DCT

4:01-cv-01090

Shinn Fu Corp v. Larin Corp

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:01-cv-01090, W.D. Mo., 05/20/2002
  • Venue Allegations: Venue is alleged to be proper based on Defendant doing business in the district, committing alleged acts of infringement in the state, and operating a website through which Missouri residents can obtain information on accused products.
  • Core Dispute: Plaintiffs allege that Defendant’s receiving bag for a car jack infringes a patent related to a specialized storage and carrying bag for such tools.
  • Technical Context: The technology concerns durable, purpose-built carrying cases for automotive jacks, designed to improve upon the conventional paper or cardboard packaging they are often sold in.
  • Key Procedural History: The provided document is a Second Amended Complaint, indicating that the pleadings have been modified at least twice since the case was originally filed. The complaint also alleges that Plaintiffs discovered the alleged infringement in or around September 2001.

Case Timeline

Date Event
1999-11-19 U.S. Patent No. 6,199,693 Priority Date (Filing)
2001-03-13 U.S. Patent No. 6,199,693 Issued
2001-09-01 Plaintiffs' Discovery of Alleged Infringement (approx.)
2002-05-20 Second Amended Complaint Filed

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

  • Patent Identification: U.S. Patent No. 6,199,693, “Receiving Bag of Jack,” issued March 13, 2001.

The Invention Explained

  • Problem Addressed: The patent addresses the deficiencies of conventional paper box packaging for car jacks, which are described as being non-durable, susceptible to water damage, and difficult to handle once the jack is removed (’693 Patent, col. 1:15-32).
  • The Patented Solution: The invention is a durable receiving bag, made of plastic or cloth, designed specifically to store a car jack. The core of the solution is an integrated, rectangular bottom plate within the bag that includes features to secure the jack. These features include transversally long fixing plates to abut the jack's wheels and fixing means to secure the jack's handle, preventing the components from moving during transport (’693 Patent, Abstract; col. 2:13-30; FIG. 1, 6).
  • Technical Importance: The invention provides a more robust and convenient method for storing and transporting a car jack compared to disposable paper packaging, thereby prolonging the life of the storage container itself (’693 Patent, col. 1:5-8).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted but makes a general allegation of infringement of the ’693 Patent (Compl. ¶13). Independent claim 1 is representative.
  • The essential elements of independent claim 1 include:
    • A receiving bag for holding a car jack, the receiving bag comprising a bag made of one of plastic and cloth;
    • the bag having front and rear ends, a top, a bottom and two sides extending between the front and rear ends of the bag;
    • a zipper arranged in the top of the bag...;
    • handle portions respectively arranged on the sides of the bag,
    • and a bottom plate arranged on the bottom of the bag, the bottom plate having a rectangular shape and means for abutting and preventing movement of a car jack held in the bag.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as "products embodying the patented invention" which are sold by Defendant Larin Corporation (Compl. ¶13). Specific product names are not provided.

Functionality and Market Context

  • The complaint alleges that the Defendant is "making, using, and/or selling" infringing products but does not describe their specific technical functionality (Compl. ¶13). The complaint references photographs of the accused product in an exhibit that was not included with the provided filing (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint, filed under pre-Twombly/Iqbal pleading standards, makes a general allegation of infringement without providing an element-by-element mapping of the accused product to the patent claims (Compl. ¶13). The complaint does not contain a claim chart or a detailed narrative infringement theory sufficient for a tabular analysis.

  • Identified Points of Contention:
    • Scope Questions: A central dispute may involve the "means for abutting and preventing movement" limitation in claim 1. This term is drafted in means-plus-function format, and its scope will be limited to the corresponding structures disclosed in the specification—namely the "long fixing plate 121" and L-shaped plates 121'—and their structural equivalents (’693 Patent, col. 2:20-22; col. 3:8-18; FIG. 8, 9). The infringement analysis will depend on whether the accused product contains structures that are the same as or equivalent to these disclosed plates.
    • Technical Questions: The complaint does not provide sufficient detail for analysis of how the accused product technically operates. A key evidentiary question will be whether discovery reveals that Defendant's product contains a "bottom plate" with dedicated structures that "abut" and "prevent movement" of a jack in the manner described by the patent, or if it uses a more generic, unstructured bag design.

V. Key Claim Terms for Construction

  • The Term: "means for abutting and preventing movement of a car jack held in the bag" (Claim 1).
  • Context and Importance: This term is the functional heart of claim 1 and is written in means-plus-function format under 35 U.S.C. § 112, ¶ 6 (pre-AIA). Its construction will define the specific structures required to infringe. Practitioners may focus on this term because its scope is not determined by its plain meaning but is strictly limited to the structures disclosed in the specification for performing the recited function, and their equivalents.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party arguing for a broader scope might contend that the term "equivalents" should encompass any structure within the accused bag that serves to block the movement of a jack, even if it is not a dedicated plate.
    • Evidence for a Narrower Interpretation: The specification repeatedly and specifically discloses "a long fixing plate 121" and "L shape fixing plates 121'" as the structures performing this function (’693 Patent, col. 2:20-22, col. 3:14-18; FIG. 1, 8, 9). A party arguing for a narrower scope will assert that the claim is limited to these exact structures and their equivalents, which must perform the function in substantially the same way to achieve substantially the same result.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain specific allegations of either induced or contributory infringement. The claims are focused on direct infringement through "making, using, and/or selling" (Compl. ¶13).
  • Willful Infringement: The complaint alleges that "Defendant has knowingly and willfully infringed the '693 Patent in disregard of Plaintiffs' rights" (Compl. ¶15). The complaint does not, however, plead specific facts supporting pre-suit knowledge, such as prior notice letters or previous litigation. The claim for willfulness may therefore depend on Defendant's conduct after the complaint was filed.

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

  • A core issue will be one of claim scope and structure: Is the "means for abutting and preventing movement" limitation met by the accused product? This will require the court to first construe the scope of this means-plus-function term by identifying the corresponding structures in the '693 patent's specification, and then determine whether the accused product contains those structures or their legal equivalents.
  • A key evidentiary question will be one of factual correspondence: As the complaint lacks technical detail, the case will depend entirely on evidence developed during discovery. The central factual dispute will be whether Larin Corporation’s product incorporates a distinct internal "bottom plate" with specific anti-movement structures, as claimed in the patent, or if it constitutes a simple bag whose functionality does not align with the specific structural limitations of the asserted claims.