DCT
1:25-cv-04035
Automated Layout Technology LLC v. Redd Iron Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Automated Layout Technology, LLC (New Hampshire)
- Defendant: Redd Iron, Inc. (Colorado)
- Plaintiff’s Counsel: Milgrom Daskam & Ellis; Lando & Anastasi, LLP
- Case Identification: Automated Layout Technology, LLC v. Redd Iron, Inc., 1:25-cv-04035, D. Colo., 12/16/2025
- Venue Allegations: Venue is asserted on the basis that Defendant is a Colorado corporation residing in the judicial district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s use of a CNC fabrication machine for commercial railing layout infringes a patent related to an automated method for fabricating railing assemblies.
- Technical Context: The technology addresses the automation of layout marking in metal fabrication, a process traditionally done manually, to increase speed, reduce labor costs, and improve accuracy.
- Key Procedural History: The complaint alleges a detailed history of pre-suit communications, including that Plaintiff provided Defendant with a quotation for its patented product that was marked with the patent-in-suit. Plaintiff further alleges it explicitly warned Defendant that a competitor's machine, which Defendant ultimately purchased, was an infringing product.
Case Timeline
| Date | Event |
|---|---|
| 2017-09-05 | ’308 Patent Priority Date |
| 2024-06-25 | ’308 Patent Issue Date |
| 2025-05-20 | Plaintiff and Defendant allegedly begin communications |
| 2025-08-25 | Defendant allegedly purchased the accused PLS-624 machine |
| 2025-12-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,017,308 - "Fabrication Layout Device and Method"
- Patent Identification: U.S. Patent No. 12,017,308, "Fabrication Layout Device and Method," issued June 25, 2024 (’308 Patent).
The Invention Explained
- Problem Addressed: The patent describes the traditional fabrication of metal railings as a time-consuming, expensive, and error-prone process that relies on manual measurements and layout techniques using tools like chalk, markers, and jigs (’308 Patent, col. 1:20-33; Compl. ¶6).
- The Patented Solution: The invention is a fabrication layout device and method that automates this process. It comprises a large, continuous work surface onto which a movable, computer-controlled ink dispenser deposits a full-scale pattern of the railing assembly (’308 Patent, Abstract; col. 3:41-51). This allows fabricators to position the physical railing components directly onto the pattern for accurate alignment and assembly, reducing layout time from hours to minutes (Compl. ¶8). The complaint provides an image of what it identifies as its commercial embodiment, the Lightning Rail®, which illustrates a large format CNC marking machine with a gantry system over a flat work surface (Compl. ¶9, p. 3).
- Technical Importance: The technology seeks to replace manual, skill-intensive layout work with a repeatable, high-precision automated process, thereby increasing throughput and reducing rework in the fabrication of commercial railings (Compl. ¶7-8).
Key Claims at a Glance
- The complaint asserts infringement of independent claim 11 (Compl. ¶33, ¶36).
- The essential elements of Claim 11 are:
- A method of fabricating a railing assembly, comprising:
- selecting a railing assembly pattern using a control panel of a workstation, the workstation including a work surface, a movable ink dispensing device, and a controller;
- operating the workstation to dispense ink directly on the work surface in the railing assembly pattern;
- positioning railing components on the work surface according to the railing assembly pattern; and
- fastening the railing components to one another to form the railing assembly.
- The complaint does not explicitly reserve the right to assert dependent claims but does plead infringement of "at least claim 11" (Compl. ¶36).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the PLS-624 machine, which Defendant allegedly uses to fabricate railing assemblies (Compl. ¶21, ¶25, ¶29).
Functionality and Market Context
- The complaint alleges the PLS-624 is a CNC fabrication machine used for railing layout and fabrication (Compl. ¶15, ¶30). Defendant’s website is cited as stating it "specialize[s] in...rail fabrication" with "the latest in CNC fabrication technology and software" to offer services including "layout, and full fabricated products" (Compl. ¶15, ¶30). The complaint alleges that using the PLS-624 machine as it is intended and advertised to be used constitutes infringement of the ’308 Patent (Compl. ¶31).
IV. Analysis of Infringement Allegations
The complaint references a claim chart in its "Exhibit B" that was not attached to the filing; the following table summarizes the infringement theory for the asserted method claim based on the allegations in the complaint body (Compl. ¶33-36).
’308 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| selecting a railing assembly pattern using a control panel of a workstation... | Defendant uses the control panel of the PLS-624 machine to select a pattern for fabricating a railing assembly. | ¶31, ¶34 | col. 6:40-52 |
| operating the workstation to dispense ink directly on the work surface in the railing assembly pattern; | Defendant operates the PLS-624 machine to create a full-size layout pattern on its work surface for railing fabrication. | ¶29-31, ¶34 | col. 12:11-19 |
| positioning railing components on the work surface according to the railing assembly pattern; and | Defendant positions metal railing components on the work surface, using the layout pattern created by the PLS-624 as a guide. | ¶29, ¶34 | col. 13:56-64 |
| fastening the railing components to one another to form the railing assembly. | Defendant fastens the positioned components together (e.g., by welding) to form a completed railing assembly. | ¶29, ¶34 | col. 14:5-13 |
Identified Points of Contention
- Scope Questions: A central question may be whether the term "ink dispensing device" as used in the patent reads on the marking mechanism of the accused PLS-624. The complaint does not specify the marking technology used by the PLS-624, raising the question of whether it uses a liquid "ink" or another method such as scribing, plasma marking, or laser etching.
- Technical Questions: The infringement allegation is for a multi-step method. A key factual question for the court will be what evidence demonstrates that Defendant performs all the claimed steps, including "selecting," "operating," "positioning," and "fastening," when using the PLS-624 machine to fabricate railing assemblies (Compl. ¶29, ¶34).
V. Key Claim Terms for Construction
The Term
- "ink dispensing device"
Context and Importance
- This term is central to the claimed invention and the infringement dispute. The definition will determine whether the claim is limited to devices that use liquid ink or can be read more broadly to cover other automated marking technologies. Practitioners may focus on this term because a narrow construction limited to liquid ink could provide a straightforward path to a non-infringement defense if the accused PLS-624 uses a different marking technology.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The patent’s general description focuses on the function of creating a "railing pattern" as a "visual cue" to guide assembly, without explicitly disclaiming other forms of marking (’308 Patent, col. 3:41-51).
- Evidence for a Narrower Interpretation: The specification consistently and repeatedly uses the specific term "ink," describing an "ink dispenser system" that includes a "movable nozzle," an "ink reservoir," and a "fluid pump" (’308 Patent, col. 5:21-34, col. 10:11-35). This detailed description of a specific liquid-based system could support a narrower construction.
VI. Other Allegations
Indirect Infringement
- While not pleaded as a separate count, the complaint alleges that infringement occurs when "Using the PLS-624 machine as it is intended and advertised to be used" (Compl. ¶31). These allegations concerning the machine's intended and advertised use could potentially support a future claim for induced infringement.
Willful Infringement
- The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the ’308 Patent (Compl. ¶38). The facts alleged to support this include that Plaintiff provided Defendant a written quotation for Plaintiff's own product that was "marked with the ‘308 Patent" and later sent written emails stating that the "alternative machine you are looking at (i.e., the PLS-624) is an infringing product" before Defendant purchased and began using the accused device (Compl. ¶19, ¶22, ¶27).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "ink dispensing device," described in the patent with specific components like a nozzle and reservoir, be construed to cover the specific marking technology employed by the accused PLS-624 machine, which is not detailed in the complaint?
- A key evidentiary question will be one of accused conduct: what factual evidence will emerge in discovery to substantiate the allegation, made on information and belief, that Defendant’s actual process for using the PLS-624 to fabricate railings includes each and every step of the asserted method claim?
- A central question for damages will be one of willfulness: do the detailed pre-suit communications alleged in the complaint—including alleged direct notice of the patent and specific warnings of infringement—rise to the level of egregious conduct required for an award of enhanced damages?