DCT

3:25-cv-00636

Camco Mfg LLC v. Seaflo Marine & RV North America LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00636, N.D. Ind., 07/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of Indiana because Defendant maintains a regular and established place of business in South Bend, Indiana, and the alleged acts of infringement occurred within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s recreational vehicle (RV) sewer hose kits and tongue jack stands infringe its utility and design patents, and further constitute trade dress infringement.
  • Technical Context: The dispute concerns accessories for the RV market, specifically a patented connector for accordion-style waste hoses and a patented ornamental design for a trailer tongue jack support pad.
  • Key Procedural History: The complaint states that on May 14, 2024, Plaintiff’s counsel sent a cease-and-desist letter to Defendant, providing notice of the alleged infringement of its patents and trade dress. Plaintiff alleges that Defendant did not provide a substantive response prior to the filing of this lawsuit, a fact that may be relevant to the claim of willful infringement.

Case Timeline

Date Event
2006-03-01 Alleged first use of Plaintiff's Trade Dress in commerce
2018-09-12 Priority Date for U.S. Patent No. D893,120
2020-08-11 Issue Date for U.S. Patent No. D893,120
2021-11-04 Priority Date for U.S. Patent No. 11,732,829
2023-08-22 Issue Date for U.S. Patent No. 11,732,829
2024-05-14 Plaintiff sends Cease-and-Desist Letter to Defendant
2025-07-23 Complaint Filing Date

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

U.S. Patent No. 11,732,829 - "CORRUGATED HOSE WITH BAYONET CONNECTOR"

  • Patent Identification: U.S. Patent No. 11732829, "CORRUGATED HOSE WITH BAYONET CONNECTOR," issued August 22, 2023. (Compl. ¶50).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the difficulty in achieving a "robust and leak-free connection" when attaching rigid fittings to flexible, corrugated RV sewer hoses, particularly those with accordion-style (non-spiral) corrugations. (’829 Patent, col. 1:12 - col. 2:9). Existing methods like external hose clamps are noted to be potentially unreliable. (’829 Patent, col. 2:22-26).
  • The Patented Solution: The invention provides a connector assembly that mechanically secures an accordion-style hose to a bayonet coupling without external clamps. As detailed in the specification and shown in figures like Fig. 6, the system uses a locking ring to sandwich a purpose-built "circumferential ridge" on the hose end, compressing it into a channel within the bayonet coupling to create a secure, frictional, leak-free seal. (’829 Patent, Abstract; col. 2:46-62).
  • Technical Importance: This solution provided a method for creating a reliable, swiveling, and tool-free connection for accordion-style corrugated hoses, which could not be effectively addressed by prior art screw-on connectors designed for spirally-wound hoses. (’829 Patent, col. 2:16-19).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 3-7. (Compl. ¶52).
  • The essential elements of independent claim 1 include:
    • An assembly of a length of hose, a bayonet coupling, and a locking ring.
    • The hose has "accordion-shaped corrugations" and a proximal end featuring a "cylindrical section" and a "circumferential ridge."
    • The bayonet coupling has a "longitudinal tubular section," a "circumferential groove," and a "circular collar" that together form a "circumferential channel."
    • The "circumferential ridge" of the hose is "frictionally compressed between the locking ring and the bayonet coupling."
  • The complaint reserves the right to assert other claims, including dependent claims that add features such as a bayonet swivel, a slip swivel, and specific blade configurations. (Compl. ¶74-120).

U.S. Patent No. D893,120 - "FASTEN TONGUE JACK PAD"

  • Patent Identification: U.S. Patent No. D893,120, "FASTEN TONGUE JACK PAD," issued August 11, 2020. (Compl. ¶121).

The Invention Explained

  • Problem Addressed: The complaint does not specify a technical problem, which is typical for a design patent. The product's context is providing a stable base for an RV trailer's tongue jack. (Compl. ¶6).
  • The Patented Solution: The patent claims the unique ornamental design for a tongue jack pad as illustrated in its figures. The design consists of a central, circular hub with four arms extending outward in a cross-shaped or "X" configuration. The invention is the specific visual appearance of the pad, not its mechanical function. (’120 Patent, Figs. 1-6).
  • Technical Importance: In the context of a design patent, the importance is aesthetic. The complaint alleges the design has "novel aspects" that distinguish it in the marketplace. (Compl. ¶127).

Key Claims at a Glance

  • Design patents contain a single claim for the ornamental design as shown and described. The complaint asserts infringement of this claim. (Compl. ¶123-125; ’120 Patent, Claim).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two categories of accused products: (1) "Infringing Sewer Hose Kits," including the "Seaflo Hose," and (2) "Infringing Tongue Jack Stands." (Compl. ¶52, ¶123).

Functionality and Market Context

  • The accused "RV Sewer Hose Kit" is marketed for connecting an RV to a dump station and is alleged to include a corrugated hose, a bayonet coupling, and a locking ring. (Compl. ¶54, ¶56). A screenshot from Defendant's website shows an orange and grey hose kit described as having "Bayonet-Style Swivel Fittings." (Compl. p. 8).
  • The accused "RV tongue jack stands" are alleged to be "copies of, identical to, or virtually identical to" the product embodying the ’120 Patent design. (Compl. ¶123).
  • The complaint alleges the accused products are "Knock-off Products" sold through Defendant's website and on Amazon.com, and that they use a confusingly similar orange trade dress to trade on Plaintiff's goodwill. (Compl. ¶9, ¶26, ¶29).

IV. Analysis of Infringement Allegations

’829 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a corrugated hose with bayonet connector comprising: a length of hose, a bayonet coupling and a locking ring The accused Seaflo Hose kit includes a length of hose, a bayonet coupling, and a locking ring that locks the hose to the coupling. ¶56 col. 2:50-52
the length of hose defining a plurality of accordion-shaped corrugations and a proximal end The accused Seaflo Hose has "accordion-shaped corrugations" and a proximal end that terminates inside the bayonet coupling. ¶58 col. 4:45-48
the proximal end including a cylindrical section and a circumferential ridge The proximal end of the accused hose includes a cylindrical section and a "circumferential ridge (26) formed by a portion of the orange rib." ¶60 col. 4:48-50
the circumferential ridge positioned between the plurality of accordion-shaped corrugations and the proximal end The circumferential ridge on the accused hose is located between the external accordion-shaped corrugations and the proximal end of the hose. ¶62 Abstract
the bayonet coupling comprises a circumferential groove positioned adjacent to the proximal end of the bayonet coupling The accused bayonet coupling comprises a circumferential groove adjacent to its proximal end. ¶66 col. 5:4-5
the bayonet coupling further comprises a circular collar located adjacent to the circumferential groove… The accused bayonet coupling has a circular collar adjacent to the groove and spaced from the tubular section. A photograph of an acquired product shows this feature. (Compl. p. 9). ¶68 col. 5:6-9
whereby a circumferential channel is formed between the circular collar and the longitudinal tubular section A circumferential channel is formed in the accused product between the circular collar and the longitudinal tubular section. ¶70 col. 5:9-12
wherein the circumferential ridge is frictionally compressed between the locking ring and the bayonet coupling The circumferential ridge of the accused hose "is frictionally compressed in the groove (28) of the locking ring between the locking ring (20) and the bayonet coupling (18)." ¶72 col. 7:29-33

Identified Points of Contention

  • Scope Questions: A central dispute may arise over the proper construction of "circumferential ridge." The defense may argue that this term is limited to the specific asymmetric profile described in the patent's preferred embodiment (’829 Patent, col. 4:56-60), raising the question of whether the accused product's "orange rib" (Compl. ¶60) meets that potentially narrower definition.
  • Technical Questions: The analysis will likely focus on the term "frictionally compressed." A key evidentiary question is what level of force or physical deformation is required to meet this limitation. The court will have to determine whether the interaction between the parts of the accused device creates the specific "tight frictional engagement" taught by the patent (’829 Patent, col. 6:55-58) or merely a loose assembly.

’120 Patent Infringement Allegations

The complaint alleges that the accused "Infringing Tongue Jack Stands" are "substantially similar" to the design protected by the ’120 Patent. (Compl. ¶126). The legal test for design patent infringement is the "ordinary observer" test. The core allegation is that an ordinary observer, familiar with prior designs, would be deceived into believing the accused product is the same as the patented design. (Compl. ¶125). The complaint asserts the accused stands adopted the novel aspects of the design, such as the number and pattern of the legs and the central openings. (Compl. ¶127). The key question for the court will be a direct visual comparison to determine if the overall appearances are confusingly similar.

V. Key Claim Terms for Construction

For the ’829 Patent:

  • The Term: "circumferential ridge"

    • Context and Importance: This is the critical feature on the hose that the connector assembly is designed to capture. The infringement analysis for claim 1 hinges on whether the protrusion on the accused Seaflo Hose qualifies as a "circumferential ridge." Practitioners may focus on this term because its definition could either broadly cover any raised ring or be narrowly limited to the specific geometry shown in the patent's figures.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification at one point refers to the element more generally as a "circumferential ridge or projection," which could support a construction that is not limited to a specific shape. (’829 Patent, col. 4:49-50).
      • Evidence for a Narrower Interpretation: The patent describes a preferred embodiment where the ridge has an "asymmetric shape" with a "first sloped surface" that is steeper than the "second sloped surface." (’829 Patent, col. 4:56-62). A party could argue this specific shape is integral to the invention's function and should limit the claim's scope.

  • The Term: "frictionally compressed"

    • Context and Importance: This term describes the final state of the assembled connector and is the basis for the secure, leak-free seal. The dispute may turn on whether the accused product achieves this specific state.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The language could be interpreted to mean any state where the parts are held together by friction, without requiring a specific quantifiable force.
      • Evidence for a Narrower Interpretation: The abstract uses the phrase "sandwiched in close frictional contact." (’829 Patent, Abstract). The detailed description further explains that assembly results in a "tight frictional engagement" that can cause "a slight expansion of the diameter" of the locking ring, suggesting a physically significant compression rather than a mere passive fit. (’829 Patent, col. 6:55-60).

VI. Other Allegations

  • Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement, as the allegations focus on direct infringement by Defendant for its own making, using, and selling of the accused products. (Compl. ¶172).
  • Willful Infringement: The complaint alleges willfulness for both patents. For the ’829 Patent, it alleges knowledge based on the May 14, 2024 cease-and-desist letter, establishing a basis for post-notice willfulness. (Compl. ¶174). For the ’120 Patent, it more broadly alleges Defendant had "actual and constructive knowledge" of the patent "since before this Complaint was filed," suggesting a potential basis for pre-suit willfulness. (Compl. ¶130).

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

  1. Claim Scope and Factual Proof (’829 Patent): A central issue will be one of claim construction: can the term "circumferential ridge", which is described with a specific asymmetric geometry in the patent’s preferred embodiment, be construed to cover the "orange rib" feature on the accused product? This legal question is tied to an evidentiary one of functional operation: does the accused connector actually place that rib into a state of "frictional compression" as required by the claim, or is there a material difference in how the components assemble and function?
  2. Visual Deception (’120 Patent): The design patent case will turn on the ordinary observer test. The key question for the fact-finder will be whether the overall visual impression of the Defendant’s tongue jack stand is "substantially the same" as the patented design, or if differences in proportion, curvature, and other details are sufficient to create a distinct visual appearance.
  3. Trade Dress and Intent: A significant parallel issue is the non-functionality and secondary meaning of Plaintiff’s orange trade dress for RV sewer fittings. The court will need to determine if consumers associate that color with a single source (Camco), and if Defendant’s use of a similar color on a directly competing product is likely to cause confusion. This inquiry is linked to the question of intent, which is central to the willfulness and unfair competition claims.