DCT
1:25-cv-22220
Metzfab Industries LLC v. Individuals Corps Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Metzfab Industries, LLC (Arizona) and Brandon Metzger (Arizona)
- Defendant: The Individuals, Corporations, Limited Liability Companies, Partnerships, and Unincorporated Associations Identified on Schedule A (jurisdictions unspecified, alleged to be primarily in the People's Republic of China)
- Plaintiff’s Counsel: Boies Schiller Flexner LLP
- Case Identification: 1:25-cv-22220, S.D. Fla., 05/14/2025
- Venue Allegations: Venue is asserted on the basis that the defendants are foreign entities who may be sued in any judicial district, and on the allegation that they have committed acts of infringement and have regular and established places of business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ online sales of automotive dipstick adapter repair kits via e-commerce platforms infringe two patents related to dipstick adapter assemblies that can be installed without removing a vehicle's oil pan.
- Technical Context: The technology provides a mechanical assembly for replacing a failed factory-installed dipstick adapter, designed to avoid a costly and time-consuming repair that would otherwise require removing the engine's oil pan.
- Key Procedural History: The complaint does not reference any prior litigation or post-grant validity challenges concerning the patents-in-suit. U.S. Patent No. 9,671,272 is a continuation of the application that issued as U.S. Patent No. 9,285,259, indicating a shared specification and priority date.
Case Timeline
| Date | Event |
|---|---|
| 2012-12-14 | Earliest Priority Date for ’259 and ’272 Patents |
| 2016-03-15 | ’259 Patent Issued |
| 2017-06-06 | ’272 Patent Issued |
| 2025-05-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,671,272 - "DIPSTICK ADAPTER ASSEMBLY"
The Invention Explained
- Problem Addressed: The patent describes an issue with factory-installed dipstick adapters in vehicle oil pans, which are prone to failure where parts of the adapter can fall into the oil pan. Retrieving these parts conventionally requires removing the oil pan and often the engine, which is described as a "very time-consuming and expensive process" (’272 Patent, col. 1:31-34).
- The Patented Solution: The invention is a replacement dipstick adapter assembly that can be installed entirely from outside the oil pan. It consists of an external "front fixture" and an internal "clamping means" (a backing plate), which are maneuvered through the hole in the oil pan and then tightened together using two fasteners, clamping the assembly onto the oil pan wall and creating a seal (’272 Patent, col. 2:48-62). This design obviates the need for oil pan removal.
- Technical Importance: This approach significantly reduces the labor, time, and expense associated with repairing a common automotive failure point (’272 Patent, col. 2:35-37).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶45).
- Claim 1 of the ’272 Patent recites the essential elements of the assembly:
- An oil pan with 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 to move the clamping means toward the front fixture.
- The clamping means is "moveable through the hole" to be positioned inside the oil pan.
- In its final applied condition, the front fixture encircles and seals the hole against the outer surface of the oil pan.
- The complaint generally alleges infringement of "one or more claims" in the patents-in-suit, suggesting the right to assert additional claims may be reserved (Compl. ¶¶1, 53).
U.S. Patent No. 9,285,259 - "DIPSTICK ADAPTER ASSEMBLY"
The Invention Explained
- Problem Addressed: The ’259 Patent addresses the same technical problem as the ’272 Patent: the difficulty and expense of replacing factory dipstick adapters when parts fall inside a vehicle's oil pan (’259 Patent, col. 1:24-41).
- The Patented Solution: The solution is also an externally-installed adapter assembly. This patent's claims focus on the specific geometry of the internal clamping component, which is described as having a "length which is larger than the hole and a width... which is a smaller than the hole" (’259 Patent, Claim 1). This dimensional relationship allows the clamping means to be inserted through the hole in one orientation and then rotated or positioned to securely brace against the inside of the oil pan wall.
- Technical Importance: As with the ’272 Patent, this design provides a practical, cost-effective alternative to a major engine repair (’259 Patent, col. 2:30-32).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶45).
- Claim 1 of the ’259 Patent recites the essential elements of the assembly:
- An oil pan with a hole.
- A front fixture larger than the hole.
- Clamping means coupled to the front fixture, having a length larger than the hole and a width smaller than the hole.
- The clamping means is "moveable through the hole" to be positioned inside the oil pan.
- In its final applied condition, the front fixture encircles and seals the hole against the outer surface of the oil pan.
- The complaint also generally alleges infringement of "one or more claims" (Compl. ¶¶1, 53).
III. The Accused Instrumentality
Product Identification
- The accused products are identified as "Dipstick Adapter Repair Kit[s]" sold by various unnamed defendants through online e-commerce stores on platforms such as eBay.com (Compl. ¶¶3, 45).
Functionality and Market Context
- The complaint alleges the accused products are "inferior imitations" of Plaintiffs' own products, designed to function as replacement dipstick adapters for specific Ford vehicles, such as the 7.3L Powerstroke engine series (Compl. ¶¶4, 45). An image in the complaint shows one such accused product advertised as "FIT FOR FORD" (Compl. p. 10). The complaint alleges that Defendants are e-commerce operators, primarily based in China, who directly compete with Plaintiffs by selling these infringing products to consumers in the United States (Compl. ¶¶20, 22).
IV. Analysis of Infringement Allegations
’971,272 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... | The accused product is a repair kit for use with a vehicle's oil pan. | ¶45 | col. 1:16-21 |
| a front fixture; | The accused product includes an external circular component with a central bore for the dipstick, shown in an online product listing (Compl. p. 10). | ¶45 | col. 2:50 |
| clamping means coupled to the front fixture; | The accused product includes an internal backing plate component that is coupled to the front fixture by fasteners. | ¶45 | col. 2:50-51 |
| 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 allegedly utilizes fasteners to connect the front and internal components. | ¶45 | col. 6:1-14 |
| a second fastener applied to the front fixture for application to the clamping means... | The accused product allegedly utilizes a second fastener to tighten the assembly. | ¶45 | col. 6:49-51 |
| the clamping means is moveable through the hole... | The internal component of the accused product is allegedly designed to pass through the oil pan hole for installation from the outside. | ¶45 | col. 6:6-18 |
| the front fixture encircles the hole in direct contact against the outer Surface of the oil pan and is sealed around the hole. | The external component of the accused product is shown with what appear to be gaskets or O-rings to create a seal around the oil pan hole. | ¶45 | col. 8:14-17 |
’9,285,259 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... | The accused product is a repair kit for use with a vehicle's oil pan. | ¶45 | col. 1:16-21 |
| a front fixture larger than the hole; | The accused product includes an external circular component that is necessarily larger than the oil pan hole it is designed to cover, as depicted in a product image (Compl. p. 11). | ¶45 | col. 7:63-64 |
| 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; | The internal backing plate of the accused product allegedly has dimensions allowing it to be inserted through the oil pan hole width-wise and then positioned to span the hole length-wise. | ¶45 | col. 5:10-15 |
| the clamping means is moveable through the hole... | The internal component of the accused product is allegedly designed to pass through the oil pan hole for installation from the outside. | ¶45 | col. 6:6-20 |
| the front fixture encircles the hole in direct contact against the outer surface of the oil pan and is sealed around the hole. | The external component of the accused product is shown with O-rings, which are alleged to create a seal when installed. | ¶45 | col. 8:14-17 |
- Identified Points of Contention:
- Scope Questions: The complaint makes allegations against a class of unnamed defendants based on exemplary product listings. A threshold issue for each defendant, once identified, will be proving that the specific product they sell meets every limitation of the asserted claims.
- Technical Questions: For the ’272 Patent, a key question will be whether the accused product's first fastener is "fixed to the clamping means with a bond to prevent rotation." The complaint does not provide evidence, such as detailed schematics or physical inspection results, to substantiate this specific structural feature. For the ’259 Patent, a dispositive question will be whether the accused product's internal "clamping means" meets the specific dimensional requirements of having a "length... larger than the hole" and a "width... smaller than the hole," which would require measurement of both the part and the corresponding oil pan hole.
V. Key Claim Terms for Construction
The Term: "bond" (’272 Patent, Claim 1)
Context and Importance: This term is critical to distinguishing the claimed invention, as it describes the mechanism that prevents the internal clamping plate from spinning freely while the external fastener is tightened. Infringement may turn on whether this term is construed narrowly to its specific embodiment (a weld) or more broadly to cover other non-rotation mechanisms. Practitioners may focus on this term because the complaint's visual evidence does not show how, or if, such a bond is implemented in the accused products.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the generic term "bond" without further limitation. Plaintiff may argue this term should be given its plain and ordinary meaning, covering any method of fixing the components together, including adhesives, mechanical interlocks, or friction fitting.
- Evidence for a Narrower Interpretation: The specification provides only one example 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" (’272 Patent, col. 6:8-10). A defendant may argue that the claim term should be limited to this disclosed embodiment or methods functionally equivalent to a weld.
The Term: "clamping means" (’259 and ’272 Patents, Claim 1)
Context and Importance: This term defines the internal component that secures the assembly from inside the oil pan. Its geometry and interaction with the front fixture are central to the invention's ability to be installed externally. The scope of this functional term will be important in determining infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is functional, and the specification consistently refers to this component as the "backing plate 11" (’272 Patent, col. 4:51). Plaintiff may argue the term covers any structure that performs the function of clamping from inside the oil pan when coupled to the front fixture via fasteners.
- Evidence for a Narrower Interpretation: The specification describes the "clamping means" with significant structural detail, including "two wings 80 and 81" and a central "hold 90" that receives a "protuberance 50" from the front fixture (’272 Patent, col. 4:36-39, col. 5:2-4). A defendant may argue that these disclosed structural features are essential to the meaning of "clamping means" and are not merely exemplary.
VI. Other Allegations
- Indirect Infringement: The complaint makes a passing allegation of direct or indirect infringement but does not plead specific facts to support the knowledge and intent required for a claim of induced or contributory infringement (Compl. ¶53). The prayer for relief seeks to enjoin "aiding, abetting, contributing to, or otherwise assisting anyone in infringing" (Compl. p. 14).
- Willful Infringement: The complaint asserts that Defendants' infringement "has been and continues to be willful" (Compl. ¶55). The factual basis for this allegation appears to be conclusory, as the complaint does not allege that any defendant had pre-suit knowledge of the patents-in-suit. Knowledge is alleged generally, upon information and belief (Compl. ¶44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary challenge in this case will be one of identification and evidence: can the Plaintiff successfully identify the foreign operators of the accused online stores, establish personal jurisdiction, and then secure evidence demonstrating that the specific products sold by each individual defendant embody every limitation of the asserted claims? The current allegations rely on exemplary marketing images, which may not be sufficient to prove infringement of detailed claim limitations.
- A central technical dispute will be one of structural correspondence: do the accused products actually possess the specific mechanical features required by the claims? In particular, the case may turn on whether evidence shows the existence of a "bond to prevent rotation" as required by the ’272 patent, and whether the components meet the precise length-to-width-to-hole-size geometric relationships required by the ’259 patent.