DCT

1:03-cv-00778

Windquest Companies Inc v. Garage Storage Cabinets LLC

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:03-cv-00778, W.D. Mich., 10/27/2003
  • Venue Allegations: The complaint asserts that venue is proper under 28 U.S.C. §§ 1391 and 1400, but does not specify the factual basis for venue in the Western District of Michigan.
  • Core Dispute: Plaintiff alleges that Defendant’s storage organizer products infringe a patent related to a system for installing wall-mounted shelving and storage components.
  • Technical Context: The technology concerns modular, wall-mounted storage systems, often used in closets and garages, which are designed for simplified, do-it-yourself installation.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with written notice of its infringement prior to filing the lawsuit. This allegation supports the claims for willful infringement and may affect the start date for potential damages.

Case Timeline

Date Event
1988-08-24 U.S. Patent No. 4,928,833 Priority Date
1990-05-29 U.S. Patent No. 4,928,833 Issued
2003-10-27 Complaint Filed

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

U.S. Patent No. 4,928,833 - Storage Organizer System and Means for Installing the Same

The Invention Explained

  • Problem Addressed: The patent's background section notes that, at the time of the invention, many popular knockdown storage systems were "quite expensive and difficult to install within the storage space such as closets" (U.S. Patent No. 4,928,833, col. 1:21-23).
  • The Patented Solution: The invention proposes an inexpensive and easily installed system centered on a single horizontal rail mounted to a wall (U.S. Patent No. 4,928,833, Abstract). This rail has a projection that extends "upwardly and away from said wall" (U.S. Patent No. 4,928,833, col. 5:39-41). Vertical panels, which support shelves and rods, have a corresponding cutout on their rear edge that allows them to be simply "hung on the rail" (U.S. Patent No. 4,928,833, col. 2:3-5; Fig. 5). This design simplifies installation, as the installer only needs to level and mount the single rail before hanging the other components.
  • Technical Importance: The invention provided a method for installing a modular storage system that reduced the complexity and number of fasteners required compared to prior systems, making it more accessible for "do-it-yourselfers" (U.S. Patent No. 4,928,833, col. 2:32-34).

Key Claims at a Glance

  • The complaint does not identify specific claims, asserting infringement of the patent generally (Compl. ¶6). Independent claim 1 is the broadest system claim.
  • Essential elements of independent claim 1 include:
    • A storage organizer system with a plurality of upright panels that support members (e.g., shelves, rods).
    • A horizontal rail mounted on a wall.
    • The rail has "a projection extending upwardly and away from said wall."
    • Each panel has an edge abutting the wall with a "cutout portion receiving said projection."
    • The panels and support members are "hung on said rail."

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific accused product or product line by name.

Functionality and Market Context

The complaint makes only a general allegation that Defendant "has been and is manufacturing, using, offering for sale, and selling products that infringe the patent" (Compl. ¶6). No specific details about the functionality, operation, or market context of any accused product are provided in the complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a claim-by-claim infringement analysis or the creation of a claim chart. It makes only a general allegation that the Defendant’s unspecified products infringe the patent (Compl. ¶6). No probative visual evidence provided in complaint.

Identified Points of Contention

Given the bare allegations, the primary points of contention cannot be definitively identified from the complaint alone. However, based on the technology, future disputes may revolve around several technical and legal questions:

  • Scope Questions: What is the scope of a "projection extending upwardly and away from said wall"? Does this term cover any hanging mechanism, or is it limited by the specific angled embodiment described in the patent (U.S. Patent No. 4,928,833, col. 3:15-17)?
  • Technical Questions: Does the accused product, once identified, possess a rail and panel structure where the panels are "hung on said rail" via a "cutout portion" as claimed? The specific geometry and interaction of the accused rail and panel will be a central factual question.

V. Key Claim Terms for Construction

The Term

"a projection extending upwardly and away from said wall" (from Claim 1)

Context and Importance

This term is the central structural element of the claimed invention, defining the specific interface between the wall-mounted rail and the vertical panels. The entire "means for installing" is predicated on this structure. Practitioners may focus on this term because its construction will likely determine whether a competitor's rail design, which may function similarly but have a different geometry, falls within the scope of the claim.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself does not specify a particular angle or shape for the projection, only its general direction ("upwardly and away"). This could support a construction that covers a range of geometric shapes that perform the specified hanging function.
  • Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the rail has "two legs 16 and 17 arranged at an angle approximately 50° from each other" (U.S. Patent No. 4,928,833, col. 3:15-17; Fig. 7). A party could argue that this disclosure limits the scope of "projection" to a structure with a similar acute angle, rather than, for example, a simple 90-degree hook.

VI. Other Allegations

Willful Infringement

The complaint alleges that "Defendant's infringement of the patent has been willful" (Compl. ¶8). The factual basis for this allegation is the assertion that Plaintiff gave "written notice to defendant of its infringement" prior to the lawsuit (Compl. ¶7).

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

  1. A threshold evidentiary question will be the identification of the accused products. The complaint's lack of specificity means the initial phase of litigation will likely focus on discovering exactly what products are accused and how they are constructed and operate.
  2. A core issue will be one of claim scope: can the term "projection extending upwardly and away from said wall," as described in the context of a 50-degree angled rail, be construed to cover other hanging mechanisms that may be used in competing storage systems? The answer will likely dictate the outcome of the infringement analysis.
  3. A key factual question will be one of pre-suit knowledge: what was the content and timing of the "written notice" allegedly provided to the Defendant? The specifics of this notice will be central to proving the willfulness claim and the request for enhanced damages.