DCT
1:25-cv-03706
ASSA ABLOY Fenestration LLC v. Vision Industries Group Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: ASSA ABLOY Fenestration, LLC (New York)
- Defendant: Vision Industries Group, Inc., a/k/a Vision Hardware, Inc. (New Jersey)
- Plaintiff’s Counsel: Saiber LLC; Rothwell, Figg, Ernst & Manbeck, P.C.
- Case Identification: 1:25-cv-03706, D.N.J., 09/04/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of New Jersey because Defendant has its principal place of business in Somerset, New Jersey, and conducts substantial business in the district, including activities related to the alleged infringement.
- Core Dispute: Plaintiff alleges that Defendant’s window balance products infringe a patent related to a mounting bracket designed to simplify the installation of window balance assemblies.
- Technical Context: The technology concerns mechanical hardware for hung windows, specifically the constant force balance systems that assist in opening, closing, and holding a window sash in place.
- Key Procedural History: The filing is an Amended Complaint. The complaint alleges that Defendant has been on notice of the patent since its issuance and of the specific infringement allegations since the filing of an Original Complaint on May 1, 2025.
Case Timeline
| Date | Event |
|---|---|
| 2021-09-08 | U.S. Patent No. 12,168,899 Priority Date |
| 2024-12-17 | U.S. Patent No. 12,168,899 Issue Date |
| 2025-05-01 | Alleged Notice of Infringement via Original Complaint Filing |
| 2025-09-04 | Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,168,899 - “WINDOW BALANCE ASSEMBLY AND MOUNTING BRACKET THEREFOR,”
- Patent Identification: U.S. Patent No. 12,168,899, “WINDOW BALANCE ASSEMBLY AND MOUNTING BRACKET THEREFOR,” issued December 17, 2024 (the “’899 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section describes challenges in installing window balance assemblies, which traditionally required installers to assemble and align multiple separate components (carrier, curl spring, mounting bracket) on-site. This process could be complex and risked improper assembly ('899 Patent, col. 1:45-54).
- The Patented Solution: The invention is a mounting bracket designed to securely connect to the curl spring before installation, allowing the entire window balance to be shipped and handled as a single, pre-assembled unit ('899 Patent, col. 2:1-8). The design includes specific features like a ledge and a vertical slot with a cantilevered wall that engage the uncurled end of the spring, simplifying the installation process for builders and contractors ('899 Patent, Abstract; Claim 18).
- Technical Importance: This design approach seeks to reduce installation time, labor costs, and potential for on-site assembly errors for a ubiquitous piece of window hardware ('899 Patent, col. 1:45-54, col. 3:62-col. 4:9).
Key Claims at a Glance
- The complaint asserts independent claims 1, 10, and 18 ('899 Patent, col. 22:15-col. 24:62; Compl. ¶19).
- Independent Claim 18, a representative claim, includes the following essential elements:
- A mounting bracket
- A carrier with a housing and a receiver
- A constant force curl spring with a curled portion located in the housing and an uncurled portion extending outside
- The mounting bracket is symmetrical about a plane bisecting it
- A lateral side of the mounting bracket comprises a ledge and a vertical slot, with the slot comprising a cantilevered wall at least partially defining a side of the slot
- The uncurled end portion of the curl spring is received in the slot and coupled to the ledge
- The slot limits movement of the uncurled end portion relative to the mounting bracket in a direction generally perpendicular to the slot
- The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "one or more claims" ('899 Patent, Compl. ¶19).
III. The Accused Instrumentality
Product Identification
- The CF1004SC window balance product (the “Accused Product”) (Compl. ¶12).
Functionality and Market Context
- The complaint alleges the Accused Product is a window balance assembly that includes a mounting bracket, a carrier with a housing, a receiver, and a constant force curl spring (Compl. ¶14, ¶16). The complaint focuses on the mounting bracket's structural features, alleging it includes a ledge and a vertical slot with a "cantilevered wall" for receiving and securing the uncurled portion of the curl spring (Compl. ¶15). A photograph provided as Figure 3 of the complaint depicts the side view of the mounting bracket with the uncurled end of a spring inserted into the slot (Compl. p. 6). The complaint frames the Accused Product as a direct competitor that misappropriates the patented technology rather than developing its own system (Compl. ¶3).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint does not attach its referenced claim chart exhibits but provides a narrative infringement theory for claims 1, 10, and 18 (Compl. ¶13). The following table summarizes the allegations against representative independent Claim 18 based on the complaint’s text and figures.
’899 Patent Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mounting bracket; a carrier comprising a housing... and a receiver... | The Accused Product is a window balance that includes these components. Figure 1 shows the integrated assembly (Compl. p. 4). | ¶14 | col. 24:47-51 |
| a constant force curl spring comprising a curled portion at least partially located in the interior space of the housing and an uncurled end portion extending from the curled portion... | The Accused Product includes a constant force curl spring with a curled portion inside the housing and an uncurled portion extending outside. | ¶16 | col. 24:52-58 |
| wherein the mounting bracket is symmetrical about a plane bisecting the mounting bracket; | The Accused Product's mounting bracket is alleged to be "symmetrical about a plane." Figure 2 provides a top-down view of the bracket (Compl. p. 5). | ¶15 | col. 24:59-60 |
| wherein a lateral side the mounting bracket comprises a ledge and a vertical slot comprising a cantilevered wall at least partially defining a side of the slot; | The Accused Product's mounting bracket is alleged to have a ledge and a vertical slot that includes a "cantilevered wall." | ¶15 | col. 24:61-64 |
| wherein the uncurled end portion of the curl spring is received in the slot and coupled to the ledge; | The uncurled end portion of the spring is received in the bracket's slot and coupled to the ledge. Figure 3 shows this engagement from the side (Compl. p. 6). | ¶16 | col. 24:65-67 |
| wherein the slot limits movement of the uncurled end portion of the curl spring relative to the mounting bracket in a direction generally perpendicular to the slot... | The slot in the Accused Product is "sized closely to fit" the spring's width and thickness, which allegedly limits its movement perpendicular to the slot. | ¶17 | col. 24:68-col. 25:3 |
Identified Points of Contention
- Scope Questions: The complaint’s allegation of a "cantilevered wall" directly tracks the claim language (Compl. ¶15). A potential point of contention is whether the structure of the Accused Product's slot, as shown in the complaint's figures, meets the technical and legal definition of a "cantilevered wall" as construed from the patent's specification.
- Technical Questions: Claim 18 requires that the slot "limits movement" of the spring in a "generally perpendicular" direction. The complaint alleges this is met because the slot is "sized closely to fit" the spring (Compl. ¶17). The case may turn on evidence demonstrating the extent to which the accused slot actually restricts movement in the specified direction, as opposed to merely holding the spring in place.
V. Key Claim Terms for Construction
The Term: "cantilevered wall at least partially defining a side of the slot"
- Context and Importance: This structural limitation is a key feature distinguishing the claimed mounting bracket. The infringement analysis will depend heavily on whether the accused bracket’s physical structure falls within the scope of this term. Practitioners may focus on this term because the specification does not appear to explicitly define it, opening it to interpretation based on the figures and prosecution history.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the term should be given its plain and ordinary meaning to one of skill in the art of mechanical engineering, covering any wall-like structure supported at one end that bounds the slot.
- Evidence for a Narrower Interpretation: The patent specification describes a "cover portion" that is a "planar-shaped member that extends from the rear surface and covers the slot" ('899 Patent, col. 13:51-53) and is described as a "cantilevered slab" (col. 15:9-10). A party might argue that "cantilevered wall" must be construed as the specific "cover portion" (368) shown in Figures 9A-11B, limiting the claim to that specific embodiment.
The Term: "symmetrical about a plane"
- Context and Importance: This feature is asserted to allow the bracket to be used interchangeably on left-hand and right-hand window jambs, a stated advantage of the invention ('899 Patent, col. 8:22-29). The dispute may center on whether absolute geometric symmetry is required or if functional symmetry suffices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that because of the symmetry, "the mounting bracket 34 may be used interchangeably in either of a left or right window jamb" ('899 Patent, col. 8:25-27). A party could argue that any bracket that achieves this interchangeability meets the "symmetrical" limitation, regardless of minor geometric deviations.
- Evidence for a Narrower Interpretation: A party could argue that the term requires strict geometric mirroring across a central plane, as depicted in Figure 4B of the patent, and that any deviation in the accused product renders it asymmetrical and non-infringing.
VI. Other Allegations
Willful Infringement
- The complaint alleges willful infringement. It asserts that Defendant had knowledge of the ’899 Patent since its issuance in December 2024 and notice of its alleged infringement since the filing of the Original Complaint on May 1, 2025 (Compl. ¶20). The complaint further alleges that Defendant continued to sell the Accused Product despite an "objectively high likelihood" that its actions constituted infringement and without a "good faith basis" for believing it did not infringe (Compl. ¶21-22).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term “cantilevered wall,” which is not explicitly defined in the specification, be construed to read on the specific physical structure of the accused mounting bracket, or will it be limited to the embodiments shown in the patent's figures?
- A second central question will be one of evidentiary proof: does the accused product's bracket meet the functional limitation of being "symmetrical" by being interchangeable for left and right jambs, and does its slot technically limit the spring’s movement in a "generally perpendicular" direction as required by the claim?