DCT
1:25-cv-07157
Bestergo Inc v. Cknapp Sales Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bestergo Inc. (Minnesota)
- Defendant: CKnapp Sales, Inc. (Illinois)
- Plaintiff’s Counsel: Rimon P.C.
- Case Identification: 1:25-cv-07157, N.D. Ill., 06/26/2025
- Venue Allegations: Venue is alleged to be proper in the Northern District of Illinois because the defendant, CKnapp, has a physical address and principal place of business in the district, and because a substantial part of the events giving rise to the action, specifically CKnapp's sending of infringement notices to Amazon.com, occurred in the district.
- Core Dispute: Plaintiff Bestergo seeks a declaratory judgment that its adjustable standing desks do not infringe Defendant CKnapp's patent for a vertically adjusting desktop workspace.
- Technical Context: The technology concerns height-adjustable desktop converters, which are placed on top of existing desks to allow users to alternate between sitting and standing positions, a market driven by workplace ergonomics.
- Key Procedural History: The complaint was filed in response to infringement allegations made by CKnapp to Amazon.com through its Patent Evaluation Express (APEX) program, which threatened the removal of Bestergo's product listings. This action seeks to resolve the controversy created by those allegations.
Case Timeline
| Date | Event |
|---|---|
| 2015-01-24 | U.S. Patent No. 12,318,003 Priority Date |
| 2025-06-03 | U.S. Patent No. 12,318,003 Issue Date |
| 2025-06-12 | Bestergo receives email from Amazon regarding CKnapp's infringement complaint |
| 2025-06-26 | Bestergo files Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,318,003 - "DESKTOP WORKSPACE THAT ADJUSTS VERTICALLY"
- Patent Identification: U.S. Patent No. 12,318,003, "DESKTOP WORKSPACE THAT ADJUSTS VERTICALLY," issued June 3, 2025 (the "'003 Patent").
The Invention Explained
- Problem Addressed: The patent identifies the health risks associated with prolonged sitting and notes that while height-adjustable desks exist, purchasing an entirely new desk can be unreasonable for many users. Existing desktop platforms, it suggests, had room for improvement regarding the need for straight vertical motion and more compact designs (’003 Patent, col. 1:41-58, col. 2:65-col. 3:2).
- The Patented Solution: The invention is a desktop platform designed to sit on an existing desk. It uses a height adjustment mechanism with at least one set of "scissoring" arms to raise and lower a work surface. The design is intended to move the platform in a "substantially straight motion" so it does not protrude toward the user when raised, and to be compact when lowered (’003 Patent, Abstract; col. 4:5-15). Figure 1 illustrates the primary components, including the work surface (10), base (12), and height adjustment mechanism (14) (’003 Patent, Fig. 1).
- Technical Importance: The patent aims to provide a healthier work environment by facilitating standing without requiring the replacement of an existing stationary desk (’003 Patent, col. 1:48-54; col. 4:25-30).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 20 (Compl. ¶16).
- The essential elements of independent claim 20 are:
- A desktop workspace that adjusts vertically, comprising: a work surface platform;
- a keyboard platform that protrudes out, down, and parallel to the work surface platform;
- a base configured to sit on an existing platform;
- a height adjustment mechanism connecting the work surface platform and the base, which includes: a set of pivot arms; a base pivot point fixed relative to the base; and a platform pivot point fixed relative to the work surface platform;
- wherein the pivot arms create a lifting motion that moves the work surface platform in a straight vertical direction; and
- a gas spring attached between the work surface and a point of the base to assist in elevation, which also acts as a locking device.
III. The Accused Instrumentality
Product Identification
- The "Products-at-Issue" are adjustable standing desks sold on Amazon.com under ASINs B0D9LZC7MB and B0D9LZV2N7 (Compl. ¶10).
Functionality and Market Context
- The complaint alleges that all Products-at-Issue have the "same overall structure" (Compl. ¶10). It does not provide a detailed description of how the products operate. Instead, the complaint's technical assertions focus on what the products allegedly lack, stating that they do not comprise certain structural elements required by claim 20 of the ’003 Patent (Compl. ¶18). The complaint indicates the products' commercial importance by noting that their removal from Amazon.com listings would cause "substantial harm" to Plaintiff's business (Compl. ¶14).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. It does not contain affirmative infringement allegations but rather identifies specific claim limitations that the Products-at-Issue allegedly do not meet. The complaint references the patent's drawings as evidence for its proposed construction of the claim terms (Compl. ¶18). For example, Figure 3 of the '003 Patent provides a side view of the claimed mechanism, illustrating the various pivot points and connections (’003 Patent, Fig. 3).
’003 Patent Infringement Allegations
| Claim Element (from Independent Claim 20) | Plaintiff's Contention of Non-Infringement | Complaint Citation | Patent Citation |
|---|---|---|---|
| a work surface platform; | The complaint does not contest this element. | col. 4:38-43 | |
| a keyboard platform that protrudes out, down, and parallel to the work surface platform; | The complaint does not contest this element. | col. 8:8-15 | |
| a base configured to sit on an existing platform; | The complaint does not contest this element. | col. 4:54-56 | |
| a height adjustment mechanism connecting the work surface platform and the base, the height adjustment mechanism including: a set of pivot arms; a base pivot point fixed relative to the base connecting the set of pivot arms to the base; and a platform pivot point fixed relative to the work surface platform and connecting the set of pivot arms... | The Products-at-Issue are alleged to not comprise "a platform pivot point fixed relative to the work surface platform and connecting the set of pivot arms" and/or "a height adjustment mechanism" as construed in light of the patent's specification and drawings. | ¶18 | col. 4:43-53; col. 4:6-12 |
| ...wherein the lifting motion when raising and lowering the work surface platform...moves the work surface platform in a straight vertical direction relative to the base; and | The complaint does not contest this element, though it is encompassed by the broader challenge to the "height adjustment mechanism." | col. 4:9-12 | |
| a gas spring attached between the work surface platform and a point of the base...wherein the gas spring acts as a locking device... | The complaint does not contest this element. | col. 4:20-25 |
Identified Points of Contention
- Scope Questions: The core of the dispute is one of claim construction. The central question will be how the court defines "a platform pivot point fixed relative to the work surface platform" and the overall "height adjustment mechanism." Plaintiff Bestergo contends that when these terms are "properly construed" in light of the patent's text and drawings, its products do not infringe (Compl. ¶18). This raises the question of whether the specific mechanical arrangement shown in the patent's embodiments limits the scope of the claims.
- Technical Questions: A key factual question for the court will be whether the specific mechanical structure and operation of Bestergo's Products-at-Issue incorporate the features of a "height adjustment mechanism" and a "platform pivot point" as claimed in the '003 Patent, once those terms are construed.
V. Key Claim Terms for Construction
The complaint explicitly identifies claim construction as a central issue (Compl. ¶18).
"a height adjustment mechanism"
- Context and Importance: This term is the heart of the invention. Bestergo's non-infringement argument relies on a construction of this term that is limited to the specific scissor-lift apparatus described in the patent. The definition will determine whether different mechanical lifting solutions fall within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The Summary section describes the mechanism more generally as including "at least one set of arms that connect at a pivot point creating a scissoring motion" (’003 Patent, col. 2:11-15), which may support a construction not strictly limited to the exact depicted embodiment.
- Evidence for a Narrower Interpretation: The Detailed Description and figures depict a specific structure comprising two sets of crisscrossing arms (16, 18) that pivot at a central point (28) and connect to the base and platform via a combination of fixed pivots (24, 26) and sliding mechanisms (20, 22) (’003 Patent, col. 4:43-53; Figs. 1, 3). A defendant could argue these details are essential to the claimed mechanism.
"a platform pivot point fixed relative to the work surface platform and connecting the set of pivot arms"
- Context and Importance: This is the second specific limitation Bestergo identifies as lacking in its products (Compl. ¶18). Its construction is critical because it defines how the lifting arms must connect to the upper work surface. Practitioners may focus on this term because Bestergo has signaled it as a key point of distinction.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires a "pivot point" that is "fixed relative to the work surface platform." This could be read to cover any type of pivoting connection that remains in a constant position on the platform, without being limited to a specific hardware implementation.
- Evidence for a Narrower Interpretation: The drawings show this connection as a specific pivot element (24) and a sliding element (30) that allow the scissoring arms to attach to the underside of the work surface platform (10) (’003 Patent, Fig. 3; col. 4:46-49). A party could argue that "fixed relative to the work surface platform" should be construed in light of this specific disclosed structure, which includes both pivoting and sliding connections to the platform.
VI. Other Allegations
Indirect Infringement
- The complaint does not provide sufficient detail for analysis of indirect infringement. Bestergo seeks a declaration that it does not contributorily infringe or induce infringement, but it pleads no facts related to these allegations beyond a general denial (Compl. ¶¶16, Prayer for Relief ¶a).
Willful Infringement
- The complaint does not provide sufficient detail for analysis of willful infringement. Bestergo seeks a declaration that it has not willfully infringed, but it provides no facts addressing CKnapp's state of mind or its own (Compl., Prayer for Relief ¶a).
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears poised to turn on the following central questions for the court:
- A core issue will be one of claim construction: How narrowly will the court construe the term "height adjustment mechanism" and its constituent elements, such as the "platform pivot point"? The outcome will depend on whether the claim scope is limited to the specific scissoring-arm embodiment shown in the '003 Patent's figures or if it can read on other mechanical lifting structures.
- A key evidentiary question will be one of technical comparison: Once the claims are construed, does the specific design of Bestergo's Products-at-Issue incorporate the legally defined "height adjustment mechanism" and "platform pivot point"? The case will require a detailed factual comparison between the accused product's structure and the language of the claims.