DCT
1:25-cv-22219
Metzfab Industries LLC v. Individuals Corps Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Metzfab Industries, LLC and Brandon Metzger (Arizona)
- Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (Primarily People's Republic of China and other foreign jurisdictions)
- Plaintiff’s Counsel: Boies Schiller Flexner LLP
- Case Identification: 1:25-cv-22219, S.D. Fla., 05/14/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants target and transact business with consumers in Florida through interactive e-commerce stores on platforms like Amazon.com. For defendants not residing in the U.S., venue is asserted under 28 U.S.C. § 1391(c)(3).
- Core Dispute: Plaintiff alleges that numerous e-commerce store operators are selling automotive dipstick adapter assemblies that infringe two U.S. patents covering a method and apparatus for installing such adapters without removing the vehicle's oil pan.
- Technical Context: The technology addresses the automotive aftermarket repair sector, offering a product that simplifies the replacement of a vehicle’s factory-installed oil pan dipstick adapter, a typically costly and labor-intensive procedure.
- Key Procedural History: The asserted U.S. Patent No. 9,671,272 is a continuation of the application that issued as the co-asserted U.S. Patent No. 9,285,259, indicating a direct familial and technical relationship between the patents. The complaint is structured as a "Schedule A" action against a large number of unidentified online sellers, a strategy often employed to combat widespread, diffuse infringement by foreign entities on e-commerce platforms.
Case Timeline
| Date | Event |
|---|---|
| 2012-12-14 | Priority Date for ’259 and ’272 Patents |
| 2016-03-15 | Issue Date for U.S. Patent No. 9,285,259 |
| 2017-06-06 | Issue Date for U.S. Patent No. 9,671,272 |
| 2025-05-14 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,671,272 - “Dipstick Adapter Assembly”
Issued June 6, 2017
The Invention Explained
- Problem Addressed: The patent describes factory-installed oil pan dipstick adapters as "poorly designed." When they fail, replacement is a "very time-consuming and expensive process" that often requires removing the entire oil pan, and sometimes the engine, to access the inside of the pan. (’272 Patent, col. 1:26-34).
- The Patented Solution: The invention is a multi-part adapter assembly that can be installed entirely from outside the oil pan. It consists of a "front fixture" that sits on the outside of the pan and a "backing plate" (clamping means) that is inserted through the hole and positioned on the inside. Fasteners are then used to pull the backing plate and front fixture together, clamping them onto the oil pan wall and creating a seal around the hole, all without requiring access to the inside of the pan. (’272 Patent, col. 2:48-68; Fig. 4A-4D).
- Technical Importance: This design purports to save "considerable time and expense" for mechanics and vehicle owners by transforming a major repair into a simpler, externally-managed installation. (’272 Patent, col. 2:34-35).
Key Claims at a Glance
- The complaint asserts independent Claim 1. (Compl. ¶45).
- Claim 1 is directed to an assembly comprising:
- an oil pan having an inner surface, an outer surface, and a hole
- a front fixture
- clamping means coupled to the front fixture
- a first fastener coupling the front fixture to the clamping means, where the fastener is "fixed to the clamping means with a bond to prevent rotation"
- a second fastener applied to the front fixture to move the clamping means
- the clamping means being moveable through the hole from a "free condition" (outside the pan) to an "applied condition" (inside the pan)
- in the applied condition, the front fixture encircles the hole in direct contact with the outer surface of the oil pan and is sealed around the hole.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,285,259 - “Dipstick Adapter Assembly”
Issued March 15, 2016
The Invention Explained
- Problem Addressed: The patent identifies the same problem as its continuation, the ’272 Patent: the high cost and difficulty of replacing failed factory dipstick adapters due to the need to remove the oil pan. (’259 Patent, col. 1:26-34).
- The Patented Solution: The ’259 Patent describes the same fundamental solution: a multi-part fixture that allows for external installation. A key aspect highlighted in this patent's claims is the specific geometry of the "clamping means" (backing plate), which is shaped with a length larger than the hole and a width smaller than the hole, enabling it to be inserted through the hole and then rotated into a clamping position. (’259 Patent, Abstract; col. 2:44-56).
- Technical Importance: The invention's value lies in providing a practical and efficient alternative to the standard, highly inconvenient repair procedure. (’259 Patent, col. 2:25-33).
Key Claims at a Glance
- The complaint asserts independent Claim 1. (Compl. ¶45).
- Claim 1 is directed to an assembly comprising:
- an oil pan with an inner surface, outer surface, and a hole
- a front fixture larger than the hole
- clamping means coupled to the front fixture, with a length larger than the hole and a transverse width smaller than the hole
- the clamping means being moveable through the hole to arrange the assembly between a "free condition" (clamping means outside the pan) and an "applied condition" (clamping means inside the pan)
- in the applied condition, the front fixture encircles the hole in direct contact against the outer surface of the oil pan and is sealed around the hole.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "Dipstick Adapter" products sold by Defendants, such as those offered by "DIYAREA" (ASIN B0CHJC86HG) and "Vvlsws" (ASIN B0CWH26DMD), through e-commerce stores on Amazon.com. (Compl. ¶45).
Functionality and Market Context
The complaint alleges these are "inferior imitations" of Plaintiff's products sold on storefronts designed to appear legitimate. (Compl. ¶¶4, 28). The provided product images depict multi-part assemblies consisting of a main body (front fixture), a separate backing plate (clamping means), and fasteners. (Compl. p. 10-12). One image for the "Vvlsws" product provides an instructional diagram showing a bolt being turned to rotate the backing plate, illustrating a method of installation consistent with the patented invention. (Compl. p. 12). The complaint alleges these products directly compete with Plaintiff's genuine goods. (Compl. ¶22).
IV. Analysis of Infringement Allegations
’272 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an oil pan having an inner surface, an outer surface, and a hole through the oil pan between the inner and outer surface; | The product is designed for installation into a hole in a standard automotive oil pan. | ¶45 | col. 7:41-43 |
| a front fixture; | The accused product includes a main body component that serves as the front fixture, as shown in the product image. The complaint provides a visual of this front fixture. (Compl. p. 10). | ¶45 | col. 2:49-50 |
| clamping means coupled to the front fixture; | The accused product includes a backing plate that functions as the clamping means and is coupled to the front fixture via fasteners, as depicted in the product image. (Compl. p. 10). | ¶45 | col. 3:50-51 |
| a first fastener coupling the front fixture to the clamping means, the first fastener fixed to the clamping means with a bond to prevent rotation...; | The accused product uses a fastener to couple the parts. The complaint does not specify the "bond," but the patent teaches a weld. | ¶45 | col. 8:62-65 |
| a second fastener applied to the front fixture for application to the clamping means to move the clamping means...; | A second fastener is used to tighten the assembly, drawing the clamping means toward the front fixture to clamp the oil pan wall. | ¶45 | col. 7:26-31 |
| the clamping means is moveable through the hole to arrange the assembly between a free condition... and an applied condition...; | The backing plate (clamping means) is inserted through the oil pan hole to an "applied condition" inside the pan, as illustrated by the patent's installation method. An instructional graphic supports this. (Compl. p. 12). | ¶45 | col. 6:6-24 |
| wherein in the applied condition... the front fixture encircles the hole in direct contact against the outer surface... and is sealed... | The product is shown with "DOUBLE SEALING RINGS," alleged to create a seal around the oil pan hole when installed. (Compl. p. 11). | ¶45 | col. 8:12-14 |
- Identified Points of Contention:
- Scope Questions: A central question may be the interpretation of "a bond." The patent specification discloses a "weld" as the bond. (’259 Patent, col. 6:1-3, incorporated by reference into ’272). The infringement analysis will depend on whether the court construes "bond" to be limited to a weld or if it can encompass other fixing methods (e.g., adhesives, press-fitting).
- Technical Questions: What evidence demonstrates that the accused product's first fastener is "fixed" to the clamping means in a way that "prevent[s] rotation" as claimed? The complaint provides images but no detailed technical breakdown of the fastener-plate connection.
’259 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an oil pan having an inner surface, an outer surface, and a hole through the oil pan between the inner and outer surface; | The product is intended for use with a standard automotive oil pan. | ¶45 | col. 7:41-44 |
| a front fixture larger than the hole; | The main body of the accused product is alleged to be the front fixture, which is dimensionally larger than the oil pan hole it is designed to cover. | ¶45 | col. 7:45 |
| clamping means... having a length which is larger than the hole and a width, transverse to the length, which is a smaller than the hole; and | The product includes a backing plate (clamping means) alleged to have these specific dimensions, allowing it to pass through the hole sideways and then be rotated to a clamping position. | ¶45 | col. 7:47-50 |
| the clamping means is moveable through the hole to arrange the assembly between a free condition... and an applied condition...; | The product's backing plate is passed through the hole. An instructional image shows the plate being rotated after insertion, consistent with this limitation. (Compl. p. 12). | ¶45 | col. 7:51-56 |
| wherein in the applied condition... the front fixture encircles the hole in direct contact against the outer surface... and is sealed... | The accused product includes "Double O-Ring For Seal" features to seal against the oil pan's outer surface when tightened. (Compl. p. 12). | ¶45 | col. 7:57-60 |
- Identified Points of Contention:
- Technical Questions: Does the accused product's backing plate actually meet the dimensional requirements of having a "length which is larger than the hole and a width... smaller than the hole"? The complaint makes this allegation via a high-level chart but provides no measurements or specific evidence to substantiate this critical structural limitation.
- Scope Questions: Does the "direct contact" requirement preclude the presence of a gasket between the front fixture and the oil pan? While Claim 2 explicitly adds a gasket, the language of Claim 1 ("direct contact") could be a point of dispute if the accused product's primary seal is between a gasket and the pan, not the fixture itself.
V. Key Claim Terms for Construction
Term 1: "bond" (’272 Patent, Claim 1)
- Context and Importance: This term is critical for the ’272 Patent infringement analysis. Claim 1 requires the first fastener to be "fixed to the clamping means with a bond." The nature of this "bond" will define the scope of infringement. Practitioners may focus on this term because if it is construed narrowly, a defendant could potentially design around the claim by using a non-bonded fixing method.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "bond" itself is a general term and is not explicitly defined in the patent. A plaintiff may argue it should be given its plain and ordinary meaning, which could include various forms of attachment like welding, brazing, or using a strong adhesive.
- Evidence for a Narrower Interpretation: The specification, which is incorporated from the parent '259 patent, discloses only one embodiment of the bond: "an end 96 of the bolt 94 has a small weld 100 to the outer face 61 of the backing plate 11." (’259 Patent, col. 6:1-3). A defendant may argue that this is a strong indication that the inventor intended "bond" to mean "weld," potentially limiting the claim scope to that specific embodiment.
Term 2: "clamping means" (’259 Patent, Claim 1)
- Context and Importance: This term defines a central structural component of the invention. While it sounds functional, Claim 1 of the ’259 Patent recites specific structural characteristics for it: "having a length which is larger than the hole and a width, transverse to the length, which is a smaller than the hole." The infringement case depends entirely on whether the accused backing plate meets this structural definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the terms "clamping means" and "backing plate" interchangeably, suggesting the term should not be overly constrained by other descriptive details. For instance, it states "the backing plate 11 is a clamping means." (’259 Patent, col. 3:50-52).
- Evidence for a Narrower Interpretation: The detailed description provides significant structural detail for the "backing plate 11," including "two wings 80 and 81," a central "hold 90," and specific arcuate ends. (’259 Patent, col. 3:57 - col. 5:16). A defendant could argue that to be a "clamping means" under the patent, an accused component must possess more of these disclosed features beyond just the length/width relationship recited in the claim.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants "directly or indirectly infringe" (Compl. ¶53) and seeks to enjoin acts of "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl., Prayer for Relief ¶a.iv). The factual basis for inducement could be inferred from the allegation that Defendants sell products with instructions. An image in the complaint for the "Vvlsws" product contains text and diagrams that could be construed as instructions for use, such as "Rotate the bolt, the plate will rotate with it." (Compl. p. 12).
- Willful Infringement: The complaint alleges that Defendants' infringement "has been and continues to be willful." (Compl. ¶55). The pleading states Defendants acted "knowingly and willfully" (Compl. ¶44), but provides no specific factual basis for pre-suit knowledge. The claim for willfulness appears to rely on the notice provided by the lawsuit itself for establishing post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of evidentiary sufficiency: can the Plaintiff, relying primarily on publicly available e-commerce listings, produce sufficient evidence to prove that the accused products meet every structural and dimensional limitation of the asserted claims? Key factual questions, such as whether the "clamping means" has the specific length/width-to-hole-size ratio required by ’259 Claim 1, may be difficult to resolve without physical inspection.
- The case will also turn on a question of claim construction: can the term "bond" in ’272 Claim 1, which the specification only discloses as a "weld," be construed more broadly to cover other methods of fixing a fastener to a plate? The answer will determine the scope of the claim and the viability of potential non-infringement arguments.
- Finally, a key practical question is one of enforceability: given that the lawsuit targets a large group of foreign-based, potentially anonymous e-commerce sellers identified on a sealed schedule, the primary challenge for the Plaintiff may not be proving infringement on the merits, but rather effectively obtaining jurisdiction over and enforcing any resulting judgment against these diffuse and transient entities.