Christopher L Kraus v. Milwaukee Electric Tool Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Christopher L. Kraus (California)
  • Defendant: Milwaukee Electric Tool Corporation (Wisconsin)
  • Plaintiff’s Counsel: Pro Se
• Case Identification: 5:25-cv-03397, C.D. Cal., 12/15/2025
• Venue Allegations: The complaint asserts that venue is proper under 28 U.S.C. §§ 1391 and 1400(b) without providing a specific factual basis for venue in the Central District of California.
• Core Dispute: Plaintiff alleges that Defendant’s PACKOUT™ line of products, which feature a twist-lock base, infringes a patent related to a container stability mounting apparatus.
• Technical Context: The technology relates to mechanical systems for securely and detachably mounting containers, such as beverage flasks or tool boxes, to various surfaces or other containers.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 11,766,144 - "Container Stability Mounting Apparatus"

• Patent Identification: U.S. Patent No. 11,766,144, "Container Stability Mounting Apparatus," issued September 26, 2023 (the "’144 Patent").

The Invention Explained

• Problem Addressed: The patent describes a need for a way to securely attach beverage containers, like thermal flasks, to outdoor equipment (e.g., snowboards, kayaks) that lack built-in holders, in order to prevent dehydration during vigorous activities ('144 Patent, col. 1:21-34). It also notes the importance of a locking mechanism to prevent the container from falling out ('144 Patent, col. 1:30-34).
• The Patented Solution: The invention is a two-part mounting system consisting of an "anchoring base" and a "connector sleeve" ('144 Patent, col. 2:15-18). The connector sleeve holds a container and has "sleeve protrusions," while the anchoring base has corresponding "protrusion-receiving channels" ('144 Patent, col. 3:1-15). A user places the sleeve onto the base and twists it, causing the protrusions to engage with an "annular channel" in the base, locking the two parts together ('144 Patent, col. 4:50-62; Fig. 5).
• Technical Importance: The invention provides a standardized, quick-release mechanical interface for attaching and detaching containers where a secure, rotation-based lock is desired.

Key Claims at a Glance

• The complaint alleges infringement of the ’144 Patent generally, without specifying claims (Compl. ¶¶ 3, 11). Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • an anchoring base;
  • a connector sleeve;
  • a first attachment mechanism;
  • a second attachment mechanism;
  • the connector sleeve comprising an open sleeve end and a closed sleeve end;
  • the anchoring base comprising a first base face and a second base face;
  • the first attachment mechanism comprising a sleeve interlocking portion and a base interlocking portion;
  • wherein the sleeve interlocking portion has sleeve protrusions and the base interlocking portion has a sleeve-receiving channel, protrusion-receiving channels, and an annular channel.

III. The Accused Instrumentality

Product Identification

• The complaint identifies "PACKOUT™ products that include a twist-lock base" as the accused instrumentalities (Compl. ¶8).

Functionality and Market Context

• The complaint alleges that the accused PACKOUT™ products perform the "same function, in the same way, to achieve the same result as the claimed invention" (Compl. ¶8).
• The complaint does not provide further technical details, specific product model numbers, or descriptions of how the accused products operate. It also does not allege facts regarding the products' commercial importance.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or specific factual allegations mapping claim elements to features of the accused products. It alleges infringement in a conclusory manner, stating that the accused products include a "twist-lock base" (Compl. ¶8). The complaint does not provide sufficient detail for a side-by-side analysis of the asserted claims against the accused instrumentalities. The narrative infringement theory is based on the doctrine of equivalents, alleging the accused products perform the "same function, in the same way, to achieve the same result" as the patented invention (Compl. ¶8).

Identified Points of Contention

• Structural Mismatch: A potential question is whether the accused PACKOUT™ products, which are part of a modular tool storage system, contain the specific structures recited in the claims, such as a "connector sleeve" with a "closed sleeve end" designed to hold a beverage container, or if they employ a different mechanical structure for interlocking tool boxes.
• Evidentiary Support: The primary question raised by the complaint's sparse allegations is what evidence Plaintiff will offer to demonstrate that the accused PACKOUT™ products meet each limitation of the asserted claims, either literally or under the doctrine of equivalents.

V. Key Claim Terms for Construction

"connector sleeve"

• Context and Importance: This term defines one of the two primary components of the claimed apparatus. Its construction will be critical to determining if the interlocking components of the accused PACKOUT™ system can be read upon by the claims, which describe the sleeve as receiving a "beverage container" ('144 Patent, col. 2:20-22).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "sleeve" is not explicitly defined, which may support an argument for its plain and ordinary meaning as a tube-like structure into which something is inserted. Claim 1 itself does not limit the sleeve to holding only beverage containers.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the connector sleeve in the context of holding a "beverage container," specifically "thermal foil flasks" ('144 Patent, col. 2:13-15). The figures, such as Fig. 9, show the sleeve holding a flask-like object. This context may support a narrower construction limited to devices for holding such containers.

"sleeve interlocking portion" and "base interlocking portion"

• Context and Importance: These terms define the interacting parts of the twist-lock mechanism. The dispute will likely center on whether the connection points on the accused PACKOUT™ products embody the specific structures claimed as these "portions."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests these portions "may be part of any type of attachment mechanism such as, but not limited to, key-locking mechanism, a magnetic mechanism, or a fastening-thread mechanism" ('144 Patent, col. 2:37-41), which could support construing the terms broadly to cover various interlocking structures.
  • Evidence for a Narrower Interpretation: The claims and figures detail a specific arrangement of "sleeve protrusions," "protrusion-receiving channels," and an "annular channel" ('144 Patent, col. 3:1-15; Fig. 3). This detailed description of a preferred embodiment may be used to argue for a narrower construction limited to a protrusion-and-channel system.

VI. Other Allegations

Willful Infringement

• The complaint alleges that "Milwaukee has continued infringing activities after notice of the '144 Patent" (Compl. ¶9). It does not specify when or how such notice was provided.

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

• A core issue will be one of definitional scope: can the term "connector sleeve," described in the patent's specification primarily for holding beverage containers, be construed to read on the interlocking components of the accused PACKOUT™ modular tool storage system?
• A key evidentiary question will be one of structural correspondence: given the conclusory nature of the complaint, can the Plaintiff produce evidence demonstrating that the accused products contain the specific interlocking structures recited in the patent's claims, including a "sleeve interlocking portion" with "protrusions" and a "base interlocking portion" with corresponding "channels"?