DCT

1:25-cv-01275

AGF Mfg Inc v. Core & Main LP

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01275, D.N.J., 02/14/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendants having committed acts of patent infringement and having established places of business in the District of New Jersey.
  • Core Dispute: Plaintiff alleges that Defendants’ automatic air vent valve for fire sprinkler systems infringes a patent related to an integrated purge and vent valve assembly, and further alleges trade dress infringement based on the product’s design.
  • Technical Context: The technology addresses the problem of oxygen corrosion in wet pipe fire sprinkler systems by providing a device to automatically vent trapped air when the system is filled with fluid.
  • Key Procedural History: Plaintiff alleges sending pre-suit notice letters to Defendants in July 2024, which included a copy of the patent-in-suit and an offer to discuss a license; Plaintiff alleges Defendants did not provide a substantive response.

Case Timeline

Date Event
2017-02-08 ’344 Patent Priority Date
2017 Plaintiff's Model 7900 AAV entered the market
2019-08-27 ’344 Patent Issue Date
2024-07-03 Plaintiff sent first pre-suit notice letter to Defendants
2024-07-16 Plaintiff sent second pre-suit notice letter to Defendants
2025-01 Accused Product (LVAV-2) first sold to customers
2025-02-14 Complaint Filing Date

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

U.S. Patent No. 10,391,344 - "Purge and Vent Valve Assembly," issued August 27, 2019

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the problem of oxygen corrosion in fluid-based fire suppression sprinkling systems, which is caused by air trapped in pipes when the system is installed or refilled after maintenance ( ’344 Patent, col. 1:19-27). Existing solutions were often formed from a plurality of individual components, increasing the size, cost, and complexity of the valve assembly (’344 Patent, col. 1:46-52).
  • The Patented Solution: The invention is a compact valve assembly designed to vent trapped air from a wet pipe system. As described in the specification, the solution integrates multiple components—including an inlet valve, a strainer, an angled port for an air release valve, and an outlet/purge valve—into a single, unitary body or housing (’344 Patent, col. 5:32-40; FIG. 1). This integrated design aims to reduce the product's overall size and cost compared to prior art assemblies built from separate parts (’344 Patent, col. 5:47-52).
  • Technical Importance: The invention provides a compact, low-cost air release assembly for a wet pipe network that helps minimize or eliminate air present in the piping system, thereby reducing corrosion (’344 Patent, col. 1:52-56).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶69).
  • Essential elements of Claim 1 include:
    • a cylindrical member through which a fluid is configured to flow, with an inlet and an outlet;
    • a first valve disposed at the inlet of the cylindrical member;
    • a strainer configured to remove particulate matter from the fluid;
    • an angled port that extends from the middle portion of the cylindrical member;
    • an air release valve connected to the angled port;
    • a second valve directly connected to the outlet of the cylindrical member;
    • wherein the cylindrical member, the first valve, the strainer, the angled port, and the second valve are housed in one body.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

  • The accused product is the "Automatic Air Vent w/ Adjustable Purge Valve Model LVAV-2" ("LVAV-2") (Compl. ¶42).

Functionality and Market Context

  • The complaint describes the LVAV-2 as a device for fire protection systems that consists of a "1" ball valve, an air vent, strainer, and adjustable purge valve" (Compl. ¶42). An image provided in the complaint shows the LVAV-2, a brass valve assembly with two red-handled ball valves and a vertical air vent component (Compl. ¶43). The complaint alleges the LVAV-2 is marketed for the same purpose as Plaintiff's patented product and copies its protectable design elements (Compl. ¶¶52, 59).

IV. Analysis of Infringement Allegations

’344 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a cylindrical member through which a fluid is configured to flow... The Accused Product comprises a cylindrical member through which fluid flows. ¶69 col. 2:27-29
a first valve disposed at the inlet of the cylindrical member... The Accused Product comprises a first valve at the inlet. ¶69 col. 2:30-31
a strainer configured to remove particulate matter from the fluid... The Accused Product comprises a strainer. ¶69 col. 4:19-29
an angled port that extends from the middle portion of the cylindrical member... The Accused Product comprises an angled port. ¶69 col. 2:32-34
an air release valve connected to the angled port The Accused Product comprises an air release valve connected to the angled port. ¶69 col. 2:33-34
a second valve directly connected to the outlet of the cylindrical member... The Accused Product comprises a second valve directly connected to the outlet of the cylindrical member. ¶69 col. 2:30-31
wherein the cylindrical member, the first valve, the strainer, the angled port, and the second valve are housed in one body The Accused Product comprises features that are all housed in one body. ¶69 col. 5:32-40

Identified Points of Contention

  • Scope Questions: The complaint provides a side-by-side photographic comparison of the Plaintiff's product and the Accused Product, which appear visually almost identical (Compl. ¶53). A primary dispute may center on the claim limitation "housed in one body." The question for the court will be whether the Accused Product's construction, which the complaint alleges meets this element, is in fact a single integrated body as claimed, or merely an assembly of discrete components connected together.
  • Technical Questions: While the complaint alleges infringement, it does not provide detailed evidence on how the LVAV-2 is manufactured or assembled. The infringement analysis will depend on evidence developed in discovery regarding whether the components of the Accused Product are integrated into a single housing or are separate standard parts that have been joined.

V. Key Claim Terms for Construction

  • The Term: "housed in one body"
  • Context and Importance: This term appears to be the central limitation distinguishing the invention from prior art assemblies of separate components. The infringement analysis, for both literal infringement and the doctrine of equivalents, will likely depend on the construction of this term. Practitioners may focus on this term because the visual similarity of the products (Compl. ¶53) makes the specific method of construction—whether the components are truly integrated into a single body or are merely bolted together to look that way—a critical factual and legal question.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the benefit as creating a "unitary valve assembly structure" to reduce overall size and avoid assembling "a combination of individual components" (’344 Patent, col. 5:32-40). A party could argue this supports a functional definition, where "one body" means a pre-integrated unit sold as a whole, rather than requiring it to be cast from a single piece of metal.
    • Evidence for a Narrower Interpretation: The language "the housing or body of the valve assembly 100 may include/house all four of these components" (’344 Patent, col. 5:34-36) could be interpreted to require a single, monolithic housing. A party may argue that if the accused product is assembled from multiple, independently manufactured sub-components that are threaded or bolted together, it is not "housed in one body."

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead a separate count for indirect infringement.
  • Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge (Compl. ¶70). The factual basis for pre-suit knowledge includes alleged actual notice via letters sent by Plaintiff's counsel to Defendants in July 2024 (Compl. ¶¶61-64, 71). The complaint also alleges constructive notice based on Defendant Core & Main's role as a distributor for Plaintiff's patented Model 7900 AAV product, which is allegedly marked with the patent number (Compl. ¶¶50, 71).

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

  1. A core issue will be one of claim construction and scope: can the term "housed in one body," which is central to the patent’s asserted novelty, be construed to read on the specific manufacturing and assembly method of the accused LVAV-2? The case may depend on whether this limitation requires a monolithic casting or allows for an integrated assembly of sub-components sold as a single unit.
  2. A key evidentiary question will be one of technical fact: discovery regarding the design, manufacture, and assembly of the LVAV-2 will be critical. The visual evidence presented in the complaint suggests a very high degree of similarity (Compl. ¶53), but the ultimate infringement determination will turn on whether the accused device is constructed in a way that meets the "one body" limitation, either literally or under the doctrine of equivalents.
  3. A parallel question for the court will be the strength of the trade dress claim: given the nearly identical appearance of the products, the court will need to assess whether the plaintiff's design is non-functional and has acquired the necessary secondary meaning to be protectable, and whether the defendant's product creates a likelihood of confusion in the marketplace.