DCT
2:25-cv-11444
Park Industries Inc v. BACA Systems LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Park Industries, Inc. (Minnesota)
- Defendant: BACA Systems, LLC (Michigan)
- Plaintiff’s Counsel: Brooks Wilkins Sharkey & Turco PLLC
- Case Identification: 2:25-cv-11444, E.D. Mich., 05/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Michigan limited-liability company residing in the district, has committed acts of infringement in the district, and maintains a regular and established place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s stone-cutting machinery, which incorporates a "tilt table" for loading stone slabs, infringes two patents related to a material loading apparatus.
- Technical Context: The technology concerns automated machinery for the stone fabrication industry, specifically addressing the safety and logistical challenges of loading heavy stone workpieces onto cutting tables.
- Key Procedural History: The complaint alleges a notable pre-suit history, including a January 2017 notice letter from Plaintiff to Defendant regarding a pending patent application related to the patents-in-suit. Following the issuance of the patents, the parties engaged in settlement discussions in March 2025, which allegedly resulted in a binding settlement agreement. Plaintiff alleges that Defendant subsequently repudiated this agreement, leading to its termination by Plaintiff and the filing of this lawsuit. This history may be central to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-01-20 | Priority Date for ’914 and ’843 Patents |
| 2017-01-31 | Plaintiff sends first notice letter to Defendant regarding related patent application |
| 2019-02-12 | U.S. Patent No. 10,201,914 Issues |
| 2022-09-20 | U.S. Patent No. 11,446,843 Issues |
| 2024-10-22 | Plaintiff sends second notice letter alleging infringement of issued patents |
| 2025-03-12 | Settlement meeting between Plaintiff and Defendant |
| 2025-05-15 | Plaintiff notifies Defendant of termination of the alleged settlement agreement |
| 2025-05-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,201,914 - "Material Loading Apparatus"
- Patent Identification: U.S. Patent No. 10,201,914, "Material Loading Apparatus", issued February 12, 2019.
The Invention Explained
- Problem Addressed: The patent’s background section identifies safety concerns and the risk of damage to both the workpiece and machinery when loading heavy and cumbersome stone workpieces onto CNC cutting machines. (Compl. Ex. A, ’914 Patent, col. 1:24-29).
- The Patented Solution: The invention is a loading apparatus featuring a work surface that moves between a horizontal cutting position and a near-vertical loading position. This movement is achieved through a specific linkage system, comprising at least a first and second link connecting the support surface to a fixed frame, which allows the surface to both pivot and translate, bringing it closer to the ground for easier loading. (Compl. Ex. A, ’914 Patent, Abstract; col. 4:56-61).
- Technical Importance: The described mechanism aims to provide a safer and more efficient method for handling heavy materials in automated fabrication environments. (Compl. Ex. A, ’914 Patent, col. 4:61-65).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1. (Compl. ¶41).
- The essential elements of Claim 1 include:
- a fixed frame;
- a movable support surface pivotally mounted to the frame;
- a first link extending between the support surface and the frame, with pivot connections at both ends;
- a second link extending between the support surface and the frame, with pivot connections at both ends;
- an actuator pivotally connected to the frame to move the support surface between horizontal and vertical positions; and
- a fluid tank positioned under the support surface in its horizontal position.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,446,843 - "Material Loading Apparatus"
- Patent Identification: U.S. Patent No. 11,446,843, "Material Loading Apparatus", issued September 20, 2022.
The Invention Explained
- Problem Addressed: As a continuation of the application that led to the ’914 Patent, the ’843 Patent addresses the same problem of safely and efficiently loading heavy stone workpieces. (Compl. Ex. B, ’843 Patent, col. 1:23-28).
- The Patented Solution: The ’843 Patent claims a complete "stone shaping machine" that integrates the material loading apparatus described in the ’914 Patent with a "movable cutting apparatus." The claims thus cover the combination of the specific tilting-and-translating loading mechanism with a cutting tool (e.g., a waterjet or saw) that operates on the material when the support surface is in the horizontal position. (Compl. Ex. B, ’843 Patent, col. 2:9-37; Claim 1).
- Technical Importance: This integrated system provides a comprehensive solution for stone fabrication, combining an improved loading mechanism with the cutting functionality into a single machine. (Compl. Ex. B, ’843 Patent, col. 1:13-17).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1. (Compl. ¶59).
- The essential elements of Claim 1 include:
- A "material loading apparatus" containing all the elements of Claim 1 of the ’914 Patent (fixed frame, movable support surface, first link, second link, actuator, and fluid tank).
- A "movable cutting apparatus" positioned to shape material on the support surface, where the cutting apparatus is movable along the length and width of the surface and also in a vertical direction.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is Defendant’s "M SERIES MITERING ROBOTIC SAWJET" equipped with a "pivoting, slab-loading 'tilt table'," collectively referred to as the "Infringing Loading and Shaping Machine." (Compl. ¶16).
Functionality and Market Context
- The complaint alleges the accused product is an automated stone fabrication machine that directly competes with Plaintiff's products. (Compl. ¶9). Its key feature for this dispute is the "tilt table," which functions as a slab loader by moving a work surface between a horizontal orientation for cutting and a tilted orientation for loading. (Compl. ¶17). The complaint includes images of the accused product, one of which depicts the tilt table in a tilted, or loading, position. (Compl. p. 4). The complaint alleges that Defendant has sold at least 21 units of the accused slab loader. (Compl. ¶21).
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim chart exhibits. The analysis below is based on the narrative allegations mapping product features to claim elements.
’914 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a fixed frame | The accused machine includes a fixed frame. | ¶43 | col. 3:56-61 |
| a movable support surface pivotally mounted to the frame, the support surface configured for supporting the material | The accused machine includes a moveable support surface pivotally mounted to the frame for supporting material. | ¶44 | col. 3:47-49 |
| a first link extending between the support surface and the frame, the first link pivotally connected to the support surface at a first end of the first link and pivotally connected to the frame at a second end of the first link | The accused machine includes a first link extending between the support surface and the frame, with pivotal connections at both ends. | ¶46 | col. 6:9-15 |
| a second link extending between the support surface and the frame, the second link pivotally connected to the support surface at a first end of the second link and pivotally connected to the frame at a second end of the second link | The accused machine includes a second link extending between the support surface and the frame, with pivotal connections at both ends. | ¶47 | col. 6:16-23 |
| an actuator pivotally connected to the frame, the actuator being configured to move the support surface between a generally horizontal position and a generally vertical position | The accused machine includes an actuator pivotally connected to the frame that moves the support surface between horizontal and vertical positions. | ¶48 | col. 6:29-45 |
| a fluid tank positioned under the support surface when the support surface is in the generally horizontal position | The accused machine includes a fluid tank positioned under the support surface when it is in the horizontal position. | ¶49 | col. 4:5-9 |
’843 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) a material loading apparatus including: [fixed frame, movable support surface, first link, second link, actuator, fluid tank] | The accused machine is a material loading apparatus that includes the components of a fixed frame, movable support surface, first and second links, an actuator, and a fluid tank. | ¶¶61-67 | col. 2:9-29 |
| b) a movable cutting apparatus positioned for shaping material supported by the support surface ... wherein the cutting apparatus is movable along a length and a width of the support surface, and wherein the cutting apparatus is also movable in a vertical direction toward and away from the support surface | The accused machine includes a movable cutting apparatus (a robotic sawjet) capable of movement along the length, width, and vertical direction relative to the support surface. An image of the robotic arm is provided in the complaint. (Compl. p. 4). | ¶68 | col. 2:30-37 |
- Identified Points of Contention:
- Technical Questions: A primary technical question is whether the mechanism of the accused "tilt table" functions in the same way as the claimed dual-link system. The patents describe a specific linkage that "dictate[s] the path of the support surface" to achieve both pivot and translation. (’914 Patent, col. 6:26-29). The infringement analysis may focus on whether the accused product's mechanism creates this specific, controlled path of motion or employs a simpler pivot that is technically distinct.
- Scope Questions: The infringement analysis for the ’843 Patent will depend on the outcome of the analysis for the ’914 Patent's loading apparatus claims, and additionally on whether the "ROBO SAWJET" component meets the multi-axis movement limitations of the "movable cutting apparatus" element.
V. Key Claim Terms for Construction
The Term: "a first link ... and ... a second link"
- Context and Importance: The interaction between these two links is fundamental to the invention's described movement. Practitioners may focus on this term because the infringement case could turn on whether the accused tilt table's mechanism, whatever its structure, functions as the claimed dual-link system that provides both pivot and translation.
- Intrinsic Evidence for a Broader Interpretation: The plain language of Claim 1 requires two separate components that are pivotally connected to both the frame and the support surface. An argument could be made that any structure meeting this basic description satisfies the limitation, regardless of the specific motion path it creates.
- Intrinsic Evidence for a Narrower Interpretation: The specification states that "Both the first and second links 128, 130 are configured to dictate the path of the support surface." (’914 Patent, col. 6:26-29). This suggests a cooperative and specific function beyond merely connecting the parts. Dependent Claim 2 of the ’914 Patent further specifies that "the support surface pivots and translates with respect to the frame," which could be used to argue that the linkage in Claim 1 must be one capable of producing such motion. (’914 Patent, col. 8:8-9).
The Term: "movable support surface pivotally mounted to the frame"
- Context and Importance: This term defines the relationship between the core moving part and the stationary frame. Its construction is critical because the patent figures show the surface mounted via the linkage system, not directly to the frame.
- Intrinsic Evidence for a Broader Interpretation: A party could argue that "mounted to" simply means "supported by," and that the pivotal mounting is achieved indirectly through the required links, thus satisfying the claim language.
- Intrinsic Evidence for a Narrower Interpretation: An opposing argument could be that the claim requires a distinct pivotal mount directly between the surface and the frame, in addition to the connections provided by the first and second links. The specific phrasing could be scrutinized to determine if the mounting is direct or indirect via the linkage.
VI. Other Allegations
- Willful Infringement: The complaint makes detailed allegations to support willfulness. It claims Defendant had pre-suit knowledge of Plaintiff’s technology and patent rights based on a January 31, 2017 letter that identified the parent application to the patents-in-suit. (Compl. ¶18). It further alleges a second notice letter was sent on October 22, 2024, identifying the issued patents and the accused product. (Compl. ¶20). The complaint characterizes the alleged infringement as "knowing and deliberate." (Compl. ¶¶52, 71).
VII. Analyst’s Conclusion: Key Questions for the Case
- Procedural Posture: An antecedent question for the court may be the status of the alleged settlement agreement. The complaint pleads the existence and subsequent breach of a binding settlement. (Compl. ¶¶26, 35-38). The court may first need to determine if this case should proceed as a patent infringement dispute or a breach of contract action.
- Claim Scope and Technical Equivalence: A central issue will be one of functional and structural scope: Does the accused "tilt table" mechanism, which tilts a work surface, operate in a manner that falls within the scope of the claimed dual-link system? This will likely require the court to construe the meaning of the "first link" and "second link" and determine if they require a specific path of combined pivot-and-translate motion, and whether the accused product's mechanism is structurally and functionally the same or equivalent.
- Willfulness and Damages: Should the case proceed on infringement, a key question will be willfulness. Given the detailed allegations of pre-suit notice dating back to 2017, the court will need to evaluate whether Defendant’s continued conduct after being made aware of Plaintiff's patent rights constitutes objective recklessness, which could expose Defendant to enhanced damages.