DCT
1:25-cv-01307
Bocci Design & Mfg Inc v. Prado America LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bocci Design & MFG, Inc. (Canada)
- Defendant: Prado America, LLC (Delaware); Intertek Testing Services NA, Inc. (New York)
- Plaintiff’s Counsel: Fisherbroyles LLP
- Case Identification: 1:25-cv-01307, D. Del., 10/24/2025
- Venue Allegations: Venue is alleged based on Defendant Prado’s incorporation in Delaware and Defendant Intertek’s registration as a foreign corporation doing business in Delaware, alongside both defendants’ alleged business activities, sales, and customers within the district.
- Core Dispute: Plaintiff alleges that Defendant Prado’s "Unifit" line of flush-mount electrical outlets infringes a patent directed to methods for installing electrical outlets without a visible external cover plate.
- Technical Context: The technology relates to high-aesthetic electrical fixtures for residential and commercial construction, where the goal is to integrate outlets seamlessly into a wall surface, eliminating the visual disruption of a traditional cover plate.
- Key Procedural History: The complaint alleges that Plaintiff communicated with Defendant Prado regarding the accused products' non-compliance with industry standards and Plaintiff's patent rights as early as April 8, 2025, several months before filing suit. It also alleges Plaintiff's expert filed a non-conforming product complaint with Defendant Intertek in November 2024.
Case Timeline
| Date | Event |
|---|---|
| 2007-03-30 | ’482 Patent Priority Date |
| 2012-07-31 | ’482 Patent Issue Date |
| 2024-04-01 | (No later than) Prado began marketing Accused Products as NEC compliant |
| 2024-08-28 | (On or about) Prado received Intertek certification for an iteration of the Accused Products |
| 2024-11-20 | Plaintiff's expert filed a complaint with Intertek regarding the Accused Products |
| 2025-04-08 | (As early as) Plaintiff's representatives communicated with Prado regarding patent rights |
| 2025-10-24 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,232,482 - "Method and Apparatus for Finished Installation of Electrical Outlet Box Without Use of External Cover Plate"
- Patent Identification: U.S. Patent No. 8,232,482, “Method and Apparatus for Finished Installation of Electrical Outlet Box Without Use of External Cover Plate,” issued July 31, 2012 (’482 Patent).
The Invention Explained
- Problem Addressed: The patent addresses the aesthetic problem of conventional electrical outlets, where the visible cover plate is described as a "necessary evil" and a "pronounced eyesore" that detracts from attractively finished interiors (’482 Patent, col. 1:53-62). Traditional installations require this plate for safety and to cover the junction box opening (’482 Patent, col. 1:5-13).
- The Patented Solution: The invention is a method and apparatus for installing an electrical component so that the mounting hardware is hidden. It uses a plate assembly that is placed over the junction box. A layer of wall finishing material, such as drywall compound, is then applied over a flange portion of this plate assembly and blended seamlessly into the surrounding wall surface. This process leaves only the functional or "operative portion" of the electrical component (e.g., the outlet slots) visible, creating a minimalist, "mudded-over" appearance (’482 Patent, Abstract; col. 2:55-67).
- Technical Importance: This method provided a way to achieve a high-end, minimalist aesthetic in interior design by eliminating a common visual distraction, while still using a conventional junction box to meet building code and safety requirements (’482 Patent, col. 2:25-29).
Key Claims at a Glance
- The complaint asserts infringement of "at least one claim" without specifying claims (Compl. ¶38). Independent method claim 1 is representative.
- Essential elements of Independent Claim 1 include:
- placing said electrical component in a junction box in said wall so that only an operative portion of said electrical component is located at a surface of said wall;
- placing a layer of wall surface material over said junction box while leaving exposed said operative portion of said electrical component;
- conforming said layer of wall surface material with a surrounding area of said surface of said wall so as to form a flush, substantially uniform surface that extends over and around said junction box and said surrounding area of said surface of said wall;
- whereby when finished, said layer of wall surface material appears substantially level and continuous with said surface of said wall and substantially only said operative portion is visibly distinguishable.
III. The Accused Instrumentality
Product Identification
- Defendant Prado’s electrical outlets marketed as “Unifit,” including products with the designation “Unifit 9000-0003” or “Unifit hardwired” (collectively, the "Accused Products") (Compl. ¶38). The complaint identifies three successive iterations of the product, termed "Unifit Hardwired V1," "V2," and "V3" (Compl. ¶¶61-63).
Functionality and Market Context
- The Accused Products are described as electrical outlets with a "unique, flush-mount design" that creates a "minimal, flexible, and interchangeable alternative to traditional systems" by eliminating visible cover plates (Compl. ¶¶3, 29). The complaint alleges that Prado directly competes with Bocci in the market for such outlets, which Bocci claims to have established (Compl. ¶5). The different product versions are alleged to have distinct technical configurations; for example, V1 is alleged to have a "free-floating" junction box, while V3 is alleged to be installable with an "optional self-contained cap" in lieu of a junction box (Compl. ¶¶61, 63). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not contain a claim chart. The infringement theory is based on allegations that the installation of the Accused Products, in accordance with Prado's instructions, practices the patented method (Compl. ¶¶38, 43).
’482 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| placing said electrical component in a junction box in said wall so that only an operative portion of said electrical component is located at a surface of said wall | The complaint alleges that the Accused Products are electrical outlets intended to be installed in a wall in a manner that practices every step of at least one claim. | ¶¶38, 42 | col. 2:36-39 |
| placing a layer of wall surface material over said junction box while leaving exposed said operative portion of said electrical component | The installation of the Accused Products allegedly results in a flush-mount appearance, which is achieved by applying wall finishing material around the operative portion of the outlet. | ¶¶29, 38 | col. 2:40-43 |
| conforming said layer of wall surface material with a surrounding area of said surface of said wall so as to form a flush, substantially uniform surface | The Accused Products are marketed as a "flush-mount" and "minimal" alternative to traditional systems, which requires blending the installation into the surrounding wall. | ¶¶3, 29 | col. 2:44-48 |
| so that when finished... substantially only said operative portion of said electrical component is visibly distinguishable at said surface of said wall | The alleged installation of the Accused Products eliminates visible cover plates, leaving only the operative portion of the outlet visible for a seamless integration with the architectural finish. | ¶29 | col. 2:48-52 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the term "junction box" as used in the patent can be construed to cover the hardware allegedly used with certain versions of the Accused Products. For example, does the "free-floating" box of the "V1" product or the "optional self-contained cap" of the "V3" product (Compl. ¶¶61, 63) meet the claim limitation of placing the component "in a junction box"?
- Technical Questions: The complaint alleges that installing the Accused Products infringes the method claim but provides limited detail on the specific installation steps for those products. A key factual question will be what evidence the plaintiff can produce to show that the instructions provided by Prado (Compl. ¶43) or the actual installation practices of its customers meet each limitation of the asserted method claim.
V. Key Claim Terms for Construction
- The Term: "junction box"
- Context and Importance: The construction of this term is critical because the complaint alleges that at least one version of the accused product may be installed with a "self-contained cap" instead of a traditional junction box (Compl. ¶63). Whether this configuration falls within the scope of the claims will be a primary point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification explicitly states that the terms "'outlet box' and 'junction box' are interchangeable and include all forms of housings that contain electrical components having portions that are exposed at the surface of a wall" (’482 Patent, col. 9:40-44). This broad, explicit definition may support an argument that a "self-contained cap" qualifies as a type of "housing."
- Evidence for a Narrower Interpretation: The patent’s "Related Art" section and figures consistently depict a conventional junction box described as a "shell nailed to a stud or otherwise mounted to the internal structure of a wall" (’482 Patent, col. 1:45-50; Fig. 13A). This repeated use of a conventional structure could support an argument that the claim term should be limited to such traditional configurations.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Prado provides customers and installers with "instructions for installation" that direct them to perform the patented method (Compl. ¶¶43, 110). It further alleges contributory infringement, asserting the Accused Products are "especially made or especially adapted for use" in an infringing manner and are "not suitable for substantial noninfringing use" (Compl. ¶¶47, 119).
- Willful Infringement: Willfulness is alleged based on Prado's purported "actual knowledge of Bocci's patent rights" prior to its infringing conduct (Compl. ¶50). The complaint cites communications from as early as April 8, 2025, in which Plaintiff's representatives allegedly informed Prado of its patent rights (Compl. ¶¶76-77, 106).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "junction box," which the patent broadly defines as any "housing," be construed to read on the "optional self-contained cap" allegedly offered with the accused "Unifit Hardwired V3" product, or is its meaning limited by the more conventional embodiments described in the specification?
- A key evidentiary question will be one of infringing acts: what factual proof will demonstrate that the installation methods promoted and used for the Accused Products meet every step of the asserted method claim? The outcome may depend heavily on the specific content of Defendant's installation manuals and the established practices of installers in the field.