DCT
2:25-cv-01275
AGF Mfg Inc v. Core & Main LP
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: AGF Manufacturing, Inc. (Pennsylvania)
- Defendant: Core & Main LP (Florida)
- Plaintiff’s Counsel: Panitch Schwarze Belisario & Nadel LLP
- Case Identification: 2:25-cv-01275, D.N.J., 04/22/2025
- Venue Allegations: Venue is asserted based on Defendant's alleged commission of infringing acts within the District of New Jersey and its operation of an established place of business, a fire protection system distribution center, in the district.
- Core Dispute: Plaintiff alleges that Defendant’s automatic air vent product for fire sprinkler systems infringes a patent related to an integrated purge and vent valve assembly.
- Technical Context: The technology involves specialized valves designed to automatically purge trapped air from wet-pipe fire sprinkler systems to mitigate oxygen corrosion, a significant cause of pipe failure and a subject of industry safety standards.
- Key Procedural History: The complaint alleges that Defendant is a distributor of Plaintiff's own patented product. It also describes pre-suit correspondence in July 2024, where Plaintiff notified Defendant of the potential infringement and offered to discuss a license, which Plaintiff claims Defendant did not substantively address.
Case Timeline
| Date | Event |
|---|---|
| 2017-02-08 | '344 Patent Priority Date |
| 2017 | Plaintiff's Model 7900 AAV enters market |
| 2019-08-27 | '344 Patent Issue Date |
| 2024-07-03 | Plaintiff's first pre-suit notice letter to Defendant |
| 2024-07-16 | Plaintiff's second pre-suit notice letter to Defendant |
| 2024-07-29 | Defendant's counsel responds to Plaintiff's letters |
| 2025-01 | Defendant allegedly begins providing LVAV-2 to customers |
| 2025-04-22 | 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 identifies the problem of oxygen corrosion in fluid-based fire sprinkler systems caused by trapped air introduced during installation or maintenance. It notes that existing valves for venting this air are often formed from a "plurality of individual components that are subsequently assembled together," which can increase the size, complexity, and cost of the valve assembly. (’344 Patent, col. 1:16-27, 1:49-54).
- The Patented Solution: The invention claims to solve this problem with a compact valve assembly where multiple functional components—an inlet valve, a strainer, an outlet/purge valve, and an angled port for an air release valve—are integrated into a single, unitary body. (’344 Patent, Abstract; col. 5:31-38). This integrated design is described as reducing the overall size and cost of production compared to conventional multi-piece assemblies. (’344 Patent, col. 1:52-54).
- Technical Importance: This approach provided a compact, cost-effective device for complying with fire safety standards that call for venting air to reduce internal pipe corrosion. (’344 Patent, col. 1:46-54).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1. (Compl. ¶59).
- The essential elements of Claim 1 are:
- A cylindrical member for fluid flow with an inlet and outlet.
- A first valve at the inlet.
- A strainer within the member.
- An angled port extending from the middle portion of the member.
- An air release valve connected to the angled port.
- A second valve connected to the outlet.
- A final limitation requiring that the cylindrical member, first valve, strainer, angled port, and second valve are "housed in one body."
III. The Accused Instrumentality
Product Identification
- The accused product is the "Automatic Air Vent w/ Adjustable Purge Valve Model LVAV-2" ("LVAV-2"). (Compl. ¶32).
Functionality and Market Context
- The complaint describes the LVAV-2 as a device "consisting of a 1" ball valve, an air vent, strainer, and adjustable purge valve." (Compl. ¶32). Its alleged function is to automatically release trapped air from wet fire sprinkler systems. (Compl. ¶¶ 24, 32). The complaint includes an image of the LVAV-2 assembly. (Compl. ¶33).
- Plaintiff alleges that Defendant imports, markets, and sells the LVAV-2. (Compl. ¶32). It further alleges that Defendant is also a distributor for Plaintiff’s own patented product, the Model 7900 AAV, giving Defendant knowledge of the product, its patent protection, and its success in the market. (Compl. ¶¶ 40-41).
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 LVAV-2 has a main cylindrical body for fluid flow. | ¶59 | col. 2:28-30 |
| a first valve disposed at the inlet of the cylindrical member... | The accused LVAV-2 includes a 1" ball valve that functions as the first valve at the inlet. | ¶¶32, 59 | col. 2:30-31 |
| a strainer configured to remove particulate matter from the fluid... | The accused LVAV-2 is alleged to contain a strainer. | ¶¶32, 59 | col. 2:31-32 |
| an angled port that extends from the middle portion of the cylindrical member... | The accused LVAV-2 has an angled port connecting to the air vent. | ¶¶32, 59 | col. 2:32-34 |
| an air release valve connected to the angled port... | An "air vent" on the accused LVAV-2 allegedly functions as the claimed air release valve. | ¶¶32, 59 | col. 2:33-34 |
| a second valve directly connected to the outlet of the cylindrical member... | An "adjustable purge valve" on the accused LVAV-2 allegedly functions as the claimed second valve at the outlet. | ¶¶32, 59 | 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 complaint alleges that all of the previously listed features of the accused LVAV-2 are housed in one body. A side-by-side photographic comparison is provided to show the visual similarity to Plaintiff's product. (Compl. ¶43). | ¶59 | col. 5:31-38 |
Identified Points of Contention
- Scope Questions: The case may turn on the construction of the term "housed in one body". A central question will be whether this limitation requires a single, unitary casting or forging of the main valve body and its integrated features, or if it can be read more broadly to cover an assembly of separate components that are screwed or fitted together to form a single external unit. The patent’s own distinction from prior art "assembled together" from a "plurality of individual components" may support a narrower construction. (’344 Patent, col. 1:49-52).
- Technical Questions: While the complaint provides a side-by-side visual comparison suggesting structural similarity (Compl. ¶43), a key evidentiary question will be the actual method of manufacture and assembly of the LVAV-2. The infringement analysis will depend on whether the accused product's components are integrated into a single piece in the manner required by the claim, or are merely discrete parts joined together.
V. Key Claim Terms for Construction
- The Term: "housed in one body"
- Context and Importance: This term appears in the "wherein" clause of Claim 1 and is central to the patent's assertion of novelty over prior art assemblies. The patent's specification contrasts the invention with valves "formed from a plurality of individual components that are subsequently assembled together." (’344 Patent, col. 1:49-52). The resolution of the infringement dispute will likely depend on the scope assigned to this term. Practitioners may focus on this term because the visual similarity between the products makes the precise structural and manufacturing definition of "one body" the dispositive issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the method of forming the "one body" (e.g., casting, forging, machining from a single block). A party could argue that as long as the components are contained within a single, continuous outer housing at the end of assembly, they are "housed in one body."
- Evidence for a Narrower Interpretation: The specification states, "Forming the valve assembly as a unitary structure permits the overall sizing of the valve assembly to be reduced as compared with existing valve assemblies that are assembled from a combination of individual components." (’344 Patent, col. 5:31-38). This language, emphasizing a "unitary structure" to achieve the benefits of the invention, suggests that "housed in one body" requires more than simply connecting separate pieces and may imply that the cylindrical member, strainer chamber, and angled port are formed from a single, indivisible piece of material.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead counts for indirect infringement.
- Willful Infringement: The complaint alleges willful infringement based on both actual and constructive knowledge. (Compl. ¶61). It alleges Defendant had actual knowledge from pre-suit notice letters sent in July 2024, which included a copy of the ’344 Patent. (Compl. ¶¶ 51-54, 61). It also alleges pre-suit knowledge on the basis that Defendant is a distributor of Plaintiff's own Model 7900 AAV product, which is allegedly marked with the patent number on the product and in its technical datasheets. (Compl. ¶¶ 40, 61).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "housed in one body," which the patent contrasts with prior art assemblies of "individual components," be construed to read on the specific manufacturing and assembly method of the accused LVAV-2? The outcome will likely depend on whether the court defines this term to require a single-piece, unitary casting or allows for an assembly of tightly integrated but initially separate components.
- A key secondary question will be one of willfulness: given that Defendant was a distributor of Plaintiff’s patented product and allegedly received explicit pre-suit notice including the patent itself, the central question for willfulness will be whether Defendant’s conduct in proceeding to market the accused LVAV-2 meets the standard for egregious infringement behavior warranting enhanced damages.