Oerlikon Textile GmbH & Co KG v. Precision Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Oerlikon Textile GmbH & Co. KG (Germany)
  • Defendant: Precision Products Inc. (Georgia, U.S.)
  • Plaintiff’s Counsel: Alston & Bird LLP; Greenblum & Bernstein, P.L.C.
• Case Identification: 1:25-cv-05525, N.D. Ga., 09/26/2025
• Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because the Defendant resides there, has a regular and established place of business, and has committed alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s replica machine parts for textile manufacturing systems infringe a patent related to a device for pneumatically guiding multifilament threads.
• Technical Context: The technology at issue involves nozzles used in high-speed textile manufacturing to convey synthetic threads using compressed air, a critical process in producing materials like carpet yarns.
• Key Procedural History: The complaint alleges that Plaintiff first contacted Defendant regarding potential infringement on March 5, 2020. Following further correspondence in February 2022, Defendant’s counsel denied infringement, a position Plaintiff now alleges was a misrepresentation. These pre-suit communications form the basis for the willfulness allegations.

Case Timeline

Date	Event
2013-02-28	U.S. Patent No. 9,631,300 Priority Date
2017-04-25	U.S. Patent No. 9,631,300 Issued
2020-03-05	Plaintiff first contacted Defendant alleging potential infringement
2022-02-09	Plaintiff contacted Defendant again, alleging infringement
2022-02-23	Defendant's counsel denied infringement in a letter
2025-09-26	Complaint Filed

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

U.S. Patent No. 9,631,300 - Device for Pneumatically Conveying and Guiding a Multifilament Thread

• Patent Identification: U.S. Patent No. 9,631,300, Device for Pneumatically Conveying and Guiding a Multifilament Thread, issued April 25, 2017.

The Invention Explained

• Problem Addressed: In pneumatic systems for guiding threads, high-pressure compressed air is used to propel the thread through a conveying duct. A portion of this air can flow backward out of the thread inlet opening, creating a "return stream" that can hamper the entry of the thread and entangle broken filaments (’300 Patent, col. 1:12-26).
• The Patented Solution: The invention introduces a "return stream duct" that opens into the main conveying duct, positioned between the thread inlet and the compressed air injectors. This secondary duct is designed to capture the problematic return stream and vent it to the ambient atmosphere, preventing it from interfering with the incoming thread (’300 Patent, col. 1:56-65; Abstract). The geometry of the duct, including an inclined orientation and a "rounded transition face," is configured to leverage aerodynamic principles (the Coandă effect) to efficiently divert the airflow (’300 Patent, col. 2:13-21, Fig. 1).
• Technical Importance: This solution allows for the use of higher compressed-air pressures, enabling faster and more reliable thread conveyance, while minimizing operational problems like filament entanglement that can disrupt high-speed manufacturing processes (’300 Patent, col. 1:48-52).

Key Claims at a Glance

• The complaint asserts independent claim 1 and notes the right to assert other claims, such as claim 9 (Compl. ¶28, ¶32).
• Independent Claim 1:
  • A device for pneumatically conveying a multifilament synthetic thread, comprising:
  • a closed conveying duct with a thread inlet opening at a first end and a thread outlet opening at a second end;
  • at least one compressed-air duct that opens into the conveying duct in an injector zone;
  • a return stream duct opening into a portion of the conveying duct (between the thread inlet and the compressed-air duct mouth) that connects the conveying duct to an ambient atmosphere;
  • wherein the return stream duct opens out with an inclination in the conveying direction; and
  • wherein a mouth of the return stream duct is configured with a rounded transition face between the return stream duct and the conveying duct.

III. The Accused Instrumentality

Product Identification

The accused products are multiple models of replica nozzles, identified by internal designators (e.g., 05-128, 09-123), offered for sale on Defendant's website (Compl. ¶25).

Functionality and Market Context

The complaint alleges these products are "knock-off 'replica' Neumag parts" designed to function as replacement components for Plaintiff's Oerlikon Neumag brand textile machinery (Compl. ¶18). Defendant’s website is alleged to have a dedicated section titled "Parts for Neumag," which the complaint provides as visual evidence. This screenshot from Defendant's website shows its branding alongside a menu option for "Parts for Neumag" (Compl. p. 4). The complaint asserts that after obtaining a physical sample of one of these replica nozzles, Plaintiff confirmed that it infringes the ’300 Patent (Compl. ¶23).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products meet each limitation of at least claim 1 of the ’300 Patent (Compl. ¶31). It states that a detailed "Infringement Claim Chart" is attached as Exhibit 5 and incorporated by reference; however, this exhibit was not filed with the complaint (Compl. ¶32). The infringement theory is therefore based on the narrative assertion that Defendant makes and sells "replica" nozzles and that a physical inspection of one such nozzle confirmed infringement (Compl. ¶18, ¶23). The complaint includes a copy of Figure 1 from the ’300 Patent to illustrate the general configuration of the claimed nozzle (Compl. ¶29, p. 7). Without the referenced claim chart, the complaint does not provide a public, element-by-element mapping of the accused product features to the claim limitations.

Identified Points of Contention

• Evidentiary Question: A central issue will be whether discovery confirms Plaintiff's allegation that the Accused Products are true "replicas" that practice every element of the asserted claims. The analysis will depend on evidence comparing the precise geometry of the accused nozzles to the claimed features, such as the "inclination" of the return stream duct and the presence of a "rounded transition face."
• Scope Question: The dispute may turn on whether any structural differences between the accused nozzles and the patent's specific embodiments are sufficient to place the products outside the scope of the claims. For example, a question may arise as to whether a particular surface on an accused nozzle constitutes a "rounded transition face" as that term is understood in the context of the patent.

V. Key Claim Terms for Construction

Term: "a return stream duct opening into a duct portion of the conveying duct, between the thread inlet opening and a mouth of the compressed-air duct"

• Context and Importance: This term defines the specific location and connectivity of the key inventive feature. The infringement analysis will depend entirely on whether the accused nozzles have a second duct with this precise placement relative to the main thread path and the air injectors. Practitioners may focus on this term to determine if any venting channel in the accused device meets these structural requirements.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not impose a specific size or angle, only a relative location, which could support a construction that covers various configurations so long as the placement is correct.
  • Evidence for a Narrower Interpretation: Figure 1 of the ’300 Patent illustrates a very specific spatial relationship and geometry for the return stream duct (12) relative to the thread inlet (3) and compressed-air duct mouths (10.1, 10.2) (’300 Patent, Fig. 1). A defendant may argue this embodiment limits the term's scope.

Term: "rounded transition face"

• Context and Importance: This term recites a specific geometric feature at the mouth of the return stream duct. Its construction is critical because the patent links this feature directly to the technical goal of using the Coandă effect to efficiently divert the return air stream. An infringement dispute could center on how "rounded" a surface must be to meet this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification explains the function of this face is to facilitate the Coandă effect, which could support interpreting the term to cover any surface geometry that achieves this aerodynamic function, not just a perfectly radiused curve (’300 Patent, col. 2:13-21).
  • Evidence for a Narrower Interpretation: The patent explicitly identifies this feature as reference number 24 in Figure 1, showing a distinct, smoothly curved surface (’300 Patent, Fig. 1). This specific depiction could be used to argue for a narrower definition limited to shapes closely resembling the drawing.

VI. Other Allegations

Indirect Infringement

The complaint includes a conclusory allegation of indirect infringement (Compl. ¶2; Prayer for Relief ¶A). It does not, however, plead specific facts to support the knowledge and intent elements required for a claim of induced infringement or contributory infringement.

Willful Infringement

The complaint alleges willful infringement based on pre-suit knowledge. It cites a March 5, 2020 communication notifying Defendant of the patent, a follow-up letter on February 9, 2022, and a denial of infringement from Defendant’s counsel on February 23, 2022, which Plaintiff characterizes as a misrepresentation (Compl. ¶19, ¶20, ¶21, ¶34). These allegations suggest Defendant was aware of the patent and the infringement allegations for over five years before the complaint was filed.

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

• A core issue will be one of evidentiary proof: Can the Plaintiff, through discovery, demonstrate that the accused "replica" products incorporate the specific and nuanced geometric features of the asserted claims, such as the precise location of the "return stream duct" and the "rounded transition face," especially given the lack of a detailed public infringement analysis in the complaint?
• A second key question will relate to willfulness: Assuming infringement is found, did the Defendant's continued sales after receiving notice in 2020 and its counsel's subsequent denial of infringement constitute objectively reckless conduct sufficient to justify enhanced damages? The outcome may depend on the reasonableness of Defendant's non-infringement position at that time.