DCT
2:23-cv-09751
Squaregles LLC v. Laltitude LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Squaregles LLC (Illinois)
- Defendant: Laltitude LLC (California)
- Plaintiff’s Counsel: Yoka | Smith, LLP; Jayaram Law; Stinson LLP
- Case Identification: 2:23-cv-09751, C.D. Cal., 11/17/2023
- Venue Allegations: Venue is asserted in the Central District of California on the basis that Defendant has committed acts of infringement and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s PicassoTiles "Marble Run" line of toy building kits infringes two patents related to systems of magnetic building tiles with interchangeable and attachable components.
- Technical Context: The dispute is in the competitive market for modular, educational toy construction systems, where innovation often centers on increasing versatility and creative possibilities.
- Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent family because Plaintiff's parent patent and/or patent application publications were cited by the U.S. Patent and Trademark Office examiner during the prosecution of at least three of Defendant's own design patents, with the earliest citation occurring in 2017.
Case Timeline
| Date | Event |
|---|---|
| 2013-11-08 | Priority Date for '896 and '963 Patents |
| 2017-04-25 | Issue Date of Defendant's U.S. Design Patent D784,938 |
| 2017-06-13 | Issue Date of Defendant's U.S. Design Patent D789,312 |
| 2019-04-16 | Issue Date of U.S. Patent No. 10,258,896 |
| 2020-06-01 | Plaintiff began marketing its Squaregles products |
| 2021-02-16 | Issue Date of U.S. Patent No. 10,918,963 |
| 2021-08-31 | Issue Date of Defendant's U.S. Design Patent D929,505 |
| 2021-11-01 | Plaintiff made its first sale of Squaregles products |
| 2023-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,258,896 - "Magnetic Building Tiles"
Issued April 16, 2019 (the “’896 Patent”)
The Invention Explained
- Problem Addressed: The patent describes a limitation in existing toy building kits, which are often either too prescriptive, limiting a child’s creative play, or their components are not easily customizable (Compl. ¶8; ’896 Patent, col. 1:21-33).
- The Patented Solution: The invention is a building system comprising two key components: magnetic frames and interchangeable panels that can be releasably inserted into the frames. The core mechanism involves a "protuberance" on the interior of the frame that mates with a corresponding "flange" on the panel, allowing the panel to be snapped into place from either side of the frame without tools or permanent deformation (’896 Patent, Abstract; col. 15:58-16:18). This two-part design separates the structural magnetic element (the frame) from the aesthetic or functional element (the panel).
- Technical Importance: This approach provided a method for enhancing the customization and play value of magnetic tile systems by allowing users to change the appearance and function of a tile without replacing the entire piece (Compl. ¶¶ 9, 22).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶82).
- Essential elements of Claim 1 include:
- A plurality of magnetically-connectable frames.
- The frames include a specific wall structure and a "protuberance" centrally disposed along the interior frame wall.
- A plurality of interchangeable panels, each capable of being "releasably and stably mounted" in a frame.
- The panels have a "rear panel wall" with at least one "flange with curvature" that is configured to mate with the frame's protuberance.
- The panels can be placed or removed by manual pressure without tools or permanent deformation.
- The complaint reserves the right to assert additional claims (Compl. ¶28).
U.S. Patent No. 10,918,963 - "Magnetic Building Tiles"
Issued February 16, 2021 (the “’963 Patent”)
The Invention Explained
- Problem Addressed: The patent addresses the same general problem of limited customizability in toy building kits but extends the concept to integrating three-dimensional structures for more dynamic play (Compl. ¶¶ 8, 24; ’963 Patent, col. 1:28-40).
- The Patented Solution: This invention discloses a system that combines magnetic frames with non-magnetic, discrete three-dimensional panels, such as slides, ramps, or tunnels. The system uses two distinct connection mechanisms: a first (magnetic) mechanism for connecting frames to each other, and a second (e.g., friction-fit) mechanism for coupling the 3D panels to the magnetic frames (’963 Patent, Abstract). The 3D panels are specifically described as having angled or curved structures to "facilitate movement of objects therethrough or thereover" (’963 Patent, col. 30:10-14). Figure 85, included in the complaint, depicts magnetic frames being used to support a complex ball run made of such 3D panels (Compl. p. 6).
- Technical Importance: The invention significantly expands the play pattern of magnetic tiles from static construction to dynamic systems like marble runs, race tracks, and mazes (Compl. ¶¶ 23-24).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claims 1, 23, and 40 (Compl. ¶90).
- Essential elements of Claim 1 include:
- A magnetic frame with magnetic elements.
- A non-magnetic, discrete three-dimensional panel having a "planar body."
- "one or more connectors extending from the planar body" configured to couple the panel to the frame via a "second connection mechanism" that is distinct from the magnetic connection.
- A "three-dimensional structure extending from the planar body" that is angled or curved to facilitate movement of objects.
- The complaint reserves the right to identify further infringing products and assert additional claims (Compl. ¶26, n.1; ¶29).
III. The Accused Instrumentality
Product Identification
The accused products are Defendant’s PicassoTiles "Marble Run" building sets, including specific sets identified as "70pc Marble Run Building Blocks PTG70," "150 Pieces Marble Run Building Blocks PTG150," and "108pc 2-in-1 Magnetic Marble Run Set & Racing Track" (Compl. ¶¶ 25-26, p. 8).
Functionality and Market Context
The complaint alleges these kits allow users to construct multi-layer, three-dimensional ball runs (Compl. ¶32). They are alleged to contain two primary types of components: flat, magnetic tiles referred to as "Magnetic Square Track Tiles" and a variety of three-dimensional, non-magnetic panels, such as quarter-round turns, u-turns, slopes, and slides (Compl. ¶¶ 33, 40). These non-magnetic panels are designed to connect to the magnetic tiles to form pathways for toy balls or "marbles" (Compl. ¶¶ 32, 40). The complaint includes an image showing an assortment of these non-magnetic panels (Compl. ¶40, p. 15).
IV. Analysis of Infringement Allegations
’896 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plurality of magnetically-connectable frames that include magnetic elements to enable each frame to be magnetically attracted to another frame... | Defendant's "Magnetic Square Track Tiles" are alleged to be magnetic frames that connect to one another. | ¶34 | col. 29:49-54 |
| the at least two frames further including a protuberance centrally disposed along the interior frame wall... | Each "Magnetic Square Track Tile" allegedly includes a recessed section that "protrudes from the interior frame wall," which the complaint identifies as the claimed protuberance. A labeled photograph in the complaint depicts this feature. | ¶38, p. 14 | col. 15:58-65 |
| a plurality of interchangeable panels, each of the panels having a thickness and being capable of being releasably and stably mounted in one of the frames... | The "quarter round turn, u-turn, tunnel, and slide panels" are alleged to be the claimed interchangeable panels. | ¶40, ¶49 | col. 29:66-30:2 |
| at least two panels including... the rear panel wall having at least one flange with curvature angled toward an edge of the panel, the curvature configured to mate with the protuberance on the frame... | The accused panels allegedly have a rear wall with "flanges with outward facing dimples, which create a curvature" and are configured to connect to the recessed section of the tiles. A photograph in the complaint shows a panel connected to a tile in this manner. | ¶43, ¶44, ¶45, p. 17 | col. 30:3-9 |
| wherein each of the panels can be placed in a position of stable equilibrium within either of the two frames or removed therefrom simply by manually applying pressure... without the use of tools. | The complaint alleges that the building panels can be connected to or removed from the tiles by "manually applying pressure, without disassembling or deforming either the panels or the tiles." | ¶48 | col. 30:10-22 |
’963 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a magnetic frame that includes: at least one linear segment... [and] magnetic elements disposed in the at least one linear segment... | Defendant’s "Magnetic Square Track Tiles" are alleged to be the magnetic frames, which contain magnetic elements along their perimeter for connecting to other tiles. The complaint provides an annotated image showing these elements. | ¶34, ¶35, p. 13 | col. 29:49-59 |
| a non-magnetic, discrete three-dimensional panel having: a planar body... | The various non-magnetic "quarter round turn, u-turn, tunnel, and slide panels" are alleged to be the claimed panels. The "planar body" is alleged to be the "flat surface at each end that forms a panel face." | ¶40, ¶41 | col. 29:60-61 |
| one or more connectors extending from the planar body, the connectors configured to engage the connecting structure of the magnetic frame to thereby couple the non-magnetic three-dimensional panel to the magnetic frame via a second connection mechanism that is distinct from the first connection mechanism... | The "Magnetic Square Track Tile" is alleged to have "connecting structure (friction holes)," and the panels are designed to connect to these holes via a friction fit, which is alleged to be the distinct second connection mechanism. | ¶39, ¶45 | col. 30:1-9 |
| three-dimensional structure extending from the planar body, wherein the three-dimensional structure... is angled from the planar body or includes curvature... to facilitate movement of objects therethrough or thereover. | The accused panels are alleged to be "quarter round turns, u-turns, slopes, and slides" with an "arcuate surface" designed to allow balls to run through or over them. | ¶40, ¶42 | col. 30:10-14 |
Identified Points of Contention
- Structural Interpretation (’896 Patent): A potential point of contention is whether the accused tile's "recessed section" and the accused panel's "flanges with outward facing dimples" (Compl. ¶¶ 38, 44) meet the specific definitions of "protuberance" and "flange with curvature" as required by claim 1. The dispute may turn on a detailed comparison of the accused product's geometry against the structures described and depicted in the patent.
- Scope of "Connectors" (’963 Patent): The infringement theory for the ’963 Patent raises the question of whether a friction fit between the panel and "friction holes" on the tile (Compl. ¶39) satisfies the claim limitation "one or more connectors extending from the planar body" of the panel. The claim language suggests a structure that is part of and projects from the panel, which may create a mismatch with the complaint's description of holes located on the frame.
V. Key Claim Terms for Construction
Term (’896 Patent): "protuberance"
Context and Importance: This term defines the key interlocking feature on the magnetic frame. The infringement case for the ’896 Patent hinges on whether the accused tile's "recessed section" which "protrudes" (Compl. ¶38) falls within the scope of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "protuberance," and the specification does not provide an explicit, limiting definition, which may support a construction that covers any feature that juts out or protrudes to engage the panel.
- Evidence for a Narrower Interpretation: The specification describes an embodiment of this feature as a "ridge or shelf 3324" and provides a specific cross-sectional view in Figure 96 (’896 Patent, col. 15:58-65; Fig. 96). A defendant may argue that the term should be limited to this specific ridge-like structure.
Term (’963 Patent): "connectors extending from the planar body"
Context and Importance: This phrase is critical as it defines the physical mechanism for attaching the non-magnetic 3D panel to the magnetic frame. Practitioners may focus on this term because the complaint's infringement theory relies on "friction holes" on the tile (Compl. ¶39), which are not structures "extending from the... panel."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue that "connectors" should be interpreted functionally to include the features on the panel that mate with the holes on the frame, even if they are not discrete protrusions.
- Evidence for a Narrower Interpretation: The plain language "extending from the planar body" suggests a physical projection. The specification shows embodiments with such features, such as the pegs (1316) on the balcony element in Figure 121, which physically extend from the panel to engage the frame (’963 Patent, Fig. 121). This may support an interpretation requiring a distinct, projecting part on the panel itself.
VI. Other Allegations
- Willful Infringement: The complaint alleges that Defendant’s infringement was and is willful, deliberate, and intentional (Compl. ¶¶ 85, 93). The allegations are primarily based on pre-suit knowledge. The complaint asserts that Defendant was made aware of Plaintiff's parent patent and/or related patent application publications when they were cited by the USPTO examiner during the prosecution of Defendant's own U.S. Design Patents D784,938, D789,312, and D929,505, with the alleged notice dating back to at least April 25, 2017 (Compl. ¶¶ 54-67). The complaint further alleges, on information and belief, that Defendant monitored Plaintiff's patent applications and continued to sell the accused products after the patents-in-suit issued (Compl. ¶¶ 68, 76-77).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue for the ’896 Patent will be one of structural correspondence: does the accused product's combination of a recessed shelf on the tile and dimpled flanges on the panel meet the specific geometric and functional requirements of the claimed "protuberance" and mating "flange with curvature"?
- A key question for the ’963 Patent will be one of claim scope and construction: can the term "connectors extending from the planar body" of the non-magnetic panel be construed to cover an attachment mechanism where the primary connecting features ("friction holes") are located on the magnetic frame, not the panel itself?
- A significant factual question will be one of scienter and willfulness: did Defendant's alleged exposure to Plaintiff’s patent family during the prosecution of its own design patents constitute knowledge sufficient to support a finding of willful infringement for its continued sale of the accused products?