6:19-cv-02001
Armstrong Aluminum Inc v. Benada Aluminum Products LLC
I. Executive Summary and Procedural Information
Parties & Counsel:
- Plaintiff: Armstrong Aluminum Inc. (Florida)
- Defendant: Benada Aluminum Products, LLC (Florida); Eagle Metal Distributors, Inc. (Florida); John Doe (Florida)
- Plaintiff’s Counsel: Watson LLP
Case Identification: 6:19-cv-02001, M.D. Fla., 01/03/2020
Venue Allegations: Venue is alleged to be proper in the Middle District of Florida as a substantial portion of the events giving rise to the action, including the manufacture, use, and sale of the accused products, occurred in Orange County, Florida.
Core Dispute: Plaintiff alleges that Defendants manufacture, distribute, and install a splashguard system for screen enclosures that infringes a patent related to an improved method for connecting a screen to a gutter system.
Technical Context: The technology relates to aluminum extrusions used in residential screen enclosures, specifically a splashguard that manages water runoff from a roof gutter while providing structural support for the enclosure.
Key Procedural History: The complaint alleges a unique business history wherein Plaintiff contracted with a now-defunct company, Florida Extruders, to manufacture the patented splashguard using a proprietary extrusion die. Defendant Benada allegedly acquired this specific die after Florida Extruders' bankruptcy and began using it to produce and sell infringing products to distributors like Defendant Eagle, who in turn sold them to installers.
Case Timeline
| Date | Event |
|---|---|
| 2005-10-17 | ’636 Patent Priority Date |
| 2009-11-17 | ’636 Patent Issue Date |
| 2017-11-09 | Plaintiff allegedly becomes aware of infringing use |
| 2020-01-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,617,636 - Splashguard system and method of installation for a screened area, issued November 17, 2009
The Invention Explained
Problem Addressed: The patent’s background section describes the technical challenge of attaching framed screen enclosures to a building’s gutter system. Prior methods often required excessive, aesthetically unpleasing framing for support and failed to prevent water from a building's roof from splashing off the gutter and into the screened area (Compl. ¶¶18, 24; ’636 Patent, col. 1:37-43).
The Patented Solution: The invention is a splashguard system that integrates with a gutter to both deflect water and provide structural support for the screen enclosure. The system features a specially designed splashguard that attaches to the front of the gutter and has a top channel to secure the screen material. This splashguard works in combination with a gutter bracket positioned inside the gutter and a splashguard bracket, creating a reinforced structure that eliminates the need for additional ground supports (’636 Patent, Abstract; col. 2:4-15).
Technical Importance: This integrated approach sought to provide a more elegant and structurally sound method for installing screen enclosures, improving both functionality and aesthetics compared to prior art methods (Compl. ¶18).
Key Claims at a Glance
The complaint asserts independent claims 1, 12, 22, and 28 (Compl. ¶33).
Independent Claim 1 (System):
- A building structure with a roof surface and support structure
- A gutter for collecting water
- A framed enclosure with an upright support
- Screen material secured with a spline
- A gutter bracket positioned entirely within the gutter's trough, with specific flanges for attachment
- A "generally planar splashguard" extending along the gutter's front side, featuring a bottom flange with a rib that mates with a channel in the gutter's top flange, and a top flange with a channel to receive the screen spline
Independent Claim 12 (System):
- A gutter
- A gutter bracket positioned entirely within the gutter's trough
- A splashguard extending along the gutter's front side with a bottom edge secured to the gutter and a top flange with a channel for a spline
- A splashguard bracket with one end secured to the gutter bracket's arm member and the other end secured to the splashguard
The complaint does not explicitly reserve the right to assert dependent claims, though this is standard practice.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are splashguard systems, and specifically the splashguard component thereof, allegedly manufactured by Benada, distributed by Eagle, and installed by John Doe (Compl. ¶¶31, 49-51).
Functionality and Market Context
The accused product is an aluminum extrusion that functions as a splashguard for screen enclosures, preventing water from a roof gutter from entering the screened area (Compl. ¶18). The complaint alleges the accused splashguard is not merely similar to the patented invention but is manufactured from the specific, proprietary extrusion die that Plaintiff had created to produce its own commercial product (Compl. ¶¶27-28, 46). This forms a central pillar of the infringement allegations.
IV. Analysis of Infringement Allegations
The complaint alleges that the installation of the accused splashguard system by Defendant John Doe meets all the limitations of the asserted claims (Compl. ¶¶34-38). The complaint provides a cross-sectional diagram illustrating the claimed invention's components, including the splashguard (70), gutter (24), and gutter bracket (52) in their assembled relationship (Compl. ¶23).
’636 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a building structure having a roof surface and a support structure; a gutter...; a framed enclosure...; screen material... | The accused system was installed on a building project with these conventional components (Compl. ¶34(a-d)). | ¶34 | col. 5:1-8 |
| a gutter bracket positioned entirely within the trough... | The installed system allegedly included a gutter bracket (Compl. ¶34(e)). | ¶34 | col. 5:11-20 |
| a generally planar splashguard extending along the front side of the gutter... | The installed system allegedly included a planar splashguard (Compl. ¶34(f)). | ¶34 | col. 5:21-32 |
| the splash guard having a bottom flange... the bottom flange having a rib extending therefrom, wherein the rib mates with the channel in the top flange of the front side top edge of the gutter... | The complaint alleges infringement "in the manner taught by Claim 1," which implies the presence of this mating structure. | ¶34 | col. 5:22-28 |
- Identified Points of Contention:
- Evidentiary Questions: A primary factual dispute may center on proving that the accused splashguard was manufactured using Plaintiff's specific, allegedly proprietary extrusion die. The complaint’s allegation of "tell-tale imperfections" suggests this will be a focus of discovery (Compl. ¶47).
- Scope Questions: The infringement analysis will likely question whether the complete accused system, as installed, contains every element of the asserted system claims. While the splashguard component itself may be identical, the defense could argue that the gutter brackets or splashguard brackets used in the installation do not meet the specific structural and relational limitations recited in the claims. The complaint’s infringement allegations are conclusory and do not detail how each component of the accused system maps to the claim limitations (Compl. ¶¶34-37).
V. Key Claim Terms for Construction
The Term: "gutter bracket positioned entirely within the trough" (Claim 1)
Context and Importance: This limitation defines the location and nature of a key structural component. The infringement analysis will depend on whether the bracket used in the accused installations is configured to sit "entirely within" the gutter, as opposed to being partially external or having a different mounting configuration. Practitioners may focus on this term to distinguish the patented system from other methods of reinforcing a gutter-enclosure connection.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify a particular shape for the bracket, only its position. This may support an interpretation covering any bracket form factor as long as it resides fully within the gutter trough.
- Evidence for a Narrower Interpretation: The specification and figures illustrate a specific embodiment of the gutter bracket (52) with an arm member (54), flanges (60, 64), and a brace member (66) (’636 Patent, Fig. 2; col. 3:7-25). A defendant may argue that the term should be limited to a bracket with these structural features.
The Term: "a generally planar splashguard" (Claim 1)
Context and Importance: The term "planar" defines the basic shape of the main infringing component. How broadly "generally planar" is construed will be critical. The accused product is an extrusion, which has a constant cross-section but is not a simple flat plane.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "generally planar" suggests the overall form is flat, allowing for minor contours, flanges, or ribs without departing from the claim scope. The patent describes the splashguard as "extending along the front side of the gutter," reinforcing the idea of a long, flat-like profile (’636 Patent, col. 3:26-28).
- Evidence for a Narrower Interpretation: The figures show a splashguard (70) with a specific, non-flat cross-section, including a bottom flange (72), a top flange (78), and a main body (’636 Patent, Fig. 2). A defendant may argue that "generally planar" must be read in light of this detailed embodiment and its functional features, effectively requiring these specific contours.
VI. Other Allegations
Indirect Infringement: The complaint asserts contributory infringement (§ 271(c)) against Defendants Benada and Eagle (Compl. ¶¶44-57). It alleges they knew the splashguard they manufactured and sold was a material component of the patented system, was specially adapted for this infringing use, and was not a staple article of commerce with substantial non-infringing uses (Compl. ¶¶52-53, 56). The basis for knowledge includes Benada's alleged acquisition of the specific die designed for the patented part and a prior offer to license the patent to Eagle (Compl. ¶¶54-55).
Willful Infringement: Willfulness is alleged against all Defendants. For Benada and Eagle, the allegations of knowledge are based on the history of the extrusion die and prior licensing discussions (Compl. ¶58). For John Doe, the allegation is made "upon information and belief" that Doe knew of the patent's existence (Compl. ¶40).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of proof and identity: Can Plaintiff produce sufficient evidence to prove its allegation that the accused splashguards were manufactured using the specific, proprietary extrusion die it commissioned, which Benada later acquired? The outcome of this factual question could significantly influence the direct infringement analysis for the splashguard element.
A second key question will be one of system scope: Assuming the accused splashguard component is found to be identical to the patented one, do the accused installations, when considered as complete systems, include every other structural element as recited in the asserted claims, particularly the specific "gutter bracket" and "splashguard bracket" configurations?
Finally, the case will present a question of contributory liability: Is the splashguard component a staple article of commerce with substantial non-infringing uses, or is it, as Plaintiff alleges, a custom component essential to the patented system with no utility apart from it? The answer will be determinative for the indirect infringement claims against the manufacturer and distributor.