DCT
2:17-cv-13931
Stahls v. Top Dog Film Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Stahls' Inc., d/b/a GroupeSTAHL (Michigan)
- Defendant: Top Dog Film, Inc. (Massachusetts) and Mich Enterprises, Inc., d/b/a Earl Mich Company (Illinois)
- Plaintiff’s Counsel: Fishman Stewart PLLC
- Case Identification: Stahls' Inc. v. Top Dog Film, Inc., 2:17-cv-13931, E.D. Mich., 02/16/2018
- Venue Allegations: Venue is alleged based on Defendants selling, promoting, and shipping infringing products into the Eastern District of Michigan via interactive websites, and targeting Michigan consumers through local dealers.
- Core Dispute: Plaintiff alleges that Defendant’s heat press products infringe patents related to adjustable, ergonomically designed heat transfer presses.
- Technical Context: The technology concerns heat transfer presses used to apply graphics, letters, and other indicia onto garments and other substrates, a key process in the custom apparel and promotional products industries.
- Key Procedural History: While the complaint focuses on trademark infringement, it alleges that Defendants' "MAX auto open heat press" purports to be a substitute for "Stahls' patented MAXX® heat press," creating a direct link between the accused products and Plaintiff's patented technology.
Case Timeline
| Date | Event |
|---|---|
| 1993-01-01 | Plaintiff's first use of CAD-CUT mark |
| 2008-01-01 | Plaintiff's first use of MAXX and FUSION marks |
| 2012-03-06 | Earliest Priority Date for U.S. Patent No. 9,573,332 |
| 2014-05-09 | New York Times article features Plaintiff's FUSION product |
| 2017-02-21 | U.S. Patent No. 9,573,332 issues |
| 2018-02-16 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,573,332 - "Threadable Heat Transfer Press with Adjustable Stand"
- Patent Identification: U.S. Patent No. 9,573,332, "Threadable Heat Transfer Press with Adjustable Stand", issued February 21, 2017.
The Invention Explained
- Problem Addressed: The patent describes conventional heat presses as being large, heavy, and difficult to use with precision, often leading to inconsistent application of pressure and heat (’332 Patent, col. 1:46-54). Furthermore, their bulky design makes it difficult to apply transfers to specific areas of a garment without affecting other parts of the item.
- The Patented Solution: The invention is a heat press mounted on an adjustable stand that is horizontally offset from the press's lower platen ('332 Patent, col. 7:8-24). This offset creates an "open throat" or "cantilever" design, allowing an operator to "thread" a garment (like a t-shirt) onto the lower platen so that only the desired print area is under the press, preventing seams or other parts of the garment from interfering with the heat application ('332 Patent, Fig. 1B; col. 8:5-24). The stand's height is also adjustable to improve operator ergonomics ('332 Patent, Fig. 5; col. 8:31-39).
- Technical Importance: This "threadable" design allows for more precise and efficient application of heat transfers, particularly for double-sided garments or items with complex shapes, by isolating the target surface.
Key Claims at a Glance
- While the complaint does not assert specific claims, Claim 1 is a representative independent claim.
- Essential elements of Claim 1 include:
- An upper platen and a lower platen.
- A support head to move the upper platen between open and closed positions.
- A stand positioned on a ground surface and defining a "throat spacing" beneath the lower platen.
- The stand being "spaced horizontally away from a geometric center of the lower platen."
- The stand is "adjustable between a plurality of heights."
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The "Results Max Heat Press" and the associated "Results Max Heat Press Stand" (Compl. ¶27).
Functionality and Market Context
- The accused product is an "Auto Open Heat Press" sold for heat transfer applications, including DTG (Direct-to-Garment) and sublimation (Compl. ¶27, p. 15).
- A screenshot from Defendant's website shows the press mounted on a stand with a single central column and multiple legs (Compl. p. 15). Another visual provides details of the stand, noting its "Adjustable Height" feature (Compl. p. 16). The complaint alleges these products are advertised in similar channels as Plaintiff's goods and are presented as a substitute for Plaintiff's own "patented MAXX® heat press" (Compl. ¶27-28). The complaint includes a photograph of the accused product's packaging, which prominently features the "MAX" branding (Compl. p. 15).
IV. Analysis of Infringement Allegations
'332 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an upper platen; a lower platen disposed below and generally aligned with the upper platen | The accused "Results Max Heat Press" is depicted with an upper heating platen and a lower platen for holding garments. The specifications list a "Changeable Under Plate" (Compl. p. 15). This visual from Defendant’s website shows the two-platen structure of the accused heat press (Compl. p. 15). | ¶27 | col. 3:24-30 |
| a support head adapted to move the upper platen between an open position... and a closed position... | The press mechanism is shown in a clamshell configuration that moves the upper platen down onto the lower platen to apply pressure (Compl. p. 15). | ¶27 | col. 4:31-43 |
| a stand positioned on a ground surface and defining a throat spacing beneath the lower platen... | The accused press is sold with a stand. The visual evidence suggests the vertical support column of the stand is positioned behind the platen, not directly underneath its center, which may create the "throat spacing" for threading garments (Compl. p. 15-16). This detailed visual of the stand shows its construction with a central post and casters (Compl. p. 16). | ¶27 | col. 8:5-14 |
| the stand being spaced horizontally away from a geometric center of the lower platen | The marketing images provided in the complaint depict the press mounted on the stand in a cantilevered fashion, where the vertical support column appears to be horizontally offset from the center of the lower platen. This configuration appears to match the "cantilever" design described in the patent (Compl. p. 15). This screenshot from Defendant’s website shows the accused heat press mounted on its stand in a configuration that may be construed as horizontally offset (Compl. p. 15). | ¶27 | col. 5:53-59 |
| wherein the stand is adjustable between a plurality of heights | The stand is explicitly marketed as having an "Adjustable Height," with a diagram showing its height range from 75.0cm to 115.5cm (Compl. p. 16). | ¶27 | col. 5:26-39 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over the proper construction of "spaced horizontally away from a geometric center of the lower platen." The question for the court will be how much of an offset is required to meet this limitation and whether the accused stand's configuration falls within that scope.
- Technical Questions: A key factual question will be establishing the precise geometric relationship between the vertical support column of the accused stand and the center of its lower platen. The marketing photographs in the complaint suggest an offset, but engineering diagrams or physical inspection would be needed to determine if it meets the claim limitation as construed by the court.
V. Key Claim Terms for Construction
- The Term: "spaced horizontally away from a geometric center of the lower platen" (Claim 1)
- Context and Importance: This term is the structural heart of the patent's "threadable" feature. The infringement analysis for the accused stand will likely turn entirely on the construction of this phrase. Practitioners may focus on this term because it distinguishes the invention from conventional presses where the stand provides support directly under the center of the press, obstructing the ability to thread a garment.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's detailed description emphasizes the functional goal: creating a "throat spacing" that is "narrow enough to allow garments to be 'threaded' over the lower platen" (col. 6:1-10). A party could argue that any degree of horizontal offset sufficient to achieve this "threadable" functionality meets the claim limitation.
- Evidence for a Narrower Interpretation: The specification refers to mounting the press in a "'cantilever' manner" (col. 5:53-59) and shows specific embodiments in Figures 1A and 1B where the support column is located entirely behind the rear edge of the platen. A party may argue these embodiments limit the term to a configuration where the stand provides no support directly underneath any part of the platen's footprint.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain an explicit count for patent infringement. However, it alleges that Defendants circulate "instruction manuals" for their products (Compl. ¶13). Should a patent claim be formally asserted, these alleged instructions could form the basis for an inducement claim, arguing that Defendants instruct customers on how to use the accused press in an infringing manner.
- Willful Infringement: The complaint alleges that Defendants' actions were "carried out intentionally, willfully and/or deliberately" with respect to Plaintiff's trademark rights (Compl. ¶44). It further alleges Defendants' products purport to be a "substitute of Stahls' patented MAXX® heat press" (Compl. ¶28), which could be used to argue that Defendants had pre-suit knowledge of the patent-in-suit and willfully disregarded Plaintiff's patent rights.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of claim construction: how broadly will the court construe the phrase "spaced horizontally away from a geometric center of the lower platen"? The outcome of this construction will likely determine whether the accused stand infringes.
- A key evidentiary question will be one of factual infringement: based on the court's claim construction, does the physical design of the "Results Max Heat Press Stand" actually feature the required horizontal offset? The marketing materials suggest it does, but this will be a matter of technical proof.
- A secondary question relates to damages and intent: given that the complaint alleges Defendants' product is a "substitute" for a "patented" product (Compl. ¶28), what evidence exists that Defendants knew of the '332 patent specifically, and could that knowledge support a finding of willfulness if infringement is found?