DCT
1:19-cv-00194
Centerline Windsor Ltd v. JR Automation Tech LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Centerline (Windsor) Ltd. (Canada) and Doben Ltd. (Canada)
- Defendant: JR Automation Technologies, LLC (Michigan)
- Plaintiff’s Counsel: Carlson, Gaskey & Olds, P.C.
- Case Identification: 1:19-cv-00194, W.D. Mich., 03/13/2019
- Venue Allegations: Venue is alleged to be proper in the Western District of Michigan because the Defendant has its principal place of business in the district and has committed acts giving rise to the Plaintiffs' claims within the district.
- Core Dispute: Plaintiffs allege that Defendant’s automated welding guns and conveyor systems infringe four patents related to fastener-presence sensing technology and automated part-handling conveyors.
- Technical Context: The dispute is in the field of automated industrial manufacturing systems, which are critical for high-volume production in industries such as automotive assembly.
- Key Procedural History: The patents related to welding guns (’279, ’664, and ’859) are asserted to be members of the same patent family. The complaint states that Plaintiffs sent a cease and desist letter to the Defendant on March 8, 2019, five days before filing the lawsuit, an event relevant to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2001-07-10 | Earliest Priority Date for ’859, ’279, and ’664 Patents |
| 2003-06-10 | U.S. Patent No. 6,576,859 Issued |
| 2005-06-14 | U.S. Patent No. 6,906,279 Issued |
| 2007-10-16 | U.S. Patent No. 7,282,664 Issued |
| 2014-07-02 | Earliest Priority Date for ’775 Patent |
| 2018-02-20 | U.S. Patent No. 9,895,775 Issued |
| 2018-10-01 | Accused Products Installation Date (approx.) |
| 2019-03-08 | Cease and Desist Letter Sent to Defendant |
| 2019-03-13 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,906,279 - “Resistance Welding Fastener Electrode”, issued June 14, 2005.
The Invention Explained:
- Problem Addressed: The patent's background describes the difficulty in automated welding processes of reliably detecting whether a fastener, such as a nut, is present and correctly oriented before welding. Prior art methods that measured the displacement of the entire weld gun arm were described as inaccurate due to mechanical tolerance stack-ups and electrical interference from high welding currents (’279 Patent, col. 1:21-48).
- The Patented Solution: The invention proposes a method where a sensor is placed within one of the electrodes to measure the displacement of a pin that directly engages the fastener. This proximity to the workpiece is intended to provide a more accurate measurement, shielded from the electrical noise and mechanical variations that affected prior systems, thereby enabling precise determination of the fastener's status (’279 Patent, col. 3:58 - col. 4:7).
- Technical Importance: This method offers a potential improvement in quality control for high-speed automated welding lines, particularly in the automotive sector, by reducing the risk of faulty welds caused by missing or misaligned fasteners (’279 Patent, col. 1:11-20).
Key Claims at a Glance:
- The complaint asserts independent claim 1 (Compl. ¶40).
- Essential elements of Claim 1:
- A method of resistance welding a fastener comprising the steps of:
- loading a fastener onto a pin;
- closing opposing weld gun electrodes about an object;
- displacing the pin; and
- measuring a weld gun component associated with movement of the pin.
U.S. Patent No. 7,282,664 - “Resistance Welding Fastener Electrode”, issued October 16, 2007.
The Invention Explained:
- Problem Addressed: The patent addresses the same technical problem as the ’279 Patent: the need for accurate, real-time detection of fastener presence and orientation in automated welding environments to avoid costly production errors (’664 Patent, col. 1:11-48).
- The Patented Solution: As the apparatus counterpart to the method claimed in the ’279 Patent, this patent claims the physical welding assembly itself. The assembly includes a movable "weld gun component" (such as a pin) that changes position depending on the fastener's orientation. An optical sensor directs light at this component, and a control system analyzes the reflected light to generate a signal indicating whether the fastener is in a desired or undesired state (’664 Patent, Abstract; col. 2:50-65).
- Technical Importance: The patent describes a physical system designed to provide the reliable, in-situ quality control necessary for high-rate automated fastener welding processes.
Key Claims at a Glance:
- The complaint asserts independent claim 1 (Compl. ¶64).
- Essential elements of Claim 1:
- A welding assembly for welding a fastener to an object, the assembly comprising:
- a weld gun having first and second electrodes movable relative to one another between an open position and a closed position;
- a weld gun component movable in said closed position between at least one of a desired fastener position and an undesired fastener position;
- an optical sensor directing light on said weld gun component with the said light reflecting from said weld gun component; and
- a sensor control system processing said reflected light into a signal corresponding to at least one of said desired fastener position and said undesired fastener position.
Multi-Patent Capsule: U.S. Patent No. 6,576,859 - “Resistance Welding Fastener Electrode”, issued June 10, 2003.
- Technology Synopsis: Belonging to the same family as the ’279 and ’664 patents, the ’859 Patent claims a method of resistance welding. The method explicitly recites directing light onto a weld gun component associated with a pin and measuring the reflected light to determine the pin's displacement, thereby verifying the fastener's condition (’859 Patent, col. 6:26-34). This adds the specific optical measurement step to the broader method.
- Asserted Claims: Independent claim 13 (Compl. ¶88).
- Accused Features: The "Accused Welding Products" are alleged to perform this patented method when operated by the Defendant or its customers (Compl. ¶89-90).
Multi-Patent Capsule: U.S. Patent No. 9,895,775 - “System And Method With Drag Conveyor For High Rate Production Welding”, issued February 20, 2018.
- Technology Synopsis: This patent addresses orienting and feeding parts in an automated production line. It describes an assembly system with a "drag conveyor" that uses "locating elements" and a "friction bar" to passively reorient randomly placed parts into a consistent position as they are moved along the conveyor, making them ready for a robot to pick up and transfer to a work station (’775 Patent, col. 2:1-9).
- Asserted Claims: Independent claim 1 (Compl. ¶112).
- Accused Features: The "Accused Conveyor Products" are alleged to be systems that use this drag-and-orient functionality (Compl. ¶18, 113). A photograph in the complaint shows a large yellow conveyor system identified as an example of the accused product (Compl. p. 6).
III. The Accused Instrumentality
- Product Identification: The complaint identifies the "Accused Welding Products" and "Accused Conveyor Products" which are included as part of "JR Automation Installation CX482/483, JR Job #222355" with a date of manufacture of October 2018 (Compl. ¶12, 18).
- Functionality and Market Context: The Accused Welding Products are described as weld guns for automated welding lines (Compl. ¶12). A photograph of an exemplary Accused Welding Product shows a robotic weld gun assembly with upper and lower electrodes (Compl. p. 4). The Accused Conveyor Products are described as conveyor assembly systems used in manufacturing (Compl. ¶18). The complaint alleges that the Defendant, JR Automation, is a direct competitor of Plaintiff Centerline in the market for these types of automated systems (Compl. ¶12, 18).
IV. Analysis of Infringement Allegations
The complaint does not contain detailed claim charts, instead referencing external exhibits not filed with the pleading. The following tables summarize the infringement theories for the lead patents based on the narrative allegations.
U.S. Patent No. 6,906,279 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) loading a fastener onto a pin; | The Accused Welding Products are part of an automated system alleged to perform all steps of the claimed method, including loading fasteners for welding. | ¶12, 41 | col. 5:2 |
| b) closing opposing weld gun electrodes about an object; | The Accused Welding Products are weld guns that necessarily close their electrodes around an object to perform a weld. | ¶12, 41 | col. 5:3 |
| c) displacing the pin; | As part of practicing the full claimed method, the pin within the accused device is allegedly displaced upon engagement with the fastener and object. | ¶41, 43 | col. 5:4 |
| d) measuring a weld gun component associated with movement of the pin. | The complaint alleges that the Accused Welding Products practice the claimed inventions, which center on technology for monitoring the welding process, implying a measurement function. | ¶8, 12, 41 | col. 5:5-6 |
U.S. Patent No. 7,282,664 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a weld gun having first and second electrodes movable relative to one another between an open position and a closed position; | The Accused Welding Products are identified as weld guns, which inherently possess movable electrodes. | ¶12, 65 | col. 9:7-10 |
| a weld gun component movable in said closed position between at least one of a desired fastener position and an undesired fastener position; | The complaint alleges infringement of patents for sensing fastener position, which relies on a movable component within the weld gun to detect the fastener's state. | ¶8, 12, 65 | col. 9:11-14 |
| an optical sensor directing light on said weld gun component with the said light reflecting from said weld gun component; | The complaint alleges that the accused systems practice the patented inventions, which include sensor-based monitoring technology. | ¶8, 12, 65 | col. 9:15-18 |
| a sensor control system processing said reflected light into a signal corresponding to at least one of said desired fastener position and said undesired fastener position. | The accused systems are alleged to contain a control system that performs the claimed processing to determine fastener orientation. | ¶8, 12, 65 | col. 9:19-22 |
- Identified Points of Contention:
- Technical Questions: The complaint's infringement allegations rely heavily on "information and belief" (Compl. ¶41, 65). A primary point of contention will be factual: does the accused JR Automation system employ a sensing mechanism that operates in the manner claimed? The case may turn on evidence obtained in discovery regarding the specific technology used in the Accused Welding Products to monitor weld quality.
- Scope Questions: A key legal question will be whether the sensing technology in the accused products, if any, falls within the scope of the patent claims. For instance, does the Defendant's system perform the step of "measuring a weld gun component associated with movement of the pin" (’279 Patent), and does it contain an "optical sensor" that processes "reflected light" (’664 Patent), or does it use a different, non-infringing technology?
V. Key Claim Terms for Construction
The Term: "measuring a weld gun component associated with movement of the pin" (’279 Patent, Claim 1d)
Context and Importance: This phrase captures the core novelty of the claimed method. The outcome of the infringement analysis for the ’279 Patent will likely depend on the construction of this term, as it defines the specific action alleged to be infringing.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the claim language itself is broad, not specifying the means of measurement or the exact component, only that it is "associated with" the pin's movement. This may support an interpretation covering various types of position sensing.
- Evidence for a Narrower Interpretation: A party could point to the specification's repeated emphasis on using an optical sensor to solve the problems of electrical interference and inaccuracy inherent in prior art displacement transducers (’279 Patent, col. 1:35-48; col. 4:35-42). This may support an argument that "measuring" should be construed as being limited to the optical techniques disclosed as the invention.
The Term: "optical sensor" (’664 Patent, Claim 1)
Context and Importance: The presence of an "optical sensor" is a required structural element of the claimed apparatus. Whether the accused device contains a component that meets this definition will be a critical issue for infringement of the ’664 Patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party may argue the term should be given its plain and ordinary meaning, encompassing any device that uses light to sense a physical property.
- Evidence for a Narrower Interpretation: A party may argue that, in the context of the patent, the term is tied to the solution for a specific problem: magnetic interference. The specification highlights that using fiber optics makes the sensor "impervious to magnetic field interference generated by the weld gun current" (’664 Patent, col. 4:35-42). This could support a narrower construction limited to sensors with such properties, potentially excluding other types of optical sensors that might be susceptible to such interference.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that the Defendant induced infringement by selling the Accused Welding and Conveyor Products to customers with the intent that the customers would use them in a manner that directly infringes the asserted patents. This is supported by allegations that the Defendant marketed the products for such infringing uses and provided instructions (Compl. ¶52-53, ¶76-77, ¶100-101, ¶124-125).
- Willful Infringement: Willfulness is alleged for all asserted patents. The claim is based on the Defendant's alleged knowledge of the patents, established at the latest by the cease and desist letter sent on March 8, 2019, and the allegation that the Defendant continued its infringing conduct without change despite this knowledge (Compl. ¶44, ¶68, ¶92, ¶116).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical evidence: The complaint lacks specific details about the inner workings of the accused products. The case will likely hinge on what discovery reveals about the technology JR Automation uses for weld quality control and part orientation. Does it employ an internal pin-based optical sensor as described in the weld gun patents, or does it rely on a different, non-infringing method?
- A second central issue will be one of claim construction: Can the claim terms "measuring a weld gun component" and "optical sensor" be limited by the specification to the specific embodiments that were described as solving the prior art's problem with electrical interference? The court's interpretation of these terms will define the scope of the patents and could be dispositive of the infringement question for the welding technology.
- Finally, a key question for the conveyor patent will be one of functional mechanics: Does the accused conveyor system achieve part orientation through the claimed interaction of a "friction bar" dragging a part against a "locating element," or does it use an alternative mechanical design that falls outside the scope of the ’775 patent’s claims?