DCT
1:25-cv-00556
Titan3 Technology LLC v. Intermatic Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Titan³ Technology, LLC (Arizona)
- Defendant: Intermatic, Inc. (Delaware)
- Plaintiff’s Counsel: Shook, Hardy & Bacon L.L.P.; Snell & Wilmer
- Case Identification: 1:25-cv-00556, N.D. Ill., 01/16/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because Defendant Intermatic maintains its corporate headquarters and principal place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s low-profile waterproof electrical outlet covers infringe three patents related to configurable and telescoping outlet cover enclosures.
- Technical Context: The technology concerns protective covers for outdoor electrical outlets, which are designed to be low-profile when not in use but expandable to accommodate bulky plugs while maintaining a weather-resistant seal.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of U.S. Patent Nos. 10,367,341 and 10,777,981 on October 1, 2021, and of U.S. Patent No. 11,799,276 on October 26, 2023, which may form the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2015-09-14 | Earliest Priority Date for all Patents-in-Suit |
| 2019-07-30 | U.S. Patent No. 10,367,341 Issues |
| 2020-09-15 | U.S. Patent No. 10,777,981 Issues |
| 2021-01-01 | Alleged Launch of Infringing Products (approximate date) |
| 2021-10-01 | Pre-Suit Notice of ’341 and ’981 Patents Allegedly Sent |
| 2023-10-24 | U.S. Patent No. 11,799,276 Issues |
| 2023-10-26 | Pre-Suit Notice of ’276 Patent Allegedly Sent |
| 2025-01-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,367,341 - Configurable Electrical Outlet Cover Enclosure
- Issued: July 30, 2019
The Invention Explained
- Problem Addressed: The patent identifies a need for exterior outlet covers that are not "large and boxy" and can be collapsed to "take up less space" when not protecting a plugged-in cord (Compl. Ex. 1, ’341 Patent, col. 1:35-39).
- The Patented Solution: The invention is an electrical outlet cover featuring a "telescoping enclosure" housed within a lid frame. This enclosure can slide between a compact, "collapsed" position for a low profile and an "expanded" position to create sufficient depth to house a plug while the cover remains closed, offering weather resistance in either state (’341 Patent, Abstract; col. 2:30-45). The movement is managed by structures like ledges and flanges that interact between the sliding enclosure and the stationary frame (’341 Patent, Fig. 6).
- Technical Importance: This design sought to provide the "in-use" weather protection of bulky "bubble" covers without their constant obtrusive size, making it more versatile and aesthetically suitable for residential and commercial buildings (’341 Patent, col. 1:29-34).
Key Claims at a Glance
- The complaint asserts independent claim 6 (Compl. ¶18a).
- Essential elements of claim 6 include:
- A base configured to couple to an electrical outlet.
- "Only one lid frame" hingedly coupled to the base, with a central aperture.
- "One enclosure" that is "telescopingly movable" within the lid frame between a collapsed and an extended position, featuring specific ledge and wall structures.
- An aperture in the base to receive an electrical device.
- The complaint reserves the right to assert additional claims (Compl. ¶19).
U.S. Patent No. 10,777,981 - Configurable Electrical Outlet Cover Enclosure
- Issued: September 15, 2020
The Invention Explained
- Problem Addressed: Similar to its parent, this patent addresses the need for a low-profile yet functional weatherproof outlet cover that can accommodate plugs when in use (Compl. Ex. 2, ’981 Patent, col. 1:30-40).
- The Patented Solution: This patent also describes a cover with a base and a lid containing a slidable "center-portion" (enclosure). The claims focus on the specific structural relationship between the components, particularly the inclusion of cooperating locking apertures on both the base and the lid frame, allowing the entire assembly to be secured with a lock (’981 Patent, col. 14:10-16).
- Technical Importance: The invention adds a specific security feature to the configurable cover design, enabling the cover to be locked shut to prevent tampering or unauthorized use of the outlet, in addition to providing weather protection (’981 Patent, col. 3:12-16).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶18b).
- Essential elements of claim 1 include:
- A base with a first hinge member and a "base locking aperture."
- A lid comprising "only one frame" with a second hinge member and a "frame locking aperture," and a slidable "center-portion" (enclosure).
- The lid is coupled to the base via the hinge members.
- The lid is pivotable between open and closed positions.
- The base and frame locking apertures are "immediately adjacent" and "configured to cooperate to enable the frame to be locked."
- The complaint reserves the right to assert additional claims (Compl. ¶19).
U.S. Patent No. 11,799,276 - Configurable Electrical Outlet Cover Enclosure
- Issued: October 24, 2023
- Technology Synopsis: Continuing the same theme, the ’276 Patent discloses a configurable outlet cover with a base, a hinged lid, and a movable enclosure. The inventive concept focuses on the specific manner of movement, requiring the enclosure to be "linearly movable" and in "contact with the frame throughout its movement," and also specifies the adjacent positioning of locking apertures on the base and lid frame (Compl. Ex. 3, ’276 Patent, Abstract; col. 1:50-col. 2:2).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶18c).
- Accused Features: The complaint alleges that the accused products' base, hinged lid with a frame, and linearly movable enclosure with a ledge and locking aperture infringe the ’276 Patent (Compl. ¶18c).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Intermatic’s WP6000, WP6200, WP7000, and WP7200 low-profile waterproof covers (the "Infringing Products") (Compl. ¶16).
Functionality and Market Context
- The complaint describes the accused products as "low-profile waterproof covers," implying they perform the same function as the patented invention (Compl. ¶16).
- Plaintiff alleges that the Infringing Products "directly compete with and are nearly identical to the Embodying Products" which practice the patents-in-suit (Compl. ¶17).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,367,341 Infringement Allegations
| Claim Element (from Independent Claim 6) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a base configured to couple to an electrical outlet | The accused products allegedly include a base that couples to an electrical outlet. | ¶18a | col. 6:58-60 |
| only one lid frame hingedly coupled to the base along a first side of the lid frame and pivotable on between an open position and a closed position, the lid frame comprising a central aperture surrounded by the lid frame | The accused products allegedly have a single, hinged lid frame with a central aperture that pivots between open and closed positions. | ¶18a | col. 7:15-24 |
| one enclosure movably coupled to the frame within the central aperture and telescopingly movable within the lid frame between a collapsed, not-in-use position and an extended, in-use position, wherein the enclosure comprises an enclosure side wall... and an enclosure front wall... the enclosure side wall comprising a ledge extending outward... | The accused products allegedly contain an enclosure that telescopingly moves within the lid frame between collapsed and extended states, and which includes the specifically claimed wall and ledge structures. | ¶18a | col. 7:40-57 |
| an aperture extending through and surrounded by the base, the aperture sized large enough to receive a portion of an electrical device therethrough | The accused products allegedly feature an aperture in the base to accommodate an electrical device. | ¶18a | col. 7:6-9 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the accused products' mechanism for expanding meets the specific limitation of being "telescopingly movable." The court may need to construe this term to determine if it requires the specific multi-part interactions (e.g., sleeve, ledges, flanges) described in the patent's embodiments or if a simpler sliding mechanism would suffice.
- Technical Questions: The complaint alleges the presence of a "ledge extending outward from an enclosure wall" in a specific position. An evidentiary question will be whether discovery shows that the accused products contain a structure that meets this precise geometric and functional description.
U.S. Patent No. 10,777,981 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a base having a first hinge member and an electrical device opening... the base further having a base locking aperture that extends through the base at a corner of the base | The accused products' base allegedly has a hinge member, an opening for an electrical device, and a locking aperture at a corner. | ¶18b | col. 13:50-55 |
| a lid comprising (a) only one frame having a second hinge member and a central aperture extending through a center of the frame, the frame further having a frame locking aperture...; and (b) a center-portion having an enclosure with a front wall and a continuous enclosure wall... | The accused products' lid allegedly has a single frame with a corresponding hinge member and locking aperture, as well as a "center-portion" with an enclosure. | ¶18b | col. 13:56-65 |
| wherein the lid is coupled to the base through the first hinge member being coupled to the second hinge member | The lid is allegedly coupled to the base via the claimed hinge members. | ¶18b | col. 14:1-2 |
| wherein the center-portion is slidably coupled to the frame... and slidable between an extended, in-use position and a collapsed, not-in-use position | The "center-portion" of the accused products is allegedly slidable between extended and collapsed positions. | ¶18b | col. 14:3-6 |
| wherein the lid is pivotable with respect to the base between an open position and a closed position | The lid of the accused products allegedly pivots relative to the base. | ¶18b | col. 14:7-9 |
| wherein the base locking aperture and the frame locking aperture are immediately adjacent to each other the lid is in the closed position and are configured to cooperate to enable the frame to be locked in the closed position against the base by a lock extending through at least one of the base locking aperture and the frame locking aperture | The base and frame locking apertures on the accused products are allegedly adjacent and cooperate to allow the device to be locked when closed. | ¶18b | col. 14:10-16 |
- Identified Points of Contention:
- Scope Questions: The claim requires that the locking apertures be "immediately adjacent" and "configured to cooperate." The scope of this functional language will be critical. The court will need to determine how close "immediately adjacent" is and what level of interaction is required for the apertures to "cooperate."
- Technical Questions: The complaint provides no details on the locking mechanism of the accused products. A key factual question will be whether the products possess two distinct apertures—one on the base and one on the frame—that align and function in the specific cooperative manner required by the claim.
V. Key Claim Terms for Construction
For U.S. Patent No. 10,367,341
- The Term: "telescopingly movable"
- Context and Importance: This term defines the nature of the movement between the enclosure and the frame. Its construction is critical because it distinguishes the invention from a simple sliding or hinged cover. Practitioners may focus on this term because the infringement analysis will depend on whether the accused product’s mechanism for changing depth qualifies as "telescoping."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition. A party could argue it should be given its plain and ordinary meaning, which could encompass any structure where one part slides over or within another to extend or retract.
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment where a "sleeve 145... slides within the central aperture 131" and is guided by features like "protrusions 147" and "ledges 146" (’341 Patent, col. 7:40-66). A party could argue that "telescopingly movable" is implicitly defined by and limited to this more complex, guided sliding structure.
For U.S. Patent No. 10,777,981
- The Term: "configured to cooperate to enable the frame to be locked"
- Context and Importance: This functional language is central to the patent's contribution of a lockable cover. The case may turn on whether the accused product's locking feature, if any, meets this functional requirement. Practitioners may focus on this term because its construction will set the standard for what constitutes an infringing locking mechanism.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue this language is broad, covering any two apertures that align when the lid is closed such that a standard padlock or other lock could pass through them.
- Evidence for a Narrower Interpretation: The broader patent family describes specific "latch assembly" embodiments, such as a "hitch seat 161" that mates with a "cutout 162" (’981 Patent, col. 8:50-60). A party could argue that the term should be limited by these disclosed embodiments, requiring more than simple alignment of two holes.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both contributory and induced infringement. The allegations state Defendant has specific knowledge of the patents and contributes to infringement by selling products "made or adapted for use" in an infringing manner. It further alleges inducement by "directing others to install and use the Infringing Products" (Compl. ¶¶ 24-25).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's alleged knowledge of the patents-in-suit prior to the lawsuit. This knowledge is purportedly established through notice letters sent on October 1, 2021 (for the ’341 and ’981 Patents) and October 26, 2023 (for the ’276 Patent) (Compl. ¶¶ 21-23).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "telescopingly movable," which is described in the patent with specific guiding structures like sleeves and ledges, be construed to read on the specific mechanism used by the accused products to expand and contract? The answer will likely dictate the outcome for the ’341 Patent.
- A second central question will be evidentiary and functional: do the accused products possess the dual "base locking aperture" and "frame locking aperture" as two distinct but cooperating structures as claimed in the ’981 Patent? Furthermore, does the enclosure in the accused products exhibit "contact with the frame throughout its movement" as required by the ’276 Patent? The complaint's conclusory allegations leave these critical factual and technical questions for discovery and expert testimony to resolve.