DCT
1:23-cv-00969
Dejule v. Millerknoll Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Aaron DeJule (Illinois)
- Defendant: MillerKnoll, Inc. (Michigan)
- Plaintiff’s Counsel: Warner Norcross + Judd LLP; Morgan, Lewis & Bockius LLP
- Case Identification: 1:23-cv-00969, W.D. Mich., 03/25/2025
- Venue Allegations: Venue is alleged to be proper as Defendant resides in the district, maintains a regular place of business, and has allegedly committed acts of infringement, including manufacturing and sales, within the district.
- Core Dispute: Plaintiff, an industrial designer, alleges that Defendant’s "Cosm" line of office chairs, featuring an "Auto-Harmonic Tilt" mechanism, infringes six patents related to self-adjusting chair tilt technology.
- Technical Context: The technology concerns mechanisms that automatically adjust the tension of a chair's backrest tilt based on the user's weight, a key feature in the competitive high-end ergonomic seating market.
- Key Procedural History: The complaint alleges a detailed pre-suit history, beginning in 2014, in which Plaintiff presented his self-adjusting tilt invention to Defendant (then Herman Miller, Inc.) under a confidentiality agreement. The complaint further alleges that after Defendant expressed no interest in the technology, it proceeded to develop and launch the accused "Cosm" chair in 2018 incorporating the allegedly infringing "Auto-Harmonic Tilt" feature. These allegations of pre-suit knowledge form the basis for Plaintiff's willfulness claims.
Case Timeline
| Date | Event |
|---|---|
| 2014-06-01 | Plaintiff first meets with Defendant's representative. |
| 2015-01-16 | Plaintiff holds confidential meeting with Defendant in Michigan. |
| 2015-02-11 | Plaintiff presents Self-Adjusting Tilt invention prototype to Defendant. |
| 2015-02-11 | Earliest Patent Priority Date (Provisional App. 62/114,706). |
| 2015-02-16 | Parties sign Mutual Confidentiality Agreement. |
| 2015-03-10 | Defendant represents to Plaintiff it is not interested in pursuing the chair design. |
| 2016-12-09 | Defendant's representative confirms to Plaintiff it is "currently working on something like that." |
| 2018-01-01 | Defendant debuts the accused "Cosm" line of chairs. |
| 2018-06-21 | Plaintiff contacts Defendant regarding similarity of Cosm chair to his invention. |
| 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. |
| 2024-04-02 | U.S. Patent No. 11,944,210 issues. |
| 2024-04-09 | U.S. Patent No. 11,950,710 issues. |
| 2025-03-25 | Second Amended 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," Issued Sep. 5, 2023
The Invention Explained
- Problem Addressed: The patent family background explains that manual adjustment mechanisms for chair tilt tension are often confusing for users, leading to improper ergonomic configurations, particularly in environments where chairs are shared by multiple people (’498 Patent, col. 2:3-11).
- The Patented Solution: The invention provides an automatic adjustment mechanism. As a user sits in the chair, their weight acts on the seat, which in turn causes a mechanism (e.g., toothed structures) to move a fulcrum point along the length of a leaf spring (’373 Patent, Abstract). For a heavier user, the fulcrum point moves to shorten the effective "working length" of the leaf spring, thereby increasing the force required to tilt the backrest ('373 Patent, Abstract; '498 Patent, col. 6:56 - col. 7:10). This creates a self-adjusting system that tailors tilt resistance to the user's weight.
- Technical Importance: This approach automates ergonomic customization, aiming to provide an optimal tilt tension for any user without requiring manual adjustment of knobs or levers (Compl. ¶2).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶55).
- The essential elements of claim 1 include:
- A chair comprising a backrest, seat, column, and linkage.
- A leaf spring in direct contact with the linkage.
- An arc-shaped toothed structure fixed relative to the column.
- A different toothed structure in contact with the arc-shaped one.
- 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, shortening the spring's working length and increasing tilt resistance.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
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," Issued Sep. 5, 2023
The Invention Explained
- Problem Addressed: The technical problem is the same as that addressed by the '373 Patent: the inefficiency and ergonomic deficiencies of manually adjusted chair tilt mechanisms ('498 Patent, col. 1:47 - col. 2:5).
- The Patented Solution: This patent describes the same core technical concept of a self-adjusting tilt mechanism but frames it in slightly different claim terms. It describes a "reconfigurable apparatus" where the seat moves from a "first position" to a "loaded position" when a user sits (’374 Patent, col. 18:28-36). This movement engages an "adjusting assembly comprising a plurality of gears" which, in turn, causes toothed structures to move relative to one another, shortening the working length of a leaf spring to increase the backrest tilt resistance ('374 Patent, col. 18:42-56).
- Technical Importance: The technical goal is identical to that of the '373 Patent: to provide a chair that automatically adapts its recline tension to the user's weight (Compl. ¶2).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶62).
- The essential elements of claim 1 include:
- A reconfigurable apparatus with a column, seat, backrest, linkage, and leaf spring.
- A first structure fixed to the column with an arc shape and teeth.
- A second structure in contact with the first, also with teeth.
- An adjusting assembly with a plurality of gears that cooperate when the seat moves to a loaded position.
- Wherein, this cooperation increases resistance to tilting by moving the toothed structures relative to each other, thereby shortening the leaf spring's working length.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 10,893,753 - "Apparatus with Weight Responsive Changeable Adjusting Characteristics," issued Jan. 19, 2021
- Technology Synopsis: This patent describes a reconfigurable apparatus for seating a user where an "adjusting assembly comprising a plurality of gears" responds to a user sitting on the seat. The gears cooperate and move as the seat moves from an unloaded to a loaded position, thereby increasing the resistance to changing the angular orientation of the backrest (’753 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶69).
- Accused Features: The "Auto-Harmonic Tilt" feature of the Cosm chairs is alleged to infringe by using gears that respond to user weight to automatically adjust tilt resistance (Compl. ¶¶9, 13, 70).
U.S. Patent No. 10,292,498 - "Apparatus with Weight Responsive Changeable Adjusting Characteristics," issued May 21, 2019
- Technology Synopsis: This patent describes a reconfigurable apparatus with a frame, a first component (e.g., a seat) that receives a user's weight, and a second movable component (e.g., a backrest). An adjusting assembly with "cooperating toothed elements" is configured so that as the user's weight on the first component changes, the force required to move the second component also changes ('498 Patent, Abstract; Claim 18).
- Asserted Claims: Dependent claim 18 (depending from independent claim 1) is asserted (Compl. ¶76).
- Accused Features: The "Auto-Harmonic Tilt" feature of the Cosm chairs is alleged to infringe by having cooperating toothed elements that alter the backrest tilt resistance in response to the force (weight) applied to the seat (Compl. ¶¶9, 13, 77).
U.S. Patent No. 11,944,210 - "Chair Having at Least Three Different Components That Move Together When a Weight is Applied to the Seat...," issued Apr. 2, 2024
- Technology Synopsis: This patent claims a chair with a backrest, seat, column, linkage, and a leaf spring. It specifies first and second toothed structures that interact, and is configured such that when weight is applied to the seat, the teeth of the second structure, a pivot point for the backrest, and the linkage are configured to "move together" to adjust tilt resistance (’210 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶83).
- Accused Features: The "Auto-Harmonic Tilt" feature is alleged to have the claimed components that move together when a user sits down to automatically adjust the recline mechanism (Compl. ¶¶9, 13, 84).
U.S. Patent No. 11,950,710 - "Chair Having a Leaf Spring With a Working Length That Shortens to Increase Resistance to Tilting of a Backrest Relative to a Column," issued Apr. 9, 2024
- Technology Synopsis: This patent claims a chair with a linkage, leaf spring, and two interacting toothed structures. The core inventive concept is that when weight is applied to the seat, the teeth of the structures move along each other to "shorten a working length of the leaf spring and provide an increased resistance to tilting" (’710 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶90).
- Accused Features: The "Auto-Harmonic Tilt" feature is alleged to operate by shortening the working length of a leaf spring via interacting structures when a user sits down, thereby increasing tilt resistance (Compl. ¶¶9, 13, 91).
III. The Accused Instrumentality
Product Identification
- The accused products are at least Defendant's "Cosm" model of professional chairs and any other products incorporating the "Auto-Harmonic Tilt" feature (Compl. ¶13).
Functionality and Market Context
- The complaint alleges that the Auto-Harmonic Tilt feature provides automatic, balanced recline for a user (Compl. ¶9). The complaint quotes Defendant's own marketing materials, which state: "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). A figure from Plaintiff's provisional application illustrates the claimed self-adjusting tension control mechanism, showing racks, a leaf spring, and a linkage that adjusts tension based on a user's weight (Compl. p. 3). The complaint further alleges that one of Defendant's representatives confirmed that in the Cosm chair, "the mechanism does slide a fulcrum based on the users weight" (Compl. ¶46). The complaint positions the accused feature as a significant commercial success, touting it as the "holy grail" of adjustable chairs and listing numerous design and innovation awards received by the Cosm chair (Compl. ¶¶9-10).
IV. Analysis of Infringement Allegations
'373 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A chair, comprising: a backrest portion; a seat portion coupled with the backrest portion; a column portion coupled with the seat portion; linkage coupled with the backrest portion; | The accused Cosm chairs are chairs with these fundamental components. | ¶13 | col. 19:42-45 |
| a leaf spring in direct contact with the linkage; | The Auto-Harmonic Tilt mechanism is alleged to contain a leaf spring that interacts with a linkage to provide tilt resistance. | ¶9 | col. 26:47-48 |
| an arc-shaped toothed structure fixed translationally relative to the column portion; and a different toothed structure in contact with the arc-shaped toothed structure... | The internal mechanism of the Auto-Harmonic Tilt is alleged to contain interacting toothed structures, such as gears, that translate the vertical force of user weight into mechanical adjustment. | ¶9 | col. 26:49-54 |
| and wherein: when a weight is applied to the seat portion, a fulcrum point of the leaf spring moves as the different toothed structure moves along the arc-shaped toothed structure to thereby shorten a working length of the leaf spring and provide an increased resistance to tilting... | The complaint alleges, based on Defendant's own statements, that the gears within the accused tilt mechanism "move the fulcrum along a leaf spring" in response to the user's weight, which "automatically adjust[s] the chair's tension." | ¶9, ¶46 | col. 26:55-63 |
'374 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A reconfigurable apparatus for seating a user... comprising: a column; a seat mounted on the column and movable relative to the column between: a) a first position... and b) a loaded position...; a backrest...; a linkage...; a leaf spring... | The accused Cosm chairs are alleged to be such an apparatus, where the seat moves to a "loaded position" when a user sits. | ¶13 | col. 18:28-41 |
| a first structure fixed to the column, wherein the first structure has an arc shape that includes one or more teeth; and a second structure in contact with the first structure, wherein a portion of the second structure includes one or more teeth, | The Auto-Harmonic Tilt mechanism is alleged to contain interacting toothed structures that facilitate the automatic adjustment. | ¶9 | col. 18:42-46 |
| an adjusting assembly comprising a plurality of gears that cooperate... as an incident of the seat moving from the first position into the loaded position and configured to thereby increase a resistance to changing of the angular orientation of the backrest... | The complaint alleges the accused products contain "gears within the tilt" that respond to the "sitter's vertical force" as the seat is loaded to adjust the chair's tension. | ¶9 | col. 18:47-56 |
| wherein the reconfigurable apparatus is configured such that, when a weight is applied to the seat, the one or more teeth of the second structure move along the one or more teeth of the first structure to thereby shorten a working length of the leaf spring and provide an increased resistance... | The complaint alleges that the accused mechanism "does slide a fulcrum based on the users weight" and that the gears "move the fulcrum along a leaf spring to automatically adjust the chair's tension." | ¶9, ¶46 | col. 18:57-65 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis may focus on whether the specific components within the "Auto-Harmonic Tilt" meet the definitions of claim terms such as "arc-shaped toothed structure" and "linkage" as they would be construed in light of the patent specifications. A potential dispute could arise over whether the accused mechanism's parts, even if functionally similar, are structurally equivalent to what is claimed.
- Technical Questions: A primary factual question for the court will be whether the accused mechanism operates as alleged. While the complaint relies on Defendant's marketing language describing a "fulcrum mov[ing] along a leaf spring," the defense may present technical evidence and expert testimony arguing that the actual principle of operation is different from the one required by the claims, and that the marketing language is a simplification.
V. Key Claim Terms for Construction
The Term: "fulcrum point"
- Context and Importance: This term is central to the patented invention, as the "movement" of this point is what allegedly shortens the leaf spring's working length to increase resistance. The infringement case hinges on establishing that the accused device has a "fulcrum point" that operates in the claimed manner. Practitioners may focus on this term because its definition—whether it must be a specific, discrete structure or can be a more conceptual point of bending—will determine the claim's breadth.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specifications describe the concept generally, for instance, noting that bending occurs "about a fulcrum location" ('498 Patent, col. 10:9-10). This may support an argument that the term refers to the functional point of bending, regardless of the precise structure creating it.
- Evidence for a Narrower Interpretation: The embodiments show the fulcrum point as a specific physical structure, such as the "edge 61 on a cantilevered part 62" ('498 Patent, col. 6:44-46, Fig. 3) or defined "fulcrum locations" created by extensions on a member ('498 Patent, col. 8:66-67, Fig. 10). This could support a narrower construction requiring a distinct, identifiable edge or surface acting as the fulcrum.
The Term: "working length" (of the leaf spring)
- Context and Importance: The core of the alleged invention is the shortening of this "working length" to increase resistance. The parties will likely dispute what portion of the leaf spring constitutes its "working length" and whether the accused mechanism actually "shortens" it as required by the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The concept is described functionally. For example, moving the contact point "below the location A" results in "a shorter moment arm" and an "effectively shorter length" for the leaf spring ('498 Patent, col. 6:65 - col. 7:5). This suggests the term may be defined functionally as the portion of the spring under bending stress.
- Evidence for a Narrower Interpretation: The patent figures consistently depict the "working length" as the cantilevered portion of the spring between its anchored base and the point of contact with the linkage or backrest mechanism ('498 Patent, Fig. 3). A defendant may argue that the term is limited to this specific structural arrangement and that its mechanism does not shorten this specific length.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement by Defendant encouraging its dealers to sell the Accused Products in the United States (Compl. ¶¶57, 64, 71, 78, 85, 92). It also alleges contributory infringement on the basis that the Accused Products are especially made or adapted for infringement and are not staple articles of commerce (Compl. ¶¶58, 65, 72, 79, 86, 93).
- Willful Infringement: The complaint makes detailed allegations of willful infringement based on Defendant's alleged pre-suit knowledge of the invention. It alleges Plaintiff disclosed his "Self-Adjusting Tilt invention" and prototype to Defendant's employees in confidential meetings in 2015, only to be told the company was not interested (Compl. ¶¶32-39). The complaint alleges Defendant then developed and launched the infringing products and that Defendant's employees later confirmed the similarity in operation (Compl. ¶¶40, 43-44, 47). These allegations, if proven, could support a finding of pre-suit willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical operation: Does the accused "Auto-Harmonic Tilt" mechanism, as a matter of engineering fact, operate by moving a fulcrum point along a leaf spring to shorten its effective working length, as required by the asserted claims? The dispute will likely involve a battle of experts analyzing the internal mechanics of the accused chairs versus the teachings of the patents-in-suit.
- A key question will be one of definitional scope: Will claim terms such as "fulcrum point" and "arc-shaped toothed structure" be construed broadly enough to read on the specific components used in the Cosm chair, or will the court adopt narrower definitions based on the patents' embodiments that allow the accused design to fall outside the claims' scope?
- A third major question, relevant to damages, will be one of intent: Given the detailed allegations of confidential disclosures prior to the development of the accused product, the court will have to determine whether Defendant independently developed its technology or copied Plaintiff's invention. The answer will be critical to the determination of willfulness.