DCT
3:24-cv-00798
Lensdigital LLC v. Rife
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: LensDigital, LLC (New Jersey)
- Defendant: Jason Earl Rife (Florida); JER Custom Designs, Inc. (Florida); Thunder Laser USA, LLC (Texas)
- Plaintiff’s Counsel: Bochner PLLC
- Case Identification: 3:24-cv-00798, M.D. Fla., 11/05/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Middle District of Florida because the defendants reside in, are subject to personal jurisdiction in, and committed tortious acts in the district.
- Core Dispute: Plaintiff alleges that Defendants’ "Talon Chuck Rotary" product infringes a patent on an attachment apparatus for laser engraving, and further seeks declaratory judgments of non-infringement and invalidity of several of Defendants' own patents.
- Technical Context: The lawsuit concerns rotary attachments for laser engraving machines, a specialized tool segment that enables the engraving of cylindrical or non-flat objects like tumblers and glassware.
- Key Procedural History: This Fourth Amended Complaint follows a history of public accusations of patent infringement made by Defendants against Plaintiff via social media and direct correspondence with Plaintiff's customers and distributors. The complaint also references Defendants' prior assertions of utility and design patents against Plaintiff's products, which Plaintiff now seeks to have declared non-infringed and/or invalid.
Case Timeline
| Date | Event |
|---|---|
| 2018-09-18 | Plaintiff LensDigital (LD) unveils its "PiBurn V1" rotary attachment. |
| 2020-06-15 | Defendant Rife files application for "640 Design Patent"; earliest priority date for Defendants' "572", "830", and "395" utility patents. |
| 2022-03-13 | Plaintiff unveils its "PiBurn V4" product. |
| 2023-01-12 | Plaintiff's U.S. Patent No. 12,194,544 ("544 Patent") earliest priority date. |
| 2023-05-09 | Defendant's U.S. Design Patent No. D985,640 issues. |
| 2024-08-23 | Plaintiff unveils its "PiBurn V" product. |
| 2024-09-17 | Defendant's U.S. Patent No. 12,090,572 issues. |
| 2025-01-07 | Defendant's U.S. Patent No. 12,186,830 issues. |
| 2025-01-10 | Defendants allegedly send letters to Plaintiff's customers regarding patent infringement. |
| 2025-01-14 | Plaintiff's "544 Patent" issues. |
| 2025-03-11 | Defendant's U.S. Patent No. 12,246,395 issues. |
| 2025-11-05 | Plaintiff files Fourth Amended Complaint. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,194,544 - ATTACHMENT APPARATUS FOR LASER ENGRAVING
- Patent Identification: U.S. Patent No. 12,194,544, entitled “ATTACHMENT APPARATUS FOR LASER ENGRAVING,” issued on January 14, 2025.
The Invention Explained
- Problem Addressed: The patent's background describes limitations of conventional rotary attachments for laser engravers. It notes that existing "chuck-style" attachments can be cumbersome, poorly suited for holding delicate articles like glassware, and often lack the tilting capabilities necessary for engraving tapered objects. The patent also identifies difficulties in properly aligning an object when clamping it from an inside surface, which traditionally requires additional tools (’544 Patent, col. 1:46-col. 2:5).
- The Patented Solution: The invention is a versatile chuck-style rotary attachment featuring a plurality of self-centering jaw bases that move within channels in a main housing, actuated by a manually-operated scroll wheel. The design allows for various interchangeable jaws (e.g., rubber fingers, L-jaws) to be attached, providing adaptability for different object shapes and materials. This configuration aims to provide a stable, precise, and easily adjustable method for holding and rotating objects during laser engraving (’544 Patent, Abstract; col. 2:24-30).
- Technical Importance: The technology seeks to provide a more adaptable and user-friendly solution for the growing market of personalized laser engraving on consumer products, which often involves objects of varying sizes, shapes, and fragility (Compl. ¶2; ’544 Patent, col. 1:35-44).
Key Claims at a Glance
- The complaint asserts infringement of independent claim 1 and dependent claims 3-4, 6-7, 10-11, 18-19, and 22-23 (Compl. ¶88).
- The essential elements of independent claim 1 include:
- An attachment apparatus with a chuck housing defining channels.
- A plurality of self-centering jaw bases within the channels, each having at least one jaw base hole.
- The channels are accessible from a circumferential perimeter, allowing the jaw bases to extend past it.
- Each jaw base includes one or more "circular indicators."
- Each channel includes one or more "ridges," and each jaw base has an "I-shaped cross section" to interface with the ridges.
- A scroll wheel in mechanical communication with the jaw bases, featuring protrusions that extend beyond the chuck housing's circumference.
- A plurality of interchangeable jaws, each with a "jaws protuberance" configured to be received by the jaw base hole.
III. The Accused Instrumentality
Product Identification
- The accused products are the "Talon Chuck Rotary" manufactured and sold by Defendants JER and Thunder (Compl. ¶¶ 11, 87).
Functionality and Market Context
- The Talon Chuck Rotary is an attachment for laser engraving machines designed to hold and rotate objects. The complaint alleges it incorporates a chuck housing, a scroll wheel for actuating self-centering jaws, and interchangeable jaws for gripping various items (Compl. ¶¶ 89-92). An annotated image in the complaint purports to show these features on the accused product, such as a "scroll wheel in mechanical communication with the plurality of self-centering jaws bases" and an "Interchangeable jaw" (Compl. Fig. 11). The complaint positions the product as a direct competitor to Plaintiff's own "Chuck Grip" product (Compl. ¶178).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint alleges that the Talon Chuck Rotary infringes at least Claim 1 of the '544 Patent. The core allegations are summarized below.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a chuck housing defining a plurality of channels | The accused product includes a chuck housing that defines multiple channels for jaw bases. | ¶90 | col. 6:58-62 |
| a plurality of self-centering jaws bases disposed within the plurality of channels | The accused product has multiple self-centering jaw bases located within the channels. | ¶90 | col. 6:58-62 |
| wherein the plurality of self-centering jaws bases comprise at least one jaws base hole | Each jaw base in the accused product is alleged to have at least one hole for attaching interchangeable jaws. | ¶90, Fig. 11 | col. 7:7-9 |
| wherein each of the plurality of channels is accessible through a circumferential perimeter of the chuck housing enabling at least a portion of the self-centering jaws bases to extend past the circumferential perimeter | The accused product's channels are open at the housing's perimeter, allowing the jaw bases to extend outward. | ¶90, Fig. 11 | col. 3:16-18 |
| wherein each of the plurality of self-centering jaws bases includes one or more circular indicators | The accused product's jaw bases are alleged to possess circular indicators. | ¶90, Fig. 11 | col. 6:64-67 |
| wherein each of the channels includes one or more ridges disposed along a length of each channel...and wherein each of the plurality of self-centering jaws bases has an I-shaped cross section configured to interface with the one or more ridges | The accused product allegedly has channels with ridges that interface with jaw bases having an I-shaped cross-section. | ¶90, Fig. 11 | col. 3:24 |
| a scroll wheel in mechanical communication with the plurality of self-centering jaws bases | The accused product uses a scroll wheel to move the self-centering jaw bases. | ¶91, Fig. 11 | col. 6:5-10 |
| wherein the scroll wheel comprises a plurality of protrusions extending radially...beyond the circumference of the chuck housing | The accused product's scroll wheel has protrusions extending past the housing for manual operation. | ¶91, Fig. 11 | col. 6:21-25 |
| a plurality of interchangeable jaws, each...comprising a jaws protuberance configured to be received by the at least one jaws base hole | The accused product uses interchangeable jaws, such as the L-jaws shown in a product image, which attach to the jaw bases. | ¶92, ¶116, Fig. 12 | col. 8:20-30 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the meaning of specific terms used in Claim 1. For instance, questions may be raised as to whether a simple hole, as depicted in the complaint's annotation of the accused product, meets the definition of a "circular indicator" as claimed in the patent.
- Technical Questions: The complaint alleges the accused product's channels include "ridges" that interface with an "I-shaped cross section" on the jaw bases. A key factual question will be whether the physical construction of the accused Talon Chuck Rotary actually incorporates these specific, interlocking geometric features as required by the claim, or if it uses a different mechanical interface.
V. Key Claim Terms for Construction
The Term: "circular indicators"
Context and Importance: This term appears in Claim 1, and the complaint explicitly identifies a feature on the accused product as meeting this limitation (Compl. ¶90, Fig. 11). Its construction is critical because if the feature on the accused product does not fall within the term's scope, a finding of non-infringement may follow. Practitioners may focus on this term because the patent specification does not provide an explicit definition, potentially creating ambiguity.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the term should be given its plain and ordinary meaning, and that any circular marking or feature on the jaw base, such as the "channel hole 401" depicted in the patent's figures, qualifies (’544 Patent, Fig. 3).
- Evidence for a Narrower Interpretation: Defendant may argue that the term implies a feature with a specific indicative or marking purpose beyond a simple structural hole, a purpose not described in the specification. They may also contend the term is indefinite for failing to provide objective boundaries for what constitutes an "indicator."
The Term: "ridges disposed along a length of each channel"
Context and Importance: This limitation defines the crucial mechanical interface that guides the self-centering jaws. The infringement analysis depends on whether the accused product's channels contain structures that can be properly defined as "ridges."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the internal surfaces of the channel that mate with the claimed "I-shaped cross section" of the jaw base inherently constitute "ridges" necessary for the claimed function (’544 Patent, col. 3:24).
- Evidence for a Narrower Interpretation: Defendant may argue that "ridges" require distinct, protruding structures, not merely the inner walls of a slot or groove. They may point to the lack of detailed description or depiction of such distinct ridges within the channels in the patent's specification as evidence that the term requires a narrow construction, or that the claim lacks adequate written description support.
VI. Other Allegations
- Willful Infringement: The complaint alleges willful infringement of the '544 Patent. The basis for this allegation is that Defendant JER's counsel contacted Plaintiff's counsel on January 13, 2025—the day before the '544 patent issued—regarding a reference believed to be relevant to the patentability of the pending claims. This is alleged to establish that Defendants had actual knowledge of the patent's impending issuance and its subject matter, yet continued their allegedly infringing conduct post-issuance (Compl. ¶¶ 93-94, 123).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can terms like "circular indicators" and "ridges," which lack explicit definition in the patent's written description, be construed broadly enough to read on the features of the accused Talon Chuck Rotary, or does the lack of specificity render the claims narrow or potentially invalid?
- A key evidentiary question will be one of technical and mechanical correspondence: beyond visual similarity, does discovery and expert analysis show that the internal components of the Talon Chuck Rotary—specifically the jaw base and channel interface—actually operate using the "I-shaped cross section" and "ridges" mechanism as claimed, or is there a fundamental mismatch in their technical operation?