DCT
1:23-cv-00407
Ridge Wallet LLC The v. Mountain Voyage Co LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: The Ridge Wallet LLC (Delaware)
- Defendant: Mountain Voyage Company, LLC (Colorado)
- Plaintiff’s Counsel: K&L Gates LLP
- Case Identification: 1:23-cv-00407, D. Colo., 02/10/2023
- Venue Allegations: Plaintiff alleges venue is proper in the District of Colorado because Defendant is a Colorado corporation with its principal place of business in the district and has committed acts of infringement there, including online sales.
- Core Dispute: Plaintiff alleges that Defendant’s "Slim Wallets" infringe a patent related to the design of compact, minimalist wallets.
- Technical Context: The technology concerns minimalist wallets designed to securely hold credit cards and cash between two rigid plates, minimizing bulk compared to traditional leather wallets.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the asserted patent through an Amazon takedown request on December 22, 2022, followed by a formal cease and desist letter on January 20, 2023. This pre-suit notice forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2015-05-07 | ’808 Patent Priority Date |
| 2019-01-01 | Ridge begins selling its patent-practicing product (approximate date) |
| 2020-10-06 | ’808 Patent Issue Date |
| 2022-12-22 | Ridge files Amazon takedown request against Mountain Voyage |
| 2023-01-20 | Ridge sends Cease and Desist letter to Mountain Voyage |
| 2023-02-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,791,808, “Compact Wallet,” issued October 6, 2020
The Invention Explained
- Problem Addressed: The patent identifies the inconvenience of traditional bi-fold or tri-fold wallets, which can "bulge uncomfortably or telltale-like from clothing" and are ill-suited for a modern lifestyle where credit cards are the primary item carried (’808 Patent, col. 1:28-32). It also notes that existing money clips can have protrusions that "snag in a pocket" (’808 Patent, col. 1:47-48).
- The Patented Solution: The invention is a minimalist wallet comprising two rigid "bookend" plates that sandwich credit cards. The plates are held together by an encircling elastic band that runs through internal "channeling means," such as longitudinal grooves, within the plates themselves (’808 Patent, col. 2:9-18; Fig. 2). This design maintains a minimal profile, protects the contents, and allows the wallet to expand to accommodate a variable number of cards without external fixtures that could snag (’808 Patent, col. 2:18-24).
- Technical Importance: The design purports to offer a wallet "substantially no larger than a credit card" while maximizing expandable storage capacity and providing a smooth, snag-free exterior (’808 Patent, col. 2:25-28).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 14 (Compl. ¶1).
- Independent Claim 1 requires:
- At least two rigid plates.
- At least one encircling elastic band to bias the plates inwardly.
- A "channeling means" to hold the position of the aelastic band.
- An "auxiliary feature removably attached" to one of the plates, which has a "tang" with a "hook" that engages an "undercut" in a recess to prevent dislodgement.
- Independent Claim 14 requires:
- At least two rigid plates, each having a "groove" along its longitudinal extent.
- At least one encircling elastic band "slidingly interposed in the grooves."
- A "recess formed inside at least one of the at least two rigid plates" operable to receive a tang of an auxiliary feature, with the recess having an undercut to engage a hook on the tang.
- The complaint does not explicitly reserve the right to assert dependent claims but references infringement of "at least Claims 1 and 14" (Compl. ¶50).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s "Slim Wallets," including a "Matte Slim Wallet," a "Natural Walnut Slim Wooden Wallet," and a "Matte Slim Carbon Fiber Wallet" (Compl. ¶30).
Functionality and Market Context
- The complaint alleges the Accused Products feature a "slim and compact design" intended to hold up to 15 cards and 8 bills (Compl. ¶31).
- They are marketed as having an "ergonomic and lightweight design" and are offered in materials such as aluminum, walnut wood, and carbon fiber (Compl. ¶32). The complaint includes an image comparing a traditional wallet to the minimalist Ridge wallet, which Plaintiff alleges is similar in concept to the Accused Products (Compl. ¶18, Ex. 2).
- The complaint also alleges these products are sold on Defendant's website and on third-party sites like Amazon.com (Compl. ¶30, 33).
IV. Analysis of Infringement Allegations
The complaint’s infringement theory is that Defendant's "Slim Wallets" copy the patented "sandwich-type design" (Compl. ¶22, 46). While the complaint states a claim chart is attached as Exhibit 15, that exhibit was not filed with the complaint. The following chart summarizes the likely infringement positions for Claim 1 based on the complaint's narrative allegations.
’808 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| at least two rigid plates interposed to sandwich card-like contents there between... | The Accused Products are constructed with two outer plates made of materials like aluminum, wood, or carbon fiber that sandwich cards. | ¶30, 32 | col. 3:58-62 |
| at least one encircling elastic band interposed with the at least two rigid plates...to bias them inwardly... | The Accused Products allegedly use an elastic band to hold the two plates together and provide compressive force to secure the contents. | ¶46 | col. 4:1-3 |
| a channeling means configured to minimize the profile of the wallet and hold position of the at least one encircling elastic band... | The Accused Products are alleged to be "slim and compact" and to embody the patented design, which requires an internal channel or groove for the elastic band. | ¶31, 46 | col. 4:3-7 |
| an auxiliary feature removably attached...the auxiliary feature having a tang insertable into a recess...the tang having a hook, the hook engaging an undercut of the recess... | The complaint does not specify if the Accused Products include a money clip or other feature, but infringement of Claim 1 requires a removably attached component with this specific tang-and-hook mechanism. | ¶46 | col. 6:15-30 |
- Identified Points of Contention:
- Technical Question: The central technical question will be whether the Accused Products contain a "channeling means" (Claim 1) or "groove" (Claim 14) for the elastic band that is internal to the plates, as depicted in the patent's figures (e.g., Fig. 8), or if the band simply wraps around the exterior edges of the plates.
- Scope Question: A critical dispute may arise over the "auxiliary feature" limitation. The infringement analysis will depend on whether the Accused Products incorporate a removable component (like a money clip) and, if so, whether that component attaches via the highly specific "tang," "hook," and "undercut" mechanism required by the asserted claims.
V. Key Claim Terms for Construction
The Term: "channeling means" (Claim 1)
Context and Importance: This term is at the core of the patent’s asserted novelty, which is minimizing the wallet's profile by locating the elastic band within the plate structure rather than on external fixtures. The outcome of the infringement analysis for Claim 1 may depend entirely on how this term is construed.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the "channeling means 20 prevents the encircling elastic band 4 from adding more than negligible breadth to profile 14" (’808 Patent, col. 4:3-5). A party might argue this functional language supports a construction covering any structure that guides the band while keeping the profile slim.
- Evidence for a Narrower Interpretation: The specification consistently describes the "channeling means" as a "longitudinal groove 21" formed in a "first lamina 22" of the rigid plate (’808 Patent, col. 4:10-13; Fig. 8). A party may argue this is the only structure disclosed for performing the function, thus limiting the term's scope to a physical groove.
The Term: "auxiliary feature removably attached ... having a tang ... a hook ... engaging an undercut" (Claim 1)
Context and Importance: Practitioners may focus on this term because it recites a multi-part, specific mechanical interface. Infringement requires not just a removable money clip, but one that attaches using the precise geometry described.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the auxiliary feature as potentially being a money clip or a windowed envelope, suggesting some flexibility in the feature itself (’808 Patent, col. 5:12-19).
- Evidence for a Narrower Interpretation: The claim language itself is highly specific, requiring a "tang," a "hook," and an "undercut" that work together to "prevent inadvertent dislodgement" (’808 Patent, col. 6:22-30). Figures 12 and 13 illustrate this exact mechanism. A party will likely argue that infringement requires meeting every one of these structural limitations.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement, stating that Defendant "instructs... an end user to use the Accused Products" in an infringing manner (Compl. ¶51). It also alleges contributory infringement, asserting the Accused Products have "no substantial non-infringing uses" (Compl. ¶52).
- Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint asserts that Defendant knew of the ’808 Patent as of at least December 22, 2022, from an Amazon takedown request and was again notified via a cease-and-desist letter on January 20, 2023 (Compl. ¶36, 38). Plaintiff alleges Defendant continued its infringing conduct despite this notice (Compl. ¶56).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the answers to two central questions:
- A core issue will be one of structural identity: do the accused "Slim Wallets" incorporate the specific "channeling means" (i.e., an internal groove) for the elastic band as claimed, or do they utilize a distinct, non-infringing construction to secure the wallet plates?
- A key evidentiary question will be one of mechanical correspondence: assuming the accused products include a removable money clip or similar feature, does its attachment mechanism meet the detailed "tang-and-hook" structural limitations recited in the asserted claims, or is there a fundamental mismatch in its mechanical design?