DCT
1:25-cv-06683
JB Innovations Ltd v. Chains for Tracks Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: JB Innovations Limited and Carac International Limited d/b/a TrackGrip (New Zealand)
- Defendant: Chains for Tracks, Inc. (Idaho)
- Plaintiff’s Counsel: McAndrews Held & Malloy, Ltd.
- Case Identification: 1:25-cv-06683, N.D. Ill., 06/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of patent infringement in the district, conducts substantial business there through an interactive commercial website and registered agents, and targets sales to Illinois residents.
- Core Dispute: Plaintiff alleges that Defendant’s "chains for tracks" products infringe a patent related to removable devices for enhancing the traction of track-driven vehicles.
- Technical Context: The technology addresses the problem of poor traction for tracked vehicles, like excavators and skid steers, on slick or sloped terrain by providing attachable traction-enhancing devices.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of its pending patent application via cease-and-desist letters on October 11, 2024, and December 10, 2024, prior to the patent issuing and the complaint being filed.
Case Timeline
| Date | Event |
|---|---|
| 2022-11-16 | U.S. Patent No. 12,275,470 Priority Date |
| 2022-11-01 | Defendant allegedly began developing Accused Products |
| 2023-01-06 | Defendant's related patent (U.S. 11,932,331) Priority Date |
| 2024-03-19 | Defendant's related patent (U.S. 11,932,331) Issues |
| 2024-04-01 | Accused Products first offered for sale on Defendant's website |
| 2024-10-11 | Plaintiff sends first cease-and-desist letter to Defendant |
| 2024-12-10 | Plaintiff sends second cease-and-desist letter to Defendant |
| 2025-04-15 | U.S. Patent No. 12,275,470 Issues |
| 2025-06-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,275,470 - Device for Enhancing Traction of a Tracked Vehicle
- Patent Identification: U.S. Patent No. 12,275,470, issued April 15, 2025.
The Invention Explained
- Problem Addressed: The patent addresses the issue that standard continuous tracks on vehicles can provide inadequate traction on steep or slippery slopes, and that typical solutions for adding traction devices, such as welding or drilling through the track, can be difficult, time-consuming, and cause permanent damage to the track itself (ʼ470 Patent, col. 1:25-44).
- The Patented Solution: The invention is a removable device that enhances traction without damaging the track. It consists of two brackets that clamp onto the opposite edges of a continuous track, which are connected by a ground-engaging "elongate member" (such as a chain) that extends over the top surface of the track. At least one bracket includes an adjustment mechanism to tighten the device, securing it in place by tension (’470 Patent, col. 2:21-44; Fig. 1).
- Technical Importance: The technology provides a non-permanent, non-damaging, and adjustable method for improving the safety and efficiency of tracked vehicles in challenging conditions (’470 Patent, col. 1:25-44, col. 2:11-15).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 10 (’470 Patent, Compl. ¶57).
- Independent Claim 1: A device for a tracked vehicle comprising:
- a first bracket and a second bracket, each with a body forming a mouth portion for engaging an edge of the track.
- a ground engaging feature comprising an elongate member extending between the brackets.
- the body of each bracket having a top flange, bottom flange, and a web.
- the elongate member being removably connected to the brackets.
- the first bracket comprising an adjustment mechanism to adjust the distance between the elongate member and the bracket body.
- the elongate member being a chain with at least one link.
- Independent Claim 10: A device for a tracked vehicle comprising:
- a chain with a first end for connecting to a first bracket and a second end connected to a second bracket.
- a tubular member attached to the chain's first end, with the tubular member having an internal thread for receiving a threaded bar.
III. The Accused Instrumentality
Product Identification
- Product Identification: Defendant’s "chains" for track-driven vehicles (the “Accused Products”) (Compl. ¶36-37).
Functionality and Market Context
- The complaint alleges the Accused Products are traction-enhancing devices for tracked vehicles like skid steers (Compl. ¶39, ¶41). They are described as having two opposing brackets connected by a chain that extends between them (Compl. ¶39). An image from the Defendant's website shows the accused product, comprising two C-clamp style brackets connected by a chain (Compl. ¶39). The complaint states the Accused Products use an adjustable bolt and washer system to fit different track widths (Compl. ¶40).
- The complaint alleges the Accused Products were developed after Defendant's founder "realized driving a skid steer in snowy McCall, Idaho is impossible," and were first offered for sale in April 2024 (Compl. ¶38, ¶45).
IV. Analysis of Infringement Allegations
12,275,470 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first bracket and a second bracket, each bracket comprising a body forming a mouth portion...engageable with the first edge of the track and...the second edge of the track | The Accused Products allegedly include first and second brackets, each with a C-clamp body forming a mouth portion that engages an edge of a vehicle track. The complaint includes a photograph of the accused device installed on a skid steer track, showing brackets on opposite edges. (Compl. p. 17). | ¶39 | col. 15:32-40 |
| a ground engaging feature comprising an elongate member...extending between the first bracket and the second bracket | The Accused Products allegedly have a chain that serves as an elongate member extending between the two brackets. An annotated image shows this chain labeled as the "elongate member." (Compl. p. 19). | ¶39 | col. 16:63-67 |
| wherein the body of each bracket comprises a top flange and a bottom flange...the body further comprising a web extending between the top flange and the bottom flange | The complaint alleges that the C-clamp of each bracket has a top flange, bottom flange, and a web forming the C-shape. An annotated image identifies these three components on the accused bracket. (Compl. p. 21). | ¶40 | col. 2:62-67 |
| the first bracket comprising an adjustment mechanism to adjust a distance between the first end of the elongate member and the body of the first bracket | The Accused Products allegedly include an adjustment mechanism consisting of a threaded bolt and lock washer system that connects the chain to the bracket and allows for adjustment. An image labels this system as the "adjustment mechanism." (Compl. p. 23). | ¶40 | col. 4:51-56 |
| the elongate member is a chain, wherein the chain comprises at least one chain link | The Accused Products' elongate member is allegedly a chain comprising at least one link. An annotated image identifies a "chain link" on the accused product. (Compl. p. 24). | ¶20 | col. 6:37-38 |
12,275,470 Infringement Allegations
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a. a chain having a first end for connecting to a first bracket and second end connected to a second bracket | The complaint alleges the Accused Products use a chain connected to at least two brackets. An annotated screenshot from an installation video shows a chain with a "first end" and "second end" connected to a "first bracket" and "second bracket." (Compl. p. 26). | ¶39 | col. 71:55-57 |
| b. a tubular member attached to the chain first end, the tubular member having an internal thread for receiving a threaded bar | The Accused Products allegedly include a tubular member with internal threading to receive a threaded bolt. The complaint points to an installation video showing this component, and installation instructions that refer to aligning "the bolt into the hex nut." An annotated image labels this component as the "tubular member." (Compl. p. 27). | ¶40 | col. 72:1-3 |
- Identified Points of Contention:
- Scope Questions: Claim 1 requires an "adjustment mechanism" comprising a "first connection member" positioned "within the mouth portion." The infringement theory rests on the accused bolt-and-washer system meeting this multipart definition. The central question is whether the accused product's relatively simple C-clamp and bolt assembly (Compl. ¶40) can be read to include the specific structural elements of the "adjustment mechanism" as detailed in the patent (ʼ470 Patent, col. 4:51-56, col. 5:16-25).
- Technical Questions: Claim 10 requires a "tubular member" with an "internal thread." The complaint alleges this is met by a hex nut in the accused product (Compl. p. 27). A key question will be whether a standard hex nut constitutes a "tubular member" in the context of the patent, which also describes the element as an "internally threaded tube" (’470 Patent, col. 5:7-8).
V. Key Claim Terms for Construction
The Term: "adjustment mechanism" (Claim 1)
Context and Importance: The infringement reading of Claim 1 hinges entirely on whether the accused product's bolt-and-washer clamping system constitutes an "adjustment mechanism." Practitioners may focus on this term because its construction will likely be dispositive for this claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the mechanism functions "to adjust a distance" between the elongate member and the bracket body (’470 Patent, col. 2:38-41), a general function that the accused bolt system arguably performs.
- Evidence for a Narrower Interpretation: The specification provides detailed embodiments where the mechanism includes a "receiving member" (like a tube or ring) and a "threaded bar" that passes through it (’470 Patent, col. 4:51-56; col. 5:16-25; Fig. 3). A defendant may argue these specific structural details limit the term to something more complex than the accused product's simple bolt and nut.
The Term: "tubular member" (Claim 10)
Context and Importance: The infringement reading of Claim 10 depends on construing the accused product's hex nut as a "tubular member." The outcome of this construction will be critical for this claim.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A nut is functionally a short tube with internal threads, which aligns with the claim's plain language ("tubular member having an internal thread").
- Evidence for a Narrower Interpretation: The specification also refers to this element as an "internally threaded tube" (’470 Patent, col. 5:7-8) and depicts it in figures (e.g., Fig. 14A, element 68) as a component distinct from a simple nut, suggesting a more specific structure may have been contemplated.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides customers with installation instructions and support, intending to encourage infringing use (Compl. ¶59). It also alleges contributory infringement on the basis that the Accused Products are customized components that are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶60).
- Willful Infringement: The willfulness allegation is based on both constructive and actual pre-suit knowledge. The complaint alleges constructive knowledge via Plaintiff's patent marking practice on its website and actual knowledge via two cease-and-desist letters sent on October 11, 2024, and December 10, 2024, which provided Defendant a copy of the patent application before it issued (Compl. ¶52-54).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "adjustment mechanism" in Claim 1, which the patent specification describes with specific components like a "receiving member" and "threaded bar," be construed broadly enough to read on the accused product's simpler bolt, washer, and C-clamp assembly?
- A second key question of claim construction will be whether a standard hex nut, as allegedly used in the accused product, meets the definition of a "tubular member" as required by Claim 10, or if the patent's language limits that term to a more specific structure.
- A central evidentiary question will concern willfulness: what evidence will emerge regarding Defendant's state of mind and conduct after receiving two cease-and-desist letters with a copy of the patent application, months before the patent issued and this lawsuit was filed?