DCT
4:25-cv-01538
Caps Inc v. Aldi Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Caps. Inc. (Missouri)
- Defendant: Aldi, Inc. (Illinois)
- Plaintiff’s Counsel: SANDBERG PHOENIX & von GONTARD, P.C.
- Case Identification: 4:25-cv-01538, E.D. Mo., 10/16/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant operates multiple grocery stores and has regular and established places of business within the Eastern District of Missouri, where the alleged acts of infringement occurred.
- Core Dispute: Plaintiff alleges that Defendant’s flip-top closures for spice containers infringe two patents related to structural features designed to prevent deformation during automated capping.
- Technical Context: The technology addresses the need for robust, injection-molded plastic closures in high-speed consumer product packaging lines, where over-torquing can compromise the container's seal.
- Key Procedural History: Plaintiff alleges it provided Defendant with notice of infringement via a letter sent on December 3, 2024. The complaint further alleges that in February 2025, Defendant admitted infringement by directing its supplier to switch to an "alternate cap," but continued selling the accused products.
Case Timeline
| Date | Event |
|---|---|
| 2005-04-19 | Priority Date for ’267 and ’457 Patents |
| 2010-10-26 | U.S. Patent No. 7,819,267 Issues |
| 2012-10-30 | U.S. Patent No. 8,297,457 Issues |
| 2024-12-03 | Plaintiff sends notice letter to Defendant |
| 2024-12-09 | Defendant receives notice letter |
| 2025-01-28 | Defendant acknowledges receipt of notice letter |
| 2025-02-14 | Defendant allegedly directs supplier to switch to a non-infringing cap |
| 2025-03-09 | Alleged infringing sale occurs post-notice |
| 2025-06-03 | Alleged infringing sale occurs post-notice |
| 2025-08-19 | Alleged infringing sale occurs post-notice |
| 2025-10-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,819,267 - "FLIP TOP CLOSURE FOR DISPENSING FLUENT PRODUCT" (Issued Oct. 26, 2010)
The Invention Explained
- Problem Addressed: The patent’s background section describes how conventional screw-on closures for containers can deform when subjected to the high torque of automated capping equipment on a production line. This deformation can cause the closure’s flip-open lid to unseat or open, leading to product rejection, jamming of equipment, and potential spillage or contamination during shipping and retail display (’267 Patent, col. 1:37-51).
- The Patented Solution: The invention introduces a pair of "stiffening shoulders" integrally molded into the closure on opposite sides of the lid's hinge (’267 Patent, col. 4:6-9). These shoulders are described as upward extensions of both the closure's top surface (end wall) and its side wall (skirt), creating a reinforced structure that resists deformation from capping torque and ensures the flip-open lid remains securely closed (’267 Patent, col. 4:22-30; Fig. 1).
- Technical Importance: This structural reinforcement provides a more robust closure suitable for high-speed automated packaging, aiming to reduce manufacturing defects and improve product integrity throughout the supply chain (’267 Patent, col. 1:42-54).
Key Claims at a Glance
- The complaint asserts independent claim 72 (Compl. ¶28).
- Claim 72 requires, in essence:
- A closure with a downwardly depending skirt for connecting to a container.
- An end wall with dispensing openings.
- A flip-open lid connected by a hinge to the skirt.
- A snap lock to retain the lid in a closed position.
- A pair of shoulders integrally formed with the end wall and skirt on opposite sides of the hinge.
- The shoulders must have a "substantial portion" formed as an upward extension of the skirt and an "insubstantial portion" above the end wall, with a top surface that is "substantially flush" with the lid when closed.
U.S. Patent No. 8,297,457 - "FLIP TOP CLOSURE FOR DISPENSING FLUENT PRODUCT" (Issued Oct. 30, 2012)
The Invention Explained
- Problem Addressed: As a continuation of the application that led to the ’267 Patent, the ’457 Patent addresses the same technical problem: deformation of flip-top closures caused by over-torquing during high-speed, automated capping operations (’457 Patent, col. 1:41-55).
- The Patented Solution: The solution is materially the same, employing integrally formed shoulders adjacent to the lid hinge to stiffen the closure structure. The claims define these shoulders with specific geometric and positional limitations relative to the lid and skirt, providing reinforcement against deformative forces (’457 Patent, col. 2:54-61; Abstract).
- Technical Importance: The invention provides an improved design for mass-produced closures, seeking to enhance reliability in automated packaging environments and maintain a secure seal for the end consumer (’457 Patent, col. 1:55-col. 2:4).
Key Claims at a Glance
- The complaint asserts independent claim 11 (Compl. ¶34).
- Claim 11 requires, in essence:
- A closure with a downwardly depending skirt.
- An end wall with an opening.
- A flip-open lid with linear side edges and a snap lock.
- A hinge integrally formed with the lid and the skirt.
- A pair of shoulders integrally formed with the end wall and skirt, positioned symmetrically on opposing sides of the hinge.
- The shoulders must have a thickness that makes the end wall "substantially greater" in that area, and the lid must be dimensioned to "substantially overlay" the area of the end wall free of the shoulders.
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are plastic, injection-molded, flip-top closures sold on containers of food products, including herbs and spices, at ALDI grocery stores (Compl. ¶¶ 1, 3). The complaint identifies the supplier of the products as Savory Seasoning (Compl. ¶14).
Functionality and Market Context
The closures function as dispensing caps for fluent products like spices (Compl. ¶1). The complaint alleges that millions of units of these infringing products have been sold to the public (Compl. ¶17, ¶23). A photograph provided as Exhibit 25 to the complaint illustrates the accused closure, detached from a container (Compl. p. 6). The core of the infringement allegation rests on the physical structure of these closures, which are alleged to embody the patented designs (Compl. ¶18).
IV. Analysis of Infringement Allegations
’267 Patent Infringement Allegations
| Claim Element (from Independent Claim 72) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a downwardly depending skirt 15 having an upper end and a bottom end and a periphery defining a perimeter of the closure 1 for sealable connection to the mouth 7 of said container 3 | The ALDI closure has a downwardly depending skirt for connection to a container mouth. | ¶28 | col. 3:14-15 |
| an end wall 19 having a top planar surface coupled to and extending diametrically across the upper end of said skirt 15...said end wall 19 having an area...defining one or more openings 21 therethrough for the dispensing of a product | The ALDI closure has an end wall with a top planar surface extending across the skirt, with one or more openings for dispensing product. | ¶28 | col. 3:26-29 |
| a flip-open lid 23 hingedly connected by a hinge 25 to a side of the skirt 15...for movement...between a closed position...and an open position | The ALDI closure has a flip-open lid connected by a hinge to the skirt, allowing movement between open and closed positions. | ¶28 | col. 3:47-49 |
| a snap lock 29 for retaining said lid 23 in its closed position, | A snap lock retains the lid in its closed position. | ¶28 | col. 3:55-56 |
| wherein said end wall 19 having shoulders 31a, 31b integrally formed with said end wall 19 and said skirt 15 proximate the upper end of said skirt 15 on opposite sides of said lid hinge 25, each shoulder 31a, 31b having a substantial portion formed as an upward extension of the skirt 15 and an insubstantial portion located above the end wall 19 free of the skirt 15...defining a top shoulder surface that is substantially flush with the top lid surface when the lid 23 is in the closed position... | The photograph shows the end wall of the ALDI closure has shoulders integrally formed with the end wall and skirt. The shoulders have a substantial portion formed as an upward extension of the skirt and an insubstantial portion located above the end wall. | ¶28 | col. 4:6-9 |
’457 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a downwardly depending skirt 15 for sealable connection to the mouth 7 of the container 3... | The ALDI closure has a downwardly depending skirt connectable to a container mouth. | ¶34 | col. 5:10-12 |
| an end wall 19 coupled at an upper edge of the skirt 15...the end wall 19 having...an opening 21 therethrough for the dispensing of a product... | The ALDI closure has an end wall at the upper edge of the skirt with an opening for dispensing product. | ¶34 | col. 5:21-24 |
| a flip-open lid 23 configured for moving over the end wall 19 between an open position...and a closed position...the lid 23 having a snap lock 29... | The ALDI closure has a flip-open lid that moves over the end wall between open and closed positions and has a snap lock. | ¶34 | col. 5:43-46 |
| a pair of shoulders 31a,31b integrally formed with the end wall 19 and the skirt 15...each shoulder 31a,31b being symmetrically positioned on opposing sides of the hinge 25...the shoulders 31a,31b having a top surface and having inner linear edges configured for receiving the side edges 39a, 39b of the lid 23...wherein a thickness of the end wall 19 containing the shoulders 31a,31b is substantially greater than a thickness of the end wall 19 free of the shoulders... | The photograph shows the ALDI closure has a pair of shoulders integrally formed with the end wall and skirt, positioned symmetrically on opposing sides of the hinge. The shoulders have top surfaces and inner linear edges configured for receiving the side edges of the lid. The thickness requirement is allegedly met. | ¶34 | col. 6:1-5 |
Identified Points of Contention
- Scope Questions: The dispute may turn on the construction of relative terms such as "substantial portion," "insubstantial portion," "substantially flush," and "substantially greater." A central question will be whether the specific geometry and dimensions of the accused closures fall within the scope of these claim limitations.
- Technical Questions: Does the accused closure's shoulder structure function as an "upward extension of the skirt" as claimed, or is it structurally distinct? The complaint relies on photographic evidence, raising the question of what a detailed physical inspection and comparison against the patent's figures and description would reveal about the precise construction of the accused part.
V. Key Claim Terms for Construction
The Term: "shoulders"
- Context and Importance: This term defines the core inventive feature that allegedly provides the non-obvious structural advantage. The entire infringement analysis depends on whether the accused product's raised structures adjacent to the hinge meet the detailed definition of the claimed "shoulders."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the term should encompass any integrally molded structure located on opposite sides of the hinge that serves the stated purpose of "stiffen[ing] and resist[ing] deformation of the closure 1" ('267 Patent, col. 4:23-24).
- Evidence for a Narrower Interpretation: The patents provide a highly detailed definition, requiring the shoulders to be formed as an "upward extension of the skirt" and have an "insubstantial portion located above the end wall free of the skirt" ('267 Patent, Claim 72). A party may argue the term is limited to the specific geometry shown in Figures 1-3, where the shoulder appears to be a continuation of the skirt's outer wall rising above the end wall.
The Term: "substantially flush"
- Context and Importance: This term is critical for infringement, as it defines the required final spatial relationship between the top of the shoulders and the top of the lid. If the accused product's lid is recessed or raised relative to the shoulders, it may not infringe. Practitioners may focus on this term because it introduces a degree of subjectivity.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue "substantially" allows for minor, commercially acceptable variations in height, and that the term's meaning is met if the surfaces are generally co-planar to create the intended flat-top appearance (’267 Patent, col. 4:33-40).
- Evidence for a Narrower Interpretation: The specification clarifies this by stating the surfaces are "substantially flush with one another (co-planar)" ('267 Patent, col. 4:37-38). A defendant could argue this requires a very close-to-perfect planar alignment, and any discernible step between the surfaces falls outside the claim scope.
VI. Other Allegations
- Indirect Infringement: The complaint includes boilerplate allegations of induced and contributory infringement (Compl. ¶¶ 26, 32). However, it does not plead specific facts to support the elements of either claim, such as alleging that Defendant's user manuals or advertising instruct users in a way that causes infringement (inducement) or that the accused closure is a material part of the invention with no substantial non-infringing use (contributory).
- Willful Infringement: The complaint alleges willful infringement based on Defendant's continued sales of the accused products after receiving actual notice of the patents-in-suit on December 9, 2024 (Compl. ¶¶ 12, 22, 29, 35). The allegation is further supported by the claim that Defendant effectively conceded infringement on February 14, 2025, by instructing its supplier to "switch immediately to the new cap" but continued selling existing inventory (Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "shoulders," as defined by a series of specific structural relationships to the skirt and end wall in the patent, be construed to read on the accused product's geometry? The outcome will likely depend on a detailed claim construction analysis of whether the accused product is merely a "stiffened cap" or if it embodies the patent's specific solution.
- A key evidentiary question will be one of factual correspondence: assuming a favorable claim construction, do the accused closures, upon physical inspection and measurement, satisfy the relative dimensional limitations of the claims, such as the top surfaces being "substantially flush" and the end wall being "substantially thicker" in the region of the shoulders?
- A central question for damages will be one of willfulness: does the allegation that Defendant directed its supplier to change designs after receiving notice constitute sufficient evidence of egregious conduct to support a finding of willful infringement and justify enhanced damages for subsequent sales?