Complaint

## I. Executive Summary and Procedural Information

*   **Parties & Counsel:**
    *   **Plaintiff:** [Cki 2712218 LLC](https://ai-lab.exparte.com/party/cki-2712218-llc) (Florida)
    *   **Defendant:** [G & L Decor Inc.](https://ai-lab.exparte.com/party/g-and-l-decor-inc) (New York)
    *   **Plaintiff’s Counsel:** [Ingram IP Law, P.A.](https://ai-lab.exparte.com/law-firm/40621/ingram-ip-law)
*   **Case Identification:** [9:24-cv-81447](https://ai-lab.exparte.com/case/dct/flsd/9:24-cv-81447/cki-2712218-llc-v-g-l-decor-inc), S.D. Fla., 11/19/2024
*   **Venue Allegations:** Venue is alleged to be proper because a substantial part of the complained-of acts, including targeting sales to and selling products to residents of Florida, occurred in the judicial district, and the alleged injuries are felt there.
*   **Core Dispute:** Plaintiff alleges that Defendant’s Mattress Lifter Tool products, sold on Amazon.com and other websites, infringe a patent related to an apparatus and method for lifting a mattress.
*   **Technical Context:** The technology concerns handheld tools designed to reduce the physical strain of making a bed by creating a wedge between a mattress and its support structure to facilitate tucking in linens.
*   **Key Procedural History:** Plaintiff alleges it became the exclusive assignee of the patent-in-suit on August 30, 2024, with rights to sue for past infringement. The complaint also notes that on February 20, 2024, Plaintiff initiated an Amazon Patent Evaluation Express (APEX) proceeding, which allegedly provided Defendant with actual notice of the patent and the infringement allegations.

#### Case Timeline

| **Date** | **Event** |
|:---|:---|
| 2008-10-14 | U.S. Patent No. [8,191,191](https://ai-lab.exparte.com/patent/8191191) Priority Date |
| 2012-06-05 | U.S. Patent No. [8,191,191](https://ai-lab.exparte.com/patent/8191191) Issued |
| 2020-08-11 | Defendant allegedly registered domain <www.lerazedecor.com> |
| 2024-02-20 | Plaintiff initiated Amazon APEX notice to Defendant |
| 2024-08-30 | ['191](https://ai-lab.exparte.com/patent/8191191) Patent assigned to Plaintiff |
| 2024-11-19 | Complaint Filed |

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

### U.S. Patent No. 8,191,191 - *Apparatus And Method For Lifting A Mattress*

#### The Invention Explained
*   **Problem Addressed:** The patent’s background section describes that mattresses are bulky and heavy, and lifting them to tuck in bed linens can result in physical strain, fatigue, and injury, particularly for housekeepers in the hospitality industry who perform this task repeatedly ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 1:28-48).
*   **The Patented Solution:** The invention is a wedge-shaped apparatus that is inserted between a mattress and its underlying support structure (e.g., a box spring) to elevate a portion of the mattress ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 2:3-11). As described in the detailed description, the apparatus is formed by several members—a base, an incline, a transition, and a handle—that create a "continuous loop" for structural strength and provide a grip for the user ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 4:52-68; Fig. 1). This design allows a user to lift the mattress with less effort and hold it in a raised position to tuck in sheets ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, Fig. 7).
*   **Technical Importance:** The invention provides a simple, lightweight, single-piece tool with no moving parts to make the physically demanding task of bed-making safer and more efficient ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 2:1-3).

#### Key Claims at a Glance
*   The complaint asserts independent apparatus Claim 11 and independent method Claim 19 (Compl. ¶21).
*   **Independent Claim 11 (Apparatus):**
    *   a base member having a first base end and a second base end
    *   an incline member having a first incline end and a second incline end, mechanically coupled to and forming an acute angle with the first base end
    *   a transition member having a first transition end and a second transition end, mechanically coupled to the second incline end
    *   a handle having a first handle end and a second handle end, with the ends fixedly coupled to the second transition end and the second base end, respectively
    *   a continuous loop defined by the base member, the incline member, the transition member and the handle
    *   an aperture defined within the continuous loop
    *   at least one support rib provided within the aperture to mechanically couple the base member and at least one of the incline member and the transition member
*   The complaint does not explicitly reserve the right to assert dependent claims but makes a general allegation of infringement of "one or more claims" (Compl. ¶28).

## III. The Accused Instrumentality

### Product Identification
The accused products are identified as the "Mattress Lifter Tool" sold under the brand name "Bed Master" on an Amazon.com storefront and a similar tool sold on the website www.lerazedecor.com (Compl. ¶¶11, 12).

### Functionality and Market Context
The complaint alleges the accused products are tools that embody the [’191](https://ai-lab.exparte.com/patent/8191191) Patent's invention for lifting a mattress (Compl. ¶¶11-12). Visual evidence provided in the complaint shows a wedge-shaped plastic tool with an integrated handle, designed to be inserted between a mattress and box spring. The product listing on lerazedecor.com describes the tool as one that "helps-lift-and-hold-the-mattress" to alleviate back strain when changing sheets (Compl. Ex. C). A screenshot from an Amazon.com product page shows a visually similar "Mattress Lifter Tool" (Compl. Ex. B). The complaint alleges Defendant targets United States consumers, including those in Florida, through these e-commerce channels (Compl. ¶¶8, 15).

## IV. Analysis of Infringement Allegations

The complaint alleges that the accused "Unauthorized Product" infringes at least Claim 11 and Claim 19 but does not provide a detailed element-by-element analysis or claim chart (Compl. ¶21). The following chart summarizes the infringement theory for Claim 11 based on the complaint's general allegations and visual exhibits.

#### '191 Patent Infringement Allegations

| **Claim Element (from Independent Claim 11)** | **Alleged Infringing Functionality** | **Complaint Citation** | **Patent Citation** |
|:---|:---|:---|:---|
| a base member having a first base end and a second base end, the first base end being located opposite to the second base end; | The flat bottom surface of the accused tool that rests on the box spring. | ¶¶11-12, Ex. B, C | col. 4:6-15 |
| an incline member having a first incline end and a second incline end...mechanically coupled to and forming an acute angle with the first base end; | The sloped upper surface of the accused tool that lifts the mattress, forming a wedge shape with the base member. | ¶¶11-12, Ex. B, C | col. 4:16-25 |
| a transition member having a first transition end and a second transition end...mechanically coupled to the second incline end; | The curved portion of the tool connecting the incline member to the handle. | ¶¶11-12, Ex. B, C | col. 4:31-36 |
| a handle having a first handle end and a second handle end...fixedly coupled to the second transition end and...the second base end; | The integrated gripping portion of the accused tool. | ¶¶11-12, Ex. B, C | col. 4:55-63 |
| a continuous loop defined by the base member, the incline member, the transition member and the handle; | The overall structure of the accused tool, which forms a closed shape. | ¶¶11-12, Ex. B, C | col. 4:65-68 |
| an aperture defined within the continuous loop; | The open space within the tool's handle and body. | ¶¶11-12, Ex. B, C | col. 5:22-30 |
| at least one support rib provided within the aperture to mechanically couple the base member and at least one of the incline member and the transition member. | The complaint does not provide sufficient detail for analysis of this element, as the visual evidence does not clearly show the internal structure of the accused tool. | ¶21 | col. 5:31-48 |

*   **Identified Points of Contention:**
    *   **Scope Questions:** A central question may be whether the term "mechanically coupled," used to describe the connection between the base, incline, and transition members, can be construed to cover a device manufactured as a single, unitary piece, as the accused product appears to be. The patent specification contemplates both multi-piece and single-mold construction, which may inform this analysis ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 3:41-64).
    *   **Technical Questions:** A key evidentiary issue will be whether the accused product contains "at least one support rib" as required by Claim 11. The visual evidence in the complaint is insufficient to confirm the presence of this feature, and its absence could be a basis for a non-infringement argument.

## V. Key Claim Terms for Construction

*   **The Term:** "mechanically coupled"
*   **Context and Importance:** This term appears multiple times in Claim 11 to describe the relationship between the tool's constituent members (base, incline, transition). Its construction is critical because the accused product appears to be a single piece of molded plastic. Defendant may argue that "mechanically coupled" implies the joining of separate components, while Plaintiff may argue it encompasses elements that are integrally formed.
*   **Intrinsic Evidence for Interpretation:**
    *   **Evidence for a Broader Interpretation:** The specification suggests the components may be formed together, stating "the base member 106, the incline member 108, the nose member 110, the transition member 112 and the handle member 150 may be formed together in a single mold" ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 3:58-60). This could support a construction that includes integrally formed parts.
    *   **Evidence for a Narrower Interpretation:** The specification also explicitly discusses multi-piece fabrication, stating the apparatus "may be fabricated from a plurality of pieces that are mechanically coupled" using "adhesive, welding, or other fastening technique" ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 3:47-51). This language could support a narrower construction requiring distinct, joined components.

*   **The Term:** "at least one support rib"
*   **Context and Importance:** This is the final structural limitation of Claim 11. Practitioners may focus on this term because its presence or absence is a dispositive factual question for infringement. The complaint does not provide clear visual or descriptive evidence showing this feature on the accused product.
*   **Intrinsic Evidence for Interpretation:**
    *   **Evidence for a Broader Interpretation:** The patent depicts a "rib 302" as a structural element spanning the interior of the aperture to connect the base and incline members, providing "increased structural support" ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, col. 5:36-41; Fig. 3). This provides a clear example of the term's meaning.
    *   **Evidence for a Narrower Interpretation:** Claim 11 requires the rib to "mechanically couple the base member and at least one of the incline member and the transition member." An embodiment in Figure 5 shows a reinforcing member (502) and a separate rib (504), suggesting a distinction between different types of internal supports ([ʼ191](https://ai-lab.exparte.com/patent/8191191) Patent, Fig. 5). If the accused product has some form of internal bracing that does not fit the specific function or structure of the "support rib" as described, it could support a non-infringement position.

## VI. Other Allegations

*   **Indirect Infringement:** The complaint alleges inducement of infringement under 35 U.S.C. § 271(b), asserting that Defendant actively induces others (presumably customers) to use the accused product in an infringing manner (Compl. ¶35). The complaint does not, however, identify specific instructions or user manuals that direct this use.
*   **Willful Infringement:** The willfulness allegation is based on alleged pre-suit knowledge of the [’191](https://ai-lab.exparte.com/patent/8191191) Patent (Compl. ¶29). The complaint provides a specific factual basis for this knowledge, citing an Amazon Patent Evaluation Express (APEX) notice sent to Defendant on February 20, 2024, which allegedly identified the patent and the accused product (Compl. ¶22). The allegation of continued sales after this date forms the core of the willfulness claim (Compl. ¶¶23, 32).

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

1.  A central issue will be one of **claim construction:** can the term "mechanically coupled," which appears throughout Claim 11, be construed to read on a device fabricated as a single, unitary piece of plastic, or does it require the joining of separate and distinct components?
2.  The case will also turn on a key **evidentiary question:** does the accused Mattress Lifter Tool possess the "at least one support rib" required by Claim 11? The complaint's evidence is silent on this point, making it a critical area for discovery and a potential basis for a straightforward non-infringement defense.
3.  A significant question regarding damages will be the **impact of pre-suit notice:** did the Amazon APEX proceeding on February 20, 2024, provide Defendant with actual knowledge of infringement, and if so, does the alleged continued sale of the accused product thereafter constitute willful infringement sufficient to support enhanced damages?

Complaint Analysis

Complaint PDF

Amazon patent notice sparks willfulness claims against G&L Decor's Mattress Lifter Tool, accused over patents on its `continuous loop` wedge design.

Prosecution History analysis

9:24-cv-81447

Cki 2712218 LLC v. G & L Decor Inc