DCT
1:24-cv-01345
MORryde Intl Inc v. Stromberg Carlson Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: MORryde International, Inc. (Indiana)
- Defendant: Stromberg-Carlson Products, Inc. (Michigan)
- Plaintiff’s Counsel: IRWIN IP LLP
- Case Identification: 1:24-cv-01345, W.D. Mich., 12/26/2024
- Venue Allegations: Venue is alleged to be proper because the Defendant is incorporated and resides in the Western District of Michigan, and has a regular and established place of business in the district where it has allegedly committed acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s recreational vehicle handrail product infringes a patent related to retractable handles that pivot and slide between a storage and a use position.
- Technical Context: The technology concerns mechanical accessories for recreational vehicles (RVs), specifically articulating handrails designed to provide user support while being stowable in a compact configuration.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendant of the patent-in-suit during a meeting on August 13, 2024, and later provided a claim chart on October 31, 2024, alleging infringement by the accused product. These allegations form the basis for claims of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2021-07-21 | U.S. Patent No. 12,030,416 Priority Date |
| 2024-07-09 | U.S. Patent No. 12,030,416 Issue Date |
| 2024-08-13 | Plaintiff and Defendant meet to discuss the ’416 Patent |
| 2024-09-01 | Accused Product offered for sale "at least as of September 2024" |
| 2024-10-31 | Plaintiff provides Defendant with a claim chart for the ’416 Patent |
| 2024-12-26 | Complaint for Patent Infringement filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,030,416 - "Retractable Handle For Recreational Vehicles"
Issued July 9, 2024
The Invention Explained
- Problem Addressed: The patent background describes that while handles are helpful for users of recreational vehicles (RVs) who need to climb into elevated doorways, a need exists for handles with "improved functionality and storage configurations" ('416 Patent, col. 1:23-28).
- The Patented Solution: The invention is a handle assembly for an RV that moves between a stowed position (flat against the vehicle) and a use position (extending outward). The assembly includes a handrail and a support arm, both of which pivot relative to the RV. The core mechanism involves the support arm being "slidingly coupled" to the handrail, so that as the handrail pivots outward, the end of the support arm slides along the handrail to provide stable support in the use position ('416 Patent, col. 1:30-46; FIG. 1-2).
- Technical Importance: This design provides a user-assist handle that can be deployed for safety and then retracted into a low-profile storage position, which is valuable for vehicle clearance and aerodynamics.
Key Claims at a Glance
- The complaint asserts independent claims 1 and 10, as well as several dependent claims (Compl. ¶¶28-49).
- Independent Claim 1 recites a handle for an RV comprising:
- a handrail;
- a support arm slidingly coupled to the handrail;
- a first pivot connection for the handrail; and
- a second pivot connection for the support arm, which includes a mount with "tabs" and a "lateral member" that spans between them to "provide lateral bracing to the support arm."
- Independent Claim 10 recites a handle for an RV comprising:
- a handrail and a support arm that pivot and slide relative to each other;
- a "sliding member" to which the support arm is pivotably coupled; and
- a "track and pin configuration" that couples the sliding member to the handrail, comprising "opposing tracks defined by ribs" and "pins" that slide within the tracks.
III. The Accused Instrumentality
Product Identification
- The Stromberg Carlson Lend-A-Hand Banister RV Handrail ("Stromberg Product") (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the Stromberg Product is a handle for an RV that features a handrail and a support arm, which pivot from a storage position to a use position (Compl. ¶15). The complaint includes a photograph of the accused product with its primary components labeled. (Compl. p. 4). A key alleged function is that as the handrail pivots, the end of the support arm slides along the handrail (Compl. ¶15). The complaint further alleges the product includes a "sliding member" that moves within an inner channel of the handrail, guided by a track-and-pin system (Compl. ¶¶17-19).
- The complaint alleges the Stromberg Product "directly competes" with the Plaintiff's own "Safe-T-Rail product" and has resulted in lost sales (Compl. ¶14).
IV. Analysis of Infringement Allegations
’416 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a handrail having a proximal end and an opposite distal end | The Stromberg Product is alleged to have a handrail with proximal and distal ends. | ¶15 | col. 10:36-37 |
| a support arm having a first end and an opposite second end slidingly coupled relative to the handrail | The product allegedly has a support arm that is slidingly coupled to the handrail. | ¶15 | col. 10:38-39 |
| a first pivot connection to pivotably couple the proximal end of the handrail to structure of a recreational vehicle | The product allegedly has a "first pivot connection" for coupling the handrail to an RV. A labeled photograph depicts this component. | ¶15, p. 4 | col. 10:40-42 |
| a second pivot connection to pivotably couple the first end of the support arm...the second pivot connection comprising a mount having tabs...and a lateral member spanning between the tabs...to provide lateral bracing to the support arm... | The complaint alleges the product's second pivot connection has a mount with tabs and a "lateral member" that provides lateral bracing. A detailed photograph is provided to show this structure. | ¶16, p. 5 | col. 10:43-56 |
| such that the handrail is configured to be pivoted from a storage position...to a use position...causing the second end of the support arm to slide towards the distal end of the handrail | The complaint alleges the product's handrail pivots between storage and use positions, causing the support arm to slide. | ¶16 | col. 10:56-61 |
’416 Patent Infringement Allegations (Claim 10)
| Claim Element (from Independent Claim 10) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a handrail having a proximal end configured to be pivotably coupled...and an opposite distal end | The accused product is alleged to have a pivotable handrail. | ¶15 | col. 10:27-29 |
| a support arm having a first end...and an opposite second end slidingly coupled relative to the handrail, such that the handrail is configured to be pivoted...causing the second end of the support arm to slide... | The product is alleged to have a support arm that slides along the handrail when it is pivoted. | ¶15 | col. 10:30-36 |
| a sliding member coupled to the handrail to slide therealong...wherein the support arm is pivotably coupled to the sliding member | The complaint alleges the product has a "sliding member" inside the handrail to which the support arm is pivotably coupled. Photographs illustrate this component. | ¶17, p. 5-6 | col. 10:37-41 |
| wherein the handrail includes opposing sidewalls; and the handrail and sliding member are coupled together with a track and pin configuration...comprising opposing tracks defined by ribs...and pins...received within the tracks to slide along therein... | The complaint alleges the handrail has opposing sidewalls and a track-and-pin system with inwardly extending ribs and pins on the sliding member. A cross-section photograph shows these alleged features. | ¶18-19, p. 6-7 | col. 10:42-53 |
Identified Points of Contention
- Scope Questions: A central question for Claim 1 may be whether the accused product's second pivot connection, depicted as what appears to be a single molded component (Compl. p. 5), meets the limitation of a "lateral member spanning between the tabs." The defense may argue this language requires a separate bar-like component, as illustrated in an embodiment of the patent ('416 Patent, FIG. 4, item 88).
- Technical Questions: For Claim 10, while the complaint provides detailed photographs of the accused product's internal mechanism (Compl. p. 6-7), the infringement analysis will depend on whether the specific geometry and interaction of the accused "ribs," "lips," and "pins" perform the functions in the same way as the claimed "track and pin configuration."
V. Key Claim Terms for Construction
The Term: "lateral member" (from Claim 1)
- Context and Importance: This term is critical as it defines a key structural element of the second pivot connection, which is recited as providing "lateral bracing." The infringement finding for Claim 1 depends on whether the accused product's structure is properly characterized as having this "lateral member."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the functional benefit of the structure as adding "lateral bracing to the support arm" and reducing "side-to-side swaying of the handle" ('416 Patent, col. 6:19-22). A party could argue that any integral structure that connects the tabs and provides this function should be considered a "lateral member."
- Evidence for a Narrower Interpretation: The specification describes an embodiment where this element is a "bar 88 that extends laterally... between the tabs 86" ('416 Patent, col. 6:15-18). A party may argue this implies a distinct, bar-shaped component, potentially limiting the scope to exclude integrated or differently shaped connecting structures.
The Term: "track and pin configuration" (from Claim 10)
- Context and Importance: This term defines the entire sliding mechanism between the handrail and the sliding member. Practitioners may focus on this term because its construction will determine whether the accused product's specific internal guide system falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent Summary describes the coupling more generally, stating the "sliding member and handrail can frictionally engage one another" or be coupled with "tongue-and-groove or other interlocking components" ('416 Patent, col. 2:54-55; col. 4:50-51). This could support a broader reading covering various interlocking guide mechanisms.
- Evidence for a Narrower Interpretation: Claim 10 itself is more specific, defining the configuration as comprising "opposing tracks defined by ribs extending inwardly from an interior surface of each of the sidewalls" and "pins" that are received within those tracks ('416 Patent, col. 10:47-53). This language, along with figures like FIG. 3 and FIG. 5, could be used to argue for a narrow construction limited to this specific structural arrangement.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b) (Compl. ¶50). The factual basis is the allegation that Stromberg provides its customers with instructional materials, including videos and manuals, that demonstrate and instruct them on how to install and use the accused product in an infringing manner (Compl. ¶¶22, 51).
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge of the ’416 Patent. The specific facts alleged are a meeting between the parties on August 13, 2024, and Plaintiff’s provision of a claim chart to Defendant on October 31, 2024, after which Defendant allegedly continued its infringing activities (Compl. ¶¶12, 20-21, 55).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural correspondence: Does the accused product's second pivot mount, which the complaint depicts as an integrated structure, meet the specific claim limitation of a "lateral member spanning between the tabs," or can that term be limited by the patent's embodiments to a distinct, bar-like component?
- A key evidentiary question will be one of technical specificity: While the complaint provides visual evidence of a track-and-pin mechanism in the accused product, the dispute may turn on whether the specific form and interaction of the accused product's internal guides, ribs, and pins are the same as or equivalent to the "track and pin configuration" as defined in Claim 10 and described in the patent specification.