DCT
1:25-cv-00356
Kenney Mfg Co v. Satori Home Ltd LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kenney Manufacturing Co. (Rhode Island)
- Defendant: Satori Home Limited, LLC. (New Mexico)
- Plaintiff’s Counsel: Reinhart Boerner Van Deuren s.c.; Adler Pollock & Sheehan P.C.
- Case Identification: 1:25-cv-00356, N.D. Ill., 01/13/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendant Satori has its principal place of business in Evanston, Illinois, and has allegedly manufactured, sold, and marketed the infringing products within the district.
- Core Dispute: Plaintiff alleges that Defendant’s curtain rod brackets infringe a patent related to a configurable mounting bracket that can be installed on either a wall or a ceiling.
- Technical Context: The technology concerns consumer hardware, specifically mounting brackets for window draperies that offer enhanced installation flexibility.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2019-05-03 | Priority Date for U.S. Patent No. 11,185,185 |
| 2021-11-30 | Issue Date for U.S. Patent No. 11,185,185 |
| 2025-01-13 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,185,185 - "Configurable Mounting Bracket For Curtain Rods"
- Patent Identification: U.S. Patent No. 11,185,185, "Configurable Mounting Bracket For Curtain Rods," issued November 30, 2021 (the "’185 Patent").
The Invention Explained
- Problem Addressed: The patent notes that traditional drapery hardware brackets typically have a "fixed-position configuration" for mounting on either a wall or a ceiling, which "lacks flexibility and tends to limit the available installation options" (’185 Patent, col. 1:21-24).
- The Patented Solution: The invention is a multi-piece curtain rod bracket assembly designed for versatility. It comprises a bracket base, which attaches to the wall or ceiling, and a separate bracket arm, which holds the curtain rod (’185 Patent, col. 1:35-38). The innovation lies in providing the bracket arm with "multiple alternative attachment points," allowing it to be connected to the base in different orientations for either wall or ceiling installation, while always keeping the curtain rod holder in a proper horizontal position (’185 Patent, col. 1:39-42, 1:56-68).
- Technical Importance: The design provides "convenience and versatility by allowing for both ceiling and wall mounting with a single bracket assembly" (’185 Patent, col. 5:2-5).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶20).
- Essential elements of independent Claim 1 include:
- A bracket base configured for mounting to a wall or a ceiling.
- A bracket arm with at least one curtain rod supporting portion and "first and second mounting locations."
- The first mounting location is configured for coupling to the base for a wall-mounted installation.
- The second mounting location is configured for coupling to the base for a ceiling-mounted installation.
- The bracket base comprises a "wall/ceiling attachment portion" and a "bracket arm mounting portion."
- The coupling is accomplished via a "mounting screw that is received in a tapped hole on a flat end face of the bracket arm mounting portion."
- The complaint makes no mention of asserting any dependent claims.
III. The Accused Instrumentality
Product Identification
- Product Identification: "Walmart's Mainstays SwiftSet No Drill ½" to 1" Diameter Curtain Rod Brackets" (the "Accused Products") (Compl. ¶1).
Functionality and Market Context
- Functionality and Market Context: The complaint alleges the Accused Products are curtain rod mounting brackets manufactured and sold by Satori (Compl. ¶2, ¶15). The complaint provides photographs of the Accused Products, which are two-piece brackets available in black and silver finishes. The first photograph shows a pair of black curtain rod brackets, appearing to consist of a base plate and a separate rod-holding arm (Compl. p. 2). The second photograph shows the same product in a silver finish (Compl. p. 3). The complaint alleges these products are sold online and in Walmart stores throughout the United States (Compl. ¶1, ¶16).
IV. Analysis of Infringement Allegations
The complaint does not contain a claim chart. The following table summarizes the infringement theory for Claim 1 based on the complaint's allegations and visual evidence.
’185 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a bracket base that is configured to be mounted to a wall or a ceiling | The Accused Products include a base component, depicted with mounting holes, alleged to be for attachment to a wall or ceiling. | ¶15; p. 2 | col. 8:21-22 |
| a bracket arm defining at least one curtain rod supporting portion that is configured to hold a curtain rod in a generally horizontal orientation, and first and second mounting locations | The Accused Products include an arm component with a U-shaped portion, alleged to be the curtain rod support, and are alleged to embody the claimed mounting locations. | ¶15, ¶20; p. 2 | col. 8:23-28 |
| wherein the first mounting location is configured to be coupled to the bracket base when the bracket base is mounted to the wall... | The Accused Products are alleged to be configurable for wall mounting. | ¶15, ¶20 | col. 8:29-34 |
| and wherein the second mounting location is configured to be coupled to the bracket base when the bracket base is mounted to the ceiling... | The Accused Products are alleged to be configurable for ceiling mounting. | ¶15, ¶20 | col. 8:35-40 |
| wherein the bracket base comprises a wall/ceiling attachment portion and a bracket arm mounting portion... [and] the coupling is accomplished using a mounting screw that is received in a tapped hole on a flat end face of the bracket arm mounting portion. | The Accused Products are alleged to embody the claimed components and coupling mechanism. | ¶15, ¶20 | col. 8:41-51 |
- Identified Points of Contention:
- Technical Questions: The complaint provides photographs but no technical description or explanation of how the Accused Products operate. A central evidentiary question will be whether the Accused Products actually have two distinct "mounting locations" on the bracket arm for wall and ceiling configurations, or if they use a single attachment point that can be oriented in different ways. Further, what evidence demonstrates that the coupling mechanism of the Accused Products is a "mounting screw" received in a "tapped hole on a flat end face" as specifically required by the claim?
- Scope Questions: A key dispute may arise over the definition of "first and second mounting locations." The case may turn on whether this phrase requires two physically separate and distinct points of attachment on the bracket arm, or if it can be read to cover a single attachment interface that facilitates two different final orientations.
V. Key Claim Terms for Construction
- The Term: "first and second mounting locations"
- Context and Importance: This limitation is the structural heart of the claimed invention's configurability. The infringement analysis will depend entirely on whether the Accused Product's design is found to possess two distinct "locations" for mounting. Practitioners may focus on this term because the patent's own figures and description could be used to support competing interpretations.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the term should be interpreted functionally, in light of the patent’s stated purpose to provide versatility for both "ceiling and wall mounting with a single bracket assembly" (’185 Patent, col. 5:2-5). This view might suggest that any structure enabling these two distinct, final installed orientations meets the claim limitation, regardless of whether the attachment points are physically separate on the arm itself.
- Evidence for a Narrower Interpretation: Claim 1 explicitly recites two distinct locations: a "first" and a "second." The specification provides examples where these locations are physically separate on the bracket arm. For instance, in one embodiment, the "first mounting location is at one end of the bracket arm and second bracket mounting location is adjacent to the first end of the bracket arm" (’185 Patent, col. 3:22-25, Figs. 1A-2B). This suggests that the claim requires two physically distinct attachment points.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Satori induces infringement among its "distributors, retailers, resellers, customers, [and] users" (Compl. ¶22). The complaint does not plead specific facts to support this allegation, such as references to user manuals or marketing materials that instruct on an infringing use.
- Willful Infringement: The complaint does not use the term "willful," but the prayer for relief requests a declaration that the case is "exceptional under 35 U.S.C. § 285" and an award of "treble damages" (Compl., Prayer for Relief ¶D). The complaint does not allege pre-suit knowledge or provide any other specific factual basis to support a claim for enhanced damages beyond the general infringement allegations.
VII. Analyst’s Conclusion: Key Questions for the Case
- A primary issue will be one of claim construction: does the term "first and second mounting locations," as used in Claim 1, require two physically distinct and separate points of attachment on the bracket arm, or can it be construed to cover a single attachment interface that allows for two different installation orientations? The resolution of this question may be dispositive.
- A key evidentiary question will be whether the Plaintiff can demonstrate, beyond the general allegations in the complaint, that the Accused Products meet every specific limitation of Claim 1. This includes not only the dual mounting locations but also the precise coupling mechanism of a "mounting screw" received in a "tapped hole on a flat end face" of the mounting portion.