DCT
1:16-cv-02737
Wine Master Cellars v. Stact Wine Displays Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wine Master Cellars, LLLP (Colorado)
- Defendant: STACT Wine Displays Inc. (Canadian)
- Plaintiff’s Counsel: Sheridan Ross P.C.
- Case Identification: 1:16-cv-02737, D. Colo., 11/08/2016
- Venue Allegations: Plaintiff alleges venue is proper because Defendant purposefully directs activities toward the district, including through sales on its own website and through third-party distributors located in the district.
- Core Dispute: Plaintiff alleges that Defendant’s L-Type Wine Rack infringes three patents related to "label-forward" wine rack designs.
- Technical Context: The technology involves wall-mounted wine racks designed to hold bottles parallel to the wall, making the labels visible without removing the bottles from the rack.
- Key Procedural History: The complaint alleges that all three asserted patents claim priority from the same 2002 provisional application. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2002-07-08 | Priority Date for '015, '194, and '085 Patents |
| 2012-07-31 | '015 Patent Issued |
| 2014-04-01 | '194 Patent Issued |
| 2016-06-14 | '085 Patent Issued |
| 2016-10-19 | Defendant allegedly posts on LinkedIn about shipping L-Type racks to the USA |
| 2016-10-29 | Alleged date window begins for Defendant adding "(not available within USA)" note to website |
| 2016-11-08 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,231,015 - "WINE RACK," Issued July 31, 2012
The Invention Explained
- Problem Addressed: The patent describes conventional wine racks that store bottles lengthwise in grid-like cavities, which hides the bottle labels from view and requires a user to remove a bottle to identify it ('015 Patent, col. 1:24-44).
- The Patented Solution: The invention is a wall-mounted wine rack comprising pairs of support members that extend perpendicularly from vertical frame elements. These support members have recessed portions designed to cradle a wine bottle horizontally and parallel to the mounting surface, thereby keeping the bottle’s label visible to a person standing in front of the rack ('015 Patent, col. 2:21-29, Fig. 3).
- Technical Importance: This design allows for high-density storage while providing "easy viewing of the labels of bottles in the rack" ('015 Patent, col. 4:62-63), which improves the user's ability to browse and select from their collection (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶26).
- The essential elements of Claim 1 include:
- A first and second "wine bottle body frame element" adapted to be attached to a structure in parallel.
- A first and second "wine bottle body support member," each extending from its respective frame element.
- Each support member has a specific geometry: a proximal portion, a first recessed portion, an intermediate portion parallel to the proximal portion, a second recessed portion, and a free end portion with an upwardly extending tip.
- The tip of the first support member extends "substantially to a plane" created by other portions, while the tip of the second extends "substantially to above" a similar plane.
- The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶21).
U.S. Patent No. 8,684,194 - "WINE RACK," Issued April 1, 2014
The Invention Explained
- Problem Addressed: The problem is identical to that described in the '015 Patent: conventional "cork-forward" racks obscure wine bottle labels ('194 Patent, col. 1:25-45).
- The Patented Solution: As a continuation of the '015 Patent, the '194 Patent discloses a similar solution involving parallel frame elements and perpendicular support members for label-forward bottle storage ('194 Patent, Fig. 3). The claims, however, describe a simplified support member structure compared to the '015 Patent.
- Technical Importance: The invention provides the same functional benefit of allowing users to view wine labels while the bottles are stored in the rack ('194 Patent, col. 4:61-63).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶26).
- The essential elements of Claim 1 include:
- A first and second "wine bottle body frame element" attached to a structure in parallel.
- A first and second "wine bottle body support member," each extending from its respective frame element.
- Each support member has: a proximal portion, a first recessed portion, an intermediate portion parallel to the proximal portion, and a free end portion with an upwardly extending tip.
- The tip of the first support member extends "substantially to a plane" created by other portions, while the tip of the second extends "substantially to above" a similar plane.
- The complaint reserves the right to assert other claims (Compl. ¶21).
U.S. Patent No. 9,364,085 - "WINE RACK," Issued June 14, 2016
- Technology Synopsis: This patent, also part of the same family, describes a label-forward wine rack. Its claims are distinct in that they recite support members extending from a "substantially vertical planar surface" rather than requiring separate "frame elements," potentially broadening the claim scope to cover integrated panel-based designs ('085 Patent, Claim 1).
- Asserted Claims: The complaint asserts independent Claim 1 (Compl. ¶26).
- Accused Features: The complaint alleges that the accused L-Type Wine Rack's back panel constitutes the "substantially vertical planar surface" and that the attached supports meet the claim limitations (Compl. ¶26, pp. 24-30).
III. The Accused Instrumentality
Product Identification
- The STACT L-Type Wine Rack (Compl. ¶21).
Functionality and Market Context
- The accused product is a wall-mounted wine rack system that uses a back panel onto which individual L-shaped aluminum supports are fastened (Compl. p. 10). These supports hold wine bottles horizontally, with their labels facing outward for display (Compl. p. 12). The complaint alleges that the product is sold in the U.S. through the Defendant’s website and various third-party retailers and that Defendant copied Plaintiff's design (Compl. ¶¶ 6, 24). The complaint includes an image from the accused product's installation manual showing how the bottle supports are fastened to the panel (Compl. p. 10).
IV. Analysis of Infringement Allegations
'015 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a first wine bottle body frame element adapted to be attached to a structure; | The accused rack's back panel, to which supports are fastened, is alleged to be the frame element. The complaint shows an installation diagram depicting attachment to a wall. | ¶26, p. 10 | col. 10:13-14 |
| (b) a second wine bottle body frame element adapted to be attached to the structure in parallel to the first wine bottle body element; | The complaint alleges the back panel contains parallel sections where the two columns of supports are attached. The installation diagram shows two parallel vertical lines of attachment points. | ¶26, p. 11 | col. 10:15-17 |
| (c) a first wine bottle body support member having: (i) a proximal portion extending perpendicularly from the first wine bottle body frame element; | An annotated diagram points to the base of the accused support where it attaches to the back panel as the proximal portion. | ¶26, p. 12 | col. 10:18-22 |
| (c)(ii) a first recessed portion extending from the proximal portion, the first recessed portion adapted to support a wine bottle body; | An annotated diagram identifies the first curve in the accused support, designed to hold the neck or body of a bottle, as the first recessed portion. | ¶26, p. 12 | col. 10:23-26 |
| (c)(iii) an intermediate portion parallel to the proximal portion and extending from the first recessed portion; | The complaint identifies a segment of the accused support between two curves as the intermediate portion, alleged to be parallel to the proximal portion. | ¶26, p. 13 | col. 10:27-29 |
| (c)(iv) a second recessed portion extending from the intermediate portion...adapted to support a wine bottle body; | The complaint identifies the second curve in the accused support as the second recessed portion. | ¶26, p. 13 | col. 10:30-32 |
| (c)(v)(aa) ...an upwardly extending tip; | An annotated diagram shows the end of the accused support curving upward. | ¶26, p. 14 | col. 10:36-37 |
Identified Points of Contention
- Scope Questions: A primary issue may be whether the accused product's single back panel can meet the limitation of a "first" and "second" "wine bottle body frame element...in parallel." The patent figures depict two structurally separate vertical bars ('015 Patent, Fig. 2), whereas the accused product uses a unitary panel (Compl. p. 10). The case may turn on whether "frame element" can be construed to mean a designated region on a single larger structure.
- Technical Questions: The infringement claim depends on mapping the specific multi-part geometry of the claimed support member onto the accused product's support. The court will have to determine if the accused support, which appears to be a continuous form, contains the discrete "proximal", "recessed", and "intermediate" portions as defined in the claim, particularly the requirement that the "intermediate portion" be "parallel to the proximal portion".
'194 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) a first wine bottle body frame element adapted to be attached to a structure; | The accused rack's back panel, to which supports are fastened, is alleged to be the frame element. | ¶26, p. 18 | col. 10:15-16 |
| (c) a first wine bottle body support member having: (i) a proximal portion extending perpendicularly from the first...frame element; | An annotated diagram points to the base of the accused support where it attaches to the back panel. | ¶26, p. 20 | col. 10:20-23 |
| (c)(ii) a first recessed portion extending from the proximal portion...adapted to support a wine bottle body; | The complaint identifies the first curve in the accused support as the first recessed portion. An annotated image shows a bottle resting in this curve. | ¶26, p. 20 | col. 10:24-27 |
| (c)(iii) an intermediate portion parallel to the proximal portion and extending from the first recessed portion; | The complaint identifies the segment between the first curve and the end of the support as the intermediate portion. | ¶26, p. 20 | col. 10:28-30 |
Identified Points of Contention
- Scope Questions: The '194 Patent shares the same "first" and "second" "frame element" language as the '015 Patent, raising the identical construction and infringement question regarding the accused product's single back panel.
- Technical Questions: The claim structure of the support member in the '194 Patent is simpler, omitting the "second recessed portion" found in the '015 Patent. The infringement analysis will still focus on whether the accused support can be shown to have the claimed "proximal", "recessed", and "intermediate" portions with the required parallel geometric relationship.
V. Key Claim Terms for Construction
The Term: "wine bottle body frame element" (’015 and ’194 Patents)
- Context and Importance: This term is central because the claims require two such elements arranged in parallel, while the accused product appears to use a single, integrated back panel. The viability of the infringement case for the '015 and '194 patents may depend on whether this term can be construed to cover designated mounting regions on a single panel.
- Evidence for a Broader Interpretation: The specification refers to the component as a "frame element or strip" ('015 Patent, col. 5:7-8), which might suggest it does not have to be a substantial structural frame.
- Evidence for a Narrower Interpretation: The patent figures consistently depict two distinct, physically separate vertical bars labeled as "first frame element 52 and a second frame element 54" ('015 Patent, Fig. 2; col. 4:46-47), suggesting the claims require two separate components.
The Term: "substantially vertical planar surface" (’085 Patent)
- Context and Importance: This term replaces the "frame element" limitation in the '085 patent, and its construction is critical to determining if that patent was successfully designed to cover products like the accused STACT rack. Practitioners may focus on this term because it appears to be a deliberate attempt to broaden the claim scope beyond the two-bar structure of the earlier patents.
- Evidence for a Broader Interpretation: The patent's background describes mounting racks to walls, suggesting this term is intended to mean any flat, upright surface suitable for mounting, such as a wall or a panel. The complaint provides a diagram with dimensions to show the accused back panel is a planar surface (Compl. p. 25).
- Evidence for a Narrower Interpretation: A defendant might argue that the term requires the surface to be perfectly flat or that it must be a component of the rack itself, separate from the wall it is mounted on, although the plain language appears broad.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant provides an "Installation Template and Manual" that instructs customers and installers on how to assemble the product in an infringing manner (Compl. ¶¶ 29, 31, 21). This provides a specific factual basis for the claim.
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It specifically alleges that Defendant altered its website between October 29 and October 31, 2016, to add the note "(not available within USA)" to the accused product's webpage, which may suggest awareness of Plaintiff's U.S. patent rights (Compl. ¶23). It also alleges constructive notice through Plaintiff's marking of its own products (Compl. ¶23).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the term "wine bottle body frame element," depicted in the '015 and '194 patents as two separate vertical bars, be construed to read on the single, solid back panel of the accused STACT system? The outcome of the '085 patent infringement claim may hinge on whether its use of "substantially vertical planar surface" successfully captures this alternative design.
- A key evidentiary question will be one of structural correspondence: do the accused product's supports, which appear to have a continuous, curved form, possess the discrete, geometrically-defined segments—such as an "intermediate portion parallel to the proximal portion"—as required by the asserted claims?
- A central question for damages will be willfulness: does the allegation that Defendant added a "not available within USA" notice to its website shortly before litigation commenced constitute sufficient evidence of conscious disregard of a known risk of infringement to support a finding of willfulness and potential enhanced damages?