DCT
1:25-cv-00595
Georgia Exposition Mfg Corp v. Exex Holding Corp
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Georgia Exposition Manufacturing Corporation (Georgia)
- Defendant: MEB EEI Holdings, LLC d/b/a OnlineEEI (Illinois)
- Plaintiff’s Counsel: Barney & Karamanis, LLP
- Case Identification: 1:25-cv-00595, N.D. Ill., 03/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is an Illinois LLC with its principal place of business in the district, resides in the district, and has committed alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "Flat Top" connectors, used for pipe and drape exhibition systems, infringe a patent related to couplers for connecting tubular members.
- Technical Context: The technology concerns mechanical connectors used to assemble temporary frameworks for trade show booths, event backdrops, and room partitions.
- Key Procedural History: The complaint notes that the patent-in-suit was assigned from the inventor to the Plaintiff on January 3, 2025. Plaintiff also alleges it sent a notice letter to Defendant detailing the alleged infringement on October 23, 2024.
Case Timeline
| Date | Event |
|---|---|
| 2016-11-03 | ’560 Patent Priority Date |
| 2021-03-09 | ’560 Patent Issue Date |
| 2024-10-23 | Plaintiff allegedly sent notice letter to Defendant |
| 2025-01-03 | ’560 Patent assigned to Plaintiff Georgia Expo |
| 2025-03-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,941,560 - "Connector for Pipes"
The Invention Explained
- Problem Addressed: The patent's background section describes problems with conventional pipe and drape systems, including steel hooks on horizontal rods "tearing" the aluminum vertical pipes and creating an uneven, "bumpy" appearance along the top of drape walls (’560 Patent, col. 1:21-42).
- The Patented Solution: The invention is a coupler insert for the top of vertical support pipes. It features specially shaped slots to receive the hooks from horizontal drape rods, aiming to provide a more secure connection that prevents damage to the pipes and ensures a uniform height for a cleaner aesthetic. The design is intended to be compatible with existing industry-standard hardware (’560 Patent, Abstract; col. 2:18-21).
- Technical Importance: The described solution sought to improve the durability and visual appearance of widely used, standardized exhibition systems without requiring users to replace their existing inventory of components (’560 Patent, col. 2:18-21).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (’560 Patent, col. 4:12-29; Compl. ¶11).
- The essential elements of Claim 1 include:
- A coupler with a lower region sized to fit inside a vertical pipe and a wider second (upper) region that forms a shoulder at the junction.
- An "upwardly opening well" formed within the coupler.
- The second region defines at least one "truncated V-shaped slot" for receiving a coupling hook.
- Each vertical side of the slot has "flat surfaces facing toward a center" of the slot.
- The flat surfaces are "tapered such that the flat surfaces are wider at the bottom than at the top."
- A "horizontal, rectangular, upward facing seat" at the bottom of the slot.
- The complaint's prayer for relief seeks judgment on "one or more claims" of the patent, but specific infringement allegations are limited to Claim 1 (Compl. p. 9).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused products as "Flat Top" connectors (Compl. ¶9).
Functionality and Market Context
- The complaint alleges these products are couplers designed to connect horizontal drape rods to vertical support pipes in exhibition systems (Compl. ¶13). The complaint includes an image showing the accused product connecting a horizontal rod to a vertical pipe, illustrating its use in forming a framework. (Compl. ¶13, p. 5). Plaintiff alleges Defendant is making, using, selling, offering for sale, and/or importing these products in the United States (Compl. ¶9).
IV. Analysis of Infringement Allegations
’560 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A coupler configured to couple to tubular members, including a vertical support pipe and at least one horizontally extending drape rod having a terminal connector... | The Accused Product is a coupler for connecting tubular members in a pipe and drape system. | ¶13 | col. 2:10-17 |
| ...comprising a lower region sized to be received within a vertical support pipe and a second region having a greater transverse dimension than said lower region such that a shoulder is formed at the junction of said lower region and said second region... | The Accused Product has a bottom portion that inserts into a vertical pipe and a wider upper portion, creating a shoulder. | ¶14-15 | col. 2:30-35 |
| ...wherein an upwardly opening well is formed with said coupler... | The Accused Product has an upwardly opening well within its upper portion. | ¶16 | col. 2:36-38 |
| ...said second region defining at least one truncated V-shaped slot configured to receive a coupling hook... | The upper portion of the Accused Product defines at least one truncated V-shaped slot. | ¶17 | col. 4:21-23 |
| ...wherein each vertical side of the truncated V-shaped slot comprises flat surfaces facing toward a center of the truncated V-shaped slot... | The vertical sides of the slots in the Accused Product are alleged to have flat surfaces facing the center. | ¶18 | col. 4:23-25 |
| ...the flat surfaces being tapered such that the flat surfaces are wider at the bottom than at the top... | The complaint alleges the flat surfaces of the Accused Product's slots are wider at the bottom than at the top. | ¶19 | col. 4:25-27 |
| ...and a horizontal, rectangular, upward facing seat of a bottom portion of the at least one truncated V shaped slot. | The Accused Product includes a horizontal, rectangular seat at the bottom of the slot, as shown in an annotated image. (Compl. ¶20, p. 8). | ¶20 | col. 4:27-29 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise from the claim language requiring flat surfaces that are "wider at the bottom than at the top." This phrasing appears to be in direct tension with the patent's detailed description, which states, "The opening 15 is preferably formed with a wider upper dimension and tapers to a narrower seat 17 at the bottom" (’560 Patent, col. 2:46-48). This raises the question of whether the claim language contains a typographical error, and how the court should construe this apparently contradictory limitation.
- Technical Questions: What evidence does the complaint provide that the accused connector's slot is geometrically "wider at the bottom than at the top"? While the complaint makes this conclusory allegation, the provided photographs are not detailed enough to independently verify this specific, counter-intuitive geometry (Compl. ¶19).
V. Key Claim Terms for Construction
- The Term: "the flat surfaces being tapered such that the flat surfaces are wider at the bottom than at the top"
- Context and Importance: The construction of this term is likely case-dispositive. If interpreted literally, it describes a slot with an inverted taper. The infringement analysis will hinge on whether the claim is interpreted literally as written or is interpreted in light of the specification's conflicting description. Practitioners may focus on this term as a basis for arguments of non-infringement or, alternatively, invalidity for indefiniteness or lack of written description.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the issued claim, which is presumed valid, explicitly recites a taper that is "wider at the bottom than at the top" (’560 Patent, col. 4:25-27). Parties may argue that this language is unambiguous and must be given its literal meaning.
- Evidence for a Narrower Interpretation: The specification describes the opposite geometry, stating that the opening "tapers to a narrower seat 17 at the bottom" (’560 Patent, col. 2:46-48). All patent figures showing the slot (e.g., Fig. 1, Fig. 5) depict a conventional V-shape that is wider at the top. This significant contrary evidence in the specification may support an argument that the claim contains an obvious error that should be interpreted consistently with the disclosed embodiments.
VI. Other Allegations
- Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that Plaintiff sent a letter to Defendant on October 23, 2024, that "attached the ‘560 Patent and detailed OnlineEEI’s infringement" (Compl. ¶21). These allegations of pre-suit notice could be used to support a later claim for willful infringement based on post-notice conduct.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim interpretation versus validity: does the claim term requiring a slot "wider at the bottom than at the top" render the claim indefinite or invalid in light of a contradictory specification, or can the court correct what may be an obvious drafting error during claim construction?
- A key evidentiary question will be one of factual proof: can the Plaintiff demonstrate that the accused product's physical geometry actually meets the literal—and counter-intuitive—"wider at the bottom" limitation recited in Claim 1?