DCT
1:18-cv-05910
REV A Shelf Co LLC v. J & K Cabinetry Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Rev-A-Shelf Company, LLC (Kentucky)
- Defendant: J & K Cabinetry Inc. (Illinois) and J & K 3 Cabinetry Ltd. (New Jersey)
- Plaintiff’s Counsel: Brinks Gilson & Lione
- Case Identification: 1:18-cv-05910, N.D. Ill., 08/31/2018
- Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant J & K Cabinetry Inc. is incorporated and headquartered in the district, and Defendant J & K 3 Cabinetry Ltd. conducts business and has committed alleged acts of infringement in the district through a network of dealers.
- Core Dispute: Plaintiff alleges that Defendants’ cabinet waste container products infringe a patent related to an adjustable mounting apparatus for drawer face panels.
- Technical Context: The technology concerns mechanical hardware for installing cabinet drawers, which is designed to allow for fine adjustments to ensure the drawer front aligns perfectly with the cabinet frame.
- Key Procedural History: The complaint alleges that Defendants had pre-suit knowledge of the patent-in-suit because they previously purchased Plaintiff's own commercial product, which is marked with the patent number, before switching to an alternative supplier for the accused products.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-16 | '576 Patent Priority Date (Filing Date) |
| 2002-05-21 | U.S. Patent No. 6,390,576 Issued |
| 2017-01-01 | Plaintiff begins marking its RVDM bracket with '576 patent number (at least since) |
| 2018-08-31 | Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 6,390,576, "Front Face Mounting Apparatus and Process," issued May 21, 2002.
The Invention Explained
- Problem Addressed: The patent’s background section describes the difficulty of properly aligning a drawer face panel with a cabinet enclosure after installation (’576 Patent, col. 1:19-24). Misalignments in height, pitch, or roll can create a "displeasing appearance" and allow dust and debris to enter the cabinet (’576 Patent, col. 1:45-54). Prior art adjustment methods were often time-consuming, requiring a "trial and error method" of repeatedly adjusting, checking, and re-adjusting the panel (’576 Patent, col. 1:61-65).
- The Patented Solution: The invention is a mechanical apparatus that allows for multi-directional adjustment of a drawer face panel relative to the drawer slide before the mounting hardware is fully tightened (’576 Patent, col. 7:1-9). It consists of a "stand" that attaches to the drawer slide and an "angled bracket" that attaches to the drawer face panel. The interface between the stand and bracket, which uses a system of specifically designed slots and openings, permits the installer to position the drawer panel correctly in a single step and then lock it into place, eliminating the need for iterative adjustments (’576 Patent, Abstract; Fig. 3).
- Technical Importance: The claimed invention sought to reduce installation time and cost by providing a system for achieving precise, multi-directional drawer front alignment without relying on expensive, tight manufacturing tolerances for the cabinet components (’576 Patent, col. 7:9-15).
Key Claims at a Glance
- The complaint asserts infringement of one or more of claims 1-25, with specific allegations directed to independent claims 1 and 21 (Compl. ¶17, ¶18, ¶22).
- Independent Claim 1 recites an apparatus for adjustably mounting a drawer face panel to a drawer slide, comprising:
- A stand having a plurality of holes;
- An angled bracket with two legs, where the first leg has holes and slots, and the second leg has openings that align with the holes in the stand;
- A "first attachment means" for adjustably connecting the angled bracket to the stand; and
- A "second attachment means" for adjustably connecting the stand to the drawer slide.
- Independent Claim 21 recites an improvement in a cabinet drawer system, comprising:
- An "L-shaped stand" fixed to the drawer slide; and
- An angled bracket fixed to the drawer panel, with a second leg that affixes to the L-shaped stand via openings, including a "first slot having a width greater than that of the hole in the stand."
III. The Accused Instrumentality
Product Identification
- The accused products are "waste container products" manufactured, imported, and sold by Defendants (Compl. ¶11, ¶15).
Functionality and Market Context
- The accused products are pull-out drawer assemblies for kitchen or bathroom cabinets, designed to hold waste containers (Compl. ¶15). The allegedly infringing components are the mechanical hardware used to mount the front cabinet door panel to the sliding portion of the assembly (Compl. ¶19-21). An annotated photograph in the complaint shows the accused product installed in a cabinet, with callouts identifying the drawer face panel and the mounting apparatus. (Compl. p. 8, ¶19). The complaint alleges that Defendants previously purchased Plaintiff's patented RVDM bracket product before beginning to sell the accused products from an unknown supplier, suggesting the accused products directly compete with Plaintiff's own offerings (Compl. ¶12).
IV. Analysis of Infringement Allegations
'576 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a drawer face panel having a rear surface including a center and outer lateral extremities, a drawer slide, and apparatus for adjustably mounting the drawer face panel to the drawer slide... | The accused product is alleged to include a drawer face panel, a drawer slide, and an apparatus for adjustably mounting the panel to the slide. | ¶19 | col. 10:52-56 |
| (a) a stand having a plurality of holes; | The accused product includes a component identified as a "stand" which has multiple holes. An annotated photograph identifies this part. | ¶20 | col. 10:57-58 |
| (b) an angled bracket having a first leg, a second leg, a plurality of holes and a plurality of slots in the first leg, and a plurality of openings in the second leg in general alignment with at least some of the plurality of holes in the stand; | The accused product includes an "angled bracket" with a first leg containing holes and slots and a second leg with openings that align with the holes in the stand. | ¶20 | col. 10:59-65 |
| (c) first attachment means engaging at least one of the plurality of openings in the second leg of the angled bracket and at least one of the plurality of holes in the stand for adjustable attaching the angled bracket to the stand; and | A fastener is alleged to engage an opening in the bracket's second leg and a hole in the stand, thereby adjustably attaching the two parts. | ¶21 | col. 11:1-6 |
| (d) second attachment means engaging at least one of the plurality of holes in the stand and the drawer slide for adjustably attaching the stand to the drawer slide. | A fastener is alleged to engage a hole in the stand and the drawer slide to adjustably attach the stand to the slide. | ¶21 | col. 11:7-9 |
Identified Points of Contention
- Scope Questions: Claim 1 recites a "first attachment means" and "second attachment means." These are means-plus-function limitations whose scope is defined by the corresponding structures in the patent specification, namely the specific bolt, screw, and washer assemblies depicted (’576 Patent, Fig. 3), and their legal equivalents. A potential dispute is whether the fasteners used in the accused product are structurally equivalent to those disclosed structures.
- Technical Questions: The complaint's infringement theory relies on a direct structural correspondence between the accused hardware and the claim elements, supported by annotated photographs. A key factual question will be whether the accused components perform the claimed functions in the same way as the patented invention. For claim 21, the analysis will focus on precise geometric relationships, such as whether the accused bracket has a "first slot having a width greater than that of the hole in the stand" and whether the accused stand is properly characterized as "L-shaped" in the context of the patent. An annotated photograph highlights the accused "angled bracket" and its various slots and legs. (Compl. p. 12, ¶24).
V. Key Claim Terms for Construction
The Term: "attachment means" (Claim 1)
Context and Importance: This term appears in means-plus-function format, and its construction will be critical to determining the scope of infringement for Claim 1. Practitioners may focus on this term because the infringement analysis will depend not on whether the accused product has any fastener, but whether it has a fastener that is structurally equivalent to the specific structures disclosed in the patent's specification for performing the stated function of "adjustable attaching."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the function is "adjustably attaching" and that any conventional fastener (e.g., screw, bolt) capable of being loosened and tightened should be considered an equivalent structure.
- Evidence for a Narrower Interpretation: The specification discloses specific structures, including an "adjusting bolt 32" used with a "washer 33" and a "pivot bolt 30" that engage threaded holes to create the adjustable connection (’576 Patent, col. 6:1-11; Fig. 3). A party may argue the term should be limited to this specific combination of components and their very close equivalents.
The Term: "L-shaped stand" (Claim 21)
Context and Importance: Claim 21 is narrower than Claim 1, in part because it requires the "stand" to be "L-shaped." The infringement analysis for this claim will hinge on whether the accused product's stand meets this structural limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the stand as "L-shaped, having a vertical leg, a horizontal leg" (’576 Patent, col. 5:16-18), suggesting that any structure with two primary surfaces oriented at a right angle could fall within the scope of the term.
- Evidence for a Narrower Interpretation: Figure 3 depicts a stand with a distinct horizontal leg for mounting to the drawer slide and a vertical leg for attachment to the bracket. A party may argue that the term requires a structure with these distinct functional surfaces, potentially raising a question if the accused product's single piece of bent metal, which appears to attach to the side of the drawer slide, qualifies. An annotated photograph identifies the accused component as an "L-shaped stand." (Compl. p. 12, ¶24).
VI. Other Allegations
Willful Infringement
- The complaint alleges that Defendants' infringement has been willful and deliberate (Compl. ¶28). The pleading supports this allegation with claims that Defendants had pre-suit knowledge of the ’576 patent because they had previously purchased Plaintiff's own commercial product, which was "marked with the '576 patent number" (Compl. ¶26). It further alleges that infringement continued after Defendants were served with the complaint (Compl. ¶27).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and equivalence: for the "attachment means" limitation in Claim 1, are the fasteners used in the accused product legally equivalent to the specific bolt-and-washer structures disclosed in the patent's specification?
- A key evidentiary question will be one of structural correspondence: does the accused mounting hardware possess the specific geometric features recited in the claims, such as the "L-shaped stand" and the slot-to-hole width relationship required by Claim 21, and does it achieve adjustability in the manner described by the patent?
- A critical question for willfulness and damages will be pre-suit knowledge: can Plaintiff prove its allegation that Defendants previously purchased the patented product, saw the patent marking, and subsequently sourced a functionally similar, infringing alternative?