DCT

1:23-cv-00969

Dejule v. Millerknoll Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Aaron DeJule v. MillerKnoll, Inc., 1:23-cv-00969, W.D. Mich., 09/13/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, maintains a regular and established place of business in the district, and has allegedly committed acts of infringement, such as manufacturing and sales, within the district.
  • Core Dispute: Plaintiff, an industrial designer, alleges that Defendant’s "Cosm" line of office chairs infringes four patents related to a self-adjusting tilt mechanism for which Plaintiff had previously disclosed designs to Defendant under a confidentiality agreement.
  • Technical Context: The technology concerns ergonomic office chairs with mechanisms that automatically adjust the backrest tilt tension in response to the user’s weight, eliminating the need for manual adjustments.
  • Key Procedural History: The complaint alleges that Plaintiff presented his "Self-Adjusting Tilt invention" to Defendant (then Herman Miller, Inc.) in confidential meetings during 2015 under a Mutual Confidentiality Agreement. After Defendant allegedly rejected the idea, it launched the accused "Cosm" chair in 2018, which Plaintiff alleges incorporates his disclosed invention. The complaint also details pre-suit communications between the parties regarding the alleged infringement.

Case Timeline

Date Event
2015-01-16 Plaintiff meets with Defendant's representatives in Michigan
2015-02-11 Plaintiff files Provisional Application No. 62/114,706
2015-02-11 Plaintiff again meets with Defendant's representatives, presenting the invention
2015-02-16 Defendant provides Plaintiff with a Mutual Confidentiality Agreement
2015-03-10 Defendant informs Plaintiff it is not interested in pursuing the chair design
2018-01-01 Defendant launches the accused "Cosm" chairs (year only specified)
2019-05-21 U.S. Patent No. 10,292,498 issues
2021-01-19 U.S. Patent No. 10,893,753 issues
2023-09-05 U.S. Patent No. 11,744,373 issues
2023-09-05 U.S. Patent No. 11,744,374 issues
2023-09-13 Complaint filed

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

U.S. Patent No. 11,744,373 - "Chair Having a Leaf Spring with a Fulcrum Point That Moves to Shorten a Working Length of the Leaf Spring and Increase Resistance to Tilting of a Backrest Portion of the Chair Relative to a Column Portion of the Chair"

The Invention Explained

  • Problem Addressed: Conventional office chairs often require users to manually adjust the backrest tilt tension via knobs or levers to suit their body weight, a process that can be confusing, time-consuming, and is often neglected, leading to suboptimal ergonomic support (’498 Patent, col. 2:1-12).
  • The Patented Solution: The invention provides a chair mechanism that automatically adjusts tilt tension. As a user sits, their weight is applied to the seat portion, which causes a "fulcrum point" to move along a leaf spring via a linkage and interacting toothed structures (’373 Patent, Abstract). This movement shortens the effective "working length" of the leaf spring, which inherently increases its resistance to bending and, therefore, the force required to tilt the backrest (’373 Patent, Abstract). The complaint includes an image from Plaintiff’s provisional application showing a prototype of this mechanism with key components labeled (Compl. p. 3).
  • Technical Importance: This design automates a key ergonomic adjustment, allowing a single chair model to provide appropriate backrest support for a wide range of user weights without requiring manual user input (Compl. ¶2).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶56).
  • Essential elements of claim 1 include:
    • A chair comprising a backrest portion, a seat portion, a column portion, and a linkage.
    • A leaf spring in direct contact with the linkage.
    • An arc-shaped toothed structure fixed relative to the column portion.
    • A different toothed structure in contact with the arc-shaped toothed structure.
    • Wherein, when weight is applied to the seat, a fulcrum point of the leaf spring moves as the toothed structures move relative to each other, thereby shortening the leaf spring's working length and increasing resistance to tilting.

U.S. Patent No. 11,744,374 - "Reconfigurable Apparatus Having a Leaf Spring with a Working Length That Shortens to Increase Resistance to Tilting of a Backrest Relative to a Column, and Process for Assembling the Reconfigurable Apparatus"

The Invention Explained

  • Problem Addressed: As with the related patents, the invention addresses the challenge of providing customized, weight-appropriate back support in seating without requiring complex manual adjustments from the user (’498 Patent, col. 1:46-55).
  • The Patented Solution: This patent describes a reconfigurable apparatus, such as a chair, where the downward movement of the seat under a user's weight actuates an "adjusting assembly comprising a plurality of gears" (’374 Patent, col. 20:1-5). This assembly, in turn, causes interacting structures to move relative to one another, shortening the working length of a leaf spring to increase resistance to backrest tilt (’374 Patent, col. 17:1-9). The core technical concept is the automatic, weight-responsive adjustment of tilt tension.
  • Technical Importance: The use of a gear-based adjusting assembly provides a specific mechanical pathway to translate the vertical force of a user's weight into a modulated resistance for reclining.

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶63).
  • Essential elements of claim 1 include:
    • A reconfigurable apparatus with a column, a seat movable between a first (unloaded) and a loaded position, and a backrest.
    • A linkage statically attached to the backrest.
    • A leaf spring in direct contact with the linkage.
    • A first arc-shaped structure with teeth, fixed to the column.
    • A second structure with teeth, in contact with the first structure.
    • An adjusting assembly with a plurality of gears that cooperate when the seat moves to the loaded position to increase tilt resistance.
    • Wherein, applied weight causes the toothed structures to move relative to each other, shortening the working length of the leaf spring and increasing tilt resistance.

U.S. Patent No. 10,893,753 - "Apparatus with Weight Responsive Changeable Adjusting Characteristics"

  • Technology Synopsis: This patent describes a reconfigurable apparatus for seating a user where the seat moves from a first position to a loaded position upon the user sitting. This movement actuates an adjusting assembly with a "plurality of gears" that move relative to each other to increase the resistance to changing the angular orientation of the backrest.
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶70).
  • Accused Features: The "Auto-Harmonic Tilt" mechanism of the Cosm chairs is alleged to infringe, specifically its use of gears to automatically adjust tilt resistance based on user weight (Compl. ¶9, 71).

U.S. Patent No. 10,292,498 - "Apparatus with Weight Responsive Changeable Adjusting Characteristics"

  • Technology Synopsis: This patent describes a reconfigurable apparatus with first and second components (e.g., a seat and backrest). A force applied to the first component (e.g., user's weight on the seat) causes a change in the force required to be applied to the second component to reconfigure the apparatus (e.g., to tilt the backrest). The dependent claim at issue specifies that the adjusting assembly uses "cooperating toothed elements."
  • Asserted Claims: Dependent claim 18 (depending from independent claim 1) is asserted (Compl. ¶77).
  • Accused Features: The "Auto-Harmonic Tilt" mechanism is alleged to infringe, particularly its use of "cooperating toothed elements" that adjust tilt force in response to the force (weight) applied to the seat (Compl. ¶9, 78).

III. The Accused Instrumentality

Product Identification

  • The accused products are MillerKnoll’s "Cosm" model professional chairs and any other products incorporating the "Auto-Harmonic Tilt" feature (Compl. ¶13).

Functionality and Market Context

  • The relevant feature is the "Auto-Harmonic Tilt," which Defendant’s marketing materials describe as an automatic, self-adjusting mechanism (Compl. ¶9). The complaint quotes Defendant as stating, "Accounting for the sitter's vertical force—which is always in flux—the gears within the tilt move the fulcrum along a leaf spring to automatically adjust the chair's tension" (Compl. ¶9). The complaint further alleges that a MillerKnoll executive confirmed the mechanism "does slide a fulcrum based on the users weight" (Compl. ¶47).
  • The complaint alleges the Cosm chairs with this feature are commercially significant, having garnered numerous design and innovation awards since their debut in 2018 (Compl. ¶10). Defendant is alleged to have described the technology as "something of a holy grail" (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint states that claim charts are attached as exhibits but these exhibits were not available for review. The infringement theory is therefore summarized from the complaint's narrative allegations.

’373 Patent Infringement Allegations

  • Plaintiff's infringement theory posits that the Cosm chair's Auto-Harmonic Tilt mechanism practices every element of at least claim 1 of the ’373 Patent (Compl. ¶57). The complaint alleges the chair has a backrest, seat, column, linkage, and a leaf spring (Compl. ¶9). The core of the alleged infringement lies in the chair’s operation, which Defendant itself describes as using "gears" to "move the fulcrum along a leaf spring" in response to the "sitter's vertical force" (Compl. ¶9). This alleged functionality maps to the claim language requiring that when weight is applied, a "fulcrum point of the leaf spring moves" as "toothed structure moves along the arc-shaped toothed structure" to shorten the spring's working length and increase tilt resistance (Compl. ¶56).

’374 Patent Infringement Allegations

  • The infringement theory for the ’374 Patent is similar, focusing on the mapping of the accused product's features to the elements of claim 1 (Compl. ¶64). The theory relies on Defendant's description of "gears within the tilt" (Compl. ¶9) to meet the claim limitation of "an adjusting assembly comprising a plurality of gears" (’374 Patent, Claim 1; Compl. ¶63). The allegation is that these gears cooperate, as an incident of the seat moving to a loaded position, to move toothed structures relative to one another, shorten the leaf spring's working length, and thereby increase the resistance to backrest tilt, as required by the claim (Compl. ¶63).

Identified Points of Contention

  • Scope Questions: A potential area of dispute may involve the construction of terms such as "direct contact" between the leaf spring and linkage or "statically attached" regarding the linkage and backrest. The litigation may raise the question of whether the specific components of the Cosm chair meet these structural limitations as defined within the patent.
  • Technical Questions: While Defendant's public description of the accused mechanism appears to align with the patented concept, a central technical question will be whether the Cosm chair's mechanism operates in a manner that corresponds to the specific sequence and relationship of elements recited in the claims. For example, does the accused "fulcrum" constitute a "fulcrum point" that "moves" in the precise manner claimed, or does it achieve a similar result through a technically distinct mode of operation that falls outside the claim scope?

V. Key Claim Terms for Construction

  • The Term: "a fulcrum point of the leaf spring moves" (’373 Patent, Claim 1)

    • Context and Importance: This phrase captures the core inventive concept of automatically adjusting tilt tension. The outcome of the case may depend on whether the operation of the accused Auto-Harmonic Tilt mechanism is found to include a "fulcrum point" that "moves." Practitioners may focus on this term because the Defendant's own marketing states that "the gears within the tilt move the fulcrum along a leaf spring" (Compl. ¶9), creating a significant factual predicate for infringement that Defendant will have to address.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification may describe the "fulcrum point" in functional terms as the location around which the leaf spring bends, which could support a construction not limited to a single, specific physical structure (’498 Patent, col. 6:48-54).
      • Evidence for a Narrower Interpretation: The patent figures depict a specific embodiment where an edge on a cantilevered part bears against the leaf spring surface, and the location of this contact point moves as the user's weight changes (’498 Patent, Fig. 3, elements 61, 62). A defendant may argue that such embodiments limit the term to this specific type of moving contact point.

  • The Term: "an adjusting assembly comprising a plurality of gears" (’374 Patent, Claim 1)

    • Context and Importance: This term is critical because Defendant's product description explicitly mentions "gears within the tilt" (Compl. ¶9). The construction will determine if the components in the accused mechanism qualify as "a plurality of gears" as claimed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The plain meaning of "plurality of gears" suggests two or more toothed wheels that interact. The specification describes the term's function as translating the force from the seat's movement into an adjustment of the tilt resistance, potentially covering any gear set that achieves this function (’498 Patent, col. 10:45-55).
      • Evidence for a Narrower Interpretation: The specification discloses specific embodiments, such as a differential pinion element that cooperates with toothed racks (’498 Patent, col. 8:1-10; Fig. 7). A defendant may argue these specific disclosures limit the scope of "plurality of gears" to the types of gear systems shown and described.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges inducement of infringement by asserting that MillerKnoll encourages third parties, such as dealers, to sell the Accused Products in the U.S. (Compl. ¶58, 65, 72, 79). It also alleges contributory infringement, stating the Accused Products contain a material component of the invention that is not a staple article of commerce suitable for substantial non-infringing use (Compl. ¶59, 66, 73, 80).

Willful Infringement

  • The complaint alleges willful infringement based on both pre- and post-suit knowledge. It alleges pre-suit knowledge stemming from the confidential meetings in 2015 where Plaintiff disclosed his invention, followed by years of communication during which Plaintiff made Defendant aware of his patent rights (Compl. ¶33, 36, 47, 54). The complaint alleges Defendant knew of the patents yet continued its infringing conduct, supporting a claim for willfulness from the date the patents issued (Compl. ¶60, 67, 74, 81).

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

  • A central issue will be one of design provenance and intent: given the detailed allegations of confidential disclosure followed by Defendant’s commercialization of a similar technology, a key factual question will be whether the accused "Auto-Harmonic Tilt" mechanism was derived from Plaintiff's disclosed invention or was the product of independent development. This question is intertwined with the breach of contract claim and will be a focal point for the willfulness allegations.
  • A key legal and technical question will be one of definitional correspondence: can the specific mechanical structures within the Cosm chair, described by Defendant as "gears" that "move the fulcrum," be mapped to the limitations of the asserted claims? The case may turn on whether the court construes terms like "fulcrum point" and "plurality of gears" broadly enough to read on Defendant’s implementation, especially in light of Defendant’s own public statements which appear to describe the core patented functionality.