DCT
8:25-cv-02593
Germ Dome Industries LLC v. Hyundai Motor America
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Germ Dome Industries LLC (Michigan)
- Defendant: Hyundai Motor America (California)
- Plaintiff’s Counsel: Maschoff Brennan Gilmore Israelsen & Mauriel LLP
- Case Identification: 8:25-cv-02593, C.D. Cal., Filed 11/18/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business within the district and having committed the alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s Hyundai Santa Fe vehicle, which includes a UV-C sterilization compartment, infringes a patent related to devices for sanitizing objects.
- Technical Context: The technology at issue involves the use of germicidal light, such as ultraviolet-C (UV-C), to sanitize high-touch surfaces or objects, a field of increasing consumer and commercial interest.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of infringement via a letter delivered on July 15, 2025, approximately four months prior to filing the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2011-03-23 | ’061 Patent - Earliest Priority Date |
| 2019-08-19 | Rights in ’061 Patent assigned to Plaintiff |
| 2025-05-13 | ’061 Patent Issues |
| 2025-07-15 | Plaintiff’s notice letter delivered to Defendant |
| 2025-08-05 | Date Plaintiff retrieved Accused Product's Owner's Manual |
| 2025-11-18 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,296,061 - "SYSTEM AND APPARATUS FOR SANITIZING A DOOR OPENING DEVICE OR OTHER POINT OF CONTACT"
- Patent Identification: U.S. Patent No. 12,296,061, "SYSTEM AND APPARATUS FOR SANITIZING A DOOR OPENING DEVICE OR OTHER POINT OF CONTACT," issued May 13, 2025 (’061 Patent).
The Invention Explained
- Problem Addressed: The patent background describes the problem of communicable germs spreading through frequently touched surfaces—referred to as "points of contact"—such as doorknobs, elevator buttons, and automatic teller machines, which can lead to illness and lost productivity (’061 Patent, col. 1:38-49).
- The Patented Solution: The invention proposes a device that houses a "point-of-contact surface" and uses a sanitizing agent, such as germicidal ultraviolet (UV) light, to periodically sterilize it (’061 Patent, Abstract; col. 1:53-65). The device includes a housing with one or more light sources and may feature reflective interior surfaces to direct the sanitizing agent efficiently toward the target surface (’061 Patent, col. 4:18-28; Fig. 1).
- Technical Importance: The patented solution offers a method for automated sanitization of high-touch surfaces, potentially reducing pathogen transmission without requiring constant manual cleaning (’061 Patent, col. 1:49-52).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 11 (’061 Patent, col. 9:40-10:55; Compl. ¶11).
- Independent Claim 1:
- An apparatus for sanitizing an object, comprising:
- a housing at least partially defining an interior cavity configured to accept the object, the housing including:
- a first end wall located at a first end of the interior cavity;
- a sidewall extending from and integral with at least a portion of the first end wall; and
- a second end wall on an opposite end of the interior cavity from the first end wall;
- wherein the second end wall at least partially defines an opening into the interior cavity; and
- at least one germicidal light source disposed within the interior cavity.
- Independent Claim 11:
- An apparatus for sanitizing an object, comprising:
- a housing at least partially defining an interior cavity configured to accept the object, the housing including:
- a posterior wall located at a first end of the interior cavity;
- a sidewall extending from and integral with at least a portion of the posterior wall; and
- an anterior wall on an opposite end of the interior cavity from the posterior wall;
- wherein the anterior wall at least partially defines an opening into the interior cavity; and
- at least one germicidal light source disposed within the interior cavity;
- wherein the posterior wall interior surface, the anterior wall interior surface, and the sidewall interior surface are UV reflective and configured to reflect germicidal light.
III. The Accused Instrumentality
Product Identification
- The Hyundai Santa Fe vehicle, which allegedly includes a device for sanitizing an object (Compl. ¶10).
Functionality and Market Context
- The complaint identifies a "UV-C sterilizable multi tray" within the Hyundai Santa Fe as the infringing device (Compl. ¶10). An image from the vehicle's owner's manual depicts a compartment, seemingly located in the dashboard or glovebox area, accompanied by a "UV-C sterilizer system button" and a "UV-C Indicator light," suggesting a feature where users can place items in the tray for sanitization via UV-C light (Compl. ¶10, p. 3). The complaint does not provide further details on the product's market positioning or commercial importance.
IV. Analysis of Infringement Allegations
'061 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus for sanitizing an object... | The Hyundai Santa Fe includes a device for sanitizing an object. | ¶10 | col. 9:40 |
| a housing at least partially defining an interior cavity configured to accept the object... | The accused device is a "UV-C sterilizable multi tray" that functions as a housing with an interior space for holding objects. | ¶10, p. 3 | col. 9:41-43 |
| the housing including: a first end wall... a sidewall... and a second end wall... wherein the second end wall at least partially defines an opening into the interior cavity | The tray structure of the accused device necessarily includes walls that form the interior cavity and an opening for users to place objects inside. The complaint's general description of the patent notes these structural elements. | ¶7, ¶10, p. 3 | col. 9:44-55 |
| at least one germicidal light source disposed within the interior cavity, wherein the germicidal light source provides germicidal light into the interior cavity. | The accused device is expressly identified as a "UV-C sterilizer," which indicates the presence of a UV-C light source within the tray to perform sanitization. | ¶10, p. 3 | col. 9:56-59 |
Identified Points of Contention
- Scope Questions: The patent’s title and detailed description heavily emphasize sanitizing fixed "points of contact" like doorknobs (’061 Patent, Title; col. 1:38-41). A central issue may be whether the term "object" in the asserted claims can be construed broadly to cover portable items placed in an integrated vehicle compartment, or if its meaning is limited by the specification to the fixed structures that are the focus of the disclosed embodiments.
- Technical Questions: The complaint provides a single, external-facing image of the accused device (Compl. ¶10, p. 3). A question for discovery will be whether the internal structure of the "UV-C sterilizable multi tray" contains the specific components recited in Claim 1, such as distinct structures that meet the definitions of a "first end wall," a "sidewall," and a "second end wall."
V. Key Claim Terms for Construction
The Term: "object"
- Context and Importance: The definition of "object" is critical because the patent specification primarily describes sanitizing fixed "points of contact" like doorknobs, whereas the accused device is a tray for sanitizing portable items (e.g., phones, keys). The case may turn on whether the accused functionality falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 1 recites "an apparatus for sanitizing an object" without further limitation, suggesting any object is covered (’061 Patent, col. 9:40). The detailed description also refers more broadly to sanitizing "objects and surfaces" (’061 Patent, col. 3:31-32).
- Evidence for a Narrower Interpretation: The specification consistently provides examples limited to fixed points of contact, such as "doorknobs, other door opening devices, automatic teller machines (ATMs), and elevator buttons" (’061 Patent, col. 1:38-41). A party could argue that these examples define the scope of the invention and limit the term "object" to such fixed items.
The Term: "housing"
- Context and Importance: The patent's embodiments depict a housing as a standalone unit affixed to a structure like a door (’061 Patent, Fig. 1; col. 4:24-27). The accused device is a compartment integrated into a vehicle dashboard. Practitioners may focus on whether an integrated compartment constitutes a "housing" as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires "a housing at least partially defining an interior cavity configured to accept the object," language which does not on its face exclude an integrated compartment (’061 Patent, col. 9:41-42).
- Evidence for a Narrower Interpretation: The specification describes the housing as "configured to be affixed about at least a portion of said point of contact" and shows "attachment structures 18" for this purpose (’061 Patent, Abstract; col. 4:24-28). This may support an interpretation that the claimed "housing" is a component added to an existing structure, rather than a pre-integrated feature of a larger apparatus.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the ’061 Patent (Compl. ¶17). This allegation is supported by a notice letter Plaintiff claims was delivered to Defendant on July 15, 2025, and Defendant's subsequent alleged continuation of infringing conduct without response (Compl. ¶13, ¶17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "object," which appears in claims originating from a specification focused on sanitizing fixed "points of contact" like doorknobs, be construed to cover portable items placed within the accused vehicle's integrated sterilization tray?
- A second central question will be one of structural interpretation: does the accused "UV-C sterilizable multi tray," an integrated vehicle component, meet the claim limitation of a "housing" with distinct "first end wall," "sidewall," and "second end wall," as those terms are understood in light of a specification that primarily discloses a standalone, add-on device?