DCT
2:25-cv-03140
Stahls' v. BEWEAR Creative
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: STAHLS' INC., d/b/a GroupeSTAHL (Michigan)
- Defendant: BEWEAR CREATIVE, INC. d/b/a Printomize America (California)
- Plaintiff’s Counsel: Fishman Stewart PLLC; Harrington, Foxx, Dubrow & Canter, LLP
- Case Identification: STAHLS' INC. v. BEWEAR CREATIVE, INC., 2:25-cv-03140, C.D. Cal., 04/10/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation, maintains a regular and established place of business in the district, and has committed the alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s dual-station heat transfer presses infringe a patent related to shuttle press technology that improves operator efficiency.
- Technical Context: The technology concerns industrial heat presses used to apply graphics to apparel and other items, where a dual-station design allows for continuous workflow.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement via a cease-and-desist letter on January 21, 2023, and a second letter on January 23, 2025. The complaint also notes the recent discovery of a responsive letter from Defendant's counsel, dated February 27, 2025, which had been previously unread in a spam folder. This history is presented to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-04-02 | ’960 Patent Priority Date |
| 2016-03-22 | ’960 Patent Issue Date |
| 2023-01-21 | Plaintiff serves first cease-and-desist letter |
| 2025-01-23 | Plaintiff serves second cease-and-desist letter |
| 2025-02-27 | Date of defense counsel letter discovered in spam folder |
| 2025-04-03 | Plaintiff discovers defense counsel's letter |
| 2025-04-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,289,960 - "Dual Shuttle Press", issued March 22, 2016
- The Invention Explained:
- Problem Addressed: The patent describes a problem of inefficiency in the use of conventional heat presses. With a single press station, an operator is idle during the "cure time," and the press is inactive while the operator prepares the next item. Using a second, separate heat press to reduce this downtime is costly and requires significant shop space (ʼ960 Patent, col. 1:47-58).
- The Patented Solution: The invention is a single heat press apparatus that incorporates two lower platens (workstations) and a single upper heating platen. A "shuttle mechanism" moves the upper platen and its associated press mechanism linearly from a position above the first lower platen to a position above the second (ʼ960 Patent, Abstract; col. 2:7-12). This design allows an operator to prepare a workpiece on the idle station while the other station is actively pressing, thereby reducing downtime and increasing throughput with a single machine (ʼ960 Patent, col. 9:15-19). The overall concept is illustrated in patent Figure 1, which shows the upper platen (22) positioned over the first lower platen (14), ready to shuttle to the second lower platen (18).
- Technical Importance: This dual-station shuttle design offers a method to increase production efficiency that is more space- and cost-effective than deploying multiple independent machines (ʼ960 Patent, col. 1:50-58).
- Key Claims at a Glance:
- The complaint asserts infringement of at least independent claims 1 and 10, as well as dependent claims 5, 7, and 10. The reference to claim 10 as dependent appears to be a typographical error, as it is an independent claim in the patent.
- Independent Claim 1 requires:
- A frame
- First and second lower platens supported by the frame
- An upper platen
- A press mechanism to move the upper platen between open and closed positions
- A shuttle mechanism to move the press mechanism linearly between a first position (over the first lower platen) and a second position (over the second lower platen)
- A heating element for the upper platen
- Independent Claim 10 requires all the elements of a dual shuttle press and adds:
- A set of first lasers coupled to the frame to project light onto the first lower platen
- A set of second lasers coupled to the frame to project light onto the second lower platen
III. The Accused Instrumentality
- Product Identification: The complaint identifies several models of heat transfer presses, including the TQB-4050, TY-4050, TQ-1515, TQA-4050, TQ-4050, and the Hyper Stamp 16" x 20" (Compl. ¶14).
- Functionality and Market Context: The accused products are described as "Double Station" heat presses, with some models being "Full-Automatic Pneumatic," "Semi-Automatic," or "Manual" (Compl. ¶14(a)-(f)). The complaint alleges that these products are sold with an included "Laser System," a feature which is alleged to infringe certain claims of the ’960 Patent (Compl. ¶14(a)). Plaintiff asserts that these products are imported and sold in the United States to compete directly with its own "DUAL FUSION Heat Press" (Compl. ¶15). The complaint includes a screenshot of Plaintiff's product page, which marks the DUAL FUSION Heat Press as being "protected by U.S. Patent No: 9,289,960" (Compl. p. 5).
IV. Analysis of Infringement Allegations
The complaint makes broad allegations of infringement without providing a detailed element-by-element analysis or a claim chart. The following tables summarize the infringement theory that can be inferred from the product descriptions and allegations in the complaint.
’960 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a frame; | The underlying structure of the accused heat presses. | ¶14 | col. 4:33-37 |
| first and second lower platens supported by the frame; | The accused products are marketed as "Double Station" machines, which suggests the presence of two lower work platens. | ¶14(a) | col. 4:50-61 |
| an upper platen; | A necessary component of any heat press, which the accused products are alleged to be. | ¶14 | col. 6:20-21 |
| a press mechanism coupled to the upper platen and operable to move the upper platen between a closed position and an open position... | The accused products are described as heat presses, some pneumatic, which implies a mechanism for applying pressure. | ¶14(a) | col. 5:16-27 |
| a shuttle mechanism supported by the frame and configured to move the press mechanism linearly between a first position...and a second position... | The "Double Station" nature of the accused products suggests a mechanism to move the single upper platen between the two lower stations. | ¶14(a) | col. 5:46-57 |
| a heating element configured to heat the upper platen. | The accused devices are "Heat Press Machine[s]," which implies a heating element. | ¶14(a) | col. 6:22-26 |
’960 Patent Infringement Allegations (Claim 10)
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| [All elements of a dual shuttle press, as listed above] | [As described in the table for Claim 1] | ¶14 | [As above] |
| a set of first lasers and a set of second lasers...each of the first lasers being coupled to the frame and configured to project laser light onto the first lower platen... | The complaint alleges that the accused heat presses are sold with a "Laser System" included, which is alleged to perform this function. | ¶14(a) | col. 8:36-48; col. 8:54-61 |
- Identified Points of Contention:
- Technical Questions: The complaint provides no technical evidence regarding the operation of the accused products. A central question will be whether the accused shuttle mechanism moves "linearly" as required by claim 1, or in some other manner (e.g., an arc). Furthermore, it is unclear if the accused "Laser System" constitutes "a set of first lasers and a set of second lasers" that are independently controlled, as claim 10 requires.
- Scope Questions: The complaint's allegations are conclusory. The court will need to determine if the features of the accused products, once established through discovery, fall within the scope of the patent's claims. For example, does the accused "Laser System" meet the structural and functional limitations for the two distinct sets of lasers taught in the patent?
V. Key Claim Terms for Construction
- The Term: "shuttle mechanism... configured to move the press mechanism linearly" (Claim 1)
- Context and Importance: This term is central to the mechanical operation defined in claim 1. Infringement may depend on whether the path of the accused device's upper platen is "linear." If the movement is arcuate or follows another non-linear path, Defendant may argue non-infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "linearly" is a common English word, and a party might argue for its plain and ordinary meaning of "in a straight line," without being limited to any specific mechanism that achieves it.
- Evidence for a Narrower Interpretation: The specification describes the movement as "axially along the axis 62" and discloses a specific embodiment using a "rodless cylinder" and "front and rear rails" (ʼ960 Patent, col. 5:11-12, 51-57). A party could argue these disclosures limit the term "linearly" to the specific straight-line-rail system shown, rather than any mechanism that moves in a straight line.
- The Term: "a set of first lasers and a set of second lasers" (Claim 10)
- Context and Importance: Practitioners may focus on this term because infringement of claim 10 depends entirely on the structure of the accused "Laser System." The dispute will likely center on what constitutes two distinct "sets" of lasers.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that a "set" can be composed of one or more lasers, and that any configuration with at least one laser for each station meets the limitation.
- Evidence for a Narrower Interpretation: The specification describes a system where lasers illuminating one platen are turned on while the lasers for the other are turned off, assisting the operator in positioning the next workpiece (ʼ960 Patent, col. 8:54-61). This functional description suggests that the "sets" must be distinct and independently controllable, not merely two groups of lasers that are always on or controlled together. The use of the plural "lasers" in each set further supports this.
VI. Other Allegations
- Indirect Infringement: The complaint makes general allegations of contributory and induced infringement (Compl. ¶18). It does not, however, allege specific supporting facts, such as references to Defendant's user manuals, marketing materials, or other instructions that would encourage infringing use by customers.
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’960 Patent since at least January 21, 2023, the date of Plaintiff's first cease-and-desist letter (Compl. ¶20). The complaint alleges that Defendant’s continued infringement after receiving notice was intentional and deliberate, justifying enhanced damages (Compl. ¶27).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary proof: given the lack of technical detail in the complaint, the case will first turn on discovering the actual design and operation of the accused "Double Station" presses. Does their shuttle mechanism move "linearly," and does their "Laser System" consist of two independently controlled sets of lasers as claimed?
- The case will also involve a core question of claim scope: can the term "a set of first lasers and a set of second lasers" be read to cover the specific configuration of the accused "Laser System"? The outcome of this construction will likely determine infringement of claim 10, which appears to be a key part of Plaintiff's infringement theory.