DCT
1:25-cv-13150
Dynocom Industries Inc v. Dynojet Research Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dynocom Industries, Inc. (Texas)
- Defendant: Dynojet Research, Inc. (Nevada)
- Plaintiff’s Counsel: Lambert Shortell & Connaughton
- Case Identification: 1:25-cv-13150, D. Mass., 10/27/2025
- Venue Allegations: Plaintiff alleges venue is proper based on Defendant offering the accused product for sale on its website and having made sales within the District of Massachusetts.
- Core Dispute: Plaintiff alleges that Defendant’s Model Vector - X4000 hub dynamometer infringes a patent related to portable vehicle dynamometers.
- Technical Context: The technology concerns dynamometers used to measure vehicle engine power, specifically portable designs that connect directly to a vehicle's wheel hub, offering a more compact alternative to traditional roller-based systems.
- Key Procedural History: The complaint alleges a history of failed acquisition discussions between the parties, beginning with a letter of intent in March 2021. During these discussions, Plaintiff allegedly disclosed confidential information regarding the patent-in-suit to Defendant. The complaint further alleges that after these discussions failed, Defendant's CEO stated a belief that Defendant could "get around the" patent before launching the accused product.
Case Timeline
| Date | Event |
|---|---|
| 2009-12-10 | ’374 Patent Priority Date |
| 2013-08-13 | ’374 Patent Issue Date |
| 2021-03-11 | Defendant sends letter of intent to acquire Plaintiff |
| 2022-06-01 | Parties enter nondisclosure agreement to discuss acquisition |
| 2025-06-01 | Parties were discussing potential patent licensing |
| 2025-09-24 | Plaintiff becomes aware of Defendant’s Accused Product |
| 2025-10-27 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,505,374 - Portable On Vehicle Dynamometer
- Patent Identification: U.S. Patent No. 8,505,374, "Portable On Vehicle Dynamometer," issued August 13, 2013 (the "’374 Patent").
The Invention Explained
- Problem Addressed: The patent describes prior art dynamometers as requiring significant dedicated space, such as being "buried in a garage floor" or needing a rack to "suspend a vehicle above the dynamometer" (’374 Patent, col. 1:19-22).
- The Patented Solution: The invention is a portable on-vehicle dynamometer that couples directly to a vehicle's drive shaft or hub (’374 Patent, col. 2:20-23). The device uses a rigid frame, an eddy current brake to provide resistance, outwardly extending support arms for stability during operation, and roller assemblies on its base to allow for easy positioning and multidirectional movement (’374 Patent, Abstract; Fig. 1). This design aims to provide a compact and mobile power-measurement solution.
- Technical Importance: The described approach allows for dynamometer testing in environments lacking the space for traditional, permanently installed equipment (’374 Patent, col. 1:22-24).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶33).
- Claim 1 Elements:
- A portable on vehicle dynamometer for determining power output from a drive shaft, comprising:
- a rigid frame;
- a load shaft rotatably coupled to said rigid frame;
- an eddy current brake having a stator connected to said rigid frame, and a rotor connected to said load shaft;
- a hub coupling secured to a first end of said load shaft and connected directly to the drive shaft for transferring power to the load shaft, wherein said hub coupling, said drive shaft and said load shaft co-axially rotate;
- said rigid frame having two outwardly extending support arms, and arm locks which secure said outwardly extending support arms in fixed positions;
- support feet assemblies mounting to respective ones of outer ends of said support arms; and
- two roller assemblies mounted to a lower end of said rigid frame, providing multidirectional movement of said dynamometer.
III. The Accused Instrumentality
Product Identification
- Product Identification: Defendant's Model Vector - X4000 hub dynamometer (the "Accused Product") (Compl. ¶1).
Functionality and Market Context
- Functionality and Market Context: The complaint alleges the Accused Product is a hub dynamometer offered for sale on Defendant's website (Compl. ¶¶26, 32). The complaint asserts that the product's features "closely resemble" those of Plaintiff's own products embodying the ’374 Patent and that it "incorporates each and every limitation of Claim 1" (Compl. ¶¶25, 34). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’374 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a rigid frame; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:36-37 |
| a load shaft rotatably coupled to said rigid frame; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:23-24 |
| an eddy current brake having a stator connected to said rigid frame, and a rotor connected to said load shaft; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:25-29 |
| a hub coupling secured to a first end of said load shaft and connected directly to the drive shaft... wherein said hub coupling, said drive shaft and said load shaft co-axially rotate; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:29-32 |
| said rigid frame having two outwardly extending support arms, and arm locks which secure said outwardly extending support arms in fixed positions; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:38-42 |
| support feet assemblies mounting to respective ones of outer ends of said support arms; | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:46-49 |
| two roller assemblies mounted to a lower end of said rigid frame, providing multidirectional movement of said dynamometer. | The complaint alleges the Accused Product is a hub dynamometer that incorporates this element. | ¶34 | col. 2:61-64 |
Identified Points of Contention
- Scope Questions: The complaint's allegations are conclusory and do not describe the specific structure of the Accused Product. A central issue will be whether the Accused Product's specific mechanisms for stabilization and mobility fall within the scope of the claim terms "outwardly extending support arms," "arm locks," and "roller assemblies."
- Technical Questions: The complaint does not provide evidence detailing how the Accused Product operates. Key questions will involve factual determinations of whether the Accused Product's components perform the functions required by the claims. For example, do its support structures secure in "fixed positions," and do its mobility features provide "multidirectional movement" as those terms are understood in the context of the patent?
V. Key Claim Terms for Construction
The Term: "outwardly extending support arms, and arm locks which secure said outwardly extending support arms in fixed positions"
- Context and Importance: This structural limitation is central to the claimed invention's stability during use. The dispute will likely focus on what constitutes an "arm lock" and a "fixed position." Practitioners may focus on this term because the specific design of a competitor’s stabilization system is a likely area of differentiation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify a particular type of arm or lock, which may support a construction covering any structure that performs the stated functions of extending outward and securing the arm.
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment where support arms (30) slide into receiver tubes (32) and are secured by "Arm locks 34" (’374 Patent, col. 2:40-46; Fig. 3). This detailed description of a particular locking mechanism could be used to argue for a narrower construction limited to similar structures.
The Term: "roller assemblies... providing multidirectional movement"
- Context and Importance: The portability and ease of positioning the dynamometer is a key feature. The definition of "multidirectional movement" will be critical to determining infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is functional and does not limit the structure of the "roller assemblies" beyond requiring that they enable movement in multiple directions, potentially encompassing various types of casters or wheels.
- Evidence for a Narrower Interpretation: The detailed description and Figure 10 depict a specific "roller assembly 46" with a support ball (144) in a bearing assembly (148) designed to "move freely" (’374 Patent, col. 4:61-62; col. 5:1-4). This specific embodiment could be cited to argue that the term requires a mechanism capable of movement similar to a ball caster, rather than simple pivoting wheels.
VI. Other Allegations
Indirect Infringement
- The complaint makes a passing reference to the Accused Product contributing to infringement but does not plead a separate count for indirect infringement or allege specific facts to support the requisite knowledge and intent for inducement or contributory infringement (Compl. ¶1).
Willful Infringement
- The complaint alleges that Defendant’s infringement has been willful based on pre-suit knowledge of the ’374 Patent (Compl. ¶36). The basis for this allegation includes Defendant’s due diligence during failed acquisition discussions, where it allegedly received confidential information about the patent, and a subsequent statement by its CEO indicating an intent to "get around the '374 Patent" (Compl. ¶¶20-21, 23).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: how broadly will the court construe structural terms such as "outwardly extending support arms" and "arm locks"? The outcome of this construction will likely determine whether the specific design of the Accused Product’s stabilization features literally infringes.
- A key evidentiary question will concern willfulness: can Plaintiff substantiate its allegations regarding Defendant's pre-suit knowledge and intent, particularly the alleged statement about designing around the patent? The facts surrounding the prior business relationship will be central to whether Plaintiff can meet the high standard for finding willful infringement.
- A fundamental question will be one of technical comparison: as the case proceeds beyond the pleading stage, the analysis will turn on a direct, element-by-element comparison between the ’374 Patent's claims and the specific components and operation of the Model Vector - X4000 dynamometer.