DCT
1:25-cv-01364
Valmont Industries Inc v. Amphenol Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Valmont Industries, Inc. (Delaware)
- Defendant: Amphenol Corporation (Delaware) and Outdoor Wireless Networks LLC (Delaware)
- Plaintiff’s Counsel: Polsinelli PC
- Case Identification: 1:25-cv-01364, D. Del., 11/07/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because both defendants are Delaware entities and therefore reside in the district for purposes of patent venue.
- Core Dispute: Plaintiff alleges that Defendants’ Sector Frame Series mounting products for wireless site components infringe a patent related to a bolt-calibrated system for adjusting the angle of tower-mounted frames.
- Technical Context: The technology concerns mechanical mounting systems used in the construction of wireless communication towers, where precise angular adjustment of heavy equipment is critical for network performance.
- Key Procedural History: The complaint notes that Defendants’ predecessor-in-interest, CommScope, previously manufactured and sold the accused products before divesting the business segment to Defendant Outdoor Wireless.
Case Timeline
| Date | Event |
|---|---|
| 2019-11-11 | ’435 Patent Priority Date |
| 2022-03-15 | ’435 Patent Issue Date |
| 2025-11-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,274,435, "Bolt Calibrated Angle Mainstay Wall Connection System And Method For Use," issued March 15, 2022.
The Invention Explained
- Problem Addressed: The patent addresses the difficulty, imprecision, and expense of adjusting the taper (angle) of vertical tower frames during construction. Conventional methods often require external force from equipment like cranes or come-alongs, are difficult to adjust precisely, and may not offer a universal range of adjustment. (’435 Patent, col. 1:23-36).
- The Patented Solution: The invention is a mounting system featuring a "duel locking system" with a "taper adjusting bolt" that allows a user to precisely adjust the angle of a mounted frame to be level, even while under load, without needing additional heavy equipment. (’435 Patent, Abstract; col. 2:8-12). As shown in an exploded view (Fig. 2), tightening the adjusting bolt (40) moves a "straight slot weldment" (42) relative to a front plate (48), which in turn changes the angle of the assembly. (’435 Patent, col. 4:30-38).
- Technical Importance: The described solution purports to reduce the man-hours and equipment costs associated with tower construction by enabling more precise, efficient, and mechanically simple adjustments of tower elements. (’435 Patent, col. 1:23-25, col. 2:12-15).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1. (Compl. ¶20).
- The essential elements of Claim 1 are:
- An "upper bracket element" comprising a front plate, a back bracket, and connecting bolts.
- The front plate is attached to right and left "front wings" with slots, which extend horizontally.
- A "straight slot weldment" comprising side walls with slots and an adjusting bolt guide, attached to the front wings.
- A plurality of "adjusting bolts" extending through slots in the wings and the weldment.
- A "lower bracket element" comprising a lower backing bracket and a lower front plate.
- A "vertical wall section" comprising at least one lateral spanning element, vertical supports, and cross spanning members.
- The complaint states its allegations are illustrative and not limiting, suggesting the right to assert additional claims is reserved. (Compl. ¶20).
III. The Accused Instrumentality
Product Identification
- The SFG22HD and SFG23HD Sector Frame Series products (collectively, the "Accused Product"). (Compl. ¶19).
Functionality and Market Context
- The Accused Product is a mechanical frame system for mounting equipment to wireless communication towers. (Compl. ¶¶14, 19). The complaint alleges the product contains an upper bracket, a lower bracket, and a vertical wall section, with specific components that correspond to the elements of the asserted patent claim. (Compl. ¶¶21-25). An annotated photograph provided in the complaint shows the Accused Product's upper bracket assembly with various components labeled to map to claim terminology. (Compl. ¶21). The complaint alleges Defendants manufacture, use, sell, and import these products in the United States. (Compl. ¶19).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,274,435 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an upper bracket element, wherein the upper bracket element comprises a front plate, a back bracket and a plurality of connecting bolts; | The Accused Product allegedly comprises an upper bracket element (1.0), which includes a front plate (1.1), a back bracket (1.2), and connecting bolts (1.3), as depicted in an annotated photograph. | ¶21 | col. 4:5-8 |
| wherein the front plate is attached to a right front wing...and a left front wing...wherein the right and left front wings extend horizontally away from the front surface of the front plate; | The front plate is allegedly attached to a right front wing (1.1.1) and a left front wing (1.1.2), with both wings extending horizontally from the front plate. | ¶21 | col. 4:8-12 |
| a straight slot weldment, wherein the straight slot weldment comprises a right side wall and a left side wall and an adjusting bolt guide...further wherein the straight slot weldment is attached to the left front wing and the right front wing; | The Accused Product allegedly includes a straight slot weldment (1.4) comprising right and left side walls (1.4.3, 1.4.4) and an adjusting bolt guide (1.4.5), which is attached to the front wings. | ¶22 | col. 4:12-14, 4:22-24 |
| a plurality of adjusting bolts, wherein at least one adjusting bolt extends through a left wing slot, one of the left wall slots, one of the right wall slots, and a right wing slot; | The Accused Product allegedly has adjusting bolts (1.6) that extend through slots in the left wing, left wall, right wall, and right wing. | ¶23 | col. 4:24-29 |
| a lower bracket element, wherein the lower bracket element comprises a lower backing bracket and a lower front plate; | The Accused Product allegedly comprises a lower bracket element (2.0) with a lower backing bracket (2.1) and a lower front plate (2.2), as shown in a second annotated photograph. | ¶24 | col. 4:39-42 |
| a vertical wall section, wherein the vertical wall section comprises: at least one lateral spanning element...vertical supports...and a plurality of cross spanning members. | The Accused Product allegedly includes a vertical wall section (3.0) with a lateral spacing element (3.1), vertical supports (3.2), and cross spanning members (3.3), as depicted in a third annotated diagram. | ¶25 | col. 5:33-43 |
- Identified Points of Contention: The complaint presents a direct, element-by-element mapping of the Accused Product's features to the language of Claim 1. This raises several potential points of contention for the court.
- Scope Question: The dispute may focus on whether the components of the Accused Product, identified by the complaint's numerical labels, meet the specific structural and functional requirements of the claim terms. For example, does the accused component labeled "adjusting bolt guide" (1.4.5) perform the same function in the same way as the guide described in the patent?
- Technical Question: A central technical question may be whether the adjustment mechanism of the Accused Product operates in the manner described in the ’435 Patent specification—specifically, by using a bolt to change the distance between the "straight slot weldment" and the "front plate" to achieve a calibrated angle adjustment. (’435 Patent, col. 4:30-38).
V. Key Claim Terms for Construction
The Term: "straight slot weldment"
- Context and Importance: This term describes a central component of the claimed invention's unique adjustment mechanism. Practitioners may focus on this term because its definition—and whether it is limited to the specific embodiment shown—will be critical to determining if the accused component with the same name infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself provides a structural definition, stating the weldment "comprises a right side wall and a left side wall and an adjusting bolt guide." (’435 Patent, col. 6:19-22). An argument could be made that any structure meeting this definition falls within the claim's scope.
- Evidence for a Narrower Interpretation: The specification describes a specific configuration where the "straight slot weldment 42 is designed to slide over a front positioning plate 32." (’435 Patent, col. 4:22-24). A defendant may argue that this description, along with the depiction in Figure 2, limits the term to this specific sliding arrangement.
The Term: "substantially orthogonal"
- Context and Importance: This term, appearing in the "vertical wall section" limitation of Claim 1, defines the spatial relationship between the vertical supports and the lateral spanning element. As a term of degree, its scope is inherently ambiguous and will likely require judicial construction.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself suggests some deviation from a perfect 90-degree angle is permitted, which could cover a range of structural configurations.
- Evidence for a Narrower Interpretation: The patent does not provide an explicit definition or numerical range for "substantially orthogonal." A party might argue its meaning should be constrained by the angles depicted in the patent's figures, such as Figure 7, which illustrates the relationship between the vertical supports (57, 59) and lateral spanning elements (50, 55).
VI. Other Allegations
- Indirect Infringement: The complaint alleges "direct infringement" under 35 U.S.C. § 271(a) and does not contain specific factual allegations to support claims of induced or contributory infringement. (Compl. ¶28).
- Willful Infringement: The complaint does not include an explicit allegation of willful infringement or facts supporting pre-suit knowledge of the ’435 Patent by the Defendants.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may turn on the court's answers to the following open questions:
- A core issue will be one of claim construction: Can the term "straight slot weldment", a key component of the patented adjustment mechanism, be interpreted broadly to cover any structure with the recited sub-elements, or is its scope limited by the specification's description of a component that slides over a positioning plate?
- A key evidentiary question will be one of operational equivalence: Does the accused product's adjustment mechanism function in the same way as the patented invention, specifically by using a bolt to precisely control the distance between the weldment and the front plate, or does it achieve angular adjustment through a mechanically distinct method?