Innovative Inventologies Inc v. Milkmen Design LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Innovative Inventologies, Inc. (Florida)
  • Defendant: Milkmen Design, LLC. (Ohio)
  • Plaintiff’s Counsel: Zevon McCarter (Pro se)
• Case Identification: 8:25-cv-00403, M.D. Fla., 02/18/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant imports, sells, and markets the accused products in the Middle District of Florida, engages in systematic and continuous business in the district, and the alleged injury to Plaintiff occurred in the district.
• Core Dispute: Plaintiff alleges that Defendant’s vehicle condiment holder infringes a patent related to a portable condiment holder system designed to be mounted on a vehicle’s interior door panel.
• Technical Context: The technology addresses the market for in-vehicle convenience accessories, specifically devices designed to securely hold small, disposable condiment containers often provided by fast-food establishments.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent-in-suit and the alleged infringement one day prior to filing the lawsuit. It also contains unusual allegations that Defendant obtained its own, unrelated patents through "misinformation and omissions" and is engaging in anti-competitive behavior, though these are not presented as formal counts. The complaint notes that Defendant is actively litigating and settling cases involving its own patents.

Case Timeline

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

U.S. Patent No. 10,604,054 - “Portable condiment holder system and device for use in a vehicle,” issued March 31, 2020

The Invention Explained

• Problem Addressed: The patent’s background section identifies a lack of suitable options for holding small condiment containers within a vehicle, which can lead to difficulty and spillage when consuming food on the go (ʼ054 Patent, col. 1:15-28).
• The Patented Solution: The invention is a portable holder system featuring a basket-like container holder attached to a "holder arm." The arm is designed with a downward-bent outer end that can be wedged into the gap between a vehicle's interior door panel and its windowpane. This configuration is intended to position the condiment container stably and conveniently for a driver or passenger (ʼ054 Patent, col. 1:36-63; Fig. 1B).
• Technical Importance: The claimed solution provides a dedicated mounting point for condiment packages by utilizing a specific, often-overlooked structural feature of a standard car door, addressing a common inconvenience for which vehicle manufacturers do not typically provide a solution (ʼ054 Patent, col. 1:21-28).

Key Claims at a Glance

• The complaint asserts at least one independent claim of the '054 Patent (Compl. ¶34). The patent contains three independent claims (1, 10, and 19). Claim 1 is representative.
• Independent Claim 1 requires:
  • A portable condiment holder device comprising a "container holder" (a basket) and a "holder arm."
  • The holder arm has an "outer part" and an "inner part," where the outer part is "bent downward relative to the inner part."
  • The inner part connects to the container holder.
  • The system includes a "condiment container" with a condiment, where the holder is adapted to match the container's shape.
  • The outer part of the holder arm is "configured to be insertable in a gap between an inner door casing and a windowpane of a door of a vehicle."
  • The inner part of the holder arm is "positioned over the inner door casing and in front of the windowpane."
• The complaint does not explicitly reserve the right to assert dependent claims, though this is a common practice.

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Product" as a condiment holder sold by the Defendant (Compl. ¶22). A visual provided in the complaint identifies the product as the "Saucemoto Dip Clip" (Compl. p. 5).

Functionality and Market Context

• The complaint alleges the Accused Product "incorporates the design, structure, and/or function of the Patent-in-Suit" (Compl. ¶22).
• A product image included in the complaint describes the device as having a "Vent Clip" that "fits almost any vent style" and a "5-in-1 Aperture Design" to hold various sauce containers (Compl. p. 5). This image shows the Accused Product, which appeared on the television show "Shark Tank," being sold on Amazon (Compl. p. 5).
• The product listing title in the same image describes the product as a "Car Sauce Holder for Vents & Windows," suggesting more than one intended mounting location (Compl. p. 5).

IV. Analysis of Infringement Allegations

'054 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may arise over whether the accused "Vent Clip" constitutes a "holder arm, comprising an outer part and an inner part" as that term is used in the patent. The patent figures depict a singular, elongated arm, whereas the accused product appears to use a multi-pronged clip designed for air vent louvers. The case may turn on whether the clip structure can be read onto the claim language.
• Technical Questions: The complaint's own evidence emphasizes the "Vent Clip" functionality of the accused product (Compl. p. 5). A key question for the court will be whether the product is, in fact, "configured to be insertable in a gap between an inner door casing and a windowpane." The infringement analysis will require evidence beyond the product's title, such as user instructions or demonstrations, to establish that it is designed to function in the manner required by the claim.

V. Key Claim Terms for Construction

• Term: "holder arm"

  • Context and Importance: The structure of the accused product's mounting mechanism—a "Vent Clip"—appears different from the "holder arm" illustrated in the '054 Patent's embodiments. The definition of "holder arm" will be critical to determining whether the accused clip structure infringes.
  • Evidence for a Broader Interpretation: The specification describes the arm's function as enabling attachment to a door, which could support an argument that any structure performing that function qualifies as a "holder arm" (ʼ054 Patent, col. 3:40-44).
  • Evidence for a Narrower Interpretation: The patent figures consistently show a specific embodiment: an elongated, flat member with a simple downward bend at its end (ʼ054 Patent, Figs. 2A, 6). This could support an argument that the term is limited to the disclosed structure and does not cover a different structure like a multi-pronged vent clip.

• Term: "configured to be insertable in a gap between an inner door casing and a windowpane"

  • Context and Importance: Infringement hinges on whether the accused product, marketed primarily as a vent-mounted device, meets this specific functional limitation.
  • Evidence for a Broader Interpretation: The product's online listing title includes the word "Windows" (Compl. p. 5). Plaintiff may argue that this marketing, combined with the physical possibility of inserting the clip into a window channel, is sufficient to show it is "configured" for such use.
  • Evidence for a Narrower Interpretation: Defendant may argue that the term implies the device was designed for or is primarily intended for this mounting method, rather than it being an incidental capability. The prominent "Vent Clip" branding in the product imagery could be cited as evidence of its primary, intended configuration (Compl. p. 5; '054 Patent, col. 3:32-36).

VI. Other Allegations

• Indirect Infringement: The complaint includes conclusory allegations of indirect infringement (Compl. ¶39). It does not, however, plead specific facts to support the required elements of knowledge and intent, such as citing user manuals or advertisements that instruct consumers to use the product in the allegedly infringing manner.
• Willful Infringement: Willfulness allegations are based on Defendant’s alleged continuation of infringing sales after receiving notice of the '054 Patent on February 17, 2025, the day before the suit was filed (Compl. ¶27-28). The complaint does not allege pre-suit knowledge.

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

• A core issue will be one of structural scope: Can the accused product’s multi-pronged "Vent Clip," which is primarily designed to attach to an automotive air vent, be construed to meet the claim limitations of a "holder arm" with distinct "inner" and "outer" parts as described and illustrated in the '054 Patent?
• A key evidentiary question will be one of functional capability: Does the accused product's listing as a holder for "Vents & Windows" provide sufficient evidence that it is "configured to be insertable" in the specific window-and-door-casing gap required by Claim 1, or will the court find that its primary design and function as a vent-mounted device places it outside the claim's scope?