DCT
1:21-cv-04756
Stahls v. Kolormatrix LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Stahls' Inc., d/b/a GroupeSTAHL (Michigan)
- Defendant: Kolormatrix, LLC (Georgia)
- Plaintiff’s Counsel: Fishman Stewart PLLC; Troutman Pepper Hamilton Sanders LLP
- Case Identification: 1:21-cv-04756, N.D. Ga., 11/17/2021
- Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because the Defendant is organized under Georgia law, maintains a regular and established place of business in the district, and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s dual-station heat transfer presses infringe a patent related to a dual shuttle press design that improves operator efficiency.
- Technical Context: The technology relates to heat presses used in the custom apparel and promotional products industries to apply graphics, letters, and logos to garments and other workpieces.
- Key Procedural History: The complaint alleges that Plaintiff’s own commercial product, the "DUAL FUSION Heat Press," is marked as being protected by the patent-in-suit. This may be relevant to questions of notice for damages calculations.
Case Timeline
| Date | Event |
|---|---|
| 2014-04-02 | ’960 Patent Priority Date |
| 2016-03-22 | ’960 Patent Issue Date |
| 2021-06-18 | Plaintiff accessed Defendant's product listings online |
| 2021-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,289,960 - "Dual Shuttle Press"
- Patent Identification: U.S. Patent No. 9,289,960, "Dual Shuttle Press", issued March 22, 2016.
The Invention Explained
- Problem Addressed: Conventional heat presses have significant downtime. An operator is typically idle while a workpiece is being cured under heat and pressure. Conversely, the press is idle while the operator removes the finished product and positions the next workpiece. This "increase[s] the overall production times and costs" (’960 Patent, col. 1:50-53). Using a second, separate heat press to improve efficiency is costly and requires additional space (’960 Patent, col. 1:53-59).
- The Patented Solution: The invention is a single heat press with two lower platens (workstations) and one upper platen (the heating element) that moves between them. The upper platen is part of a press mechanism mounted on a "shuttle mechanism" that "move[s] the press mechanism linearly between a first position... and a second position" (’960 Patent, col. 2:8-12). This design allows an operator to prepare a workpiece on one lower platen while the other is being pressed, thereby reducing idle time for both the operator and the machine (’960 Patent, col. 9:15-24). FIG. 1 of the patent illustrates the overall assembly with the upper platen (22) positioned over one of two lower platens (14, 18).
- Technical Importance: This dual shuttle design allows for nearly continuous operation, aiming to increase production throughput without the capital expense and physical footprint of a second complete heat press machine (’960 Patent, col. 1:50-59).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1 (Compl. ¶19).
- Independent Claim 1 of the ’960 Patent recites the following essential elements:
- a frame;
- first and second lower platens supported by the frame;
- an upper platen;
- a press mechanism coupled to the upper platen and operable to move the upper platen between a closed position and an open position;
- a shuttle mechanism supported by the frame and configured to move the press mechanism linearly between a first position wherein the upper platen is located above the first lower platen, and a second position wherein the upper platen is located above the second lower platen;
- a heating element configured to heat the upper platen.
- The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.
III. The Accused Instrumentality
Product Identification
The accused products are Defendant's heat presses, including models UHP-20MD ("Microtec 16 x 20 auto open – dual slide platen heat transfer press") and UHP-15MD ("Microtec 15 x 15 auto open – dual slide platen heat transfer press") (Compl. ¶14).
Functionality and Market Context
Based on the product descriptions and images provided in the complaint, the accused products are heat transfer presses featuring two lower work surfaces, or platens, and a single upper heating assembly that moves between them (Compl. ¶14). A screenshot from Defendant's website shows the accused UHP-20MD product, which has two distinct lower platens and an upper press assembly positioned over one of them (Compl. p. 8). Another screenshot from an eBay listing describes the UHP-15MD model as having "DUAL Sliding Platens" (Compl. p. 9). The complaint alleges these products are sold to compete with Plaintiff's own "DUAL FUSION Heat Press" (Compl. ¶16).
IV. Analysis of Infringement Allegations
The complaint states that a detailed infringement claim chart for Claim 1 has been prepared but does not attach it, noting it will be provided to the Court upon request (Compl. ¶19). The infringement theory can be inferred from the complaint's narrative and the visual evidence provided. A screenshot from Plaintiff's website shows its own "Dual Air Fusion IQ® Heat Press" (Compl. p. 5), and a subsequent screenshot notes this product is "protected by U.S. Patent No: 9,289,960" (Compl. p. 6). The infringement theory is that the accused products, shown in screenshots from Defendant's website and an eBay listing (Compl. pp. 8-9), embody the same patented configuration.
’960 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a frame; | The overall structural body of the accused heat presses, visible in product images. | ¶14, p. 8 | col. 4:33 |
| first and second lower platens supported by the frame; | The two lower work surfaces, described as "dual slide platen" in product marketing. | ¶14 | col. 4:51-66 |
| an upper platen; | The heated upper element that is lowered to apply pressure to a workpiece on one of the lower platens. | ¶14, p. 8 | col. 5:58 |
| a press mechanism coupled to the upper platen and operable to move the upper platen between a closed position and an open position...; | The component of the upper assembly that moves the upper platen vertically to apply and release pressure. | ¶14, p. 8 | col. 6:16-29 |
| a shuttle mechanism supported by the frame and configured to move the press mechanism linearly between a first position ... and a second position...; | The mechanism, described in marketing as "dual slide," that moves the entire upper heating and press assembly horizontally between the two lower platen stations. | ¶14, p. 9 | col. 6:37-45 |
| a heating element configured to heat the upper platen. | The component within the upper platen that generates heat for the transfer process. | ¶14, p. 8 | col. 6:1-4 |
Identified Points of Contention
- Scope Questions: A central dispute may involve the proper construction of "shuttle mechanism." The patent discloses a specific embodiment using rails and linear bearings (col. 6:37-55). The question will be whether the claim term is limited to such a structure or can read on other mechanical arrangements that perform a similar "shuttling" function.
- Technical Questions: The claim requires the "shuttle mechanism" to "move the press mechanism linearly." A factual question for the court will be whether the accused products' upper assembly, which contains the pressing components, is moved "linearly" and whether the entire "press mechanism" is moved as a unit, as depicted in the patent's figures and description.
V. Key Claim Terms for Construction
Key Claim Term: "shuttle mechanism"
- Context and Importance: This term is the core of the invention, distinguishing it from single-station presses. Its construction will determine whether the accused products, described as having "dual slide platens" (Compl. ¶14), fall within the scope of the claims. Practitioners may focus on this term because the patent's specific disclosure of a rail-and-carriage system (col. 6:37-55) could be used by a defendant to argue for a narrow construction that its product avoids.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself uses the general term "shuttle mechanism" without specifying its components, suggesting any mechanism that shuttles the press assembly could be covered. The abstract also refers generally to a "shuttle mechanism" that can "move the press mechanism linearly" (’960 Patent, Abstract).
- Evidence for a Narrower Interpretation: The detailed description explains the shuttle mechanism with specific reference to a "front rail 250, a rear rail 254, a set of front sliders or blocks 258, a set of rear sliders or blocks 262, a plurality of keeper members 266, a carriage 270," and a "linear actuator 278" (’960 Patent, col. 6:37-55). A defendant may argue that these details define and limit the scope of the term.
Key Claim Term: "move the press mechanism linearly"
- Context and Importance: This phrase dictates the required function and relationship between the shuttle and press mechanisms. Infringement will hinge on whether the accused product's "dual slide" feature moves the entire upper pressing assembly in a linear path between the two workstations.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is relatively general. An argument could be made that any horizontal movement in a straight line, regardless of the specific components achieving it, meets the "linearly" requirement.
- Evidence for a Narrower Interpretation: The patent consistently depicts the entire "upper arm 26," which includes the "press mechanism 218," moving as a single unit along a linear axis (62) on a carriage system (’960 Patent, FIG. 1, FIG. 3, col. 6:5-15). This could support an interpretation that the entire press mechanism structure must be transported, not just that its effective location changes.
VI. Other Allegations
Indirect Infringement
The complaint alleges contributory and induced infringement, stating Defendant's actions have caused others to infringe (Compl. ¶18, Requested Relief ¶b). The factual basis for this is not specified but would likely rely on allegations that Defendant sells the accused presses knowing they will be used in an infringing manner.
Willful Infringement
The complaint alleges that Defendant’s infringement was "intentionally, willfully and/or deliberately" carried out, seeking treble damages (Compl. ¶22, ¶23). The complaint does not allege any specific facts to support pre-suit knowledge, such as a cease-and-desist letter. It does, however, plead that Plaintiff's own product is marked with the patent number (Compl. ¶12), which could be used to argue constructive notice.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: will the term "shuttle mechanism" be interpreted broadly to cover any system that moves a press head between two stations, or will it be narrowed to the specific rail, block, and carriage embodiment detailed in the patent’s specification? The outcome of this question may be dispositive of infringement.
- A key evidentiary question will be one of technical operation: can the Plaintiff demonstrate that the accused "dual slide" products in fact "move the press mechanism linearly" as required by the claim? While product marketing and visuals suggest a functional similarity, the case may turn on a detailed mechanical analysis of how the accused products actually operate compared to the specific requirements of the asserted claim.