REV Robotics LLC v. Westcoast Products & Design LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: REV Robotics LLC (Texas)
  • Defendant: Westcoast Products & Design LLC (California)
  • Plaintiff’s Counsel: Carstens, Allen & Gourley, LLP
• Case Identification: 1:25-cv-00275, E.D. Cal., 03/04/2025
• Venue Allegations: Venue is asserted based on Defendant's residence within the judicial district and its maintenance of a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s robotics product line infringes a patent related to a universal mounting system for robotic components that can accommodate different axle types.
• Technical Context: The technology concerns modular robotics components, particularly for the educational market, where cost-effectiveness and interchangeability are significant design factors.
• Key Procedural History: The complaint alleges that Defendant was sent a cease and desist letter, which included a detailed claim chart, approximately three months prior to the filing of the lawsuit. The complaint also notes that one of the co-inventors of the patent-in-suit is now an employee of the Defendant.

Case Timeline

Date	Event
2022-04-13	'813 Patent Priority Date
2024-10-15	'813 Patent Issue Date
2024-12-13	Plaintiff sends cease and desist letter to Defendant
2025-03-04	Complaint Filing Date

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

• U.S. Patent No. 12,115,813, "APERTURED ARTICLE, INSERTION ARTICLE AND ASSOCIATED SYSTEMS," issued October 15, 2024

The Invention Explained

• Problem Addressed: The patent describes a problem in the field of modular components where existing articles were typically designed for only one function—either torque transfer (for a "live axle") or bearing support (for a "dead axle")—but not both. (’813 Patent, col. 1:59-64). This lack of interchangeability required a greater number of different parts to achieve desired functionality, increasing cost and complexity. (’813 Patent, col. 2:13-17).
• The Patented Solution: The invention is a specific geometric aperture for a robotic component (like a wheel or gear) that can universally accept different types of insertion articles. The aperture is defined by an inner periphery and an outer periphery, where the inner periphery consists of "elongated arcs" for providing bearing support, and the outer periphery is defined by protrusions that can engage with a splined shaft to transfer torque. (’813 Patent, col. 24:1-15). This dual-function geometry allows a single component to be used with either a live axle (engaging the protrusions for torque) or a dead axle (using the inner arcs as a bearing surface). (’813 Patent, col. 24:54-68).
• Technical Importance: This design approach seeks to provide a single, modular component that is compatible with multiple system configurations (live or dead axle), thereby reducing part count, manufacturing cost, and complexity for users. (’813 Patent, col. 2:6-13).

Key Claims at a Glance

• The complaint asserts dependent claim 6. Claim 6 incorporates independent claim 1.
• Independent Claim 1:
  • An assembly for rotating a wheel-shaped object comprising:
  • the wheel-shaped object that comprises an aperture that includes an outer periphery coinciding with a first reference circle with a first radius and an inner periphery coinciding with a second reference circle with a second radius that is less than the first radius,
  • wherein the inner periphery defines a plurality of inner peripheral surfaces forming elongated arcs that are concentric with the first reference circle and the second reference circle; and
  • one or more insertion articles dimensioned to be inserted into the aperture, wherein the one or more insertion articles provides the assembly with an option of a live axle and a dead axle.
• The complaint does not explicitly reserve the right to assert other claims but infringement is alleged for "at least claim 6." (Compl. ¶5).

III. The Accused Instrumentality

• Product Identification: Defendant’s "Spline XL line of robotics products." (Compl. ¶7).
• Functionality and Market Context:
  • The complaint alleges these are competing robotics products sold through Defendant’s website and other distributors. (Compl. ¶7).
  • The infringement theory is based on the products as assembled by customers, such as students, to create a robot. (Compl. ¶8). The complaint does not provide further technical detail on the operation of the Spline XL products themselves.

IV. Analysis of Infringement Allegations

The complaint alleges that the Defendant's Spline XL products, when assembled by a customer to create a robot, directly infringe at least claim 6 of the ’813 Patent. (Compl. ¶¶ 7-8). The complaint states that a detailed claim chart demonstrating this infringement was attached as Exhibit B and incorporated by reference. (Compl. ¶8). However, this exhibit was not filed with the complaint. Therefore, a detailed element-by-element analysis based on the plaintiff's specific allegations is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the specific geometry of the accused Spline XL products' mounting interface "coincides" with the "first reference circle" (outer periphery) and "second reference circle" (inner periphery) as defined by the patent. The interpretation of "coinciding with" and the precise shape of the "elongated arcs" will be critical.
  • Technical Questions: A key factual dispute will likely concern the precise dimensions and geometry of the accused products. The infringement analysis will depend on whether the Spline XL products contain both the specific torque-transferring protrusions defining the outer periphery and the distinct arc-shaped bearing surfaces defining the inner periphery as claimed.

V. Key Claim Terms for Construction

• The Term: "inner periphery... forming elongated arcs that are concentric with the first reference circle and the second reference circle" (from Claim 1)
• Context and Importance: This phrase defines the specific geometry of the bearing surface, which is a core element of the purported invention. The defendant may argue for a narrow construction tied to the specific shapes and ratios disclosed in the specification, while the plaintiff may argue for a broader functional interpretation. The ability of the accused products' inner surfaces to meet this geometric limitation will be a primary issue.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes the invention in functional terms as providing both torque transfer and bearing support, which could support an interpretation covering any geometry that achieves this dual function. (’813 Patent, col. 1:26-32, col. 2:9-13).
  • Evidence for a Narrower Interpretation: The specification provides very specific geometric details, including that the inner periphery may be "positioned along 0.4 to 0.6 of the entire circumference of the inner aperture reference circle." (’813 Patent, col. 1:42-45). The patent also repeatedly emphasizes the specific structure of "elongated arcs" that are "concentric" with the reference circles, suggesting a precise geometric constraint, not just a functional outcome. (’813 Patent, col. 24:5-10).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both contributory and induced infringement. (Compl. ¶7). It states the Spline XL products are "not a staple article or commodity of commerce suitable for substantial non-infringing use." (Compl. ¶9). The basis for inducement appears to be the sale and distribution of products intended to be assembled by customers in an infringing manner. (Compl. ¶8).
• Willful Infringement: Willfulness is alleged based on Defendant’s "continuing acts of infringement" after receiving a detailed cease and desist letter on December 13, 2024, which allegedly included a claim chart. (Compl. ¶¶ 10, 12). The complaint further alleges that Defendant's knowledge is supported by its employment of one of the patent's co-inventors. (Compl. ¶1).

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

1. A question of geometric scope: Will the claim term "inner periphery... forming elongated arcs" be construed narrowly to require the specific concentric, arcuate geometry shown in the patent's figures, or more broadly to cover any inner surface that provides bearing support? The resolution of this claim construction issue may determine infringement.
2. A question of willfulness: The complaint presents two strong factual allegations for pre-suit knowledge: a cease and desist letter and the employment of a co-inventor. A key issue will be whether Defendant’s continued sales after this notice were objectively reckless, potentially exposing it to enhanced damages.
3. An evidentiary question of infringement: As the complaint lacks a detailed claim chart, a central question for discovery will be whether the plaintiff can produce evidence demonstrating that the Defendant's "Spline XL" products meet every limitation of the asserted claim, particularly the precise geometric relationships of the inner and outer peripheries.