DCT
2:24-cv-11439
REV Ambulance Group Orlando Inc v. PL Custom Body Equipment Co Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: REV Ambulance Group Orlando, Inc. (Florida)
- Defendant: PL Custom Body and Equipment Co., Inc. (New Jersey)
- Plaintiff’s Counsel: Rivkin Radler LLP; Michael Best & Friedrich LLP
- Case Identification: 2:24-cv-11439, D.N.J., 12/23/2024
- Venue Allegations: Venue is alleged to be proper in the District of New Jersey because the Defendant's principal place of business is located within the district, where it maintains a regular place of business and has allegedly committed acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s emergency vehicles incorporating an external condenser and light assembly infringe a patent related to a dual-purpose housing for both air conditioning components and warning lights.
- Technical Context: The technology integrates an external air conditioning condenser with a light bar for emergency vehicles, resolving the conflict for limited mounting space on the front of an ambulance body.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendant of its infringement of the patent-in-suit on April 19, 2024, approximately eight months prior to filing the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2010-08-26 | U.S. Patent No. 11,896,534 Priority Date |
| 2024-02-13 | U.S. Patent No. 11,896,534 Issue Date |
| 2024-04-19 | Plaintiff allegedly notified Defendant of infringement |
| 2024-12-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,896,534 - "External Condenser and Light Assembly," issued February 13, 2024
The Invention Explained
- Problem Addressed: The patent describes a conflict in designing emergency vehicles between the need for an efficient, externally mounted air conditioning condenser and the need for sufficient space to mount critical warning lights on the front of the vehicle's modular body (’534 Patent, col. 1:41-67). Placing the condenser in other locations, such as underneath the vehicle, exposes it to road hazards and engine heat, which severely limits its performance ('534 Patent, col. 2:5-17).
- The Patented Solution: The invention is an integrated assembly where a condenser housing is specifically designed to also function as a light bar ('534 Patent, Abstract). The housing features a solid front face for mounting warning lights, while airflow for the internal condenser coils is managed through top and bottom openings, often covered by gratings ('534 Patent, col. 4:30-49). This design frees the forward-facing surface for its primary safety-signaling purpose without compromising the air conditioner's operational efficiency.
- Technical Importance: This dual-function design provides a method to optimize both the vehicle's air conditioning performance and its safety-signaling capabilities by resolving the spatial competition between two critical systems ('534 Patent, col. 2:18-24).
Key Claims at a Glance
- The complaint asserts infringement of claims 1-20 (Compl. ¶32).
- Independent claim 1 recites the core elements of the assembly:
- An external automotive condenser and light assembly for mounting on a vehicle body.
- A condenser housing with a top portion that has a top opening and a bottom portion that has a bottom opening, configured to permit airflow between them.
- The housing includes a front face, a right face extending rearward, and a left face extending rearward.
- The front face is configured to permit a warning light to be affixed thereto and to face the vehicle's direction of travel.
- At least one warning light is affixed to the exterior of the front face.
III. The Accused Instrumentality
Product Identification
The accused products are emergency vehicles manufactured and sold by Defendant PL that incorporate an "external condenser box and light assembly" (Compl. ¶¶1, 21). The complaint provides a schematic and a photograph of an ambulance, identified via a URL as a "medium-duty-titan-ambulance," as an exemplary accused product (Compl. ¶¶22-23, fn. 1).
Functionality and Market Context
The complaint alleges the accused products are external assemblies mounted on the body of an emergency vehicle (Compl. ¶24). The assembly allegedly includes a housing with top and bottom openings for airflow, a front face configured for mounting warning lights, and left and right side faces extending rearward (Compl. ¶¶25-30). A schematic from the defendant's website shows the accused assembly mounted above the vehicle's cab on the front of the modular body (Compl. ¶22). A photograph of a "GORHAM RESCUE" ambulance shows a real-world implementation of the accused product (Compl. ¶23).
IV. Analysis of Infringement Allegations
U.S. Patent No. 11,896,534 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An external automotive condenser and light assembly for mounting on a body of a vehicle, the condenser and light assembly comprising: | The Accused Product is described as an external automotive condenser and light assembly designed for mounting on a vehicle body. | ¶24 | col. 8:20-24 |
| a condenser housing having a top portion defining at least one top opening and a bottom portion defining at least one bottom opening... | The Accused Product's condenser housing is alleged to have a top portion with a top opening and a bottom portion with a bottom opening. | ¶25 | col. 8:29-31 |
| wherein each of said top opening and said bottom opening is configured to permit air to flow through the top opening and the bottom opening... | The top and bottom openings of the accused housing are alleged to be configured to permit air to flow through them. | ¶26 | col. 8:32-35 |
| wherein said condenser housing includes a front face to permit at least one warning light to be affixed thereto, and wherein said condenser housing is configured to face a direction of travel of the vehicle... | The housing of the Accused Product allegedly has a front face that allows a warning light to be attached and is configured to face the direction of travel. | ¶27 | col. 8:36-40 |
| wherein said condenser housing includes a right face extending rearward from the front face... | The Accused Product's housing is alleged to include a right face that extends rearward from its front face. | ¶28 | col. 8:43-44 |
| wherein said condenser housing includes a left face extending rearward from the front face... | The Accused Product's housing is alleged to include a left face that extends rearward from its front face. | ¶29 | col. 8:45-46 |
| at least one warning light affixed to an exterior of the front face. | The Accused Product is alleged to have at least one warning light affixed to the exterior of its front face. | ¶30 | col. 8:49-50 |
Identified Points of Contention
- Scope Questions: The infringement allegations in the complaint track the claim language almost verbatim. A potential point of contention is whether the accused product's structure, particularly its openings and airflow path, performs in the manner described by the patent or achieves a similar result through a materially different design.
- Technical Questions: The complaint alleges the existence of top and bottom openings for airflow (Compl. ¶¶25-26). A key factual question for the court will be whether the specific design and function of these openings in the accused product meet the limitations of the claims. The patent specification emphasizes a design that facilitates "substantially vertically" flowing air, and evidence will be needed to show the accused product operates this way ('534 Patent, col. 4:33-36).
V. Key Claim Terms for Construction
The Term: "condenser housing"
- Context and Importance: This term defines the central structure of the invention. Its construction will determine whether a wide range of enclosures can infringe or only those with specific characteristics described in the patent. Practitioners may focus on this term because the specification provides significant detail about a preferred embodiment.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "condenser housing" without importing the geometric limitations from the specification. This may support an interpretation covering any structure that encloses the condenser components and provides a surface for mounting lights.
- Evidence for a Narrower Interpretation: The detailed description repeatedly discusses a specific embodiment with an "isosceles trapezoid in transverse cross section" ('534 Patent, col. 5:6-8). A defendant may argue this detailed description of a single embodiment limits the term to that specific shape, especially if that shape is presented as key to solving the stated problem.
The Term: "top opening" and "bottom opening"
- Context and Importance: The location and function of these openings are fundamental to the patent's asserted novelty, which is moving the airflow path from the front face (as in the prior art) to the top and bottom surfaces. The dispute will center on what qualifies as an "opening" for the purposes of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires only "openings" that "permit air to flow." This could be read to cover any aperture, vent, or hole on the top and bottom surfaces.
- Evidence for a Narrower Interpretation: The specification and figures show these openings are implemented as "grating" ('534 Patent, Fig. 3, element 22; col. 4:37-43). A party may argue that the term "opening" should be construed to require a structure, like a grating, that facilitates the "substantially vertically" directed airflow described as the invention's purpose ('534 Patent, col. 4:33-36).
VI. Other Allegations
Indirect Infringement
The complaint alleges inducement of infringement by "actively encouraging distributors, customers, and others to sell, offer for sale, use and/or import the Accused Products" (Compl. ¶33). The complaint does not specify the form of this encouragement, such as through user manuals or marketing materials.
Willful Infringement
The willfulness allegation is based on alleged knowledge of the '534 Patent as of April 19, 2024, the date Plaintiff claims it provided notice to the Defendant (Compl. ¶¶34-36, 41). The complaint alleges that any infringement after this date has been willful and deliberate.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope: will the structural terms in the claims, such as "condenser housing", be interpreted broadly to cover any enclosure with the claimed features, or will they be narrowed to the specific trapezoidal geometry and angled side-walls detailed in the patent’s preferred embodiments?
- A central evidentiary question will be one of technical and functional equivalence: does the accused product's design, particularly its use of "top" and "bottom" openings, create the "substantially vertical" airflow path that the patent describes as its key innovation, or is there a fundamental mismatch in the operational principles of the two systems?
- A threshold procedural question is one of pleading sufficiency: will the complaint's conclusory, claim-tracking infringement allegations, supported by a website schematic and a single product photograph, be deemed sufficient to state a plausible claim for relief under the Iqbal and Twombly standard?