Charles Walters Equipment LLC v. Earthway Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Charles Walters Equipment, LLC (Illinois)
  • Defendant: Earthway Products, Inc. (Indiana)
  • Plaintiff’s Counsel: MCDONALD HOPKINS LLC
• Case Identification: 1:26-cv-00424, N.D. Ill., 01/14/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Illinois because Defendant is subject to personal jurisdiction, a substantial part of the events giving rise to the claims occurred there, and Plaintiff is a resident of the district.
• Core Dispute: Plaintiff seeks a declaratory judgment that its commercial rotary spreader products do not infringe Defendant’s patents related to spread control mechanisms, following infringement accusations and an Amazon intellectual property complaint by Defendant.
• Technical Context: The technology concerns mechanical rotary spreaders used for turf and grounds applications, focusing on mechanisms that control the pattern and flow rate of dispersed materials like fertilizer or seed.
• Key Procedural History: The complaint alleges that Defendant first accused Plaintiff of infringement in June 2023. After nearly two years of intermittent correspondence, during which Plaintiff provided a detailed non-infringement analysis that allegedly went unrebutted, Defendant initiated an intellectual property takedown of Plaintiff's products on Amazon. This action for declaratory judgment followed.

Case Timeline

Date	Event
2011-10-27	Earliest Priority Date for '368 and '974 Patents
2021-05-04	U.S. Patent No. 10,993,368 Issues
2023-06-28	Defendant sends first letter asserting '368 Patent
2024-10-22	U.S. Patent No. 12,120,974 Issues
2025-06-10	Defendant sends second letter asserting '368 and '974 Patents
2025-06-27	Plaintiff requests specificity on infringement allegations
2025-09-02	Defendant identifies accused products
2025-09-11	Plaintiff provides detailed non-infringement analysis
2026-01-07	Defendant initiates Amazon IP takedown of Plaintiff’s products
2026-01-14	Complaint for Declaratory Judgment filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,993,368 - *"SPREAD CONTROL MECHANISM,"* issued May 4, 2021

The Invention Explained

• Problem Addressed: The patent’s background section notes that conventional broadcast spreaders often use a simple deflector to prevent material from being cast onto non-lawn areas like driveways. A disadvantage of this approach is that the total flow rate of material remains the same, causing the deflected material to over-treat the lawn area, leading to waste and potential damage (’368 Patent, col. 1:21-34).
• The Patented Solution: The invention is a spread control assembly comprising two key interacting components below the hopper: a "shut-off adjustment plate" with multiple exit openings and a "spread control mechanism" with paddles. By moving the spread control mechanism into an "activated position," its paddles cover some of the exit openings. This action is designed to simultaneously block material from exiting toward one side and reduce the overall material flow rate, thereby preventing the over-application described in the background (’368 Patent, col. 2:45-54; Fig. 8).
• Technical Importance: This design offers a more sophisticated method for edge control than a simple deflector by integrating directional control with flow rate reduction in a single mechanism (’368 Patent, col. 4:56-68).

Key Claims at a Glance

• The complaint’s analysis focuses on independent Claim 1 (Compl. ¶20).
• The essential elements of Claim 1 are:
  • a hopper including a plurality of openings in a bottom of the hopper;
  • a shut-off adjustment plate movably coupled to the hopper below the plurality of openings and including a plurality of exit openings; and
  • a spread control mechanism disposed below the shut-off adjustment plate, including a plurality of segments that can move to an activated position to cover one or more of the exit openings.
• The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement as to the "Asserted Patents" generally (Compl. ¶41).

U.S. Patent No. 12,120,974 - *"SPREAD CONTROL MECHANISM,"* issued Oct. 22, 2024

The Invention Explained

• Problem Addressed: The ’974 Patent addresses the same technical problem as its parent '368 Patent: known spreader deflectors lead to over-treatment of lawn areas and wasted product when trying to avoid spreading on adjacent surfaces like walkways (’974 Patent, col. 1:40-53).
• The Patented Solution: This patent claims a method of operating a broadcast spreader by shifting it between at least two distinct configurations. In a "first configuration," a first set of openings allows material to pass through for a first spread pattern (e.g., a wide broadcast). The user can then "shift" the spreader to a "second configuration" where a second, different set of openings is used, resulting in a different spread pattern (e.g., a directed, narrower broadcast). A key aspect is that the number of active through-openings is different between the two configurations (’974 Patent, Abstract; col. 2:1-16).
• Technical Importance: The claimed method provides a user with the ability to adjust not just the direction but also the fundamental pattern and volume of the material spread, allowing for more efficient operation in both open areas and along sensitive borders (’974 Patent, col. 4:50-59).

Key Claims at a Glance

• The complaint does not specify which claims of the '974 Patent are asserted against it, but its arguments track the concepts of independent method Claim 1 (Compl. ¶21). The complaint notes that Defendant’s pre-suit letter identified “claim 21,” but suggests this was in error (Compl. ¶16).
• The essential steps of Claim 1 are:
  • placing the spreader in a first configuration with a "first set of one or more through openings";
  • shifting the spreader into a second configuration with a "second set of one or more through openings";
  • shutting off flow using a shut-off adjustment plate;
  • wherein the first set has a different number of openings than the second set; and
  • wherein the resulting first spread pattern is different from the second spread pattern.
• The complaint seeks a declaration of non-infringement as to the '974 Patent generally (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

• The accused products are commercial rotary spreaders manufactured by Plaintiff Charles Walters Equipment, specifically Product Nos. CW1500 and CW2800 (Compl. ¶18).

Functionality and Market Context

• The complaint describes the products as rotary spreaders for professional turf and landscape applications (Compl. ¶11). It alleges they are sold through distributors, including on Amazon (Compl. ¶12). A central technical allegation in the complaint is that the accused spreaders are constructed with only a single opening in the bottom of the hopper, which interfaces with a shut-off plate below it (Compl. ¶20). The complaint includes an annotated photograph to support this structural characterization. This annotated photograph from an exhibit to the complaint shows the accused spreader's distinct blue hopper and black shut-off plate, highlighting the single opening in the hopper (Compl. ¶20, Ex. D).

IV. Analysis of Infringement Allegations

10,993,368 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Non-Infringing Functionality	Complaint Citation	Patent Citation
a hopper including a plurality of openings in a bottom of the hopper	Plaintiff alleges its hopper has only one singular opening in its bottom, not a "plurality."	¶20	col. 7:19-21
a shut-off adjustment plate...including a plurality of exit openings	Plaintiff's argument acknowledges that a separate component, the shut-off plate, has a plurality of openings, but contends this does not satisfy the "hopper" limitation.	¶20	col. 7:22-24
a spread control mechanism disposed below the shut-off adjustment plate and including a plurality of segments...	The complaint does not provide sufficient detail for analysis of this element.		col. 7:31-33

• Identified Points of Contention:
  • Scope Questions: The primary dispute appears to center on the claim term "a plurality of openings in a bottom of the hopper." The central question is whether this language requires two or more distinct physical apertures formed in the hopper structure itself, or if it could be construed more broadly to be met by a single large hopper opening that works in conjunction with a multi-opening plate situated below it.
  • Technical Questions: A key factual question will be whether the accused hopper is a single, integral component with one opening, as alleged by Plaintiff. The complaint asserts that Claim 1 requires "two separate structures...each containing a plurality of openings," a position it supports with a visual depiction of the accused device (Compl. ¶20).

12,120,974 Patent Infringement Allegations

The complaint does not provide an element-by-element chart for the '974 Patent. Instead, it presents a narrative argument based on visuals from Defendant's own pre-suit claim charts.

Plaintiff's core non-infringement theory is that its spreaders do not practice the claimed method because they lack the structure to be "shifted" between two different configurations having different numbers of openings to create different spread patterns (Compl. ¶21). The complaint includes annotated photographs from Defendant's purported claim chart, which are used to argue that the device has only one configuration of openings in the hopper and lacks any mechanism for creating a "second set of one or more through openings" as required by the claims (Compl. ¶21, Ex. D).

• Identified Points of Contention:
  • Scope Questions: The analysis may turn on the definition of "shifting the broadcast spreader into a second configuration." The question for the court will be what degree of mechanical or operational change is required to constitute a "shift" into a "second configuration" that utilizes a "second set" of openings.
  • Technical Questions: The dispute raises the factual question of whether the accused spreader's mechanism, in any mode of operation, results in the use of a different number of active openings to produce a different spread pattern. Plaintiff alleges its product is not capable of performing this claimed function (Compl. ¶21).

V. Key Claim Terms for Construction

• The Term: "a plurality of openings in a bottom of the hopper" (’368 Patent, Claim 1)
• Context and Importance: This term is central to Plaintiff's non-infringement argument for the '368 Patent. The definition will determine whether the claim reads on a device with a single large aperture in the hopper that feeds a multi-opening plate below. Practitioners may focus on this term because the complaint’s photographic evidence suggests a clear structural difference between the patent's embodiments and the accused product’s design (Compl. ¶20).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification’s focus is on the functional outcome of controlling the spread pattern. A party could argue that any structure achieving this functional alignment of openings meets the claim’s intent, regardless of whether the "plurality" is in the hopper itself or created in combination with the plate below.
  • Evidence for a Narrower Interpretation: The plain language of Claim 1 recites two distinct elements: "a hopper including a plurality of openings" and, separately, "a shut-off adjustment plate... including a plurality of exit openings" (’368 Patent, col. 7:19-24). This parallel structure suggests the limitations apply to two different physical components. Plaintiff's complaint argues this requires "two separate structures... each containing a plurality of openings" (Compl. ¶20).

VI. Other Allegations

• Indirect Infringement: The complaint broadly seeks a declaration of non-infringement "directly or indirectly" but does not contain specific factual allegations from Defendant that would form the basis for an indirect infringement claim (Compl. ¶40). The complaint does not provide sufficient detail for analysis of indirect infringement.

VII. Analyst’s Conclusion: Key Questions for the Case

This declaratory judgment action appears poised to turn on two central disputes, one rooted in claim construction and the other in technical function.

• A core issue will be one of definitional scope: For the '368 Patent, can the claim term "a plurality of openings in a bottom of the hopper" be construed to read on a device with a single hopper aperture that overlays a separate plate containing multiple openings, or does the plain language require multiple distinct holes in the hopper structure itself?
• A key evidentiary question will be one of functional capability: For the '974 Patent, does the accused spreader's mechanism in fact perform the claimed method of "shifting" between distinct operational "configurations" that use different numbers of openings to create different spread patterns, or is there a fundamental mismatch in its mechanical operation as Plaintiff alleges?