DCT
3:25-cv-01596
A Stucki Co v. Transquip USA Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: A. Stucki Company (Delaware)
- Defendant: TransQuip U.S.A. Inc. (Florida)
- Plaintiff’s Counsel: Buchanan Ingersoll & Rooney PC
- Case Identification: 3:25-cv-01596, M.D. Fla., 12/23/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains its principal place of business in Jacksonville, Florida, within the Middle District of Florida.
- Core Dispute: Plaintiff alleges that Defendant’s manway nozzle gaskets for railroad cars infringe a patent related to gasket sealing technology.
- Technical Context: The technology concerns resilient gaskets used to create a fluid-tight seal for manway openings on railroad tank cars, a critical component for safe transport of materials.
- Key Procedural History: The complaint details a pre-suit correspondence history initiated by a notice letter from Plaintiff to Defendant on October 2, 2025. Defendant replied on November 10, 2025, denying infringement on the basis that its product had "Differentiating Dimensions" from the patented product. This exchange is cited as the basis for Plaintiff's willful infringement allegations.
Case Timeline
| Date | Event |
|---|---|
| 2009-11-11 | ’840 Patent Priority Date |
| 2014-02-25 | ’840 Patent Issue Date |
| 2025-10-02 | Plaintiff sends initial notice letter to Defendant |
| 2025-10-31 | Plaintiff sends follow-up letter to Defendant |
| 2025-11-10 | Defendant replies, denying infringement |
| 2025-11-17 | Plaintiff sends further letter asserting infringement is willful |
| 2025-12-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,656,840 - "Manway Gasket"
- Patent Identification: U.S. Patent No. 8,656,840, "Manway Gasket," issued February 25, 2014 (’840 Patent).
The Invention Explained
- Problem Addressed: The patent’s background section describes the difficulty of achieving an adequate fluid-tight seal for railroad car manway openings due to the uneven clamping force imparted by bolts around the cover's perimeter and irregularities on the rigid sealing surfaces (’840 Patent, col. 1:30-49). Force is maximized near the bolts and minimized midway between them, compromising the seal in those weaker areas (’840 Patent, col. 1:47-49).
- The Patented Solution: The invention is a gasket that employs concentric, upstanding annular ribs, or "chevrons," on both its upper and lower sealing surfaces (’840 Patent, Abstract). These deformable chevrons are designed to seal against the corresponding surfaces of the manway nozzle and cover, accommodating surface irregularities and ensuring a more uniform, fluid-tight seal even with uneven clamping pressure (’840 Patent, col. 2:60-65; Fig. 4).
- Technical Importance: The use of deformable chevrons on both sealing surfaces enhances sealing capability compared to conventional flat gaskets, which is critical for the safe containment of materials in railroad tank cars (’840 Patent, col. 1:40-43, col. 6:8-13).
Key Claims at a Glance
- The complaint asserts independent claim 1 of the ’840 Patent (Compl. ¶26).
- Essential elements of Claim 1 include:
- An annular ring member having a generally planar annular body portion defining an upper annular cover sealing surface and a lower annular nozzle body sealing surface;
- The upper sealing surface including at least one annular upstanding chevron configured to engage the cover's contact surface; and
- The lower sealing surface including at least one annular lower chevron extending in a generally opposite direction and configured to engage the nozzle's contact surface.
- The complaint does not explicitly reserve the right to assert dependent claims, but infringement allegations are made as to "one or more claims" (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- Defendant TransQuip’s "manway nozzle gaskets" (Compl. ¶13). The complaint alleges these products are offered for sale on Defendant's website and advertised in marketing brochures (Compl. ¶16-17).
Functionality and Market Context
- Based on the complaint, the accused products are gaskets designed for sealing the manway nozzle of a containment vessel, such as a railroad car, against an associated cover (Compl. ¶27).
- The complaint alleges the accused gaskets possess the key structural features of the patented invention, including an annular ring member with upper and lower sealing surfaces, and at least one upstanding chevron on each of those surfaces (Compl. ¶28-29).
- Plaintiff alleges the accused products are marketed in the same markets and are in direct competition with Plaintiff's own gaskets (Compl. ¶13).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’840 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A gasket for sealing between the manway nozzle of a containment vessel and an associated cover... | The accused product is a gasket for sealing between a manway nozzle of a containment vessel and an associated cover. | ¶27 | col. 7:34-39 |
| an annular ring member having a generally planar annular body portion defining an upper annular cover sealing surface and a lower annular nozzle body sealing surface, | The accused gasket includes an annular ring member with a generally planar annular body portion defining upper and lower sealing surfaces. | ¶28 | col. 4:7-10 |
| said upper annular cover sealing surface including at least one annular upstanding chevron extending therefrom and configured to engage the lower contact surface of the cover... | The upper sealing surface of the accused gasket includes at least one annular upstanding chevron configured to engage the cover's contact surface. | ¶29 | col. 4:46-52 |
| ...and said lower annular nozzle body sealing surface including at least one annular lower chevron extending therefrom in a direction generally opposite said upstanding chevron and configured to engage the upper contact surface of the nozzle. | The lower sealing surface of the accused gasket includes at least one annular lower chevron extending oppositely to the upstanding chevron and configured to engage the nozzle's contact surface. | ¶29 | col. 4:46-52 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the definition of "chevron." Defendant’s pre-suit denial of infringement based on "Differentiating Dimensions" (Compl. ¶21) suggests it will argue that the sealing structures on its gaskets do not meet the structural or dimensional properties required by this claim term.
- Technical Questions: The case raises the factual question of whether the physical structure of the accused gaskets includes features that perform in the manner claimed. The court will need to examine what evidence exists to show that the accused product's sealing ribs are structurally and functionally equivalent to the claimed "chevrons," particularly in light of Defendant's assertion that its product's dimensions differ.
V. Key Claim Terms for Construction
- The Term: "chevron"
- Context and Importance: This term describes the core inventive feature of the gasket—the deformable, V-shaped ribs that create the seal. The definition of "chevron" will be critical, as Defendant’s "Differentiating Dimensions" defense (Compl. ¶21) appears to be a direct challenge to whether its product's sealing ribs fall within the scope of this term. Practitioners may focus on this term because its construction could be dispositive of infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term is not limited to a purely triangular shape, stating that "the cross-sectional shape could be semi-circular, or other suitable shape" (’840 Patent, col. 5:2-3). Plaintiff may argue this supports a construction covering a variety of protruding, deformable sealing rib structures.
- Evidence for a Narrower Interpretation: The primary embodiment described and illustrated in the patent has a "generally triangular cross section" (’840 Patent, col. 4:51-52; Fig. 4). Defendant may argue that the term should be construed more narrowly to reflect this specific disclosed shape, potentially excluding its product.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement (Compl. ¶44-46). Inducement is alleged based on Defendant providing marketing and instructions that lead users to infringe (Compl. ¶45). Contributory infringement is alleged on the basis that the gaskets are especially made for an infringing use and are not a staple article of commerce suitable for substantial non-infringing use (Compl. ¶46).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged pre-suit knowledge of the ’840 Patent, stemming from Plaintiff's notice letter dated October 2, 2025 (Compl. ¶35). The complaint alleges that Defendant continued its infringing activities despite this notice and an objectively high likelihood that its actions constituted infringement of a valid patent (Compl. ¶37-38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "chevron," which is exemplified in the patent with a specific triangular geometry, be construed to read on the sealing structures of the accused gasket, which Defendant asserts possess "Differentiating Dimensions"?
- A key question regarding willfulness will be one of objective recklessness: did Defendant’s pre-suit "Differentiating Dimensions" defense provide it with a good-faith, reasonable basis for believing it did not infringe, or was its continued conduct after receiving notice objectively reckless in view of the patent's claims?