DCT

1:24-cv-02447

Ridge Wallet LLC The v. 2985 LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-02447, D. Colo., 09/05/2024
  • Venue Allegations: Venue is alleged to be proper in the District of Colorado because Defendant is a Colorado corporation with its principal place of business in the district, transacts business there, and has committed alleged acts of infringement through online sales into the district.
  • Core Dispute: Plaintiff alleges that Defendant’s line of minimalist wallets infringes two U.S. design patents covering the ornamental designs of a wallet and a clip component.
  • Technical Context: The dispute is in the consumer goods sector, specifically concerning minimalist, card-centric wallets that have gained popularity as an alternative to traditional bi-fold and tri-fold wallets.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of infringement, including claim charts, on the same day each of the patents-in-suit issued. It also notes that the patents were allowed during prosecution with consideration of Inter Partes Review petitions filed against a related family member patent, U.S. Patent No. 10,791,808.

Case Timeline

Date Event
2015-05-07 Earliest Priority Date for ’246 and ’852 Patents
2016-Mid-to-Late Plaintiff first began offering its patent-practicing product for sale
2021-10-29 Application for ’852 Patent filed
2023-01-19 Application for ’246 Patent filed
2023-03-XX Defendant's founder allegedly stated he “emulated” Plaintiff's product
2024-07-23 U.S. Design Patent D1,036,246 ('’246 Patent) issued
2024-07-23 Plaintiff sent notice of infringement of ’246 Patent to Defendant
2024-07-30 U.S. Design Patent D1,036,852 ('’852 Patent) issued
2024-07-30 Plaintiff sent notice of infringement of ’852 Patent to Defendant
2024-08-02 Defendant acknowledged receipt of both infringement notices
2024-09-05 Complaint filed

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

U.S. Design Patent No. D1,036,246 - "Clip"

  • Patent Identification: D1,036,246, "Clip," issued July 23, 2024.

The Invention Explained

  • Problem Addressed: The complaint frames the relevant context as a market for minimalist wallets, suggesting a need for streamlined and aesthetically distinct accessories (Compl. ¶¶ 13, 15, 18).
  • The Patented Solution: The patent protects the specific visual appearance of the clip, not its mechanical function. The design, as illustrated in the patent's figures, features a distinct, slightly flared body with a gentle concave curve along its length, creating a specific visual profile (’246 Patent, Figs. 1, 6, 7).
  • Technical Importance: The complaint alleges that Plaintiff's overall wallet design, of which a clip is a component, is "one of the most distinct and recognizable wallets on the market" (Compl. ¶ 17).

Key Claims at a Glance

  • The patent contains a single claim for "The ornamental design for a clip, as shown and described" (’246 Patent, Claim).
  • The essential ornamental elements are the visual characteristics depicted in solid lines in the patent's drawings, including:
    • The overall shape, which is wider at the attachment end and tapers toward the free end.
    • The profile view, showing a specific concave curvature.
    • The relationship between the surfaces and edges that create the visual appearance.

U.S. Design Patent No. D1,036,852 - "Wallet"

  • Patent Identification: D1,036,852, "Wallet," issued July 30, 2024.

The Invention Explained

  • Problem Addressed: The complaint asserts that prior to its innovations, wallets were not minimalist and were designed to hold a wide variety of items beyond cards and cash (Compl. ¶ 14).
  • The Patented Solution: The patent protects the specific ornamental design of a wallet constructed from two main plates. Key visual features shown in the drawings include the overall rectangular shape of the plates, the presence and shape of a semi-circular finger notch on one edge for accessing cards, and the specific pattern of circular fasteners located near the corners (’852 Patent, Figs. 1-2). The broken lines in the figures indicate that the cards held within the wallet are not part of the claimed design (’852 Patent, DESCRIPTION).
  • Technical Importance: The complaint alleges that this type of "dual track, metal design has become synonymous with the brand itself" (Compl. ¶ 21).

Key Claims at a Glance

  • The patent contains a single claim for "The ornamental design for a wallet, as shown and described" (’852 Patent, Claim).
  • The essential ornamental elements depicted in solid lines include:
    • A pair of generally rectangular outer plates.
    • A prominent semi-circular cutout on one of the shorter edges of a plate.
    • A specific arrangement of exposed, circular fasteners.

III. The Accused Instrumentality

Product Identification

The "Accused Products" are Defendant's wallets, which are offered in various materials including metal, wood, leather, and carbon fiber, and which incorporate a money clip (Compl. ¶ 40).

Functionality and Market Context

The complaint describes the Accused Products as having a "streamlined design" that allows a user to "carry only what you need" (Compl. ¶ 41). Plaintiff alleges that Defendant entered the compact wallet market nearly eight years after Plaintiff's own product creation and that Defendant's founder admitted to having "just emulated [Ridge's] product" (Compl. ¶¶ 37, 26). The complaint includes a screenshot from an article that refers to similar products as "Ridge knock offs" (Compl. ¶ 22, Exhibit 4).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products are substantially the same in ornamental appearance as the patented designs, which would cause an ordinary observer to purchase the accused product believing it to be the patented one.

’246 Patent Infringement Allegations

The complaint provides a side-by-side visual comparison of the patented clip design and the clip on an accused wallet (Compl. p. 11).

Patented Design Feature (from Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
The overall ornamental appearance of a clip. The clip on the Accused Product, which is alleged to be confusingly similar to the patented design. ¶58; p. 11 ’246 Patent, Fig. 1
A specific flared shape that is wider at one end and tapers toward the other. The accused clip exhibits a flared shape, appearing wider where it attaches to the wallet. p. 11 ’246 Patent, Fig. 2
A distinct profile view with a gentle concave curvature. The accused clip, as depicted, appears to show a similar curved profile. p. 11 ’246 Patent, Fig. 6

’852 Patent Infringement Allegations

The complaint provides a side-by-side visual comparison of the patented wallet design and an accused wallet (Compl. p. 13).

Patented Design Feature (from Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
The overall ornamental appearance of a wallet. The overall design of the Accused Product, which is alleged to be confusingly similar to the patented design. ¶71; p. 13 ’852 Patent, Fig. 1
A pair of generally rectangular plates with a semi-circular finger notch on one edge. The accused wallet is constructed of two rectangular plates and features a semi-circular finger notch. p. 13 ’852 Patent, Fig. 2
A specific pattern of exposed, circular fasteners located near the corners of the plates. The accused wallet displays a pattern of exposed, circular fasteners in locations similar to the patented design. p. 13 ’852 Patent, Fig. 1
  • Identified Points of Contention:
    • Scope Questions: The central question will be whether an ordinary observer, viewing the designs in the context of the prior art, would find the designs substantially the same. A defense may focus on any perceived differences in the curvature of the clip, the proportions of the wallet plates, or the precise shape of the finger notch to argue against a finding of similarity.
    • Technical Questions: A likely point of contention is whether the shared design features are primarily ornamental or dictated by function. The court may need to consider if the rectangular shape, the size of the plates, and the presence of a finger notch are functional requirements for a minimalist wallet designed to hold credit cards, which could limit the scope of the design patent protection.

V. Key Claim Terms for Construction

In design patent litigation, the claim is defined by the drawings rather than by extensive text, so traditional claim term construction is less common. The analysis focuses on the overall ornamental impression created by the design. However, the scope of what is considered ornamental versus functional will be critical.

  • The Term: "ornamental design"
  • Context and Importance: The core of the dispute rests on what aspects of the wallet and clip are protectable "ornamental" designs versus unprotectable functional features. Practitioners may focus on this distinction because if the key similarities between the patented design and the accused product are functional, there can be no infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (more ornamental): The patent figures depict specific curvatures, proportions, and fastener arrangements that are not strictly required to hold cards. Plaintiff may argue that alternative designs could achieve the same function, making the chosen design aesthetic and ornamental (’852 Patent, Fig. 1; ’246 Patent, Fig. 1).
    • Evidence for a Narrower Interpretation (more functional): A defendant may argue that the basic "sandwich" construction of two plates is functional for holding cards, the finger notch is functional for deploying them, and the fasteners are functional for holding the assembly together. The broken lines in the ’852 Patent showing credit cards reinforce that the design's purpose is to hold standard-sized cards, which may constrain its overall shape and size (’852 Patent, Fig. 1, DESCRIPTION).

VI. Other Allegations

  • Indirect Infringement: The complaint does not allege indirect infringement.
  • Willful Infringement: The complaint alleges that Defendant’s infringement has been willful. The factual bases cited include Defendant’s founder’s public statement about having “emulated” Plaintiff’s product, and Defendant's alleged continuation of sales after receiving actual notice of the issued patents, which included infringement charts, from Plaintiff (Compl. ¶¶ 26, 29, 45-48, 62, 75).

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

  • A core issue will be one of ornamental scope: In applying the "ordinary observer" test, will the court determine that the overall visual impression of the accused wallets is substantially the same as the patented designs, or will it find that the similarities are primarily driven by unprotectable functional elements common to minimalist wallets?
  • A key evidentiary question will be the impact of prior art: The scope of a design patent is viewed in light of the prior art. The degree of novelty and ornamentality the court assigns to the patented designs will depend on how distinct they are from earlier wallet and clip designs.
  • A central question for remedies will be willfulness: Given the complaint’s allegations of direct notice and admissions of emulation, if infringement is found, the court will likely face the question of whether the infringement was willful, which could expose Defendant to enhanced damages and attorney's fees under 35 U.S.C. §§ 284 and 285, in addition to disgorgement of profits under § 289.