Agricultive LLC v. Markic

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Agricultive LLC (Florida)
  • Defendant: Jure Markic (Slovenia)
  • Plaintiff’s Counsel: Saul Ewing LLP
• Case Identification: 6:25-cv-02308, M.D. Fla., 12/02/2025
• Venue Allegations: Plaintiff is a Florida-based company, and alleges that Defendant directed patent infringement allegations into the district, causing harm, and conducts business in Florida through a related corporate entity.
• Core Dispute: Plaintiff seeks a declaratory judgment that its automatic chicken coop doors do not infringe Defendant’s patent and/or that the patent-in-suit is invalid due to prior public disclosures and sales.
• Technical Context: The technology at issue involves automated, light-sensitive doors for animal enclosures, such as chicken coops, designed to operate without daily human intervention.
• Key Procedural History: The action was initiated by the accused infringer, Agricultive LLC v. Markic, in response to infringement allegations from the patent owner, Jure Markic. The complaint centers on allegations that both the plaintiff's accused product and the defendant's own patented product were on sale and publicly disclosed prior to the patent's critical date, potentially rendering the patent invalid under 35 U.S.C. § 102.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 12,070,016 - "Automated Light-Sensitive Configurable Animal Door" (issued Aug. 27, 2024)

The Invention Explained

• Problem Addressed: The patent describes the burden on animal owners who must manually open and close coop doors twice daily, which is inconvenient and exposes animals to risk from predators or inclement weather if the owner forgets or is unavailable ( ’016 Patent, col. 1:10-33).
• The Patented Solution: The invention is an automated door unit featuring a door plate with a series of guide holes running vertically. A motor drives a sprocket that directly engages these holes, converting the motor's rotational motion into the linear up-and-down movement of the door. The entire system is controlled by a printed circuit board (PCB) with a light sensor that detects sunrise and sunset to trigger the opening and closing cycles automatically ( ’016 Patent, Abstract; col. 1:56-64). The overall assembly is depicted in Figure 1 of the patent.
• Technical Importance: This design provides a self-contained, automated solution that aims to be more robust and reliable than systems relying on ropes or pulleys, which may fray or fail to overcome obstacles like ice or debris ( ’016 Patent, col. 7:13-24).

Key Claims at a Glance

• The complaint’s invalidity and non-infringement counts focus exclusively on independent claim 1 (Compl. ¶¶ 42, 50).
• Claim 1 Elements:
  • An animal door unit comprising:
  • an entrance comprised of at least one panel,
  • a door plate having a plurality of guide holes, the door plate configurable in a retracted state and an open state... wherein, in the retracted state, the door plate traverses the entrance, and wherein, in the open state, the door plate does not traverse the entrance;
  • a motor; and
  • a sprocket in rotational communication with the motor, wherein the sprocket interfaces with the plurality of guide holes, such rotational movement of the sprocket inducing linear movement in the door plate.

III. The Accused Instrumentality

Product Identification

Plaintiff’s "Accused Products" are automatic chicken coop doors sold under various Amazon Standard Identification Numbers (ASINs) on Amazon.com and through the Plaintiff's website, farmlite.store (Compl. ¶¶ 4, 7, 27).

Functionality and Market Context

The complaint describes the products as "automatic chicken coop doors" and alleges they have been offered for sale since at least September 2021 (Compl. ¶¶ 4, 6, 9). An exemplary photograph shows the Accused Product, which includes a main housing, a vertically-oriented door, and associated packaging and accessories (Compl. p. 6). The complaint does not provide specific details on the internal drive mechanism of the Accused Products, stating only that the Defendant contends they are covered by claim 1 of the ’016 Patent (Compl. ¶34).

IV. Analysis of Infringement Allegations

The complaint is a declaratory judgment action for non-infringement and does not contain a detailed infringement claim chart from the patentee. It alleges only that Defendant Markic has accused Plaintiff's products of infringing claim 1 (Compl. ¶¶ 13, 34). The following table outlines a putative infringement theory based on the claim language and the limited visual evidence provided for the Accused Product.

• U.S. Patent No. 12,070,016 Infringement Allegations

• Identified Points of Contention:
  • Validity Question: The complaint's central argument is that the invention was disclosed to the public before the patent's critical date. It raises the question of whether the Defendant's own alleged sales starting in February 2021 created a statutory bar to patentability, or if the Plaintiff's sales starting in September 2021 qualify as invalidating prior art, given the patent's February 18, 2022 priority date (Compl. ¶¶ 35, 39, 45-46).
  • Technical Question: For the non-infringement claim, a key factual dispute will be the nature of the Accused Product's internal drive mechanism. What evidence does the complaint provide that the Accused Product utilizes a "sprocket" that "interfaces with... guide holes," as required by the claim, versus a different, non-infringing technology (e.g., a friction drive, belt, or screw mechanism)? The complaint provides no such evidence.

V. Key Claim Terms for Construction

• The Term: "sprocket... interfaces with the plurality of guide holes"
  • Context and Importance: This phrase defines the core mechanical interface of the claimed invention. The non-infringement case may depend entirely on whether the Accused Product's drive system meets this definition. Practitioners may focus on this term because if the accused device uses any mechanism other than a toothed wheel engaging perforations in the door plate, infringement may be avoided.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "sprocket" outside of its functional context, which may support using its plain and ordinary meaning as a toothed wheel designed to engage with a perforated or linked element.
    • Evidence for a Narrower Interpretation: The specification consistently describes and depicts the sprocket (332) as directly engaging "rectangular guide holes (116)" that run "vertically along the center of the door plate (102)" ( ’016 Patent, col. 7:3-9; FIG. 1, FIG. 2A). A party could argue the term should be limited to this specific configuration of a wheel's teeth entering holes in a flat plate, as distinguished from engaging a chain or a toothed rack.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of other allegations such as indirect or willful infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

• A central issue will be one of patent validity based on timing: Will discovery show that either the Plaintiff’s product sales activities before the patent's priority date, or the Defendant’s own alleged sales activities more than one year prior to the filing date, constitute an invalidating public disclosure or on-sale bar under 35 U.S.C. § 102?
• A key evidentiary question will be one of technical operation: Does the Accused Product’s internal drive mechanism literally meet the "sprocket... interfaces with... guide holes" limitation of claim 1, or does it employ a functionally distinct and non-infringing method to move the door plate?