DCT
2:25-cv-05317
Truth Hardware Corp v. Custom Hardware Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Truth Hardware Corp. (Delaware)
- Defendant: Custom Hardware, Inc. (California)
- Plaintiff’s Counsel: DeWitt LLP
- Case Identification: 2:25-cv-05317, C.D. Cal., 06/12/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation that resides in and conducts business within the Central District of California, including the alleged acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s sliding door handle assembly infringes a patent related to a recessed, low-profile lock actuating device.
- Technical Context: The technology concerns mechanical hardware for sliding doors, specifically lock mechanisms designed to have a low or recessed profile to avoid physical interference with other door panels or obstructions.
- Key Procedural History: The complaint alleges that Plaintiff’s counsel sent a cease-and-desist letter to Defendant on October 25, 2023, providing notice of the asserted patent and the alleged infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-20 | ’035 Patent Priority Date |
| 2016-11-01 | ’035 Patent Issue Date |
| 2023-10-25 | Plaintiff sends cease-and-desist letter to Defendant |
| 2025-06-12 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,482,035 - "Recessed Lock Actuating Device for Sliding Doors"
The Invention Explained
- Problem Addressed: The patent addresses the problem of conventional sliding door handles and locks that project from the door surface, which can prevent door panels from sliding past one another or into a wall pocket, and may catch on draperies (’035 Patent, col. 1:21-36). Existing low-profile solutions were often limited in their compatibility with different lock styles and could be difficult to assemble (’035 Patent, col. 1:40-44).
- The Patented Solution: The patent describes a low-profile lock actuator assembly featuring recessed handles and a versatile internal mechanism. The core of the mechanism is a "vertically slidable arm" that links user inputs—from either an interior thumb slide or an exterior key cylinder—to one or more "rotatable drive disk[s]" (’035 Patent, col. 2:51-68). This design translates the linear motion of the thumb slide or the rotational motion of the key into the rotational motion of a drive disk, which in turn operates a separate, potentially pre-existing, lock assembly (’035 Patent, col. 7:10-29; Fig. 1A).
- Technical Importance: This approach allows for a slim, aesthetically pleasing door handle that solves the physical clearance issues of traditional hardware, while being designed to interface with a "wide variety of single point and multi-point locks in the industry" (’035 Patent, col. 1:45-47).
Key Claims at a Glance
- The complaint asserts independent claim 13 (’035 Patent, col. 10:1-28; Compl. ¶9).
- The essential elements of independent claim 13 include:
- An interior lock actuator assembly, comprising an interior escutcheon with a recessed first handle portion and a control.
- At least one rotatable drive disk.
- A vertically slidable arm operably coupled with the drive disk to rotate it when the arm is shifted by the control.
- An exterior lock actuator assembly, comprising an exterior escutcheon with a recessed second handle portion.
- The at least one rotatable drive disk is adapted to couple with a lock assembly to shift it between locked and unlocked positions.
- A second rotatable drive disk is operably coupled to the arm, such that rotation of this second disk vertically shifts the arm.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the "Custom Hardware Assembly," identified as a sliding door handle assembly made, sold, and imported by Defendant Custom Hardware, Inc. (Compl. ¶11).
Functionality and Market Context
- The complaint alleges the Custom Hardware Assembly is a direct competitor product used in the door and window industry (Compl. ¶5, ¶11). Its relevant functionality is described as mirroring the elements of the asserted patent claim. For instance, the complaint alleges the accused assembly includes an interior escutcheon with a recessed handle and a sliding lever that acts as a control (Compl. ¶14, ¶15). A visual provided in the complaint is described as showing the accused interior assembly with its recessed handle and sliding lever control (Compl. ¶15; Ex. B, p. 2). The assembly is further alleged to contain at least one rotatable drive disk and a vertically slidable arm that is coupled to it (Compl. ¶16, ¶17).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint alleges that the Custom Hardware Assembly infringes at least Claim 13 of the ’035 Patent. While the complaint references an Exhibit B claim chart, the exhibit itself is not provided; the following table summarizes the narrative allegations from the complaint body.
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an interior lock actuator assembly, including: an interior escutcheon presenting a substantially planar outer surface and including a first handle portion recessed relative to the outer surface and a control; | The accused assembly is comprised of an interior lock actuator assembly with an interior escutcheon, a recessed handle portion, and a control in the form of a sliding lever. | ¶14, ¶15 | col. 5:17-29 |
| at least one rotatable drive disk; | The accused assembly has at least one rotatable drive disk. | ¶16 | col. 5:30-31 |
| a vertically slidable arm operably couple[d] with the at least one drive disk so as to rotate the at least one drive disk when the arm is shifted vertically with the control; | The accused assembly has a vertically slidable arm coupled with the drive disk, such that when the arm is shifted via the control, the drive disk rotates. A visual is cited as depicting this mechanism. | ¶17; Ex. B, p. 3 | col. 6:5-14 |
| an exterior lock actuator assembly comprising an exterior escutcheon presenting a substantially planar outer surface and including a second handle portion recessed relative to the outer surface; | The accused assembly has an exterior lock actuator assembly with an exterior escutcheon and a recessed second handle portion. A visual is cited as showing this exterior assembly. | ¶18; Ex. B, p. 4 | col. 6:55-58 |
| wherein the at least one rotatable drive disk is adapted to couple with a lock assembly so as to shift the lock assembly between a locked position and an unlocked position when the at least one rotatable drive disk rotates... | The accused assembly is constructed such that its rotatable drive disk is adapted to couple with a lock assembly to shift it between locked and unlocked positions. | ¶19 | col. 6:15-18 |
| ...the lock actuator assembly further comprising second rotatable drive disk operably coupled to the arm such that rotation of the second drive disk vertically shifts the arm. | The accused assembly is constructed with a second rotatable drive disk operably coupled to the arm, where rotation of this second disk vertically shifts the arm. | ¶20 | col. 7:34-40 |
Identified Points of Contention
- Scope Questions: Claim 13 recites a "vertically slidable arm operably couple[d]" to two different drive disks in two distinct ways. The first disk is rotated by the arm's movement, while the second disk's rotation causes the arm's movement. A central question for the court will be whether the term "operably couple[d]" can be construed to cover these two different types of mechanical linkages as found in a single "arm" component.
- Technical Questions: A key factual question is whether the accused product's internal mechanism functions as alleged. Specifically, what evidence does the complaint provide that rotation of the accused "second rotatable drive disk" (presumably key-operated) actually "vertically shifts the arm," as required by the final limitation of Claim 13? The litigation will likely require detailed analysis of the accused product's internal components.
V. Key Claim Terms for Construction
The Term: "operably couple[d]"
Context and Importance: This term appears twice in Claim 13 to describe the critical relationship between the "vertically slidable arm" and the two separate "rotatable drive disk[s]". The construction of this term is fundamental because the two couplings it describes appear to have inverse functions (one where the arm drives the disk, the other where the disk drives the arm). Practitioners may focus on this term because its scope will determine whether the accused product's dual-actuation mechanism falls within the claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the term "coupled" more generally in the summary and abstract to mean functionally connected, without specifying the direction of force (e.g., ’035 Patent, Abstract). This may support a construction where "operably coupled" simply requires a functional link, regardless of which component is the driver and which is driven in the sub-system.
- Evidence for a Narrower Interpretation: The specific claim language suggests two distinct types of coupling. The arm is coupled to the first disk "so as to rotate" it, while the second disk is coupled to the arm "such that rotation of the second drive disk vertically shifts the arm" (’035 Patent, col. 10:7-10, 19-22). This differentiation in the claim itself may support a narrower construction requiring two distinct mechanical relationships to be present.
The Term: "vertically slidable arm"
Context and Importance: This is the central mechanical component that translates user inputs from two different sources (thumb turn and key) into action at the lock. Its structure and movement are core to the invention's operation. The dispute may involve whether the corresponding component in the accused device meets the "vertically slidable" limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not impose structural limits beyond being an "arm" that is "vertically slidable." This may support a purely functional definition, covering any component that slides vertically to link the controls and the disks.
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment, "slide arm 140," as an "elongate plate 140a" with channels (142, 148) and apertures (154) that constrain its movement along a defined vertical path when interacting with retainers (156, 158) (’035 Patent, col. 6:3-9, 26-33). This could support an argument that the term is limited to a plate-like structure moving in a defined track, rather than any component that moves vertically.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringing activities after receiving a cease-and-desist letter on or about October 25, 2023 (Compl. ¶23). This alleged post-notice conduct is characterized as a "deliberate and conscious decision to infringe" or, at a minimum, a "reckless disregard of Truth Hardware’s patent rights" (Compl. ¶25, ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "operably couple[d]", as used in Claim 13, be interpreted broadly enough to read on the two mechanically distinct relationships between the central sliding arm and the two separate drive disks, where in one instance the arm drives the disk and in the other the disk drives the arm?
- A key evidentiary question will be one of mechanical operation: does the accused Custom Hardware Assembly, upon inspection of its internal workings, actually possess a "second rotatable drive disk" and a "vertically slidable arm" that interact in the precise manner claimed, where rotation of the second disk causes the linear, vertical translation of the arm? The outcome may depend on factual evidence of how the accused product is actually constructed and functions.