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., 04/09/2024
- Venue Allegations: Venue is alleged to be proper in the Western District of Michigan because Defendant resides in the district, maintains a regular place of business, and has allegedly committed acts of infringement, including manufacture and sale of the accused products, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Cosm" line of office chairs, which feature an "Auto-Harmonic Tilt" mechanism, infringes six patents related to self-adjusting, weight-responsive chair tilt technology.
- Technical Context: The technology concerns ergonomic office chair design, specifically mechanisms that automatically adjust the force required to recline the backrest based on the user's weight, eliminating the need for manual adjustments.
- Key Procedural History: The complaint details a series of meetings in 2014 and 2015 where Plaintiff allegedly disclosed his invention to Defendant (then Herman Miller, Inc.) under a mutual confidentiality agreement. Plaintiff alleges that after Defendant formally rejected the idea, it incorporated the confidential technology into its commercially successful Cosm chair. The complaint also notes pre-suit communications between the parties’ counsel regarding infringement of the patents that had issued at that time.
Case Timeline
| Date | Event |
|---|---|
| 2015-02-11 | Plaintiff files Provisional Application No. 62/114,706 (Earliest Priority Date for all Patents-in-Suit) |
| 2015-02-11 | Plaintiff presents invention and prototype to Defendant's personnel |
| 2018-01-01 | Defendant debuts the accused "Cosm" line of chairs (approximate date) |
| 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 |
| 2024-04-09 | First 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 September 5, 2023
The Invention Explained
- Problem Addressed: The patent family's background describes the difficulty users face with conventional office chairs that require manual adjustment of tilt tension using knobs or levers. This process is often confusing or ignored, resulting in suboptimal ergonomics where a chair may be too stiff for a lighter person to recline or too loose for a heavier person. (U.S. Patent No. 10,292,498, col. 2:1-12).
- The Patented Solution: The invention provides a self-adjusting tilt mechanism that automatically adapts to a user's weight. When a user sits in the chair, their weight causes a "fulcrum point" to move along the length of a leaf spring. This movement shortens the "working length" of the spring, which increases its stiffness and thus the resistance to tilting the backrest. The mechanism employs interacting toothed structures to translate the vertical force of the user's weight into this repositioning of the fulcrum. (’373 Patent, Abstract). An annotated diagram from the priority application illustrates a prototype mechanism with racks, gears, and a leaf spring designed to automatically adjust tension based on a user's weight (Compl. p. 3).
- Technical Importance: This approach creates a "self-adjusting" chair that provides an appropriate tilt resistance for users across a wide weight range without requiring any manual input from the user. (U.S. Patent No. 10,292,498, col. 8:21-25).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶58).
- Essential elements of claim 1 include:
- A chair with a backrest, seat, and column.
- A linkage coupled to the backrest.
- 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, applying weight to the seat causes a fulcrum point of the leaf spring to move as the toothed structures move relative to each other, which shortens the spring's working length and increases tilt resistance.
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 September 5, 2023
The Invention Explained
- Problem Addressed: This patent arises from the same specification as the ’373 Patent and addresses the identical problem of providing automatic, weight-responsive tilt tension in seating. (U.S. Patent No. 10,292,498, col. 2:1-12).
- The Patented Solution: The solution is functionally identical to that of the ’373 Patent, using a user's weight to move a fulcrum along a leaf spring to modulate tilt resistance. This patent frames the invention as a "reconfigurable apparatus" and describes an "adjusting assembly comprising a plurality of gears" that cooperates to increase resistance as the seat moves from an unloaded "first position" to a "loaded position." (’374 Patent, col. 26:1-24).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶65).
- Essential elements of claim 1 include:
- A reconfigurable apparatus with a column, seat, and backrest.
- A linkage statically attached to the backrest.
- A leaf spring statically attached at one end and 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.
- An adjusting assembly with a plurality of gears that cooperate when the seat is loaded to increase resistance to tilting.
- Wherein, when weight is applied, the teeth of the second structure move along the teeth of the first structure to shorten the leaf spring's working length.
U.S. Patent No. 10,893,753 - "Apparatus With Weight Responsive Changeable Adjusting Characteristics," issued January 19, 2021
- Technology Synopsis: The patent describes a reconfigurable apparatus, such as a chair, where the force required to move a second component (e.g., a backrest) changes automatically in response to a change in force on a first component (e.g., a seat). The invention uses an adjusting assembly with a plurality of gears that move relative to each other when a user sits down, thereby increasing the resistance to recline. (’753 Patent, Abstract).
- Asserted Claims: Independent claim 1 (Compl. ¶72).
- Accused Features: The "Auto-Harmonic Tilt" feature of Defendant's "Cosm" model chairs (Compl. ¶¶13, 73).
U.S. Patent No. 10,292,498 - "Apparatus With Weight Responsive Changeable Adjusting Characteristics," issued May 21, 2019
- Technology Synopsis: This patent, the parent of the other patents-in-suit, discloses an apparatus where an adjusting assembly automatically changes the force required to reconfigure the apparatus. As the force applied in a "first manner" (e.g., a user sitting down) changes, the force required in a "second manner" (e.g., leaning back) also changes. The asserted claim specifies that the adjusting assembly includes "cooperating toothed elements." (’498 Patent, Abstract; Claim 18).
- Asserted Claims: Dependent claim 18, which depends from independent claim 1 (Compl. ¶79).
- Accused Features: The "Auto-Harmonic Tilt" feature of Defendant's "Cosm" model chairs (Compl. ¶¶13, 80).
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 April 2, 2024
- Technology Synopsis: The patent describes a chair with a leaf spring and interacting toothed structures. It is configured such that when a user applies weight to the seat, three components—the teeth of a second structure, a pivot point for the backrest, and a linkage—are all "configured to move together." This coordinated movement adjusts the tilt resistance. (’210 Patent, Abstract).
- Asserted Claims: Independent claim 1 (Compl. ¶95).
- Accused Features: The "Auto-Harmonic Tilt" feature of Defendant's "Cosm" model chairs (Compl. ¶¶13, 96).
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 April 9, 2024
- Technology Synopsis: The patent describes a chair with a leaf spring and two interacting toothed structures, one of which is arc-shaped and fixed to the chair's column. When a user sits down, the teeth of the second structure move along the teeth of the first, which shortens the working length of the leaf spring and increases the resistance to tilting the backrest. (’710 Patent, Abstract).
- Asserted Claims: Independent claim 1 (Compl. ¶102).
- Accused Features: The "Auto-Harmonic Tilt" feature of Defendant's "Cosm" model chairs (Compl. ¶¶13, 103).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s "Cosm" model professional chairs and any other products incorporating the "Auto-Harmonic Tilt" feature (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the Auto-Harmonic Tilt is the central feature of the Cosm chair, which Defendant markets as a "holy grail" in seating technology (Compl. ¶9). According to Defendant's own description cited in the complaint, the mechanism functions by using "gears within the tilt" to "move the fulcrum along a leaf spring to automatically adjust the chair's tension" in response to the "sitter's vertical force" (Compl. ¶9). The complaint further alleges that a representative of Defendant confirmed the mechanism "does slide a fulcrum based on the users weight" (Compl. ¶49). The Cosm chair line has received numerous industry awards since its debut in 2018 (Compl. ¶10).
IV. Analysis of Infringement Allegations
'373 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a leaf spring in direct contact with the linkage; | The Auto-Harmonic Tilt mechanism contains a "leaf spring" that provides resistance to the chair's recline. | ¶9 | col. 6:23-25 |
| 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 mechanism contains "gears within the tilt" that interact to adjust tension. | ¶9 | col. 7:8-13 |
| 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 "gears within the tilt move the fulcrum along a leaf spring" in response to the "sitter's vertical force" to "automatically adjust the chair's tension." | ¶9, ¶49 | col. 6:55-7:10 |
'374 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a leaf spring statically attached at one end and in direct contact with the linkage to provide a resistance to tilting... | The Auto-Harmonic Tilt mechanism uses a "leaf spring" to resist the chair's recline. | ¶9 | col. 6:23-25 |
| 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 mechanism contains interacting "gears within the tilt." | ¶9 | col. 7:8-13 |
| an adjusting assembly comprising a plurality of gears that cooperate with each other as an incident of the seat moving from the first position into the loaded position... | The "gears" cooperate to adjust tension when a user sits down. | ¶9, ¶49 | col. 7:62-8:2 |
| 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... | The "gears...move the fulcrum along a leaf spring" in response to the user's weight, which adjusts its effective length and resistance. | ¶9, ¶49 | col. 6:55-7:10 |
Identified Points of Contention
- Scope Questions: A central question may be whether the "gears" in the Cosm chair's mechanism meet the claim limitations of an "arc-shaped toothed structure" interacting with a "different toothed structure." The construction of these terms will be pivotal. Similarly, the '374 patent's requirement for a "plurality of gears" will require specific evidence from the accused device.
- Technical Questions: The complaint's infringement theory relies heavily on Defendant's public-facing marketing descriptions. A key point of contention will be whether the actual technical operation of the Auto-Harmonic Tilt mechanism matches the claimed process, specifically how the "fulcrum point" is moved and how this movement "shorten[s] a working length of the leaf spring" to increase resistance. The complaint does not provide technical diagrams or reverse engineering of the accused product.
V. Key Claim Terms for Construction
The Term: "fulcrum point" (asserted in '373 Patent, Claim 1)
- Context and Importance: This term is central to the claimed invention's method of operation. The infringement analysis will turn on whether the accused product has a "fulcrum point" that "moves" along a leaf spring in the manner claimed. Practitioners may focus on this term because its definition will determine whether a wide or narrow range of mechanical actions can be said to satisfy this core limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not appear to provide an explicit definition, which may suggest the term should be given its plain and ordinary meaning to one of skill in the art—any point about which the spring bends or pivots to provide resistance.
- Evidence for a Narrower Interpretation: The specification describes embodiments where a component edge bears against the leaf spring, and "the body 46 projects away from the part of the member 36 in which it is anchored" at a "fulcrum location at 66" (U.S. Patent No. 10,292,498, col. 6:49-51). This could be argued to tie the term to a specific type of pivot point created by an anchored cantilever spring.
The Term: "arc-shaped toothed structure" (asserted in '373 Patent, Claim 1)
- Context and Importance: Plaintiff alleges Defendant's "gears" meet this limitation. The viability of the infringement claim depends on whether the components of the accused device fall within the scope of this term. The term combines a geometric property ("arc-shaped") with a functional one ("toothed structure").
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "toothed structure" could be argued to broadly cover any component with projections designed to inter-engage, including racks and pinions. The term "arc-shaped" may not require a perfect geometric arc but could encompass any generally curved component.
- Evidence for a Narrower Interpretation: Embodiments in the patent family's specification show specific curved components, such as a leg with a "curved shape that moves in a complementarily-curved channel" (U.S. Patent No. 10,292,498, col. 8:26-28 and Fig. 8). This may support an argument that "arc-shaped" requires a specific type of curved track or guide, rather than just a circular gear.
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. ¶¶60, 67). It also alleges contributory infringement on the basis that the Accused Products are especially adapted for use in an infringing manner and are not staple articles of commerce (Compl. ¶¶61, 68).
Willful Infringement
- Willfulness is alleged based on Defendant’s alleged pre-suit knowledge of the invention and patents. The complaint asserts this knowledge arises from the 2015 meetings where Plaintiff presented his invention and prototype, subsequent communications in 2016 regarding Plaintiff's patent filings, and post-launch communications starting in 2018 regarding infringement of the then-issued patents (Compl. ¶¶38, 46, 56, 62, 69).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: can the term "arc-shaped toothed structure," as defined by the patent's intrinsic evidence, be construed to cover the "gears" used in the accused Auto-Harmonic Tilt mechanism? The outcome of this claim construction dispute will likely be dispositive for several of the asserted patents.
- A second central issue will be factual and evidentiary: beyond Defendant's marketing language, does the accused mechanism actually operate in the claimed manner? The case may turn on whether discovery reveals a direct operational correspondence, specifically evidence that a "fulcrum point" physically "moves" along a leaf spring to "shorten a working length" and thereby increase stiffness, or if the accused product achieves a similar result through a different, non-infringing technical method.
- A third key question, particularly relevant to damages and willfulness, will be the role of the pre-litigation history: how will the facts surrounding the 2015 confidential disclosures and Defendant's subsequent development of the Cosm chair influence the narrative of the case? While legally separate from the technical infringement analysis, this history is a prominent feature of the complaint and may be significant in framing the parties' conduct.