DCT
5:25-cv-00007
Yukon Packaging LLC v. Jones Sustainable Packaging LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Yukon Packaging, LLC (North Carolina)
- Defendant: Jones Sustainable Packaging, LLC (Delaware)
- Plaintiff’s Counsel: Shumaker, Loop, & Kendrick, LLP
- Case Identification: 5:25-cv-7, W.D.N.C., 09/26/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has committed acts of infringement in the district and maintains a regular and established place of business in Charlotte, North Carolina.
- Core Dispute: Plaintiff alleges that Defendant’s 3-piece insulated containers infringe two utility patents, one design patent, and another utility patent related to insulated shipping containers and their methods of manufacture.
- Technical Context: The technology pertains to insulated packaging for shipping temperature-sensitive goods, a key component of the cold chain logistics sector for food, medical, and pharmaceutical products.
- Key Procedural History: The complaint alleges that the validity of the patents-in-suit has never been challenged. No other significant procedural events are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2020-12-30 | Earliest Priority Date for ’264, ’265, ’562, and ’014 Patents |
| 2025-01-14 | U.S. Patent No. 12,195,264 Issues |
| 2025-01-14 | U.S. Patent No. 12,195,265 Issues |
| 2025-01-14 | U.S. Design Patent No. D1,057,562 Issues |
| 2025-09-23 | U.S. Patent No. 12,421,014 Issues |
| 2025-09-26 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,195,264 - “Insulated Container”
The Invention Explained
- Problem Addressed: The complaint identifies a need in the prior art for an insulated shipping container that is inexpensive, effective, mass-producible, can be specially tailored to the item being shipped, and is made from recycled industrial waste (Compl. ¶16).
- The Patented Solution: The invention is an insulated shipping container comprising a standard rigid outer box and a three-piece insulation system (Compl. ¶18). This system consists of a first insulated pad for the container bottom, a second identical pad for the top, and a third, longer pad that is folded to form the four interior side walls, resting on the bottom pad (’265 Patent, Fig. 2-7). The insulation pads are made from recycled materials, such as "post-industrial, pre-consumer natural fiber, and synthetic fiber" (Compl. ¶18).
- Technical Importance: The patent describes a design that aims to provide a cost-effective and environmentally sustainable packaging solution for the cold chain industry by using a specific three-piece configuration of recycled materials (Compl. ¶16).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶18).
- The essential elements of Claim 1 include:
- A rigid container with specific symmetrical dimensions.
- A first insulated pad with a predetermined thickness and density, made from a quantity of recycled post-industrial, pre-consumer natural and synthetic fiber.
- A second insulated pad identical to the first.
- A third insulated pad with a length longer than the width of the first pad but shorter than its perimeter.
- A specific positional arrangement: the first pad on the bottom, the third pad lining the sides perpendicular to the first, and the second pad positioned atop the third.
U.S. Patent No. 12,195,265 - “Method of Forming an Insulated Container”
The Invention Explained
- Problem Addressed: The complaint describes a need for a manufacturing method that is easy, can be adapted for made-to-order containers, recycles industrial waste, and produces a recyclable or biodegradable final product (Compl. ¶26).
- The Patented Solution: The patent claims a method of manufacturing the three-piece insulated container. The process involves using a machine (such as an airlay machine) to process waste fiber into a continuous sheet, using a blade to cut that sheet into the three specifically dimensioned pads, and then placing the pads into a rigid container in a prescribed order: bottom pad first, then the folded side-wall pad, and finally the top pad (’265 Patent, col. 9:11-64; Compl. ¶28). The patent specification notes an unexpected efficiency gain from this method, as a continuous sheet can be cut with a single knife, reducing manufacturing costs (’265 Patent, col. 7:1-8).
- Technical Importance: This method purports to offer a streamlined and cost-effective process for producing sustainable insulated packaging at scale (Compl. ¶26).
Key Claims at a Glance
- The complaint asserts independent Claim 1 (Compl. ¶28).
- The essential steps of Claim 1 include:
- Providing a rigid container and a quantity of post-industrial, pre-consumer waste fiber.
- Using a processing machine (e.g., carding, airlay) to form a continuous sheet of non-woven material from the fiber.
- Cutting the sheet with a blade to form a first, second, and third insulated pad with specific relative dimensions.
- Placing the first pad on the container bottom.
- Placing and folding the third pad to line the container walls.
- Placing the second pad on top, supported by the third pad.
- The resulting pads are biodegradable in an anaerobic environment or recyclable.
U.S. Design Patent No. D1,057,562 - “Insulation for a Rigid Container”
Technology Synopsis
This patent claims the ornamental design for the three-piece insulation assembly itself when laid flat, prior to being placed in a container. The design consists of a central rectangular pad with two identical square pads positioned at opposite ends, forming a distinct T-shape.
Asserted Claims
The single claim for "the ornamental design for insulation for a rigid container as shown" (Compl. ¶38).
Accused Features
The complaint alleges that the Accused Product infringes the design patent, implying that the defendant's set of three insulation pads embodies the claimed ornamental design (Compl. ¶97). The complaint provides an image from the patent showing the claimed T-shaped configuration of the three pads (Compl. ¶38).
U.S. Patent No. 12,421,014 - “INSULATED CONTAINER AND METHOD OD FORMING AND LOADING AN INSULATED CONTAINER”
Technology Synopsis
This patent is directed to an insulated container comprising three pads made from recycled materials, similar to the ’264 Patent. The complaint states it addresses needs for safe transport of temperature-sensitive items, consistent density, temperature maintenance, and efficient manufacturing and assembly while minimizing environmental impact (Compl. ¶43).
Asserted Claims
Independent Claim 1 (Compl. ¶45).
Accused Features
The complaint alleges that Defendant's 3-piece insulated containers infringe one or more claims of this patent (Compl. ¶109).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant's "3-piece insulated containers used to ship temperature sensitive items," which are marketed and sold under the "EcoFiber Packaging" brand (Compl. ¶1, ¶55).
Functionality and Market Context
- The complaint describes the Accused Product, based on Defendant's marketing materials, as providing "Sustainable Cold Chain Solutions" for the food and pharmaceutical industries (Compl. ¶56). The product is presented as a "turnkey sustainable packaging" solution designed to keep goods fresh with "minimal environmental impact" and is produced via a "best-in-class manufacturing process" (Compl. ¶55, ¶56).
IV. Analysis of Infringement Allegations
The complaint references, but does not attach, claim charts detailing its infringement theories (Compl. ¶57). The following tables summarize the apparent infringement allegations based on the complaint's narrative and the asserted claims.
12195264 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a rigid container having a bottom, front, rear, left, and right sides... | The outer cardboard box component of the Accused Product. | ¶1, ¶18 | col. 5:27-33 |
| a first insulated pad having a predetermined thickness and density... | The bottom insulation pad of the Defendant's 3-piece system. | ¶1, ¶18 | col. 5:34-37 |
| a second insulated pad identical to the first insulated pad... | The top insulation pad of the Defendant's 3-piece system. | ¶1, ¶18 | col. 5:37-38 |
| a third insulated pad having... a length that is longer than the width of the first insulated pad but is shorter than the perimeter... | The wrap-around side-wall insulation pad of the Defendant's 3-piece system. | ¶1, ¶18 | col. 5:38-41 |
| wherein the first insulated pad is positioned inside the rigid container in contact with the bottom... the third insulated pad is positioned perpendicular... and the second insulated pad is positioned atop the third insulated pad... | The alleged assembly of the Defendant's 3-piece system within its outer box. | ¶1, ¶18 | col. 2:35-41 |
| wherein the first insulated pad comprises a quantity of recycled post-industrial, pre-consumer natural fiber, and synthetic fiber. | The material composition of the "EcoFiber" insulation, which is marketed as sustainable. | ¶15, ¶56 | col. 1:61-64 |
12195265 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| providing a quantity of post-industrial, pre-consumer cotton or synthetic waste fiber... | Defendant's alleged use of recycled fiber as a raw material for its "EcoFiber" product. | ¶28, ¶56 | col. 1:61-64 |
| providing a processing machine... to process... fiber into a continuous non-woven sheet... | Defendant's "best-in-class manufacturing process" is alleged to use machinery to form insulation sheets from raw fiber. | ¶28, ¶56, ¶82 | col. 7:29-37 |
| cutting the continuous sheet... to form a first insulated pad, a second insulated pad, and a third insulated pad... | Defendant's alleged manufacturing step of cutting the insulation sheet into the three distinct pads that comprise the Accused Product. | ¶28, ¶82 | col. 7:37-43 |
| placing the first insulated pad... placing the third insulated pad... placing the second insulated pad... | Defendant's alleged process of assembling the Accused Product by inserting the three pads into the rigid container. | ¶28, ¶82 | col. 7:44-67 |
| wherein each one of the respective... pads are biodegradable... or recyclable. | Defendant's marketing of its product as "sustainable" with "minimal environmental impact." | ¶28, ¶56 | col. 2:56-59 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis for the product claims ('264 and '014 Patents) may turn on whether the accused containers meet the precise dimensional and positional limitations recited in the claims, such as the pads being "identical" and the third pad's length being within the claimed ratio relative to the first pad's perimeter.
- Technical Questions: For the method claims ('265 Patent), a central evidentiary question is whether Defendant's manufacturing process practices the specific sequence of steps recited, including the use of a "continuous non-woven sheet." For all utility patents, a factual dispute may arise over whether the material composition of Defendant's "EcoFiber" product meets the claim limitation of "recycled post-industrial, pre-consumer" fiber.
V. Key Claim Terms for Construction
- The Term: "recycled post-industrial, pre-consumer natural fiber, and synthetic fiber" (’264 Patent, Claim 1)
- Context and Importance: The definition of this term is fundamental to the scope of the utility patents. The infringement case rests on the allegation that the defendant's "EcoFiber" material falls within this definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests a wide range of sources, including waste from "raw cotton processing, cotton yarn manufacturing, cotton fabric manufacturing, synthetic fabric manufacturing, [and] plastic recycling" (’265 Patent, col. 2:8-12).
- Evidence for a Narrower Interpretation: The specification states these materials "may or may not have been converted into finished products (such as clothing or other fabrics)" (’265 Patent, col. 2:4-6). A party could argue this language serves to distinguish the claimed material from post-consumer textile waste, potentially narrowing the scope.
- The Term: "identical" (’264 Patent, Claim 1; ’265 Patent, Claim 1)
- Context and Importance: This term defines the required relationship between the top and bottom insulation pads. Practitioners may focus on this term because a defendant could argue its pads are merely similar, not strictly "identical," in an attempt to avoid literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that in the context of manufacturing, "identical" should be construed to mean identical in all material respects (e.g., length, width, thickness, and composition) while allowing for minor, commercially acceptable manufacturing tolerances. The specification states the first and second pads "are identical in length, width, and thickness" (’265 Patent, col. 5:46-47), focusing the identity on these key dimensions.
- Evidence for a Narrower Interpretation: A party could advocate for a literal, dictionary definition requiring the pads to be indistinguishable. The patent's repeated emphasis on specific dimensions and relationships could be cited to support a reading that requires strict geometric conformity.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for the '264 and '562 patents on the basis that Defendant instructs "downstream customers and end-users to practice the" patents by using the Accused Product as intended (Compl. ¶76, ¶103). For the '265 method patent, inducement is alleged based on inducing customers to use or sell the Accused Product, which is an article made by the patented method (Compl. ¶90).
- Willful Infringement: Willfulness is alleged for all four patents-in-suit. The allegations are based on purported pre-suit knowledge, asserting that Defendant was aware of the patents "since the day each of them issued" (Compl. ¶59). The complaint further alleges that Defendant's predecessor company was "closely following all patent filings related to Yukon Packaging," suggesting knowledge was acquired prior to the patents' issuance (Compl. ¶60).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of material composition: does the defendant's "EcoFiber" product consist of materials that fall within the scope of the patents' definition of "recycled post-industrial, pre-consumer" fiber, and what level of proof will be required to establish the material's origin and properties?
- A key question of claim construction will be the degree of precision required by claim terms describing the container's geometry, such as "identical" pads and the specific length-to-perimeter ratio of the third pad. The outcome of this construction may determine whether minor variations in the accused product are sufficient to avoid literal infringement.
- An evidentiary challenge for the plaintiff will be to prove the specific steps of Defendant's internal manufacturing method to establish infringement of the '265 patent. This question will likely depend on the evidence obtained through discovery concerning Defendant's proprietary processes.