1:24-cv-00124
Shenzhen Creality 3D Technology Co Ltd v. Slice Engineering LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Creality 3D Technology Co., Ltd. (People's Republic of China)
- Defendant: Slice Engineering, LLC (Florida)
- Plaintiff’s Counsel: Morgan, Lewis & Bockius LLP
- Case Identification: 1:24-cv-00124, N.D. Fla., 07/23/2024
- Venue Allegations: Venue is asserted on the basis that Defendant Slice Engineering, LLC is a Florida company with its principal place of business within the judicial district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its 3D printer hotend products do not infringe two of Defendant's patents related to the mechanical and thermal design of 3D printer extrusion heads.
- Technical Context: The technology concerns the "hotend" of a fused filament fabrication 3D printer, specifically the design of the "heat break" that isolates the hot melting zone from the cool filament feed zone to improve printing performance and reliability.
- Key Procedural History: This declaratory judgment action follows pre-suit licensing discussions initiated by Defendant in mid-2023. Plaintiff alleges that between February and July 2024, Defendant filed multiple online takedown notices against Plaintiff's products on AliExpress.com and filed infringement complaints through the Amazon Patent Evaluation Express (APEX) program, creating an actual controversy between the parties.
Case Timeline
| Date | Event |
|---|---|
| 2017-05-17 | Priority Date for ’810 and ’244 Patents |
| 2020-12-29 | U.S. Patent No. 10,875,244 Issues |
| 2023 (Mid) | Defendant allegedly approaches Plaintiff to license technology |
| 2023-05-30 | U.S. Patent No. 11,660,810 Issues |
| 2024 (Feb-Jul) | Defendant allegedly files online takedown notices |
| 2024 (Jun-Jul) | Defendant allegedly files complaints via Amazon APEX program |
| 2024-07-23 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,660,810 - "Adaptable High-Performance Extrusion Head for Fused Filament Fabrication Systems"
- Patent Identification: U.S. Patent No. 11,660,810, "Adaptable High-Performance Extrusion Head for Fused Filament Fabrication Systems", issued May 30, 2023.
The Invention Explained
- Problem Addressed: The patent's background describes a fundamental design conflict in all-metal 3D printer hotends. The "heat break"—a thin tube connecting the hot and cold ends—must be both an effective thermal insulator (requiring thin walls) and a strong structural support (requiring thick walls). This tradeoff limits performance. (’810 Patent, col. 7:26-38). Additionally, changing the hot zone length to adjust print speed often changes the overall hotend length, requiring machine recalibration. (’810 Patent, col. 7:39-54).
- The Patented Solution: The invention separates these competing functions. It uses a very thin-walled metal feed tube for thermal isolation, which is relieved of most mechanical loads. A separate structural "bridge" spans the gap between the heater and cooler to provide rigidity, preventing the feed tube from bearing the mechanical stress of the printing process. (’810 Patent, Abstract; col. 8:11-24).
- Technical Importance: This approach allows for a heat break with significantly better thermal isolation (a thinner wall) without sacrificing the mechanical stability of the extrusion head assembly. (’810 Patent, col. 7:22-29).
Key Claims at a Glance
- The complaint identifies independent claim 1 as the basis for Defendant's prior infringement allegations (Compl. ¶24).
- Independent Claim 1 of the ’810 Patent requires:
- A generally axially extending metal feed tube.
- A heater thermally coupled with the downstream portion of the feed tube.
- A cooler thermally coupled with the upstream portion of the feed tube and spaced axially upstream from the heater.
- A generally axially extending gap between the cooler and the heater, traversed by the feed tube.
- A bridge that traverses the gap, is spaced radially from the feed tube, provides a rigid mechanical connection, and at least partially reduces mechanical loading on the feed tube.
- The bridge comprises a "first structural component" and a "second structural component," each spaced from the feed tube and having portions bearing against the heater and the cooler.
- The complaint does not assert any position on dependent claims but notes that non-infringement of an independent claim would preclude infringement of its dependent claims (Compl. ¶25).
U.S. Patent No. 10,875,244 - "Adaptable High-Performance Extrusion Head for Fused Filament Fabrication Systems"
- Patent Identification: U.S. Patent No. 10,875,244, "Adaptable High-Performance Extrusion Head for Fused Filament Fabrication Systems", issued December 29, 2020.
The Invention Explained
- Problem Addressed: The ’244 Patent shares a specification with the ’810 Patent and thus addresses the same technical problem of the conflicting thermal and structural requirements of a conventional heat break. (’244 Patent, col. 7:26-38).
- The Patented Solution: The solution is conceptually identical to that of the ’810 Patent: separating the structural and thermal-insulating roles. The claims of the ’244 Patent provide a more specific definition for the "bridge" structure. (’244 Patent, Abstract). The bridge is explicitly defined as comprising two distinct types of components working together.
- Technical Importance: As with the ’810 patent, this design purports to enable a more efficient and robust hotend by resolving a core design tradeoff. (’244 Patent, col. 8:11-24).
Key Claims at a Glance
- The complaint identifies independent claim 1 as the basis for Defendant's prior infringement allegations (Compl. ¶52).
- Independent Claim 1 of the ’244 Patent requires:
- A generally axially extending metal feed tube.
- A heater thermally coupled with the downstream portion of the feed tube.
- A cooler thermally coupled with the upstream portion of the feed tube and spaced axially upstream from the heater.
- A generally axially extending gap between the cooler and the heater, traversed by the feed tube.
- A bridge that traverses the gap, provides a rigid connection, and reduces mechanical loading.
- The bridge comprises "at least one generally axially extending spacer" bearing against both the heater and cooler.
- The bridge also comprises "at least one tension member" connected to and exerting tension between the heater and cooler and compression on the spacer.
- The complaint notes that non-infringement of independent claim 1 would preclude infringement of its dependent claims (Compl. ¶53).
III. The Accused Instrumentality
Product Identification
- The complaint seeks a declaration of non-infringement for several of Plaintiff's products, including the Spider High Temperature Hotend, K1 Series Ceramic Heating Block Kit, Spider High Temperature and High Flow Hotend Pro, Spider Water-cooled Ceramic Hotend, Spider Speedy Ceramic Hotend, Ender-3 V3 SE/KE Ceramic Heating Block Kit, and the Creality K1C 3D printer which incorporates one of the accused kits (Compl. ¶¶18-20, 34).
Functionality and Market Context
- The complaint describes the accused products as hotend kits for 3D printers that consist of a heater, a cooler, a filament guiding tube, and a nozzle (Compl. ¶20). The complaint presents two primary alternative designs. In one design, an "external bracket," alleged to not be part of the cooler, connects to the heating block via screws (Compl. ¶21, ¶26). An annotated diagram of the Spider High Temperature Hotend shows this configuration, labeling a "cooling block," a separate "bracket," a "heating block," and "screws" (Compl. p. 11). In a second design, a "mounting plate" with low thermal conductivity is positioned between the heater and cooler, with the cooler connecting to the mounting plate rather than directly to the heater (Compl. ¶21, ¶30). An annotated diagram of the K1 Series Ceramic Heating Block Kit shows a "cooler" connected to a "mounting plate" via a "positioning pin," with the mounting plate separating the cooler from the "heater" (Compl. p. 13).
- The complaint alleges these products are part of a complete 3D printing ecosystem and have received high recognition from global users (Compl. ¶11).
IV. Analysis of Infringement Allegations
’810 Patent Infringement Allegations
The complaint alleges non-infringement by arguing that the accused products lack a "bridge" with "structural components" that bear against both the heater and cooler as claimed.
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a generally axially extending gap, bound by a bridge traversing the gap between the cooler and the heater | The accused products allegedly lack the claimed "bridge." In products like the Spider High Temperature Hotend, screws connect the heating block to an external bracket, which is alleged to not be part of the cooler. Thus, there is no component providing a rigid mechanical connection between the heater and the cooler. | ¶26, ¶29 | col. 5:32-41 |
| wherein the bridge comprises: a first structural component, spaced radially and apart from the feed tube, and having a first portion bearing against the heater and a second portion bearing against the cooler... | The screw is alleged not to be the "first structural component" because it does not have a portion bearing against the cooling block. | ¶27 | col. 9:1-7 |
| and a second structural component, spaced radially and apart from the feed tube, and having a first portion bearing against the heater and a second portion bearing against the cooler... | The screw is alleged not to be the "second structural component" because it does not have a portion bearing against the cooling block. | ¶28 | col. 9:8-14 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the definition of "cooler." Plaintiff alleges that the "external bracket" in some accused products is not part of the cooler because it "has no cooling fins to execute a cooling function" (Compl. ¶26). The case may turn on whether the term "cooler" is limited to a component with active cooling features or if it can be construed more broadly to include structural mounting hardware attached to it.
- Technical Questions: The complaint's non-infringement theory for products like the K1 Series kit hinges on the presence of an intermediate "mounting plate" (Compl. ¶30). A key question will be whether this mounting plate is a distinct component, as Plaintiff alleges, or if it could be considered part of the "heater" or "cooler" assembly for the purposes of the claim, thereby allowing the positioning pins or screws to meet the "bridge" limitation.
’244 Patent Infringement Allegations
The complaint's non-infringement arguments for the ’244 Patent are similar but focus on the more specific "spacer" and "tension member" limitations of claim 1.
| Claim Element (from Independent Claim 1) | Plaintiff's Alleged Non-Infringing Functionality - | Complaint Citation | Patent Citation |
|:--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |:-----------------------|:--------------------|
| wherein the bridge 117 comprises: at least one generally axially extending spacer 107... having a first portion 134 bearing against the heater 102 and a second portion 135 bearing against the cooler 101 | In products with an external bracket, the screw is alleged not to be a "spacer" because it does not have a portion bearing against the cooling block, and the bracket is not a spacer because it does not bear against the heating block (Compl. ¶55). In products with a mounting plate, neither the positioning pin nor the plate itself allegedly bears against both the heater and cooler (Compl. ¶59). | ¶55, ¶59 | col. 6:45-50 |
| and at least one tension member 108... connected to and exerting tension between the heater 102 and the cooler 101... | The screw is alleged not to be a "tension member" because it does not connect to the cooling block, and the bracket is not a tension member because it does not connect to the heating block (Compl. ¶56). A similar argument is made for the mounting plate configuration (Compl. ¶60). | ¶56, ¶60 | col. 7:11-18 |
- Identified Points of Contention:
- Scope Questions: The dispute will likely focus on whether the accused components (screws, pins, brackets, plates) meet the functional and structural requirements of a "spacer" and "tension member" as defined in the claim. The claim requires these components to create a system of compression and tension between the heater and the cooler. Plaintiff's argument is that its components connect to intermediate parts, not directly between the heater and cooler.
- Technical Questions: Resolution will require a factual determination of how forces are distributed in the accused assemblies. The court may need to analyze whether the "mounting plate" or "external bracket" is a functionally distinct element or simply an extension of the heater or cooler, which would affect whether the connecting screws can be seen as "exerting tension between the heater and the cooler."
V. Key Claim Terms for Construction
The Term: "bridge"
Context and Importance: This term is central to the non-infringement allegations for both patents. Plaintiff's core argument is that its products do not have a "bridge" because no single component or assembly provides a rigid mechanical connection that traverses the gap between the cooler and the heater. Practitioners may focus on this term because its construction will likely determine the outcome of the infringement analysis.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract of both patents describes the bridge more generally as providing "a rigid mechanical connection between the heater and the cooler" without specifying that the connection must be direct. (’244 Patent, Abstract; ’810 Patent, Abstract).
- Evidence for a Narrower Interpretation: The claims themselves recite a structure that connects "the cooler and the heater" (’810 Patent, Claim 1; ’244 Patent, Claim 1). The specification of the ’244 Patent describes the spacer element of the bridge as "having a first portion 134 bearing against the heater 102 and a second portion 135 bearing against the cooler 101," which suggests direct contact between the bridge components and both the heater and cooler. (’244 Patent, col. 6:47-50).
The Term: "cooler"
Context and Importance: Plaintiff's non-infringement argument relies on distinguishing certain components, such as an "external bracket," from the "cooler" (Compl. ¶26). The definition of "cooler" is therefore critical to determining the boundaries of the claimed invention and whether Plaintiff's products meet the "bridge" limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent provides little explicit definition, referring to the cooler as being "thermally coupled with the upstream portion for reducing upstream heat transfer" (’244 Patent, col. 5:24-26). This functional language could be argued to encompass any component that assists in that role, including structural parts attached to a heatsink.
- Evidence for a Narrower Interpretation: The patent repeatedly refers to the cooler in the context of a "finned heatsink or a liquid cooling system" (’244 Patent, col. 8:64-65). Plaintiff alleges a component like its "external bracket" is not a cooler because it "has no cooling fins" (Compl. ¶26), suggesting a definition tied to specific heat-dissipating structures.
VI. Other Allegations
- Indirect Infringement: The complaint's prayer for relief seeks a declaration that Plaintiff has not infringed any claim of the patents-in-suit "directly or indirectly" (Compl. p. 40). However, the body of the complaint focuses exclusively on arguments for direct non-infringement and does not provide sufficient detail for an analysis of any potential indirect infringement allegations.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on fundamental questions of claim construction and the application of that construction to the accused product designs. The key questions for the court will likely be:
A core issue will be one of definitional scope: Can the term "bridge", as claimed in the patents, be construed to read on a structure that uses an intermediate component (like a "mounting plate" or "external bracket") to physically separate the main heater and cooler bodies, or does the claim require a more direct connection where the bridge components bear against both the heater and cooler?
A related key question will be one of component identity: Are the "external brackets" and "mounting plates" in the accused products functionally and structurally part of the "cooler" or "heater" assemblies as those terms are used in the patents, or are they distinct, unclaimed elements? The answer may depend on whether terms like "cooler" are defined by their primary function (heat dissipation) or can encompass adjacent structural hardware.
Finally, for the ’244 Patent specifically, a critical evidentiary question will be one of load distribution: Do the accused screws and brackets function as the claimed "spacers" and "tension members" by creating a system of compression and tension between the heater and cooler, or is the mechanical load path fundamentally different from that described and claimed in the patent?