DCT
1:25-cv-01515
Watson Guide IP LLC v. 360 Imaging LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Watson Guide IP, LLC (Delaware) and GuidedSMILE, LLC (Ohio)
- Defendant: 360 Imaging, LLC d/b/a 3Sixty (Delaware)
- Plaintiff’s Counsel: Connolly Gallagher LLP; Orbit IP, LLP (Of Counsel)
- Case Identification: 1:25-cv-01515, D. Del., 12/17/2025
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is a Delaware corporation.
- Core Dispute: Plaintiffs allege that Defendant’s 360 Anatomic Guide surgical guide product infringes a patent related to apparatus and methods for installing multi-tooth dental prostheses.
- Technical Context: The technology concerns guided dental surgery, a field focused on using pre-planned physical guides to improve the accuracy, speed, and predictability of dental implant procedures.
- Key Procedural History: The complaint alleges that the Defendant was given notice of the patent-in-suit and its alleged infringement via a letter in October 2022, a fact which may be material to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2017-05-18 | ’016 Patent Priority Date |
| 2021-11-16 | ’016 Patent Issue Date |
| 2022-10-XX | Plaintiffs send notice letter to Defendant |
| 2025-12-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 11,173,016, “Fixation Base and Guides for Dental Prosthesis Installation,” issued November 16, 2021 (the “’016 Patent”).
U.S. Patent No. 11,173,016 - “Fixation Base and Guides for Dental Prosthesis Installation”
The Invention Explained
- Problem Addressed: The patent’s background section states that existing methods and apparatuses for installing multi-tooth dental prostheses anchored by implants are "complex, and require considerable time for completion" (’016 Patent, col. 1:19-23).
- The Patented Solution: The invention provides a system of pre-designed geometric guides to streamline the installation of a prefabricated dental prosthesis, enabling the procedure to be completed in a single session (’016 Patent, col. 1:26-30). The core of the system is a foundational tool called a "fixation base," which attaches directly to the patient's jawbone to provide "geometrically correct reference points for subsequent operations" and other attachable guides, such as drill and abutment guides (’016 Patent, col. 1:35-40).
- Technical Importance: This approach aims to replace more complex, time-consuming installation methods with a predictable, guide-based workflow that improves efficiency in full-arch dental restorations.
Key Claims at a Glance
- The complaint asserts independent claim 6 (’016 Patent, col. 10:7-24).
- The essential elements of independent claim 6 are:
- An apparatus for installing a dental prosthesis to a jaw bone.
- A fixation base for providing an attachment surface for a dental guide.
- The fixation base comprising a generally arcuate base member with a front surface, a rear surface, a horizontal surface, and manually releasable attachment elements.
- The fixation base is configured and dimensioned to fit only in front of the maxillary or mandibular bone structure.
- The fixation base itself does not include any portions which would otherwise extend in back of the maxillary or mandibular bone structure.
- The complaint also makes a general allegation of infringement of "one or more claims" (Compl. ¶1).
III. The Accused Instrumentality
Product Identification
- Defendant 3Sixty’s "360 Anatomic Guide" surgical guide product and associated services (Compl. ¶1, ¶15).
Functionality and Market Context
- The complaint alleges the 360 Anatomic Guide is a guided surgery product (Compl. ¶15). The core of the infringement allegation centers on a component identified as the "fixation base of the 360 Anatomic Guide" (Compl., p. 4).
- The complaint provides visuals depicting this fixation base as an arch-shaped device designed to be attached to a patient's lower jaw (Compl., p. 4). This base is shown to have openings for fasteners and serves as an attachment point for other surgical components, such as a drill guide (Compl., p. 5, 7).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint provides allegations mapping features of the 360 Anatomic Guide to the elements of claim 6. A visual in the complaint depicts the accused fixation base attached to a model of a lower jaw (Compl., p. 4).
| Claim Element (from Independent Claim 6) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a fixation base for providing an attachment surface for a dental guide used during a dental prosthesis installation procedure... | The 360 Anatomic Guide includes a fixation base shown attached to the lower jaw. | ¶16, p. 4 | col. 3:57-4:1 |
| the fixation base further comprising a generally arcuate base member... | The fixation base is described as being "arch-shaped." A visual shows the accused base member's arcuate form (Compl., p. 5). | ¶16, p. 5 | col. 3:66-4:1 |
| with a front surface that includes a plurality of openings through which fasteners can be passed... | The accused guide's front surface allegedly has holes through which fasteners, such as screws, can be placed. | ¶16, p. 5 | col. 4:1-4 |
| a rear surface... | The accused guide's rear surface is shown against the jaw in a provided visual (Compl., p. 6). | ¶16, p. 6 | col. 4:4-7 |
| a horizontal surface... | A horizontal surface with square openings for fasteners is identified on the accused guide. | ¶16, p. 6 | col. 4:7-11 |
| manually releasable attachment elements for attachment of a dental guide used during a prosthesis installation to the fixation base... | The accused guide allegedly has manually releasable elements used to attach a drill guide. A visual shows these elements in use (Compl., p. 7). | ¶16, p. 7 | col. 3:28-31 |
| wherein the fixation base is configured and dimensioned to fit only in front of the maxillary or mandibular bone structure of a patient and which fixation base itself does not include any portions which would otherwise extend in back of the maxillary or mandibular bone structure of a patient. | The 360 Anatomic Guide fixation base is alleged to fit only in front of the bone, as depicted in a complaint visual (Compl., p. 7). | ¶16, p. 7 | col. 10:16-24 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the negative limitation requiring the fixation base to "fit only in front of the... bone structure" and not "extend in back." The resolution of the case may depend on how the court defines the anatomical boundaries of "in front of" versus "in back of" the jawbone and whether the accused product's geometry, when actually installed, adheres to this limitation.
- Technical Questions: What evidence does the complaint provide that the attachment elements for the drill guide are "manually releasable" as required by the claim? The complaint's visual shows the elements in use, but does not detail the mechanism of release, which could become a point of factual dispute.
V. Key Claim Terms for Construction
The Term
- "configured and dimensioned to fit only in front of the maxillary or mandibular bone structure... and which fixation base itself does not include any portions which would otherwise extend in back of the maxillary or mandibular bone structure"
Context and Importance
- This negative limitation appears to be a defining feature of the claimed apparatus, distinguishing it from devices that might wrap around or otherwise engage the posterior aspects of the jaw. Infringement will turn on whether the accused product's physical shape and placement fall within this strictly defined geometric scope.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: Parties arguing for a broader view may contend that "in front of" should be interpreted functionally, referring to the primary anterior placement, and that incidental or minor contact with lateral aspects of the jaw does not constitute "extend[ing] in back of" the bone structure.
- Evidence for a Narrower Interpretation: The specification emphasizes that a key benefit of the fixation base's design is minimizing its mass to allow the practitioner to "view the work site more effectively than would be the case if fixation base 100 were larger, thereby obscuring the work site" (’016 Patent, col. 3:51-55). This stated purpose could support a narrower construction that strictly limits the device to the anterior region to preserve visibility. The claim language itself, using "only in front of" and "does not include any portions which would otherwise extend in back," suggests a sharp, exclusionary boundary.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that 3Sixty induces infringement by causing others to use the 360 Anatomic Guide, supported by the existence of "advertisements, instruction manuals and videos" (Compl. ¶17, ¶21).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringement "despite knowing of the ’016 patent and the infringement" (Compl. ¶18). This knowledge is alleged to have been established by a notice letter sent in October 2022 (Compl. ¶13).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: How will the court construe the negative limitation requiring the fixation base to be "configured and dimensioned to fit only in front of" the jawbone, and does the physical geometry of the accused 360 Anatomic Guide fall within that precise boundary?
- A second key question will be evidentiary: Can Plaintiffs produce sufficient evidence to demonstrate that the accused product meets every claim limitation, particularly the requirements that its attachment elements are "manually releasable" and that the device does not "extend in back of" the patient's bone structure during actual use?