DCT
1:16-cv-01940
Hunter Douglas Inc v. Ching Feng Home Fashions Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Hunter Douglas, Inc. (Delaware) and Andrew J. Toti Testamentary Trust (California)
- Defendant: Ching Feng Home Fashions Co., Ltd. (Taiwan)
- Plaintiff’s Counsel: Kilpatrick, Townsend & Stockton LLP
- Case Identification: 1:16-cv-01940, D. Colo., 07/29/2016
- Venue Allegations: Plaintiff alleges venue is proper in the District of Colorado because Defendant has solicited and transacted business in the state, sells infringing products through retailers in the district, and has placed products into the stream of commerce with the expectation of use by consumers in the district.
- Core Dispute: Plaintiff alleges that Defendant’s cordless window blinds infringe three patents related to spring drive systems that enable window coverings to be raised, lowered, and held in position without external cords.
- Technical Context: Spring-assisted mechanisms for cordless window blinds are a key safety and convenience feature in the home furnishings market, designed to eliminate the strangulation hazard posed by traditional pull cords.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2005-10-24 | Earliest Priority Date for ’814, ’554, and ’051 Patents |
| 2016-04-19 | U.S. Patent No. 9,316,051 Issues |
| 2016-05-03 | U.S. Patent No. 9,328,554 Issues |
| 2016-06-07 | U.S. Patent No. 9,359,814 Issues |
| 2016-07-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,359,814 - “Systems for Maintaining Window Covers”
- Patent Identification: U.S. Patent No. 9,359,814, titled “Systems for Maintaining Window Covers,” issued on June 7, 2016 (the “’814 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section explains that for conventional blinds, the force required to raise them is not constant; it increases as slats are collected on the bottom rail or as pleated material is compressed. Standard spring drives, which provide a relatively constant or inversely proportional force, are not well-suited to this varying load, which can lead to instability, uncontrolled movement, or the inability to hold the blind at a desired position without a locking mechanism. (’814 Patent, col. 2:6-32).
- The Patented Solution: The invention claims a window cover system that uses a spring drive in combination with a "transmission" to tailor the lifting force to match the cover's changing weight characteristics as it is raised and lowered. This balanced system is designed to hold the blind stable at any position without an external, hand-operated control cord. (’814 Patent, Abstract; col. 3:30-44).
- Technical Importance: This technology enables the design of "cordless" window coverings that can be operated by simply pushing or pulling the bottom rail and that remain in place once released, enhancing both safety and ease of use. (Compl. ¶13).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 2, 4-20, and 23-24. (Compl. ¶¶24, 26).
- The essential elements of independent claim 1 include:
- A housing and an extendible window cover.
- At least one lift cord and a first cord spool.
- A spring drive system disposed within the housing.
- A "transmission for tailoring the spring force to a varying weight of the window cover" as it moves.
- A configuration where the spring drive system controls tension on the cord spool and has "no external hand-operated control cord as an input used to raise and lower the window cover."
U.S. Patent No. 9,328,554 - “Spring Drive Systems for Window Covers”
- Patent Identification: U.S. Patent No. 9,328,554, titled “Spring Drive Systems for Window Covers,” issued on May 3, 2016 (the “’554 Patent”).
The Invention Explained
- Problem Addressed: The patent addresses the same technical challenge as the ’814 Patent: the force mismatch between conventional spring motors and the variable load of a window blind during operation, which hinders the creation of stable, easy-to-use cordless systems. (’554 Patent, col. 2:6-32).
- The Patented Solution: The invention describes a cordless window cover system that uses a spring drive system with at least one "flat spring" wound between two spools. The system is configured so that the spring drive and a cord spool "cooperate to maintain the cover in the selected position" without requiring an external hand-operated control cord for raising, lowering, or locking the blind. (’554 Patent, Abstract; col. 3:10-24).
- Technical Importance: The use of a flat spring drive system, as opposed to a coil spring, provides an alternative mechanical approach to achieving the force-balancing necessary for stable cordless blind operation. (Compl. ¶13).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 4-8, 17-21, and 24. (Compl. ¶30).
- The essential elements of independent claim 1 include:
- A housing and an extendible window cover.
- At least one lift cord.
- A spring drive system comprising a pair of spaced apart spools and "at least one flat spring."
- A cord spool with a rotational axis parallel to the housing's longitudinal axis.
- A configuration where the spring drive system and cord spool "cooperate to maintain the cover in the selected position."
- The system has "no external hand-operated control cord input to raise and lower the window cover."
Multi-Patent Capsule: U.S. Patent No. 9,316,051
- Patent Identification: U.S. Patent No. 9,316,051, titled “Window Cover System with Spring Drive Arrangement,” issued on April 19, 2016 (the “’051 Patent”).
- Technology Synopsis: The ’051 Patent addresses the same technical problem of matching a spring's force output to the variable load of a window blind. (’051 Patent, col. 2:6-32). The patented solution combines spring drives with gear and band transmissions to create a balanced system that allows a blind to be held in any position without external cords or locks. (’051 Patent, Abstract; col. 3:10-44).
- Asserted Claims: Independent claim 1 and dependent claims 2-3 are asserted. (Compl. ¶35).
- Accused Features: The complaint alleges that Defendant’s cordless window blinds are "window cover systems as claimed in the '051 Patent." (Compl. ¶22).
III. The Accused Instrumentality
Product Identification
- The accused products are identified as "window coverings and cordless window blinds," with specific examples including the "Ikea Hoppvalls Cellular Blind," "Blind Saver Basics Light Filtering Cordless Cellular Shade," "Blinds Max d/b/a Gable Point LLC Phase II 3/8” Light Filtering Cordless Cellular Shade," and "JC Penney Cut-to-Width 1½” Two Tone Cordless Blackout Cellular Shade." (Compl. ¶¶16, 19, 22, 26, 30, 35).
Functionality and Market Context
- The complaint alleges these products are "cordless window blinds" that function as "window cover systems as claimed in the" asserted patents. (Compl. ¶¶16, 19, 22). No specific technical details about the internal mechanisms or operation of the accused products are provided in the complaint. The identification of products sold through major retailers such as Ikea and JC Penney suggests they have a significant commercial presence in the U.S. market. (Compl. ¶¶16, 26).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'814 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing having a longitudinal axis; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 9:50-52 |
| an extendible window cover coupled with the housing; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 9:45-49 |
| at least one lift cord to facilitate movement of the window cover...; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 13:51-53 |
| a first cord spool; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 13:50-51 |
| a spring drive system disposed within the housing...; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 13:1-4 |
| a transmission for tailoring the spring force to a varying weight of the window cover...; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 15:10-14 |
| ...wherein the spring drive system has an output that controls tension on the first cord spool and has no external hand-operated control cord as an input used to raise and lower the window cover. | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶16 | col. 33:1-3 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the scope of the term "transmission for tailoring the spring force." The question will be whether the mechanism within the accused products performs this specific, dynamic function of matching the force to the cover's varying weight, or if it is a more conventional spring-assist mechanism that does not "tailor" the force in the manner claimed.
- Technical Questions: The complaint does not provide any technical details or evidence regarding the internal components of the accused products. A primary question for discovery will be to determine the actual structure and principle of operation of the accused blinds' lift mechanisms and whether they include a component that functions as the claimed "transmission."
'554 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing having a longitudinal axis; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 9:50-52 |
| an extendible window cover coupled with the housing; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 9:45-49 |
| a spring drive system comprising a first spring drive spool spaced apart from a second spring drive spool... and at least one flat spring...; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 17:9-11 |
| a cord spool having a rotational axis parallel to the longitudinal axis of the housing; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 17:3-8 |
| ...the spring drive system and the cord spool cooperate to maintain the cover in the selected position; | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 18:2-5 |
| ...the spring drive system... has no external hand-operated control cord input to raise and lower the window cover. | The complaint alleges the Accused Products are window cover systems that meet this limitation. | ¶19 | col. 33:1-3 |
- Identified Points of Contention:
- Scope Questions: Claim 1 of the ’554 Patent specifically requires "at least one flat spring." A potential point of contention is whether the accused products utilize a flat spring, as distinguished from other spring types like a coil spring. If they do not, infringement of this claim may be contested.
- Technical Questions: The functional limitation requiring the spring drive and cord spool to "cooperate to maintain the cover in the selected position" will likely be a focus. The question for the court will be what degree of stability and what specific mechanical interaction constitutes this "cooperation," and whether the accused products achieve their stability through this claimed method or through other means, such as simple friction.
V. Key Claim Terms for Construction
The Term: "transmission for tailoring the spring force to a varying weight of the window cover" (’814 Patent, Claim 1)
Context and Importance: This term appears to capture the core of the inventive concept for the ’814 Patent—solving the force-mismatch problem described in the background. The construction of this term will be critical to infringement, as it defines the specific function the accused mechanism must perform beyond being a simple spring-assist.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes various mechanical arrangements as "transmissions," including gear sets and band/cord systems. (’814 Patent, col. 3:17-19). A party may argue that any combination of gears or pulleys that modifies the force output from the spring meets this definition.
- Evidence for a Narrower Interpretation: The specification repeatedly emphasizes that the purpose is to offset the "decreasing supported weight or the decreasing compression force" as the blind is lowered. (’814 Patent, col. 2:47-51). A party may argue that "tailoring" requires a dynamic and proportional change in the force profile to closely match this specific, varying load, not merely a static gear ratio.
The Term: "cooperate to maintain the cover in the selected position" (’554 Patent, Claim 1)
Context and Importance: This phrase defines the cordless, position-holding capability of the invention. Practitioners may focus on this term because its interpretation will determine whether a product that holds its position primarily through friction, rather than a balanced force system, falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any system that successfully holds the blind's position without an external lock—regardless of the underlying mechanism—demonstrates the required "cooperation."
- Evidence for a Narrower Interpretation: The patent describes achieving "smooth stable operation in which the blind stayed in position" due to the combination of the spring and transmission. (’554 Patent, col. 15:42-44). A party may argue this requires a system where forces are actively balanced, as opposed to a system that relies on high static friction, which might not be considered "smooth" or true "cooperation" in the sense taught by the patent.
VI. Other Allegations
- Indirect Infringement: The complaint states that Defendant infringes "alone and in conjunction with others," which may be construed as an allegation of joint or indirect infringement. (Compl. ¶¶24, 30, 35). However, the complaint pleads no specific facts to support the knowledge or intent elements required for claims of induced or contributory infringement.
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement and does not plead facts concerning pre- or post-suit knowledge of the patents-in-suit by the Defendant.
VII. Analyst’s Conclusion: Key Questions for the Case
The litigation will likely center on the resolution of two fundamental, open questions for the court:
- A core issue will be one of definitional scope: How broadly will key functional limitations, such as the ’814 Patent’s requirement for a "transmission for tailoring the spring force," be construed? The outcome will determine whether the internal mechanisms of the accused products, once revealed, perform the specific, dynamic balancing function described in the patents or a more generic, and potentially non-infringing, spring-assist function.
- A key evidentiary question will be one of structural and functional correspondence: As the complaint provides no technical detail on the accused products, the case will depend on evidence obtained in discovery. The central dispute will be whether the accused blinds physically contain the structures recited in the claims (e.g., a "flat spring" as required by the ’554 Patent) and operate in a manner that performs the claimed functions (e.g., "cooperate to maintain the cover").