DCT
3:19-cv-01567
Arlington Industries Inc v. Hubbell Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Arlington Industries, Inc. (New York)
- Defendant: Hubbell Incorporated and Hubbell Incorporated (Delaware)
- Plaintiff’s Counsel: McCARTER & ENGLISH, LLP; Crowell & Moring LLP
- Case Identification: 3:19-cv-01567, D. Conn., 10/04/2019
- Venue Allegations: Venue is asserted in the District of Connecticut based on Defendant Hubbell Incorporated's state of incorporation and principal place of business, as well as alleged acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Push-In cable connectors" infringe a patent related to electrical fittings that ensure improved electrical continuity with a junction box.
- Technical Context: The technology concerns specialized electrical connectors used to securely and safely attach armored electrical cables to junction boxes, a ubiquitous component in building construction.
- Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2002-01-17 | ’280 Patent Priority Date |
| 2004-03-23 | ’280 Patent Issue Date |
| 2019-10-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,709,280 - "Fitting with Improved Continuity"
- Patent Identification: U.S. Patent No. 6,709,280, "Fitting with Improved Continuity", issued March 23, 2004.
The Invention Explained
- Problem Addressed: The patent describes a need to improve upon prior art "snap fitting connectors" for electrical junction boxes. The specific problem is that while prior designs offered a quick connection, they could be improved to create a tighter, more secure fit that "vastly improves the electrical continuity and lowers the millivolt droop between the fitting, the cable, and the junction box" (’280 Patent, col. 2:30-36).
- The Patented Solution: The invention is an electrical fitting featuring a novel "grounding tang" on its conductive spring member. This tang is shaped with a rising slope, a crest, and a downward slope. When the fitting is pushed into a junction box hole, the tang compresses and then springs outward. The key innovation is that the "downward slope cause the fitting to be drawn tightly against the junction box wall," ensuring a secure mechanical and electrical connection (’280 Patent, col. 2:57-63; Fig. 7).
- Technical Importance: This design claims to provide a more reliable ground path than prior quick-connect fittings, which is a critical safety and performance feature in electrical systems (’280 Patent, col. 2:33-36).
Key Claims at a Glance
- The complaint asserts independent claims 1 (apparatus) and 5 (method) (Compl. ¶¶ 24, 25).
- The essential elements of independent claim 1 include:
- A hollow electrically conductive connector.
- An electrically conductive spring member surrounding the connector's leading end.
- A spring locking member to prevent withdrawal from the junction box hole.
- A "grounding tang" that is integral with the spring member.
- The grounding tang must have a specific geometry: "a rising slope at said supported end, a downward slope at said trailing end and a crest separating said rising slope and said downward slope."
- The tang must perform a specific function: "enabling said grounding tang to draw said face of said electrical connector against said junction box."
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶ 28).
III. The Accused Instrumentality
Product Identification
- The complaint identifies Defendant's "Push-In cable connectors," specifically Catalog Numbers 38RAC and 40RAC, as the "Accused Connectors" (Compl. ¶ 21).
Functionality and Market Context
- The complaint alleges the Accused Connectors are used to connect electrical cables to junction boxes (Compl. ¶ 21). Their function, as alleged, mirrors that of the patented invention: they are inserted into a hole in a junction box and use spring-like features to lock in place and provide electrical continuity (Compl. ¶¶ 22-23). The complaint includes an image of the Accused Connectors, showing their general construction with external spring-like elements. This image shows the Accused Connector, model 38RAC, which is alleged to infringe (Compl. ¶ 21, p. 5).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint alleges that the Accused Connectors literally infringe every element of Claim 1 of the ’280 Patent (Compl. ¶ 22).
’280 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a hollow electrically conductive connector through which an electrical conductor is inserted... | The Accused Connectors each have a hollow electrically conductive connector through which an electrical conductor is inserted. | ¶22 | col. 2:58-59 |
| an electrically conductive spring member surrounding said leading end of said electrical connector... | Each connector also has an electrically conductive spring member surrounding its leading end. | ¶22 | col. 2:59-60 |
| a spring locking member integral with and cantilevered at one end from said spring member... [which] springs outward to lock said electrical connector from being withdrawn from said hole... | Each connector further includes a spring locking member integral with and cantilevered at one end from the spring member... [which] springs outward to lock the electrical connector from being withdrawn from the hole. | ¶22 | col. 3:3-5 |
| a grounding tang integral with and supported at one end from said spring member... | Each grounding tang on the Accused Connectors is integral with and supported at one end from said spring member. | ¶23 | col. 3:29-32 |
| with said grounding tang having a rising slope at said supported end, a downward slope at said trailing end and a crest separating said rising slope and said downward slope... | The grounding tang has a rising slope at said supported end, a downward slope at the trailing end and a crest separating said rising slope and downward slope. | ¶23 | col. 3:40-44 |
| thereby enabling said grounding tang to draw said face of said electrical connector against said junction box and provide electrical continuity... | ...enabling said grounding tang to draw the face of the connector against said junction box and provide electrical continuity... | ¶23 | col. 4:40-45 |
Identified Points of Contention
- Structural Questions: A central question will be whether the accused products' grounding feature possesses the specific three-part geometry—"rising slope," "crest," and "downward slope"—recited in the claim. The defense may argue that its structure, while providing spring contact, does not map onto this precise claimed configuration.
- Functional Questions: The claim requires that the tang "draw said face of said electrical connector against said junction box." The complaint alleges this function is met (Compl. ¶ 23). A key dispute may arise over whether the accused product performs this specific "drawing" action, as opposed to simply creating spring-biased electrical contact. The patent describes this drawing action as a consequence of the downward slope and the tang's tendency to return to its relaxed state (’280 Patent, col. 4:40-44).
V. Key Claim Terms for Construction
The Term: "grounding tang"
- Context and Importance: This term describes the novel feature of the invention. Its construction will determine whether only structures with the specific shape disclosed in the patent can infringe, or if a wider range of grounding features are covered. Practitioners may focus on this term because the patent’s primary asserted point of novelty resides in the tang's specific structure and function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent occasionally refers to the feature as a "tensioner or grounding tang" (’280 Patent, col. 2:32-33), which could suggest a functional definition focused on providing tension, not just a specific structure.
- Evidence for a Narrower Interpretation: The specification consistently describes and illustrates the "grounding tang 16" as having a very specific profile, including a "rising slope 48", "crest 50", and "downward slope 52" (’280 Patent, col. 3:40-44; Fig. 3). The defense could argue the term is implicitly limited to this disclosed embodiment.
The Term: "draw said face ... against said junction box"
- Context and Importance: This functional language is critical, as it defines the required result of the grounding tang's action. The infringement analysis will turn on whether the accused device performs this specific function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue that any mechanism on the tang that causes the connector's face to be pulled tighter against the junction box, even slightly, satisfies this limitation.
- Evidence for a Narrower Interpretation: The specification explicitly links this "drawing" action to the geometry of the "downward slope 52" contacting the inner edge of the junction box hole, which "causes the face 62 of the fitting 10 to be drawn tightly against the wall 66 of the junction box" (’280 Patent, col. 4:40-44). A defendant may argue this requires a specific cam-like pulling or wedging action, not just a general spring force pressing the connector against the box.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement of method claim 5 (Compl. ¶¶ 26-27).
- Inducement: The allegation is based on the theory that Defendant encourages its customers to use the Accused Connectors in an infringing manner, citing "Defendants' marketing literature" as evidence of encouragement (Compl. ¶ 27).
- Contributory Infringement: The complaint alleges the Accused Connectors are a "material part" of the patented method, are "especially made or especially adapted" for infringing use, and are not staple articles of commerce suitable for substantial noninfringing use (Compl. ¶ 26).
- Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it requests "enhanced damages, pursuant to 35 U.S.C. § 284" in the prayer for relief (Prayer for Relief, B). The factual basis for willfulness appears to be post-suit, as the complaint alleges Defendant has known of the infringement "at least since the filing date of this Complaint" (Compl. ¶¶ 26, 27).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may depend on the court's answers to two central questions:
- A core issue will be one of structural definition: do the allegedly infringing features on the accused connectors possess the distinct "rising slope," "crest," and "downward slope" geometry required by the patent's "grounding tang," or do they represent a structurally different design?
- A key evidentiary question will be one of functional performance: does the accused product's grounding feature perform the specific, claimed function of "draw[ing]" the connector’s face against the junction box, as described in the patent specification, or does it merely provide a general spring force for electrical contact without this distinct pulling action?