DCT
3:15-cv-01410
Research & Design Innovations LLC v. ITC Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Research & Design Innovations, LLC (Connecticut)
- Defendant: ITC Incorporated (Michigan)
- Plaintiff’s Counsel: Delio, Peterson & Curcio, LLC
- Case Identification: 3:15-cv-01410, D. Conn., 09/25/2015
- Venue Allegations: Plaintiff alleges venue is proper in the District of Connecticut because Defendant transacts business, has solicited business, and has sold the accused products in the district, and derives substantial revenue from the district.
- Core Dispute: Plaintiff alleges that Defendant’s illuminated cup holder products infringe a patent related to a lighted holder for containerized beverages.
- Technical Context: The technology relates to accessory products for vehicles, particularly boats, where aesthetic features like integrated lighting can provide a competitive advantage.
- Key Procedural History: The complaint alleges that Plaintiff placed Defendant on notice of the patent and its infringement prior to the lawsuit, which may form the basis for a willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2007-04-16 | U.S. Patent No. 7,500,443 Priority Date |
| 2009-03-10 | U.S. Patent No. 7,500,443 Issues |
| 2015-09-25 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,500,443 - “HOLDER FOR A CONTAINERIZED BEVERAGE,” issued March 10, 2009
The Invention Explained
- Problem Addressed: The patent background suggests that in competitive markets for items like boats, the style and features of ancillary components such as cup holders can be a significant factor in a consumer's purchasing decision. The patent identifies a need for a cup holder that "attracts customers in a way previous cup holders have not" (’443 Patent, col. 1:41-43).
- The Patented Solution: The invention is a cup holder with an integrated lighting system. As described in the detailed description, it comprises a base for holding a beverage container and a rim that extends outwardly from the top of the base. This rim is constructed to contain an "enclosed rim channel" which houses a light source, such as an LED (’443 Patent, col. 5:50-54; col. 6:7-12). At least a portion of the rim's perimeter is made of a translucent material, allowing light from the internal source to illuminate the rim, creating an aesthetic glow (’443 Patent, col. 6:15-19; Fig. 7).
- Technical Importance: The invention provides a method for integrating aesthetic lighting directly into the structure of a common vehicle accessory, potentially enhancing the product's market appeal (’443 Patent, col. 1:23-28).
Key Claims at a Glance
- The complaint asserts independent claim 1.
- The essential elements of Claim 1 are:
- A cup holder comprising: a base having an interior surface defining a base channel having an opening and having a bottom,
- a rim attached to and extending outwardly from the base,
- the rim defining an enclosed rim channel and the rim having a perimeter,
- the perimeter having at least some portion that is translucent; and
- a light source positioned in the enclosed rim channel, whereby the light source illuminates the rim through the at least some portion that is translucent.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused products are the ITC "Stainless Steel Drink Holder with LED Illuminated Ring," identified by part numbers 81425SS304-LEDBL, 81425SSHPPN304-LEDBL, and 81426SS316-LEDBL (Compl. ¶7).
Functionality and Market Context
- The complaint describes the accused product as a "holder for a containerized beverage" that features an "LED Illuminated Ring" (Compl. ¶7). The allegations suggest the product is a functional cup holder with an integrated lighting feature for aesthetic purposes. The complaint alleges these products are sold through authorized distributors and interactive websites in the United States (Compl. ¶¶10-11). The complaint includes a photograph, Exhibit C-4, showing the accused product's light source positioned within the rim structure (Compl. ¶9(e)).
IV. Analysis of Infringement Allegations
’443 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A cup holder comprising; a base having an interior surface defining a base channel having an opening and having a bottom | The accused product is alleged to have a base with an interior surface defining a channel, as shown in a photograph (Exhibit C-1) | ¶9(a) | col. 2:35-37 |
| a rim attached to and extending outwardly from the base | The accused product is alleged to feature a rim attached to and extending from the base, as shown in a photograph (Exhibit C-2) | ¶9(b) | col. 2:42-44 |
| the rim defining an enclosed rim channel and the rim having a perimeter, the perimeter having at least some portion that is translucent | The accused product's rim allegedly defines an enclosed channel and has a translucent perimeter, as shown in a photograph (Exhibit C-3) | ¶9(c), ¶9(d) | col. 5:50-54 |
| a light source positioned in the enclosed rim channel, whereby the light source illuminates the rim through the at least some portion that is translucent | The accused product allegedly has a light source positioned in the rim channel that illuminates the rim, as depicted in a photograph (Exhibit C-4) | ¶9(e) | col. 6:7-12 |
- Identified Points of Contention:
- Structural Questions: A central question may be whether the accused product's structure constitutes an "enclosed rim channel" as required by the claim. The interpretation of "enclosed" will be critical, specifically whether the accused product's configuration, as depicted in the complaint's photographic exhibits, meets the structural requirements taught in the patent's specification and figures. The complaint cites Exhibit C-3 to show the "enclosed rim channel," which may become a focal point of discovery (Compl. ¶9(c)).
- Technical Questions: The analysis may turn on the specific properties of the accused product's illuminated ring. The parties may dispute whether the material used in the ring qualifies as "translucent" within the meaning of the patent, particularly if the patent's context implies specific optical properties beyond simply allowing light to pass through.
V. Key Claim Terms for Construction
The Term: "enclosed rim channel"
- Context and Importance: The existence of an "enclosed rim channel" is a core structural limitation of the invention. The infringement analysis will depend entirely on whether the physical structure of the accused product's rim is found to meet this definition. Practitioners may focus on this term because it defines the specific housing for the light source, distinguishing it from general surface illumination.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification broadly states "the rim 14 defines a channel 54" (ʻ443 Patent, col. 5:50-51), which a party could argue supports any structure that forms a channel or recess within the rim.
- Evidence for a Narrower Interpretation: Figure 7 of the patent depicts a very specific channel structure formed by an inside side (58), outside side (60), top side (62), and a separately secured bottom side (64). A party could argue that "enclosed" requires a structure with distinct top, bottom, and side walls, similar to the specific embodiment shown (ʻ443 Patent, col. 5:51-64).
The Term: "translucent"
- Context and Importance: This term describes the material property that enables the claimed illumination effect. The dispute may hinge on whether the accused product's illuminated ring is merely transparent or if it possesses the light-diffusing properties that might be implied by the term "translucent" in the context of creating a "glow."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue for the plain and ordinary meaning of translucent, which is simply permitting the passage of light but not detailed images.
- Evidence for a Narrower Interpretation: The specification discusses the use of a "light diffuser" in conjunction with the light source, which "acts to disperse the light from a point light source to create a glow" (ʻ443 Patent, col. 6:20-22). A party could argue that "translucent," as used in the patent, requires this diffusing quality and is not satisfied by a merely transparent material that does not create a "glow."
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant "authorizes and intends for its distributors to sell such infringing device" and that distributors have acted as agents in selling the device (Compl. ¶10). This forms the basis for a claim of induced infringement.
- Willful Infringement: The complaint alleges that Plaintiff "placed defendant ITC on notice of the '443 Patent and of the infringement" and that Defendant's infringement continued thereafter with "conscious disregard for the rights of plaintiff RDI" (Compl. ¶¶12-13). This allegation of post-notice conduct supports the claim for willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural definition: Does the accused product's method of mounting an "LED Illuminated Ring" create a structure that meets the claim limitation of an "enclosed rim channel," or does the patent require a more specific, multi-walled construction as depicted in its preferred embodiments?
- A second key question will be one of material properties: Does the term "translucent," as used in the patent, simply mean allowing light to pass through, or does the specification's discussion of creating a "glow" with a "light diffuser" imply a narrower definition that requires specific light-scattering properties that may or may not be present in the accused product's ring?