, Arizona.
  • Core Dispute: Plaintiff alleges that Defendant’s "Doggo Ramp RTT" product infringes a patent related to a safety device for a ladder.
  • Technical Context: The technology concerns attachable safety devices for ladders, designed to prevent user slips and falls, a field relevant to automotive accessories like rooftop tents and general utility equipment.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement as early as July 2025, prior to filing the lawsuit. This allegation may form the basis for a claim of willful infringement.

Case Timeline

Date Event
2020-04-06 ’117 Patent Priority Date
2025-07-22 ’117 Patent Issue Date
2025-07 Plaintiff alleges it put Defendant on notice of infringement
2025-10-29 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 12,366,117, "Safety Device for Ladder," issued July 22, 2025 (’117 Patent).

U.S. Patent No. 12,366,117 - "Safety Device for Ladder"

The Invention Explained

  • Problem Addressed: The patent's background section describes the problem of accidents occurring when using conventional ladders, where a user's hands miss the vertical supports or their feet slip from the horizontal supports (rungs) (’117 Patent, col. 1:26-33). Existing safety devices are described as having complicated configurations, being time-consuming to install, and cumbersome to store (’117 Patent, col. 1:36-40).
  • The Patented Solution: The invention is a safety device that can be mounted onto a ladder, comprising a "guard member" that extends longitudinally along the ladder and "fixing members" that attach it to the rungs (’117 Patent, Abstract). The guard member includes "cover portions" with a "folding line," allowing them to be unfolded to cover the rear surface of the ladder, creating a wider and more secure surface for the user's feet and preventing them from slipping through the rungs (’117 Patent, col. 3:9-15; Fig. 1). The device is designed to be easily installed, stored, and capable of preventing safety accidents (’117 Patent, col. 1:59-64).
  • Technical Importance: The invention purports to provide a retrofittable safety solution for standard ladders that is both effective in preventing falls and convenient to store, addressing perceived shortcomings in prior art solutions (’117 Patent, col. 1:40-44).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 9 (Compl. ¶14).
  • Claim 1 recites a safety device for a ladder comprising:
    • A guard member extending in a longitudinal direction and mountable on the ladder.
    • A plurality of fixing members connected to the guard member to fix it to the ladder.
    • The guard member includes a plurality of connection portions and cover portions, with each cover portion having a folding line.
    • The guard member is "movable between the use configuration and the alternate mounted configuration while being mounted on the ladder."
    • In the "use configuration," the folding line is disposed behind the ladder's horizontal support.
    • In the "alternate mounted configuration," the folding line is disposed in front of the horizontal support.
  • Claim 9 is similar in structure but focuses on the "fixing members," requiring:
    • A "first fixing body" configured to cover at least a portion of a horizontal support's circumferential surface.
    • A "second fixing body" configured to cover another portion of the support and "selectively engaged with the first fixing body."
  • The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "one or more claims of the '117 Patent" (Compl., Prayer for Relief ¶1).

III. The Accused Instrumentality

Product Identification

  • The "Doggo Ramp RTT" (Compl. ¶9).

Functionality and Market Context

  • The complaint describes the Doggo Ramp RTT as a product developed by Defendant for its rooftop camping equipment business (Compl. ¶9). The product is alleged to be "modeled closely after the '117 Patent" (Compl. ¶9). The complaint states that Defendant sells or offers for sale the accused product from a showroom in Phoenix, Arizona (Compl. ¶27). The complaint does not provide further technical details on the product's specific structure or operation.

IV. Analysis of Infringement Allegations

The complaint references a "detailed claim chart demonstrating that infringement is attached as Exhibit B" (Compl. ¶10, ¶15). However, this exhibit was not filed with the complaint. The narrative infringement theory alleges that the Doggo Ramp RTT infringes at least Claims 1 and 9 of the ’117 Patent, either literally or under the doctrine of equivalents (Compl. ¶10). The core of the allegation is that Defendant, recognizing the success of Plaintiff's commercial embodiment (the "HC Steps"), created a product "modeled closely" on the patented invention (Compl. ¶¶8-9).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of specific infringement disputes that would highlight claim construction issues. However, based on the claim language, certain terms may become central to the case.

  • The Term: "movable between the use configuration and the alternate mounted configuration while being mounted on the ladder" (Claim 1).

    • Context and Importance: This functional language appears to be a critical limitation defining how the device operates after initial installation. The dispute may turn on whether the accused product can be reconfigured between a front-mounted and rear-mounted position without being detached from the ladder. Practitioners may focus on this term because it distinguishes the invention from devices that must be fully removed and reinstalled to change their function.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the guard member being mounted and then a user pressing it to move it from the front to the rear (col. 5:34-44). This could support an interpretation that "movable" simply means it can be shifted between positions after being affixed.
      • Evidence for a Narrower Interpretation: The detailed description of mounting the device involves arranging fixing bodies on either side of a horizontal support and interconnecting them (col. 5:21-30). A defendant could argue that this interconnection must be undone to move the device between the "use" and "alternate" configurations, meaning it is not "movable... while being mounted."

  • The Term: "cover portion" (Claims 1, 9).

    • Context and Importance: The structure and function of the "cover portion" is the primary safety feature of the invention, providing a surface to prevent a user's foot from slipping through the ladder. The scope of this term will define what structures can be considered infringing.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent states the cover portion may be "selectively unfolded to cover the rear surface of the ladder" and serve as a "footrest" (col. 3:40-42). This functional language may support a broad definition covering any foldable flap that provides a step surface.
      • Evidence for a Narrower Interpretation: The specification repeatedly describes the cover portion as including a "first cover body" and a "second cover body" with different lengths, creating an "asymmetric" shape about the folding line (col. 3:56-66; col. 4:1-4). A defendant may argue that this specific asymmetric structure is a required feature of the "cover portion."

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain specific allegations of indirect infringement (inducement or contributory infringement).
  • Willful Infringement: The complaint alleges willful infringement, stating that Plaintiff "put AJS on notice of infringement as early as July 2025, but AJS refused to cease infringing" (Compl. ¶11). This allegation of pre-suit knowledge is the stated basis for seeking treble damages (Compl. ¶17; Prayer for Relief ¶4).

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

  • A central issue will be one of structural and functional correspondence: Does the accused Doggo Ramp RTT possess a guard member with "cover portions" that are "movable between the use configuration and the alternate mounted configuration while being mounted on the ladder," as required by Claim 1? The analysis will depend on the precise mechanical operation of the accused device.
  • A key evidentiary question will concern willfulness: Assuming infringement is found, did the Defendant's alleged continuation of sales after receiving notice in July 2025 constitute egregious conduct sufficient to warrant enhanced damages? The timing and content of the alleged notice will be critical evidence.