DCT
3:24-cv-00873
Uriah Products LLC v. Curt Mfg LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uriah Products, LLC (Missouri)
- Defendant: CURT Manufacturing LLC (Delaware)
- Plaintiff’s Counsel: CALFEE, HALTER & GRISWOLD LLP
- Case Identification: 3:24-cv-00873, N.D. Ind., 10/24/2024
- Venue Allegations: Venue is alleged to be proper in the Northern District of Indiana because Defendant maintains a principal place of business in Elkhart, Indiana, within the district, and has allegedly committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s adjustable aluminum trailer hitches infringe a patent related to an adjustable hitch assembly.
- Technical Context: The technology concerns adjustable trailer hitch ball mounts, a common automotive accessory used to connect a towing vehicle to a trailer at various heights.
- Key Procedural History: The asserted patent, U.S. Patent No. 10,857,846, was the subject of an ex parte reexamination proceeding, which concluded on August 12, 2024, with the U.S. Patent and Trademark Office confirming the patentability of all original claims. The complaint also alleges that Plaintiff’s own products are marked with the patent, providing notice to the public.
Case Timeline
| Date | Event |
|---|---|
| 2017-04-11 | ’846 Patent Priority Date |
| 2020-12-08 | ’846 Patent Issue Date |
| 2024-08-12 | ’846 Patent Reexamination Certificate Issued |
| 2024-10-24 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 10857846 (“Adjustable Hitch Assembly”), issued December 8, 2020.
The Invention Explained
- Problem Addressed: The patent is directed to "ball and socket type hitch apparatus" for vehicles, implicitly addressing the need for a single hitch that can be easily reconfigured to accommodate trailers and vehicles of different heights. (’846 Patent, col. 1:12-14).
- The Patented Solution: The invention is a multi-part adjustable hitch assembly. As described in the specification and illustrated in figures such as FIG. 3, it consists of a primary "hitch bracket" with an L-shape and a separate "hitch-ball mounting block." (’846 Patent, col. 2:56-58, Fig. 3). The mounting block is designed to slide vertically along the vertical "tenon portion" of the L-shaped bracket and can be secured at different heights using pins. (’846 Patent, col. 3:41-43). The mounting block itself contains a through-hole to receive the shank of a hitch ball. (’846 Patent, col. 3:17-18).
- Technical Importance: The design allows for significant "drop to rise capability" in a single unit, and the patent discloses a preferred manufacturing method using monolithic aluminum extrusions for the main components, suggesting an aim for a combination of strength and relatively low weight. (’846 Patent, col. 2:58-64).
Key Claims at a Glance
- The complaint asserts at least independent claim 1. (Compl. ¶18).
- Independent Claim 1 requires, in essence:
- A hitch bracket, a vertically-adjustable hitch-ball mounting block, hitch pins, and at least one hitch ball.
- The hitch bracket must be "generally L-shaped" with a horizontal drawbar portion and a vertical tenon portion.
- The mounting block must have a "slotted mortise hole" defined by a web, arms, and in-turned flanges, which receives the bracket's tenon portion to allow for sliding vertical adjustment.
- The web of the mounting block must define a rear wall for the mortise hole and have a vertical through-hole.
- A hitch ball with a cylindrical shank base is received in the mounting block's through-hole.
- The rear wall of the mounting block's mortise hole is formed with a "pin-receiving hole" adapted for a "pin to secure the hitch ball."
- The complaint reserves the right to assert additional claims. (Compl. ¶20).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Alumalite Adjustable Aluminum Hitch with Dual Ball" products, specifically models #45366, #45365, #45364, and #45363, as the "Accused Products." (Compl. ¶14).
Functionality and Market Context
- The Accused Products are adjustable trailer hitch ball mounts sold and distributed by Defendant CURT. (Compl. ¶14). Based on images in the complaint, the products feature a main L-shaped body and a separate block that holds two hitch balls of different sizes. (Compl. p. 7). This block can be attached at different vertical positions on the L-shaped body to adjust the towing height. (Compl. p. 8). The complaint alleges the accused models are "nearly identical, except for differences in the size and maximum 'drop'." (Compl. ¶14). An annotated image provided in the complaint shows the accused hitch ball mounting block, which can be vertically adjusted on the hitch bracket. (Compl. p. 8).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint provides an image-based claim chart alleging that the Accused Products meet every limitation of Claim 1 of the ’846 Patent. (Compl. ¶20).
’846 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a hitch bracket; a vertically-adjustable hitch-ball mounting block; a plurality of hitch pins; one or more hitch balls | The Accused Products are alleged to be adjustable hitch assemblies containing these four fundamental components, as depicted in annotated images. | ¶20 (pp. 7-9) | col. 2:56-58 |
| wherein the hitch bracket is generally L-shaped and comprises a generally horizontal drawbar portion...and a generally-vertical tenon portion... | The complaint alleges the main body of the Accused Product is L-shaped, with a horizontal portion for insertion into a vehicle receiver and a vertical portion for adjustment. An annotated image in the complaint identifies these alleged portions. | ¶20 (p. 10) | col. 2:60-63 |
| wherein the vertically-adjustable hitch-ball mounting block comprises a web, arms extending out..., and in-turned flanges on the arms...which collectively define a slotted mortise hole...for receiving the tenon portion | The complaint alleges the accused mounting block has a web, arms, and flanges that form a channel (slotted mortise hole) for sliding onto the vertical tenon of the bracket. A photograph with callouts illustrates these alleged features. | ¶20 (p. 11) | col. 3:1-6 |
| wherein the web of the...mounting block defines a rear wall for the slotted mortise hole and is formed with a generally vertical through hole | The accused mounting block is alleged to have a rear wall for its adjustment channel and a vertical hole passing through it to accept the hitch ball shank. An annotated photograph in the complaint identifies these alleged features. | ¶20 (p. 12) | col. 3:17-18; col. 3:32-33 |
| the hitch ball comprises a cylindrical shank base that transitions into a neck which in turn transitions into a ball head | The hitch balls on the Accused Products are alleged to have the claimed three-part structure of a shank, neck, and ball head. | ¶20 (p. 13) | col. 3:53-56 |
| said cylindrical shank base of the hitch ball is received in the through hole in the web of the...mounting block | The complaint alleges the shank of the hitch ball is inserted into the vertical through-hole of the mounting block. | ¶20 (p. 13) | col. 4:1-3 |
| said rear wall for slotted mortise hole of the...mounting block is formed with a pin-receiving hole into the through hole and adapted for a pin to secure the hitch ball | The complaint alleges the mounting block has a rear wall with holes that align with the vertical through-hole, allowing a "pin" to secure the hitch ball. | ¶20 (p. 14) | col. 6:55-58 |
Identified Points of Contention
- Scope Questions: The infringement analysis may turn on the interpretation of claim terms in relation to the accused device's structure. For example, the claim requires a "slotted mortise hole" in the mounting block, which the complaint maps to a C-shaped channel in the accused product. (Compl. p. 11). The court may need to determine if the accused structure meets the specific definition of a "mortise" as contemplated by the patent.
- Technical Questions: A key technical question arises from the final limitation requiring a "pin" to secure the hitch ball. The patent specification, in its preferred embodiment and in dependent Claim 5, describes a "threaded fastener" (e.g., a cap screw) for this purpose. (’846 Patent, col. 4:13-14, col. 10:14-15). The court will have to address whether the fastener used in the Accused Products, which appears to be a threaded bolt, constitutes a "pin" within the meaning of independent Claim 1.
V. Key Claim Terms for Construction
- The Term: "a pin to secure the hitch ball"
- Context and Importance: The construction of "pin" is critical. If construed narrowly to mean only an unthreaded, cotter-style pin, it may not read on the Accused Products, which appear to use a threaded fastener to secure the ball to the mounting block. Practitioners may focus on this term because of the potential application of the doctrine of claim differentiation, which presumes that a difference in wording between an independent and dependent claim reflects a difference in scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 1 does not explicitly restrict "pin" to being unthreaded. Plaintiff may argue that in the context of mechanical fasteners, "pin" can broadly refer to any pin-shaped object that secures one component to another, including a threaded one.
- Evidence for a Narrower Interpretation: Defendant may argue that the patent consistently uses the term "hitch pins" to refer to the unthreaded locking pins for vertical adjustment. (’846 Patent, col. 6:27). More significantly, dependent Claim 5 explicitly recites "a threaded fastener" for securing the hitch ball. (’846 Patent, col. 10:14-22). This suggests the patentee viewed a "threaded fastener" as a distinct and narrower species of the securing mechanism, implying the generic "pin" of Claim 1 is something different, i.e., unthreaded.
VI. Other Allegations
- Indirect Infringement: The complaint includes a general allegation of indirect infringement but does not plead specific facts to support the requisite knowledge and intent for inducement, such as referencing defendant's specific instructions or advertising that would encourage infringing use. (Compl. ¶23).
- Willful Infringement: The complaint alleges willful infringement, asserting that Defendant had pre-suit knowledge of the ’846 Patent. (Compl. ¶¶26-27). The basis for this alleged knowledge is constructive notice via Plaintiff's patent marking on its own commercial products. (Compl. ¶22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction and differentiation: can the term "pin," used in Claim 1 to describe the component securing the hitch ball, be interpreted to cover the threaded fastener allegedly used in the Accused Product, or does the specific recitation of a "threaded fastener" in dependent Claim 5 mandate a narrower construction for the term in the independent claim?
- A key procedural question will be the impact of the reexamination certificate: Plaintiff will likely argue that the PTO's confirmation of the patent's validity over additional prior art strengthens the presumption of validity and demonstrates the objective unreasonableness of any continued infringement by the Defendant, particularly as it relates to willfulness and potential damages enhancement.