DCT
2:21-cv-00450
E Z Dock Inc v. Snap Dock LLC
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: E-Z-Dock, Inc. (Minnesota)
- Defendant: Snap Dock, LLC (Indiana) and Golden Manufacturing, Inc. d/b/a Golden Boat Lifts (Florida)
- Plaintiff’s Counsel: Akerman LLP
- Case Identification: 2:21-cv-00450, M.D. Fla., 08/10/2021
- Venue Allegations: Plaintiff alleges venue is proper because Defendants regularly conduct business in the district, have committed acts of infringement in the district, and are subject to personal jurisdiction there.
- Core Dispute: Plaintiff alleges that Defendants’ floating watercraft port products infringe a patent related to modular floating watercraft port assemblies.
- Technical Context: The technology relates to floating, drive-on docks for personal watercraft, a market segment focused on providing convenient dry-docking solutions for consumers.
- Key Procedural History: The complaint alleges that Defendant Golden Boat Lifts is a former exclusive distributor of Plaintiff’s products, a fact that may be relevant to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2007-08-16 | U.S. Patent No. 7,918,178 Priority Date |
| 2011-04-05 | U.S. Patent No. 7,918,178 Issue Date |
| 2021-03-08 | Alleged date of Snap Dock's knowledge of infringement |
| 2021-06-18 | Alleged date of Golden Boat Lifts' knowledge of infringement |
| 2021-08-10 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,918,178 - "Modular Floating Watercraft Port Assembly"
- Patent Identification: U.S. Patent No. 7918178 (“Modular Floating Watercraft Port Assembly”), issued April 5, 2011 (the “’178 Patent”) (Compl. ¶¶47, 49).
The Invention Explained
- Problem Addressed: The patent’s background section notes that the ability to customize the port and lift area of a marina is limited by the design of available watercraft ports, creating a need for a modular system that allows for greater design versatility (’178 Patent, col. 1:23-34).
- The Patented Solution: The invention is a modular floating watercraft port system comprising an “entry member,” an “extension member,” and a removable “bow stop” (or bulkhead) (’178 Patent, Abstract). These components are designed to be connected in various configurations—such as in series to accommodate longer watercraft or side-by-side to create wider platforms—to allow for customized port layouts (’178 Patent, col. 2:1-4; Fig. 27A). The modularity is enabled by the distinct designs of the entry member, which has a defined entrance ramp, and the extension member, which is open at both ends to allow for pass-through connection.
- Technical Importance: This modular approach provided marina operators with increased flexibility to configure docking areas to accommodate different watercraft sizes and marina footprints (’178 Patent, col. 1:30-34).
Key Claims at a Glance
- The complaint asserts at least independent claim 29 of the ’178 Patent (Compl. ¶¶53, 88).
- The essential elements of independent claim 29 include:
- A floating watercraft port comprising a “port member” with various surfaces and a “cradle” defined by a pair of opposed inwardly sloping walls.
- A plurality of roller sockets and rollers positioned along the cradle walls.
- A “bow stop” that is “separate from and mountable to” the port member at its front.
- The bow stop has a bottom surface with at least a portion that is “shaped complementarily to said port cradle.”
- When mounted, the bow stop “closes said opening to said cradle at the front of said port member.”
- The complaint states that Defendants infringe “one or more claims” of the patent, reserving the right to assert others (Compl. ¶87).
III. The Accused Instrumentality
Product Identification
- The accused product is the “Snap Port” (Compl. ¶51).
Functionality and Market Context
- The complaint describes the Snap Port as a floating watercraft port with a “2-piece design” (Compl. ¶¶54, 57). The product consists of a main component, which the complaint calls the “First Piece Port Member,” and a separate bow stop, referred to as the “Second Piece Bow Stop,” which is mountable to the front of the first piece (Compl. ¶¶58, 66). An image provided in the complaint shows the two-piece structure of the accused product (Compl. ¶55, p. 13). The complaint alleges Defendant Golden Boat Lifts is the lead U.S. distributor for the Snap Port (Compl. ¶78).
IV. Analysis of Infringement Allegations
The complaint’s infringement allegations are based on a literal reading of claim 29. The allegations are supported by numerous annotated photographs of the accused Snap Port product.
U.S. Patent No. 7,918,178 Infringement Allegations
| Claim Element (from Independent Claim 29) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a floating watercraft port comprising a port member having an upper surface...a cradle being formed in at least a part of said upper surface...said cradle being defined by a pair of opposed inwardly sloping walls | The accused product is a floating watercraft port, and its first piece acts as the port member, which includes a cradle formed by inwardly sloping walls (pictured at Compl. ¶63, p. 16) | ¶¶57, 59, 63 | col. 4:10-20 |
| a plurality of roller sockets positioned along said cradle walls and rollers received in said roller sockets | The first piece of the accused product has multiple roller sockets positioned along the cradle walls, with rollers received within them (pictured at Compl. ¶64, p. 17) | ¶64 | col. 4:21-25 |
| a bow stop which is separate from and mountable to said port member at the front of said port member | The accused product includes a second piece (the bow stop) that is separate from and can be mounted to the front of the first piece (the port member) using a coupler (pictured at Compl. ¶70, p. 21) | ¶¶58, 66, 70 | col. 8:25-30 |
| at least a portion of said bottom surface of said bow stop being shaped complementarily to said port cradle | A portion of the bottom surface of the accused product's second piece is allegedly shaped to complement the cradle of the first piece (pictured at Compl. ¶68, p. 19) | ¶68 | col. 9:4-14 |
| such that when said bow stop is mounted to said port member, said bow stop closes said opening to said cradle at the front of said port member | When the second piece is mounted to the first piece, it closes the opening to the cradle at the front, as depicted in an annotated photograph (Compl. ¶69, p. 20) | ¶69 | col. 9:15-23 |
Identified Points of Contention
- Scope Questions: The complaint's theory appears to equate the claimed "port member" with the "first piece" of the accused product. A potential point of contention may be whether the accused "first piece" embodies all structural limitations of the "port member" as understood from the patent's specification, or if there is a definitional mismatch.
- Technical Questions: The allegations rely heavily on photographic evidence. A central question for the court will be whether the accused product's components and their interaction—particularly the "complementary" fit between the bow stop and the cradle—function in a manner that corresponds to the specific requirements of the claim language when examined beyond surface-level visual comparison.
V. Key Claim Terms for Construction
The Term: "a port member"
- Context and Importance: The claim structure requires a single "port member" to which a "separate" bow stop is mounted. The resolution of the case may depend on whether the accused "First Piece" component constitutes the entirety of the claimed "port member."
- Evidence for a Broader Interpretation: The specification describes the system using terms like "entry member" and "extension member" (’178 Patent, col. 1:40-41). Plaintiff may argue that "port member" is a generic term intended to encompass such components, which possess a cradle and are adapted to receive a bow stop.
- Evidence for a Narrower Interpretation: The defense may argue that the term "port member" must be construed to include all features of the specific "entry member" embodiment (e.g., element 20), including its specific ramp section and dimensions, potentially arguing the accused product's first piece differs in a material way.
The Term: "shaped complementarily to said port cradle"
- Context and Importance: This term defines the required fit between the bow stop's bottom surface and the port member's cradle. Practitioners may focus on this term because the degree of "fit" required could be a dispositive issue.
- Evidence for a Broader Interpretation: Plaintiff may argue the term requires a functional, rather than a perfect, correspondence, allowing the bow stop to nest securely and close the cradle's front opening, as is allegedly shown in the complaint's photographs (Compl. ¶69).
- Evidence for a Narrower Interpretation: The defense could argue that the term implies a precise geometric match between the surfaces. Language in the specification describing the bottom surface of the bow stop being shaped "substantially complementarily" to the port upper surface could be cited to argue for a close-tolerance standard (’178 Patent, col. 8:9-11).
VI. Other Allegations
Willful Infringement
- The complaint alleges that Defendants' infringement has been willful based on pre-suit knowledge of the ’178 Patent (Compl. ¶79). Specific dates of alleged knowledge are provided for Snap Dock (March 8, 2021) and Golden Boat Lifts (June 18, 2021) (Compl. ¶¶89, 90). The complaint further alleges that Defendant Golden Boat Lifts is a "former exclusive distributor of EZ Dock products," which may be used to support the claim of prior knowledge of Plaintiff's technology and intellectual property (Compl. ¶80).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: How will the court define the scope of the term "port member"? The case may turn on whether the accused product's primary component meets the full definition of this term as established by the patent's specification and prosecution history.
- A key evidentiary question will be one of technical identity: The complaint presents a strong visual case for literal infringement. The central factual dispute will likely be whether the accused Snap Port, upon technical inspection, possesses the specific structural and functional characteristics required by Claim 29, particularly the precise nature of the "complementary" fit between its two main components.
- Finally, a key issue for damages will be willfulness: Given the allegation that a defendant is a "former exclusive distributor" of the plaintiff's products, the court will likely examine the extent of Defendants' pre-suit knowledge and conduct to determine if any infringement was egregious enough to warrant enhanced damages.