DCT
1:25-cv-00494
Mattco Industrial Products, LLC v. LTA Distributing, LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Mattco Industrial Products, LLC (North Carolina)
- Defendant: LTA Distributing, LLC (Delaware)
- Plaintiff’s Counsel: Pierson Ferdinand LLP
- Case Identification: 1:25-cv-00494, D. Del., 04/23/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is organized under Delaware law, has allegedly committed acts of infringement in the district, and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s poultry defeathering apparatuses, marketed as "quick finger change plates," and the methods of using them, infringe three patents related to a system for efficiently replacing the plucking fingers on such devices.
- Technical Context: The technology relates to high-volume poultry processing equipment, where minimizing downtime for maintenance, such as replacing worn defeathering fingers, has significant operational and economic importance.
- Key Procedural History: The complaint alleges that Plaintiff's counsel sent a letter to the Defendant on December 17, 2024, offering to resolve the matter, which the Defendant is said to have refused. This event is cited as a basis for the willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 2018-04-19 | Priority Date for '988, '556, and '735 Patents |
| 2020-09-29 | '988 Patent Issued |
| 2022-09-06 | '556 Patent Issued |
| Before 2024-02-14 | Alleged First Infringing Activity by Defendant |
| 2024-02-14 | Defendant Uploads Demonstrative Video to YouTube |
| 2024-12-17 | '735 Patent Issued |
| 2024-12-17 | Plaintiff's Counsel Sends Letter to Defendant |
| 2025-04-23 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,785,988: "Poultry Defeathering Apparatus" (issued Sep. 29, 2020)
The Invention Explained
- Problem Addressed: The patent describes conventional replacement of rubber fingers on poultry plucking machines as a "difficult and time consuming" process that is "labor intensive and dangerous" due to the need to cut off old fingers and pull new ones into place in a tight, slippery environment (ʼ988 Patent, col. 2:47-52).
- The Patented Solution: The patent discloses a method for quickly changing out multiple fingers at once. The system uses a compression plate and a separate finger plate. The fingers, which have oversized bases, are inserted through the finger plate. The finger plate is then placed over the compression plate and secured by a central mounting bolt. This action compresses the oversized bases of all the fingers between the two plates, holding them securely in place. To replace the fingers, a user simply removes the single mounting bolt, lifts the finger plate, and swaps the fingers (ʼ988 Patent, col. 6:1-51).
- Technical Importance: This method aims to replace a finger-by-finger replacement process with a batch-replacement system, promising a more "efficient and less dangerous" way to perform essential maintenance on poultry processing lines (ʼ988 Patent, col. 2:57-62).
Key Claims at a Glance
- The complaint asserts the '988 Patent, with specific allegations detailed in a referenced but unattached exhibit (Compl. ¶26, 32). Independent claim 1 is a method claim with the following key steps:
- Providing a defeathering apparatus comprising a compression plate, a finger plate with an annular abutment ring, a plurality of fingers with oversized bases, and a mounting bolt.
- Removing the mounting bolt.
- Removing the finger plate from the hub drive shaft.
- Grasping and removing one or more fingers.
- Inserting replacement finger(s).
- Securing the finger plate back onto the hub drive shaft.
- Inserting and tightening the mounting bolt to compress the finger bases between the two plates.
U.S. Patent No. 11,432,556: "Poultry Defeathering Apparatus" (issued Sep. 6, 2022)
The Invention Explained
- Problem Addressed: The patent identifies the same problem as its parent '988 Patent: the inefficiency and hazards associated with replacing individual fingers in conventional defeathering machines (ʼ556 Patent, col. 2:54-65).
- The Patented Solution: This patent claims the apparatus that enables the simplified replacement method. The key components are a compression plate secured to a hub drive shaft, and a finger plate that is operationally associated with it. The finger plate consists of an "annular abutment ring" and apertures for the fingers. The fingers themselves have "oversized" bases that are compressed between the two plates when a central mounting bolt is tightened, holding them in place for operation (ʼ556 Patent, Abstract; col. 4:5-24).
- Technical Importance: The claimed apparatus provides the physical structure that transforms the time-consuming task of individual finger replacement into a simpler process of releasing and securing an entire plate of fingers at once.
Key Claims at a Glance
- The complaint asserts the '556 Patent, referencing an unattached exhibit for detailed allegations (Compl. ¶27, 42). Independent claim 1 is an apparatus claim requiring:
- A compression plate with a central aperture, secured to a hub drive shaft.
- A finger plate consisting of a central aperture and an "annular abutment ring secured to the front side of the finger plate."
- A plurality of fingers with an "oversized base."
- A mounting bolt secured on the finger plate's front side within a mounting hole on the hub drive shaft.
- The structure is configured such that the oversized base of each finger is compressed between the two plates.
- The complaint does not specify if dependent claims are asserted, but this right is typically reserved.
U.S. Patent No. 12,167,735: "Poultry Defeathering Apparatus" (issued December 17, 2024)
- Technology Synopsis: Continuing the technology of the parent patents, this patent addresses the need for an efficient and less dangerous method for replacing worn fingers on poultry defeathering machines (ʼ735 Patent, col. 2:55-65). It claims a specific apparatus configuration comprising a compression plate and a finger plate that cooperate to clamp the oversized bases of multiple fingers, facilitating rapid, batch replacement (ʼ735 Patent, Abstract).
- Asserted Claims: The complaint asserts the '735 patent generally without specifying claim numbers (Compl. ¶¶28, 52). The patent contains independent claims 1 and 7.
- Accused Features: The accused features are Defendant's "Infringing Products," which are poultry defeathering apparatuses marketed as "quick finger change plates" (Compl. ¶¶24-25, 28).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are poultry defeathering apparatuses referred to as the "Infringing Products" and the methods of using them, called the "Infringing Processes" (Compl. ¶24). Defendant’s website allegedly markets these products as "quick finger change plates" (Compl. ¶25).
Functionality and Market Context
- The complaint alleges that the accused products embody the apparatuses claimed in the '556 and '735 patents and are used to perform the methods claimed in the '988 patent (Compl. ¶¶26-28). The complaint's primary evidence of functionality is a YouTube video, which allegedly "shows a user performing Infringing Processes" (Compl. ¶26). This video demonstrates the use of the "quick finger change plates," linking the accused product directly to the accused method of use (Compl. ¶25).
IV. Analysis of Infringement Allegations
The complaint alleges that infringement is detailed in claim charts attached as exhibits, but these exhibits were not filed with the complaint. The infringement theory is based on allegations that Defendant's products and associated YouTube video demonstrate every element of the asserted claims (Compl. ¶¶26-28).
'988 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| (a) providing the poultry defeathering apparatus comprising: a compression plate... a finger plate... a plurality of fingers comprising an oversized base... and a mounting bolt... | Defendant is alleged to make, use, sell, and offer for sale the complete apparatus, referred to as "quick finger change plates," which constitutes provision of the apparatus (Compl. ¶24). | ¶¶24, 32 | col. 8:51-9:25 |
| (b) removing the mounting bolt... | Defendant's demonstrative video is alleged to show a user performing the steps of the claimed method, including removing the central bolt (Compl. ¶26). | ¶26 | col. 9:26-29 |
| (c) removing the finger plate from the hub drive shaft... | The demonstrative video is alleged to show the removal of the finger plate after the bolt is released, exposing the finger bases (Compl. ¶26). | ¶26 | col. 9:30-34 |
| (d) grasping and removing one or more fingers from the finger plate... | The demonstrative video is alleged to show a user removing fingers from the detached finger plate (Compl. ¶26). | ¶26 | col. 9:35-38 |
| (e) inserting a replacement finger into each open finger aperture | The demonstrative video is alleged to show a user inserting new fingers into the plate (Compl. ¶26). | ¶26 | col. 10:1-2 |
| (f) securing the finger plate to the hub drive shaft by passing through the central aperture and engaging the annular abutment ring | The demonstrative video is alleged to show the re-installation of the finger plate onto the apparatus hub (Compl. ¶26). | ¶26 | col. 10:3-6 |
| (h) tightening the mounting bolt... compressing the oversized base of each finger between the compression plate and the finger plate... | The demonstrative video is alleged to show the final step of tightening the bolt, which secures the assembly and compresses the finger bases (Compl. ¶26). | ¶26 | col. 10:9-14 |
'556 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a compression plate... secured to the hub drive shaft... | The accused "quick finger change plates" are alleged to be apparatuses that include a compression plate element secured to a drive hub (Compl. ¶27). | ¶27 | col. 4:46-54 |
| a finger plate operationally associated with the hub drive shaft... consisting of... an annular abutment ring secured to the front side of the finger plate... | The accused products allegedly include a finger plate with the claimed features, including the specific annular abutment ring (Compl. ¶27). | ¶27 | col. 4:5-18 |
| a plurality of fingers comprising an oversized base and a body extending from the base... | The accused products are used with and sold for use with defeathering fingers that allegedly have the claimed oversized base structure (Compl. ¶¶24, 27). | ¶¶24, 27 | col. 4:30-34 |
| wherein the oversized base of each finger is compressed between the compression plate and the finger plate and held substantially stationary during use | The accused products allegedly function by compressing the finger bases between the two plate components to secure them (Compl. ¶27). The complaint references a YouTube video allegedly showing at least one Infringing Product (Compl. ¶27). | ¶27 | col. 5:1-4 |
| a mounting bolt secured on the front side of the finger plate within the mounting hole of the hub drive shaft | The accused products allegedly use a central mounting bolt to secure the finger plate to the hub, completing the assembly (Compl. ¶27). | ¶27 | col. 6:1-5 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the scope of "annular abutment ring." The defense may argue this requires a separate, distinct structural element as shown in the patent's figures, whereas the plaintiff may argue it covers any integral or separate feature on the finger plate that performs the same abutting and alignment function.
- Technical Questions: The complaint's infringement case appears to rely heavily on a YouTube video (Compl. ¶¶25-28). A key question for the court will be what the video actually shows. For instance, does the video provide sufficient visual detail to confirm that the accused finger bases are "compressed" in the manner required by the claims, or does it merely show them being held in place by some other mechanism?
V. Key Claim Terms for Construction
The Term: "annular abutment ring" ('988 Patent, cl. 1; '556 Patent, cl. 1)
- Context and Importance: This term appears in the independent claims of both the method and apparatus patents and describes a key structural interface between the finger plate and the hub. Practitioners may focus on this term because if the accused product achieves alignment and seating using a structure that falls outside the court's construction of this term, it could be a basis for a non-infringement defense.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the ring as being "operationally associated with the central aperture" and serving to stop the hub drive shaft when it is inserted into the finger plate ('988 Patent, col. 4:2-6). A party could argue that any structure, whether integral or separate, that performs this function meets the definition.
- Evidence for a Narrower Interpretation: The patent states the ring is "secured to the front side 41 of the finger plate" and the figures appear to show it as a discrete component (e.g., '988 Patent, Fig. 1, element 45). A party could argue the term is limited to this specific embodiment of a separate part affixed to the plate, not an integrally molded feature.
The Term: "oversized base" ('988 Patent, cl. 1; '556 Patent, cl. 1)
- Context and Importance: The novelty of the invention rests on clamping the "oversized base" of the fingers between two plates. The definition of this term is critical because if the accused fingers do not have a base that is "oversized" in the manner required by the claims, the entire infringement theory fails.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes the function: the base must be large enough to be "retained on the back side... of the finger plate" after the finger body is inserted through an aperture ('988 Patent, col. 4:35-40). This supports a simple functional definition where any base larger than the aperture is "oversized."
- Evidence for a Narrower Interpretation: The claims require the oversized base to be "compressed between the compression plate and the finger plate" to hold it "substantially stationary during use" ('988 Patent, col. 6:38-44). A party may argue this implies a specific structural quality and material resilience beyond simply being larger than the aperture, requiring a base designed specifically for this compressive interaction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement for all three patents. The inducement allegations are based on claims that Defendant actively aids and abets infringement by its customers and end users (Compl. ¶¶33, 43, 53). The contributory infringement allegations state that the accused products are a material component specially made for practicing the patented inventions and are not a staple article of commerce with substantial non-infringing uses (Compl. ¶¶34, 44, 54). The YouTube video demonstrating the infringing use is likely the key evidence for both theories (Compl. ¶26).
- Willful Infringement: Willfulness is alleged for all three patents. The claim is based on alleged pre-suit knowledge stemming from a letter sent by Plaintiff's counsel to Defendant on December 17, 2024, which Defendant allegedly "refused," and on Defendant's continued infringement after this notice (Compl. ¶¶29, 38, 48, 58).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural definition: can the term "annular abutment ring," which the patents describe as "secured to" the finger plate, be construed broadly enough to read on the specific design of the accused "quick finger change plates," or is it limited to a physically distinct component as depicted in the patent figures?
- A key evidentiary question will be one of visual proof: does the demonstrative YouTube video provide clear and unambiguous evidence of every limitation of the asserted claims—particularly the internal mechanics of how the finger bases are "compressed"—or will its interpretation be a central point of factual dispute?
- The viability of the willfulness claim will likely depend on the specificity of notice: did the December 17, 2024 letter provide notice of the specific patents and infringing products with sufficient particularity to establish that Defendant's subsequent conduct was objectively reckless?