DCT
2:23-cv-12894
Trek Armor Inc v. FCA US LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Trek Armor Inc. d/b/a Bartact, Inc. (California)
- Defendant: FCA US, LLC (Delaware)
- Plaintiff’s Counsel: Taft Stettinius & Hollister LLP; Rozier Hardt McDonough PLLC
- Case Identification: 2:23-cv-12894, E.D. Mich., 02/08/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district and has committed the alleged acts of patent infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s vehicle seats, as featured in certain Jeep models, infringe three patents related to integrated, MOLLE-style accessory and storage systems on seat backs.
- Technical Context: The technology concerns the integration of modular tactical gear attachment systems (known as MOLLE or PALS) onto vehicle seats, a feature of particular interest in the off-road and utility vehicle markets for its customizable storage capabilities.
- Key Procedural History: The complaint alleges that Plaintiff presented its patented technology to Defendant’s representatives at a 2015 industry trade show. It further alleges that Defendant obtained Plaintiff's products and subsequently incorporated the technology into its own vehicle seats, which may be used to support allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-11-02 | Earliest Priority Date for all Asserted Patents (Provisional App. 62/249,349) |
| 2018-01-01 | Approximate Launch of Accused Jeep Wrangler JL (MY2018-) |
| 2019-01-01 | Approximate Launch of Accused Jeep Gladiator (MY2019-) |
| 2019-06-04 | U.S. Patent No. 10,308,301 Issued |
| 2023-10-24 | U.S. Patent No. 11,794,836 Issued |
| 2024-02-06 | U.S. Patent No. 11,891,142 Issued |
| 2024-02-08 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,308,301 - Vehicle Seat With Storage Capacity, issued June 4, 2019
The Invention Explained
- Problem Addressed: The patent identifies that open-air vehicles, such as Jeeps and ATVs, have limited space for storing gear, which is particularly problematic for users traveling extended distances (ʼ301 Patent, col. 1:19-24).
- The Patented Solution: The invention solves this by integrating a modular accessory assembly directly onto the rear portion of a vehicle seat. This assembly consists of a plastic frame with vertical "stabilizing components" and horizontal "straps" that are arranged cross-wise to form a grid, creating a system for attaching storage pouches and other gear ('301 Patent, Abstract; col. 6:40-65). The assembly can be built into a new seat or provided as a retrofit kit for an existing seat ('301 Patent, col. 5:28-36).
- Technical Importance: This approach provides a standardized and robust method for adding secure, customizable storage to vehicles where interior space is at a premium, leveraging the widely adopted military-style MOLLE/PALS standard ('301 Patent, col. 4:8-14).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶37).
- Essential elements of independent claim 1 include:
- A seat for use with a vehicle, comprising a seat frame, cushioning material, and an outer cover forming a base and back portion.
- An accessory assembly on the rear back portion, comprising:
- A plastic accessory frame with vertical and horizontal frame edge margins.
- Plastic stabilizing components coupled to the frame, extending between the horizontal margins.
- Straps coupled to the frame, extending between the vertical margins and positioned cross-wise to the stabilizing components.
U.S. Patent No. 11,794,836 - Vehicle Seat With Storage Capacity, issued October 24, 2023
The Invention Explained
- Problem Addressed: The patent addresses the same need for additional, easily accessible storage options in vehicles with limited space (’836 Patent, col. 1:21-29).
- The Patented Solution: This invention refines the concept of an integrated seat-back storage system. It describes an accessory assembly secured by bolts or screws, with a plastic frame that "contours to a pre-existing shape of the rear back portion" for a more seamless fit ('836 Patent, Claim 1). A key feature is that the system's straps are routed "behind each of the plastic stabilizing components such that a portion of each of the straps is not visible when the accessory assembly is viewed from the outside," suggesting a more integrated and aesthetically refined construction ('836 Patent, col. 10:63-11:2).
- Technical Importance: The invention represents an evolution toward a factory-integrated appearance, focusing on a precise fit with the seat's underlying structure and a design that partially conceals the mounting straps for a cleaner look ('836 Patent, col. 7:26-34).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶66).
- Essential elements of independent claim 1 include:
- A seat with a base and back portion.
- An accessory assembly secured to the rear back portion by bolts or screws.
- A plastic accessory frame that contours to the pre-existing shape of the rear back portion.
- Plastic stabilizing components coupled to the frame.
- Straps coupled to the frame and extending behind the stabilizing components so that a portion of each strap is not visible from the outside.
- A specific spacing for the straps (0.25 to 4 inches apart).
U.S. Patent No. 11,891,142 - Vehicle Seat With Storage Capacity, issued February 6, 2024
Technology Synopsis
This patent also describes a vehicle seat with an integrated accessory storage system, further detailing the attachment method. The claims recite a "first plurality of projections configured to mate with slots in the rear back portion to aid in attaching the plastic accessory frame to the seat," in addition to being coupled by screws (’142 Patent, Claim 1; Compl. ¶98). This invention appears focused on a specific, robust, and potentially factory-installed mounting solution that combines mechanical fasteners with interlocking projections for a secure fit.
Asserted Claims
The complaint asserts at least independent claim 1 (Compl. ¶97).
Accused Features
The complaint accuses the plastic accessory panel on the seats of Jeep Wrangler and Gladiator vehicles, alleging they embody the claimed combination of features, including the method of attachment to the seat back (Compl. ¶¶98-104).
III. The Accused Instrumentality
Product Identification
The Accused Products are the vehicle seats included in Defendant’s Jeep® Wrangler JL (model year 2018-present), Jeep® Wrangler JLU Rubicon (model year 2018-present), and Jeep® Gladiator (model year 2019-present) vehicles (Compl. ¶28).
Functionality and Market Context
- The accused seats feature a plastic panel integrated into the rear surface of the seat back. This panel incorporates a grid of horizontal fabric straps and vertical plastic ribs, which Plaintiff alleges creates a MOLLE/PALS-compatible system for attaching storage pouches and other equipment (Compl. ¶¶40, 69-70). The complaint provides an image of the plastic panel removed from the seat, showing the grid structure. (Compl. ¶29, Figure 6). Another image shows the seat installed in a vehicle, with annotations indicating the components alleged to meet claim limitations (Compl. ¶40, p. 14 image).
- The Jeep Wrangler and Gladiator are marketed as rugged, off-road capable vehicles whose owners often value utility and customization. The complaint alleges that Defendant manufactures, uses, and sells these vehicles with the allegedly infringing seat-back storage system, which provides a functional and aesthetic feature consistent with the vehicles' market positioning (Compl. ¶28).
IV. Analysis of Infringement Allegations
'301 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a seat for use with a vehicle, the seat comprising: a seat frame; a cushioning material... an outer cover... | Defendant provides a seat for use with a vehicle, including a seat frame, cushioning, and an outer cover forming a base and back portion. | ¶38 | col. 4:11-14 |
| an accessory assembly on the rear back portion... comprising: a plastic accessory frame having vertical and horizontal frame edge margins | The accused seats include a plastic accessory assembly on the rear back portion with a frame having vertical and horizontal edge margins. An image labels these margins "A" and "B". | ¶40 | col. 9:50-51 |
| plastic stabilizing components coupled to the plastic accessory frame... having lengths extending between the horizontal frame edge margins... | The plastic frame includes vertical plastic ribs, labeled "C," which are alleged to be the "plastic stabilizing components." | ¶40 | col. 9:52-57 |
| straps coupled to the plastic accessory frame and having lengths extending between the vertical frame edge margins... generally cross-wise relative to the plastic stabilizing components. | The assembly includes horizontal straps, labeled "D," that are alleged to be coupled to the frame and run cross-wise to the vertical plastic ribs. | ¶40 | col. 9:58-65 |
Identified Points of Contention
- Scope Questions: The claim recites "plastic stabilizing components" and "straps" as distinct elements "coupled to the plastic accessory frame." The accused product appears to be a single molded plastic piece with integrated vertical ribs and separately attached horizontal straps. A question for the court will be whether the integrated vertical ribs constitute separate "components" that are "coupled to" the frame, or if they are simply features of the frame itself.
- Technical Questions: Claim 1 requires the components to be "coupled." The complaint's evidence will need to establish how the vertical ribs and horizontal straps are attached to the main frame of the accessory assembly and whether this method falls within the scope of "coupled" as defined by the patent.
'836 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an accessory assembly... secured to the rear back portion by bolts or screws... | The complaint alleges the accessory assembly is secured to the seat back using bolts or screws. | ¶68 | col. 10:50-51 |
| the plastic accessory frame contours to a pre-existing shape of the rear back portion... | The plastic frame is alleged to be shaped to match the contour of the underlying seat structure. An image depicts the seat with the cover removed to show this underlying shape, labeled "C". | ¶68, ¶100 | col. 10:54-55 |
| straps coupled to the plastic accessory frame... behind each of the plastic stabilizing components such that a portion of each of the straps is not visible... | The horizontal straps, labeled "E" in an annotated image, are alleged to pass behind the vertical plastic stabilizing components ("D"), rendering portions of the straps not visible from the outside. | ¶70 | col. 10:63-11:2 |
| adjacent ones of the straps are spaced apart from one another by a distance of 0.25 inches... to 4 inches... | The complaint alleges the spacing between the horizontal straps falls within the claimed range. | ¶71 | col. 11:7-11 |
Identified Points of Contention
- Scope Questions: A central dispute may be the meaning of "a portion of each of the straps is not visible when the accessory assembly is viewed from the outside of the seat." The complaint's theory is that the strap portion passing directly behind a vertical rib is "not visible." A counterargument could be that this language requires a greater degree of concealment than simple obstruction.
- Technical Questions: The allegation that the frame "contours to a pre-existing shape" will be an evidentiary question. Plaintiff will need to demonstrate through technical analysis or measurement that the shape of the accused accessory frame corresponds to the shape of the underlying seat structure, as suggested by the complaint's visual evidence (Compl. ¶68, p. 21 image).
V. Key Claim Terms for Construction
Term: "plastic stabilizing components" ('301 Patent, Claim 1)
- Context and Importance: The definition of this term is critical for determining the basic structure of the claimed invention. Practitioners may focus on this term because the accused product appears to be a single, integrally molded plastic panel with vertical ribs, raising the question of whether these ribs are distinct "components" that are "coupled to" a "frame," or are simply part of the frame itself.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes embodiments where the components can be molded together, which may support an interpretation that "coupled" does not require separate manufacture and subsequent attachment ('301 Patent, col. 10:12-14).
- Evidence for a Narrower Interpretation: Claim 1 lists the "plastic accessory frame" and the "plastic stabilizing components" as two separate elements of the assembly. The patent figures, such as Figure 7, depict the frame (502) and stabilizing components (506) as visually distinct parts, which could support an argument that they must be structurally distinguishable elements.
Term: "behind each of the plastic stabilizing components such that a portion of each of the straps is not visible" ('836 Patent, Claim 1)
- Context and Importance: This limitation appears to be a key point of novelty for the '836 patent. The infringement analysis for this patent will likely hinge on whether the accused Jeep seat, where horizontal straps pass behind vertical plastic ribs, meets this "partially not visible" requirement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain meaning of the words suggests that if any part of the strap is obscured from view from the outside (e.g., the portion directly under a rib), the limitation is met. The specification does not appear to define "not visible" in a special or limited way.
- Evidence for a Narrower Interpretation: A defendant may argue that this language, in the context of the overall invention, implies a more substantial concealment, such as routing the strap through an internal channel, rather than mere surface-level obstruction. However, the specification does not explicitly describe such an alternative, potentially limiting the basis for a narrower construction.
VI. Other Allegations
Indirect Infringement
The complaint alleges that Defendant induces infringement by selling the accused vehicles to distributors and end-users, and by providing instructions, advertising, and promotional materials that encourage the use of the infringing seat-back storage system (Compl. ¶¶41-45, 73-76). Contributory infringement is also alleged on the basis that the accused features are specially designed for an infringing use and have no substantial non-infringing use (Compl. ¶¶50-51, 81-82).
Willful Infringement
The complaint makes detailed allegations to support willfulness. It alleges Defendant had pre-suit knowledge of the '301 patent's underlying technology from a 2015 SEMA trade show, where its representatives allegedly viewed Plaintiff's product and later obtained samples (Compl. ¶¶18-26). For the more recent '836 and '142 patents, willfulness is alleged based on knowledge acquired from the filing of the original and amended complaints (Compl. ¶¶84, 117). The complaint further alleges that Defendant maintains a policy of not reviewing patents of others, which it characterizes as willful blindness (Compl. ¶¶54, 85, 118).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of factual proof and intent: will the evidence surrounding the alleged 2015 trade show interaction and subsequent product development support the complaint's narrative of knowing appropriation? The outcome of this factual dispute will be central to the claim of willful infringement.
- A second key issue will be one of claim construction: can the term "plastic stabilizing components" in the '301 patent be construed to read on the integrated vertical ribs of the accused product, or are they merely features of a unitary "plastic accessory frame"?
- A final dispositive question will be one of definitional scope: does the accused system, where straps are routed behind vertical ribs, meet the '836 patent's requirement that a "portion of each of the straps is not visible"? The court's interpretation of this seemingly simple phrase will be critical to the infringement analysis for that patent.