DCT
8:25-cv-03358
Knobez LLC v. Lowe's Home Centers LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Knobēz LLC (Florida)
- Defendant: Lowe's Home Centers, LLC (North Carolina)
- Plaintiff’s Counsel: Akerman LLP
- Case Identification: 8:25-cv-03358, M.D. Fla., 12/09/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district by selling the accused product and maintains regular and established places of business, including physical retail stores, within the Middle District of Florida.
- Core Dispute: Plaintiff alleges that Defendant’s decorative cabinet knob covers infringe a patent related to removable, friction-fit knob covers.
- Technical Context: The technology operates in the home décor market, offering consumers a method to temporarily and non-permanently alter the appearance of existing cabinet and furniture knobs.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement on October 31, 2025, and subsequently provided a detailed claim chart on November 6, 2025, placing Defendant's state of mind and potential willfulness at issue.
Case Timeline
| Date | Event |
|---|---|
| 2022-04-XX | Knobēz LLC established |
| 2022-06-23 | ’843 Patent Priority Date (Provisional Application) |
| 2025-03-25 | ’843 Patent Issue Date |
| 2025-10-31 | Plaintiff sends notice letter to Defendant |
| 2025-11-04 | Defendant’s counsel responds to notice letter |
| 2025-11-06 | Plaintiff provides Defendant with a detailed claim chart |
| 2025-11-24 | Accused Product observed for sale on Defendant’s website |
| 2025-12-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,256,843 - “Decorative Knob Cover”
- Patent Identification: U.S. Patent No. 12,256,843, “Decorative Knob Cover,” issued March 25, 2025 (the “’843 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section describes the drawbacks of conventional decorative knobs, noting that their replacement is often costly, time-consuming, requires tools, and may not be easily reversible (’843 Patent, col. 1:24-31). It further notes that prior art solutions for interchangeable decorations often leave a non-functional or unsightly stem when the decorative portion is removed (’843 Patent, col. 1:46-52).
- The Patented Solution: The invention is a removable decorative cover designed to fit over an existing, fixed knob without altering it. The core of the solution is a “fitting” that forms an “elastomeric shaft” with a passageway, which allows for a “friction-fit attachment to the existing knob” (’843 Patent, Abstract; col. 2:1-7). This design allows a user to easily install and remove different decorative covers to change the appearance of standard hardware (’843 Patent, Fig. 11).
- Technical Importance: The claimed approach provides a tool-free, non-permanent, and versatile method for customizing standard home hardware, particularly for seasonal or themed décor (Compl. ¶¶11, 13).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claim 7 (’843 Patent, col. 5:48-6:3; Compl. ¶38).
- Independent Claim 1:
- A decorative knob cover for use with a fixed knob for cabinets or drawers, comprising:
- a fitting comprising an elastomeric shaft, the shaft having a first end, a second end and a passageway therebetween, wherein the fitting is adapted for a friction-fit attachment to the fixed knob; and
- a handle connected to the fitting, the handle comprising a first side and a second side, the first side being affixed to the second end of the shaft, and the second side having a decorative surface.
- The complaint reserves the right to assert additional claims (’843 Patent, col. 6:4-12; Compl. ¶64).
III. The Accused Instrumentality
Product Identification
- The “Holiday Living 1-1/2-in Red Round Modern Cabinet Knob 10-Pack,” Item #6853417, Model #08-3894 (the “Accused Product”) (Compl. ¶35).
Functionality and Market Context
- The complaint alleges the Accused Product is a decorative cover for existing cabinet knobs, made of materials including “soft silicone” (Compl. ¶39). The product packaging includes instructions to “Stretch the opening at the back of the cover” and “Position the cover over the cabinet knob... to cover the knob completely” (Compl. ¶41). Figure 5 of the complaint reproduces these instructions with diagrams illustrating the friction-fit attachment process (Compl. ¶41). The complaint positions the Accused Product as a “knockoff” of Plaintiff’s popular “Red Peppermint” product, sold during the holiday season (Compl. ¶¶2-3, 31).
IV. Analysis of Infringement Allegations
’843 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a fitting comprising an elastomeric shaft... adapted for a friction-fit attachment to the fixed knob | The Accused Product is made of "soft silicone" and is configured for a friction-fit attachment, as its instructions direct the user to "stretch" the opening over an existing cabinet knob. | ¶¶39, 41 | col. 5:51-56 |
| a handle connected to the fitting... the first side being affixed to the second end of the shaft... | The Accused Product includes a handle (the decorative portion) connected to the fitting (the part that covers the knob). | ¶42 | col. 5:57-61 |
| ...and the second side having a decorative surface. | The Accused Product features a decorative surface with a "candy cane swirl." Figure 6 of the complaint shows the Accused Product's decorative appearance. | ¶42 | col. 6:1 |
Identified Points of Contention
- Scope Questions: A central question may be whether the Accused Product's structure, described as being made of "soft silicone," meets the claim limitation of "a fitting comprising an elastomeric shaft." The complaint's Figure 1, which reproduces a patent drawing, depicts a distinct shaft structure, raising the question of whether the Accused Product’s form aligns with the patent’s disclosure (Compl. ¶29).
- Technical Questions: The analysis may focus on the nature of the connection. What evidence does the complaint provide that the Accused Product’s method of being "stretched" over a knob constitutes a "friction-fit attachment" as contemplated by the patent, which describes a connection "sufficiently strong to withstand repeated opening and closing of the door" (’843 Patent, col. 3:35-37)?
V. Key Claim Terms for Construction
The Term: "elastomeric shaft"
Context and Importance: This term defines the core structural and material properties of the invention's attachment mechanism. The outcome of the infringement analysis may depend on whether the Accused Product's silicone structure is construed as an "elastomeric shaft."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests a range of materials, including "elastic polymer or rubber" and "thermoplastic elastomer," which could support a broad definition of "elastomeric" (’843 Patent, col. 3:19-20, 51-52).
- Evidence for a Narrower Interpretation: The specification repeatedly refers to the "cylindrical configuration of fitting 18," and figures such as Fig. 4 depict a distinct, elongated, and hollow cylinder (’843 Patent, col. 3:37-38, 41-42). This could support an argument that "shaft" requires a more specific structure than a simple cap or cover.
The Term: "friction-fit attachment"
Context and Importance: This term describes how the cover attaches to the knob. Its construction will determine whether the stretching-on mechanism of the Accused Product falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's summary distinguishes the friction-fit embodiment from an alternative "clasp" mechanism, suggesting that "friction-fit" is intended to cover non-mechanical attachments broadly (’843 Patent, col. 2:5-12).
- Evidence for a Narrower Interpretation: The specification provides functional context, stating the connection is strong enough to "withstand repeated opening and closing" and "prevent[] inadvertent detachment" (’843 Patent, col. 3:35-45). This functional requirement could be used to argue for a narrower definition that requires a specific level of retaining force.
VI. Other Allegations
Indirect Infringement
- The complaint does not provide sufficient detail for analysis of indirect infringement.
Willful Infringement
- The complaint alleges that Defendant had pre-suit knowledge of the ’843 Patent and its alleged infringement as of at least early November 2025 (Compl. ¶67). This allegation is based on a series of communications, including an October 31, 2025 notice letter from Plaintiff and Plaintiff’s provision of a detailed claim chart on November 6, 2025 (Compl. ¶¶45, 49). The complaint further alleges that Defendant continued to sell the Accused Product after receiving this notice, which is presented as evidence of willful blindness or reckless disregard for Plaintiff's patent rights (Compl. ¶¶51-53, 68).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the term "elastomeric shaft," which is depicted in the patent with a specific cylindrical configuration, be construed to cover the "soft silicone" structure of the Accused Product? The resolution will likely depend on whether "shaft" is interpreted as a structural limitation or more broadly as any elastomeric component that performs the friction-fit function.
- A second central issue will be willfulness: given the complaint's detailed allegations of pre-suit notice, including the delivery of a claim chart, the focus will be on whether Defendant's continued sales of the Accused Product were objectively reckless. The timeline of the alleged notice relative to the Defendant's ongoing sales will be a critical factual element in determining potential eligibility for enhanced damages.