DCT

5:26-cv-00005

Heico Fasteners Inc v. Reaction Washer Co LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:26-cv-00005, W.D.N.C., 01/09/2026
  • Venue Allegations: Plaintiff HEICO alleges venue is proper in the Western District of North Carolina because it is headquartered there and Defendants purposefully directed business activities and threats of litigation into the district.
  • Core Dispute: Plaintiff seeks a declaratory judgment that its HEICO-LOCK® Reaction Washers do not infringe a patent owned by Defendants related to multifunction reaction washers.
  • Technical Context: The technology concerns reaction washers, which are specialized mechanical components used with power torque wrenches to tighten or loosen large nuts and bolts in industrial applications by preventing the washer from slipping.
  • Key Procedural History: The complaint details over a year of pre-suit correspondence initiated by Defendants, who allegedly accused Plaintiff of patent infringement and trade secret misappropriation, and threatened litigation if Plaintiff did not cease and desist from selling its competing products.

Case Timeline

Date Event
2014-01-01 Approximate start of discussions between HEICO and RWC regarding technology (earliest date mentioned)
2015-11-04 Earliest Priority Date for U.S. Patent No. 10,107,325
2018-10-23 Issue Date for U.S. Patent No. 10,107,325
2023-01-01 Approximate date ’325 Patent was assigned to PRIMESOURCE CONSULTING, LLC (year only provided)
2024-10-21 RWC sends letter to HEICO alleging infringement of the ’325 Patent
2024-11-26 HEICO sends letter to RWC denying infringement
2025-01-31 RWC sends letter to HEICO alleging trade secret misappropriation
2025-03-07 HEICO sends letter to RWC disputing all claims
2025-10-16 RWC sends letter to HEICO alleging breach of an NDA and demanding cessation of activities
2025-11-05 HEICO sends letter to RWC disputing NDA allegations
2025-11-11 RWC sends email to HEICO indicating openness to dialogue
2025-12-09 Telephonic meeting held between HEICO and RWC representatives
2025-12-22 RWC sends letter to HEICO accusing it of bad faith
2026-01-09 Complaint for Declaratory Relief filed

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

U.S. Patent No. 10,107,325 - *"Multifunction reaction washer and stack accessed by slim reaction socket"*

  • Patent Identification: U.S. Patent No. 10,107,325, “Multifunction reaction washer and stack accessed by slim reaction socket,” issued October 23, 2018.

The Invention Explained

  • Problem Addressed: The patent’s background section describes several problems with prior art reaction washers. These include a tendency for the washer to slip on the resting surface during initial power-assisted tightening, the risk of incorrect upside-down assembly which renders the washer inoperative, and the need for a large clearance area for the reaction socket, which can interfere with the workspace around the bolt. (’325 Patent, col. 2:30-56).
  • The Patented Solution: The invention proposes a reaction washer with unique structural features designed to solve these problems. It includes "tool access castles" that extend away from the washer's top face, ensuring that a reaction socket can only engage from one side, thus preventing incorrect assembly. (’325 Patent, col. 3:20-27). These castles are also designed to be engaged by a "slim reaction socket" that does not exceed the washer's outer diameter. (’325 Patent, col. 3:23-27). A "lock-on groove" is provided to allow the socket to securely interlock with the washer, preventing it from slipping off during operation. (’325 Patent, col. 3:27-34).
  • Technical Importance: This design aims to improve the reliability and safety of high-torque bolting operations by ensuring correct orientation and a secure, low-profile tool connection. (’325 Patent, col. 2:36-42).

Key Claims at a Glance

  • The complaint does not specify which claims were asserted by Defendants, but Claim 1 is the broadest independent claim.
  • Independent Claim 1 Elements:
    • A reaction washer comprising:
    • a) a washer axis;
    • b) a top face;
    • c) a number of tool access castles that are circumferentially arrayed with respect to said washer axis and that are extending away from said top face and within and up to an outer washer diameter of said reaction washer;
    • d) a lock-on groove that is circumferentially at least partially undercutting at least one of said access castles and that is encompassing said reaction washer; and
    • e) a bottom face that is radially extending up to the said washer outer surface.
  • The complaint does not mention any assertion of dependent claims.

III. The Accused Instrumentality

Product Identification

The HEICO-LOCK® Reaction Washers (Compl. ¶33).

Functionality and Market Context

The complaint identifies these products as "reaction washers" that are at the "heart of this dispute." (Compl. ¶33). It alleges that Defendants have accused these products of being "competing reaction washer technology that mirrors RWC’s designs." (Compl. ¶35a). The complaint does not provide technical details of the HEICO-LOCK® washers' operation, but HEICO's response letters, as summarized in the complaint, differentiate its "wave spline teeth" and "wedge lock structures" from the patented features. (Compl. ¶35b).

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not contain a claim chart or detailed infringement allegations by the Plaintiff. Instead, it summarizes the allegations made by Defendants in pre-suit correspondence. The complaint states that RWC alleged HEICO's reaction washer infringes the ’325 Patent, either directly or under the doctrine of equivalents. (Compl. ¶35a). A letter from HEICO, described in the complaint, appears to address specific features, differentiating its own "wave spline teeth" from the claimed "tool access castles" and its "wedge lock structures" from the claimed "lock-on groove." (Compl. ¶35b). This suggests that Defendants' infringement theory centers on these specific patented features.

No probative visual evidence provided in complaint.

  • Identified Points of Contention: The dispute, as framed by the complaint, raises several key questions for the court.
    • Scope Questions: Do HEICO's "wave spline teeth" meet the definition of "tool access castles" as recited in Claim 1? Does HEICO's "wedge lock structure" function in a way that falls within the scope of the claimed "lock-on groove that is circumferentially at least partially undercutting"? The resolution will depend on how these terms are construed.
    • Technical Questions: What is the precise mechanical structure and operation of the HEICO-LOCK® Reaction Washer? The complaint lacks sufficient detail to conduct a technical comparison, but this factual evidence will be central to determining whether its components perform the same function, in the same way, to achieve the same result as the claimed elements, particularly for any doctrine of equivalents analysis.

V. Key Claim Terms for Construction

  • The Term: "tool access castles"

  • Context and Importance: This non-standard term appears to be a neologism coined by the inventor and is a central element of the asserted independent claim. The infringement dispute may hinge on whether the structures on HEICO’s accused washer are encompassed by the definition of "castles." Practitioners may focus on this term because its unique nature makes it highly susceptible to disputes over scope.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes them simply as features that "are extending away from the top face" for engagement by a socket, which could potentially cover a range of protruding structures. (’325 Patent, col. 7:10-14).
    • Evidence for a Narrower Interpretation: The figures (e.g., Fig. 1A, element 133) consistently depict the "castles" as distinct, block-like battlements on a castle wall. The term itself, along with the drawings, may support a narrower construction limited to structures with a specific shape and separation, potentially excluding continuous structures like "wave spline teeth."

  • The Term: "a lock-on groove that is circumferentially at least partially undercutting at least one of said access castles"

  • Context and Importance: This limitation defines the mechanism for securing the reaction socket to the washer. The question of whether HEICO's "wedge lock structures" meet this definition is critical. A key dispute may arise over the meaning of "undercutting" in this mechanical context.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The functional description states the groove is for the socket "to axially interlock prior to torque transfer," which could be argued to cover any feature that prevents axial separation, regardless of its specific shape. (’325 Patent, col. 3:29-30).
    • Evidence for a Narrower Interpretation: The term "undercutting" implies a specific geometry where a recess is formed behind an outer surface. The patent states the groove allows "circumferential hooking noses" of a socket to engage. (’325 Patent, col. 10:10-14). This could support a narrower definition that requires a specific recessed shape designed to catch a corresponding hook, potentially distinguishing it from a "wedge lock" mechanism that may rely on friction or angled surfaces.

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

The resolution of this declaratory judgment action will likely depend on the answers to two primary questions:

  1. A core issue will be one of definitional scope: How will the court construe the unique, inventor-coined term "tool access castles"? The outcome will likely turn on whether this term is interpreted broadly to mean any raised structure for tool engagement, or narrowly to mean the specific block-like structures depicted in the patent's figures.

  2. A secondary issue will be one of structural and functional comparison: Does HEICO’s "wedge lock structure" create "a lock-on groove that is circumferentially at least partially undercutting" an access feature as required by the claim? This presents a technical question of whether two potentially different mechanical locking mechanisms are structurally and functionally equivalent under patent law.