Admar Intl Inc v. J 1 Trading Wholesale Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Luv N’ Care, LTD. (Louisiana) and Admar Intl, Inc. (Delaware)
  • Defendant: J-1 TRADING WHOLESALE, INC. (California)
  • Plaintiff’s Counsel: Luv N’ Care, LTD.
• Case Identification: 3:20-cv-00487, W.D. La., 04/17/2020
• Venue Allegations: Venue is based on Defendant allegedly advertising, promoting, distributing, and selling products to residents within the Western District of Louisiana.
• Core Dispute: The provided complaint alleges trademark infringement. This report, following the prompt’s patent-centric format, analyzes U.S. Patent No. 2,335,700, related to photographic distortion lens mounts, which was provided for analysis.
• Technical Context: The patent addresses the field of photographic enlargers, specifically the mechanical means for adjusting a lens to correct for perspective distortion present in a photographic negative.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent analyzed in this report.

Case Timeline

Date	Event
1941-07-05	U.S. Patent No. 2,335,700 Priority Date (Application Filing)
1943-11-30	U.S. Patent No. 2,335,700 Issue Date
2020-04-17	Complaint Filing Date

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

U.S. Patent No. 2,335,700 - "DISTORTION LENS-MOUNT"

• Patent Identification: U.S. Patent No. 2,335,700, “DISTORTION LENS-MOUNT,” issued November 30, 1943.

The Invention Explained

• Problem Addressed: The patent seeks to solve the problem of correcting distortion in photographic enlargements, which occurs when a picture is taken at an angle, and to do so without requiring the lens to be stopped down to small apertures. (U.S. Patent No. 2,335,700, col. 1:1-9).
• The Patented Solution: The invention is a novel lens mount for a photographic enlarger that allows the lens to be both revolved horizontally and tilted on a pivot axis. It achieves this using a "bell" structure that rotates within the enlarger head and a lens board with a "substantially spherical" outer wall that nests and tilts within the bell, creating a ball-and-socket-type joint. (’700 Patent, col. 1:13-18, col. 2:14-21). This design maintains the lens's nodal point on the enlarger's central optical axis during adjustment, which is critical for preventing further image shifting. (’700 Patent, col. 2:5-12).
• Technical Importance: This mechanism provided a precise and repeatable method to straighten images to exact scale measurements from distorted negatives, a significant capability for technical fields using photography for maps, architectural drawings, and scientific subjects. (’700 Patent, col. 1:5-12).

Key Claims at a Glance

• The complaint does not assert any specific claims of the ’700 patent. For the purpose of analysis, independent claim 1 is representative.
• The essential elements of independent claim 1 include:
  • An attaching plate with a centrally located opening defined by a cylindrical wall.
  • A "bell" structure, open at both ends, with a hollow neck that slidingly enters the plate's opening.
  • A spring mechanism that engages the neck and plate to hold the bell in place.
  • A lens board having an external wall that extends into the bell.
  • "Trunnion members" that interconnect the bell and the lens board, allowing the lens board to be "rockably" maintained within the bell.
  • A mechanism to releasably secure the bell in various rotational positions.
  • A separate mechanism to releasably fix the lens board in various "rocked" (tilted) positions.
• The complaint does not reserve the right to assert any dependent claims.

III. The Accused Instrumentality

The complaint does not identify a specific product accused of infringing U.S. Patent No. 2,335,700. The complaint's allegations are directed to alleged trademark infringement by medical thermometers. (Compl. ¶4). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain infringement allegations, narrative theories, or claim charts corresponding to U.S. Patent No. 2,335,700. Therefore, an analysis of infringement allegations cannot be performed.

V. Key Claim Terms for Construction

As the complaint does not allege infringement of the ’700 patent, there is no active dispute over claim terms. However, in a hypothetical infringement action, the following terms from claim 1 would likely be central to the dispute.

• The Term: "substantially spherical surface"

• Context and Importance: This term defines the interface between the tilting lens board (19) and the rotating bell (18). The scope of "substantially" is critical, as it determines how closely an accused device's geometry must match a perfect sphere to infringe. This feature is also key to the inventor's goal of preventing light leaks without separate shields. (’700 Patent, col. 2:50-52).

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification refers to the overall mechanism as a "ball and socket arrangement," suggesting the term should be interpreted functionally to cover geometries that achieve a similar pivoting and sealing effect. (’700 Patent, col. 2:20-21).
  • Evidence for a Narrower Interpretation: The figures, particularly Figs. 6 and 7, show a specific, continuous curvature. An accused infringer might argue the term is limited to a shape that closely tracks the depicted embodiment, rather than any surface that merely permits tilting.

• The Term: "trunnion members"

• Context and Importance: This term defines the physical components that create the pivot axis for the lens board's tilting motion. Its construction would determine whether the claims are limited to the specific screw-and-bolt structure shown or could read on other mechanical pivots. Practitioners may focus on this term because it is the linchpin of the claimed tilting functionality.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: "Trunnion" is a general mechanical term for a pivot, suggesting the claim could cover a variety of pivoting structures that allow the lens board to "rock" as claimed.
  • Evidence for a Narrower Interpretation: The patent provides a detailed description of the trunnion members as a specific assembly comprising a screw (34) and a bolt (35) that pass through aligned "ears" (32, 33, 27, 28) on the lens board and bell. (’700 Patent, col. 2:32-44). A party could argue the term should be limited to this disclosed two-part, diametrically opposed pivot structure.

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement related to U.S. Patent No. 2,335,700. The willfulness allegations in the complaint pertain exclusively to the trademark claims. (Compl. ¶32).

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

Given that the complaint does not allege infringement of the ’700 patent, any litigation would first need to establish a viable infringement theory. If such a case were brought, it would likely turn on the following high-level questions:

1. Technological Applicability: A threshold question would be one of relevance to modern technology: could the claims, drafted for purely optical-mechanical photographic enlargers from the 1940s, be construed to cover any modern technology, such as adjustable lens mounts in digital projectors or industrial machine vision systems, if such were accused?
2. Structural Scope: A central claim construction dispute would be one of definitional boundaries: are the terms "bell", "trunnion members", and "substantially spherical surface" limited to the specific mechanical "ball-and-socket" structure disclosed in the patent's figures, or can they be interpreted more broadly to encompass any functionally equivalent mechanisms that provide independent rotation and tilting of a lens?