DCT
3:25-cv-02031
Metalcraft Of Mayville Inc v. Merit Hardware Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Metalcraft of Mayville, Inc., d/b/a Scag Power Equipment (Wisconsin)
- Defendant: Merit Hardware Inc. (Connecticut)
- Plaintiff’s Counsel: Robinson & Cole LLP; Boyle Fredrickson, S.C.
- Case Identification: 3:25-cv-02031, D. Conn., 12/08/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, conducts regular business, has an established place of business in Bridgeport, Connecticut, and has sold or offered for sale the accused products in the district.
- Core Dispute: Plaintiff alleges that Defendant’s stand-on leaf blowers infringe a patent related to the mechanical structure and adjustable airflow nozzle of such equipment.
- Technical Context: The technology concerns professional-grade, self-propelled lawn maintenance equipment designed for pneumatic cleanup of leaves and debris.
- Key Procedural History: The complaint alleges that Plaintiff sent a cease-and-desist letter to Defendant identifying the alleged infringement. Following correspondence in which Defendant’s counsel purportedly stated one accused product was discontinued, Plaintiff alleges Defendant continued to market and sell both that product and a new, also allegedly infringing, model, forming the basis for a willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 2018-10-17 | ’079 Patent Priority Date |
| 2024-04-16 | ’079 Patent Issue Date |
| 2025-06-01 | Accused Merit Maniac Cyclone Product Launch (on or before) |
| 2025-06-26 | Plaintiff sends cease-and-desist letter to Defendant |
| 2025-07-13 | Defendant’s counsel responds to Plaintiff |
| 2025-09-25 | Plaintiff’s counsel sends follow-up demand to Defendant |
| 2025-12-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,957,079 - "Stand-On Blower", issued April 16, 2024 (’079 Patent)
The Invention Explained
- Problem Addressed: The patent’s background section describes the inefficiency of conventional stand-on blowers that have either a fixed nozzle direction or multiple, discrete outlets. These designs require the operator to change the machine’s travel direction to aim the airflow or result in inconsistent performance between different outlets (’079 Patent, col. 1:38-54).
- The Patented Solution: The invention is a stand-on blower featuring a single, movable outlet nozzle that can be rotated horizontally and adjusted vertically. This allows the operator to continuously vary the direction of the accelerated airflow without repositioning the entire vehicle, as described in the abstract and detailed description (’079 Patent, Abstract; col. 2:1-9). The core of the solution is a nozzle positioning system that provides full directional control over the airflow path (’079 Patent, Fig. 7).
- Technical Importance: This approach allows for more efficient and precise clearing of debris by enabling the operator to direct a powerful, consistent stream of air in a wide arc while the machine is in motion (’079 Patent, col. 2:1-5).
Key Claims at a Glance
- The complaint asserts independent claim 21 (’079 Patent, col. 13:1-14:26; Compl. ¶¶23, 60).
- Essential elements of claim 21 include:
- A chassis with a frame, engine, a pair of drive wheels, and a pair of pivotable casters.
- A riding platform for an operator.
- A blower system with an impeller and surrounding housing.
- A "housing outlet duct" that extends "angularly forward" from the impeller housing.
- The housing outlet duct has an inlet connected to the impeller housing and an outlet end that is forward of the inlet end and defines a "downwardly-facing opening."
- An outlet nozzle with an "upwardly-facing opening" that receives airflow from the duct's downwardly-facing opening.
- The outlet nozzle is configured to rotate about a vertical axis that is "positioned forward of each of the pivot axes of the pair of casters."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The Merit Maniac Cyclone and the Merit Razor Cyclone ZTS blowers (collectively, the "Infringing Merit Blowers") (Compl. ¶16).
Functionality and Market Context
The accused products are self-propelled, stand-on leaf blowers used for lawn maintenance and debris clearing (Compl. ¶24). The complaint alleges, through extensive use of annotated photographs and diagrams, that the products incorporate a frame-mounted engine, drive wheels, front casters, an operator platform, and a blower system (Compl. ¶¶25-38). A key alleged feature is a large outlet nozzle that receives airflow from a duct connected to the impeller housing and is capable of rotation to direct the airflow (Compl. ¶¶39-58). An image of the Merit Maniac Cyclone shows a large, green, self-propelled machine with an operator platform at the rear and a prominent, side-mounted, black airflow nozzle at the front (Compl. p. 4). The complaint alleges these are commercial products manufactured, imported, and sold by the Defendant (Compl. ¶16).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,957,079 Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a chassis that includes a frame; an engine mounted to the frame; a pair of drive wheels supported by the frame... | The accused blowers possess a chassis, a frame, an engine mounted to the frame, and a pair of drive wheels powered by the engine. | ¶¶25-30, 62-67 | col. 4:12-24 |
| a pair of casters pivotally attached to the frame, each caster defining a pivot axis... | The accused blowers have a pair of front casters that pivotally attach to the frame, each with its own pivot axis. | ¶¶31-34, 68-71 | col. 4:14-16 |
| a riding platform mounted to the frame... | The accused blowers include a platform upon which the operator stands. | ¶¶35-36, 72-73 | col. 4:26-30 |
| a blower system, including: an impeller housing that surrounds an impeller to direct a volume of air... | The accused blowers include a blower system with an impeller inside a housing that directs airflow. | ¶¶37-40, 74-77 | col. 5:12-20 |
| a housing outlet duct that extends between the impeller housing and an outlet nozzle, wherein: the housing outlet duct extends angularly forward from the impeller housing... | An outlet duct on the accused blowers extends from the impeller housing to the nozzle in a forward, angled direction. The complaint provides an annotated image showing this angular extension (Compl. p. 10). | ¶¶41-44, 78-81 | col. 5:50-54 |
| ...a housing outlet duct outlet end arranged forward of the housing outlet duct inlet end...and defining a downwardly-facing opening; | The outlet end of the accused duct is positioned forward of its inlet end and terminates in an opening that faces downward. An annotated image illustrates this downward-facing opening (Compl. p. 12). | ¶¶47-50, 84-87 | col. 5:46-49 |
| the outlet nozzle defines an inlet end with an upwardly-facing opening that receives the airflow from the downwardly-facing opening of the housing outlet duct; | The accused nozzle has an inlet with an upward-facing opening that aligns with and receives air from the duct's downward-facing opening. | ¶¶51-52, 88-89 | col. 6:1-3; col. 14:11-15 |
| the outlet nozzle is configured to rotate about a vertical axis that...is positioned forward of each of the pivot axes of the pair of casters. | The accused nozzle rotates around a vertical axis. The complaint alleges this axis of rotation is located forward of the pivot axes of the front casters, supported by an annotated photograph (Compl. p. 14). | ¶¶53-58, 90-95 | col. 6:13-25; col. 14:19-26 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused duct, which appears to be a large, curved tube, meets the "extends angularly forward" limitation. The interpretation of "angularly" may be disputed, raising the question of whether it requires a distinct angle or if a continuous curve suffices.
- Technical Questions: Infringement of the final limitation—requiring the nozzle's rotational axis to be "positioned forward of each of the pivot axes of the pair of casters"—is a precise geometric condition. The dispute may turn on measurement and evidence of the actual physical configuration of the accused blowers, questioning whether the complaint's photographic evidence accurately depicts a configuration that meets this spatial requirement.
V. Key Claim Terms for Construction
The Term: "extends angularly forward from the impeller housing"
Context and Importance
This term defines the fundamental geometry and orientation of the air conduit between the impeller and the nozzle. The infringement analysis for both accused products hinges on whether their duct structure falls within the scope of this phrase.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The specification describes the duct body as "extending tangentially away from the impeller housing 50 and also angularly in a forward direction," which provides an "at least partially scrolling spiraling configuration" (’079 Patent, col. 5:50-54). Plaintiff may argue that any configuration that is not purely tangential or radial, but has a forward vector, meets the "angularly forward" requirement.
- Evidence for a Narrower Interpretation: Defendant may point to the patent's figures, such as Figure 1, to argue that the term implies a more specific shape or angle of departure from the housing than is present in the accused products. The use of "scrolling spiraling" could be argued to require a more complex geometry than a simple curve.
The Term: "positioned forward of each of the pivot axes of the pair of casters"
Context and Importance
This limitation defines a specific spatial relationship between the nozzle's axis of rotation and the steering casters. It is a highly factual and precise requirement that could be a dispositive point of non-infringement if not met.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim uses the general term "forward of," which Plaintiff may argue simply means located anterior to the caster axes along the machine's longitudinal axis, without any further distance or angular constraint. The plain and ordinary meaning would support any forward position.
- Evidence for a Narrower Interpretation: Defendant may argue that, in the context of the invention's overall geometry as shown in Figure 1, the term implies a functionally significant forward placement necessary to achieve the invention's stability or performance, a quality their product may lack. However, the claim language itself does not impose such a functional requirement.
VI. Other Allegations
Indirect Infringement
The complaint does not plead a separate count for indirect infringement and focuses its factual allegations on Defendant's direct acts of making, using, selling, and importing the accused products (Compl. ¶¶16, 99).
Willful Infringement
The complaint makes a detailed allegation of willful infringement. It alleges that Defendant had pre-suit knowledge of the ’079 Patent and its infringement at least as of June 26, 2025, via a cease-and-desist letter (Compl. ¶¶13, 17). The complaint further alleges that despite this notice, and after communications between counsel, Defendant continued to import, manufacture, and sell the accused products (Compl. ¶¶14, 22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of claim scope and geometry: Does the physical shape and orientation of the air duct on the accused blowers satisfy the "extends angularly forward" limitation as defined by the patent's specification and figures?
- A key evidentiary question will be one of spatial configuration: Can Plaintiff prove, likely through expert testimony and measurement, that the vertical axis of rotation for the accused nozzle is strictly "positioned forward of each of the pivot axes of the pair of casters" as required by the claim?
- The case will also present a critical question regarding culpability: Given the detailed allegations of pre-suit notice via a cease-and-desist letter and subsequent continued sales, the court will need to determine whether Defendant’s alleged conduct rises to the level of "egregious" behavior necessary to support a finding of willful infringement.