DCT

2:26-cv-00160

Cambria Co LLC v. Ohm Intl Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-00160, D.N.J., 01/09/2026
  • Venue Allegations: Venue is alleged to be proper in the District of New Jersey because Defendant is incorporated in, maintains its principal place of business in, and has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s processed quartz slab products infringe three patents related to the systems, methods, and resulting products for manufacturing synthetic stone slabs with a veined appearance.
  • Technical Context: The technology concerns the manufacturing of engineered stone surfaces, such as quartz countertops, designed to emulate the complex, veined appearance of natural quarried stone in a repeatable, industrial process.
  • Key Procedural History: The complaint certifies that Plaintiff has also filed a complaint for patent infringement at the U.S. International Trade Commission (ITC) asserting the same patents, indicating a parallel investigation that may proceed on an expedited timeline and could result in an order excluding infringing products from importation into the U.S.

Case Timeline

Date Event
2014-01-01 Cambria introduces its Coastal Collection of quartz designs
2015-01-30 Earliest Priority Date for ’762, ’440, and ’718 Patents
2019-02-05 U.S. Patent No. 10,195,762 Issues
2019-04-09 U.S. Patent No. 10,252,440 Issues
2025-07-29 U.S. Patent No. 12,370,718 Issues
2026-01-09 Complaint Filed

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

U.S. Patent No. 10,195,762 - *"Processed Slabs, and Systems and Methods Related Thereto,"* issued February 5, 2019

The Invention Explained

  • Problem Addressed: The patent's background section notes that while quarried stone slabs (e.g., granite, marble) are aesthetically appealing, they are expensive and limited to naturally occurring patterns. It states that prior engineered stones "fall noticeably short of the complicated look and texture of quarried stone" (’762 Patent, col. 1:35-37).
  • The Patented Solution: The invention is a synthetic molded slab and a method for its creation that produces repeatable, predefined veining patterns emulating natural stone (’762 Patent, col. 1:40-56). The process involves sequentially depositing two or more differently colored particulate mineral mixes into a mold using a series of complementary stencils. A first mix is deposited through a "positive" stencil, and a second mix is subsequently deposited into the remaining empty regions using a "negative" stencil, creating distinct regions for the "veins" and the "background" that extend through the full thickness of the slab (’762 Patent, Abstract; col. 2:28-56).
  • Technical Importance: This technology allows for the industrial-scale production of engineered quartz slabs with consistent and complex veining, offering an alternative to natural stone with predictable aesthetics and physical properties (’762 Patent, col. 4:11-25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 22 (Compl. ¶23).
  • Essential elements of Claim 22:
    • A processed slab with a major surface defined by a set of particulate mineral mixes, having a rectangular shape of at least 2x6 feet.
    • The major surface comprises a first and a second different particulate mineral mix.
    • The first mix occupies the entire slab thickness at a "set of first regions," which includes a "first vein" in a width-wise direction and a "second vein" in a lengthwise direction.
    • The second mix occupies the entire slab thickness at a "set of second regions."
    • The first mix is absent from the second regions, and the second mix is absent from the first regions.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,252,440 - *"Processed Slabs, and Systems and Methods Related Thereto,"* issued April 9, 2019

The Invention Explained

  • Problem Addressed: As with the related ’762 Patent, the technology aims to solve the problem of creating engineered stone slabs with repeatable, complex veining patterns that mimic natural stone (’440 Patent, col. 1:35-37).
  • The Patented Solution: This patent claims the manufacturing process itself. The claimed method involves sequentially dispensing a first pigmented particulate mix (predominantly quartz) through a first stencil into a mold, followed by dispensing a second pigmented mix through a second stencil into the remaining regions (’440 Patent, Claim 1). The process concludes with vibrating and compacting the arranged mixes to form the final slab (’440 Patent, Claim 1). The specification illustrates this with a clear, multi-step flow diagram (Fig. 7).
  • Technical Importance: By patenting the specific manufacturing method, the invention provides control over the means of producing slabs with the desired aesthetic qualities, a key aspect of protecting the technology from replication (’440 Patent, col. 4:11-25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 14 (Compl. ¶31).
  • Essential elements of Claim 14:
    • A process of sequentially dispensing at least a first and a second different pigmented particulate mineral mix into a slab mold.
    • The first mix is dispensed into a "first set of regions," and the second mix is dispensed into a "second set of regions" that is different from the first.
    • The process includes vibrating and compacting the mixes to form a rectangular slab at least 3x6 feet.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 12,370,718 - *"Processed Slabs, and Systems and Methods Related Thereto,"* issued July 29, 2025

  • Patent Identification: U.S. Patent No. 12,370,718, "Processed Slabs, and Systems and Methods Related Thereto," issued July 29, 2025 (Compl. ¶15).
  • Technology Synopsis: The ’718 patent claims the structure of the resulting synthetic slab. It describes a product with a "first pattern" of a first particulate mix defining a "background" and a "second pattern" of a second, different mix defining a "plurality of veins," where the second pattern is a "negative" of the first (’718 Patent, Claim 1). This structure is alleged to result from the manufacturing process described in the related patents.
  • Asserted Claims: Independent claims 1 and 9 (Compl. ¶39).
  • Accused Features: The complaint alleges that the accused processed slabs, such as the "Giselle" design, are structured with a background material and a veined pattern that infringes the claims of the ’718 Patent (Compl. ¶17, 39).

III. The Accused Instrumentality

Product Identification

  • The accused products are processed slabs sold by OHM, at least under the “Valiant” brand name, with the “Giselle” design identified as a specific, non-limiting example (Compl. ¶18).

Functionality and Market Context

  • The accused products are engineered quartz slabs intended for use as countertops and other decorative surfaces (Compl. ¶8, 18). The complaint alleges these products are made using an infringing process and have an infringing structure that creates a veined appearance emulating natural stone (Compl. ¶17). The complaint provides a visual of an exemplary accused product, which depicts a light-colored slab with prominent, dark, branching veins. This image shows an exemplary Accused Product (Compl. ¶19). The complaint alleges that the commercial success of Plaintiff’s products prompted competitors like Defendant to copy its patented technology (Compl. ¶17).

IV. Analysis of Infringement Allegations

U.S. Patent No. 10,195,762 Infringement Allegations

Claim Element (from Independent Claim 22) Alleged Infringing Functionality Complaint Citation Patent Citation
a major surface defined by a set of particulate mineral mixes and having a rectangular shape that is at least 2 feet wide by at least 6 feet long... The accused "Giselle" product is a rectangular slab used for countertops, which are of similar or larger dimensions. ¶18, 19 col. 13:5-9
the major surface comprising a first particulate mineral mix and a second particulate mineral mix... the first and second particulate mineral mixes being different... The accused product visually comprises at least two different materials: a lighter background material and a darker vein material. ¶19 col. 13:17-19
wherein the first particulate mineral mix occupies the entire slab thickness at a set of first regions, the set of first regions including a first vein in a generally width-wise direction... and a second vein in a generally lengthwise direction... The image of the accused product shows veins extending in multiple directions, including portions that run generally along the slab’s length and others that run across its width. ¶19 col. 13:11-16
wherein the second particulate mineral mix occupies the entire slab thickness at a set of second regions... the first particulate mineral mix being absent from the set of second regions and the second particulate mineral mix is absent from the set of first regions. The background and vein materials appear to occupy distinct, complementary regions of the slab's surface. ¶19 col. 13:16-24

U.S. Patent No. 10,252,440 Infringement Allegations

Claim Element (from Independent Claim 14) Alleged Infringing Functionality Complaint Citation Patent Citation
sequentially dispensing at least first and second pigmented particulate mineral mixes into a slab mold... the first... mix different than the second... mix... The structure of the accused product, with its distinct background and vein regions, is alleged to be the result of a process where different materials are dispensed sequentially. ¶17, 19, 31 col. 14:15-20
wherein the first... mix is dispensed into the first set of regions... and the second... mix is dispensed into the second set of regions..., the second set of regions different than the first set of regions... The visual appearance of the accused slab, with complementary vein and background patterns, is alleged to result from dispensing materials into different, non-overlapping regions as defined by a stencil process. ¶17, 19, 31 col. 14:20-26
vibrating and compacting the pigmented particulate mineral mixes... to form a processed slab that is generally rectangular and has a major surface with a width of at least 3 feet and a length of at least 6 feet. The accused product is a finished, compacted rectangular slab sold for countertop applications. ¶18, 19 col. 14:27-32

Identified Points of Contention

  • Scope Questions: For the ’762 Patent, a potential point of dispute may arise from the claim's language that the "first particulate mineral mix" forms the "veins." The question will be whether the accused product's structure maps onto this specific claim definition or if, for instance, the material forming the visual "vein" is considered the "second mix" under a different interpretation, potentially creating a non-infringement argument.
  • Technical Questions: For the ’440 Patent process claim, the central question is one of evidence. The complaint alleges the accused products are made by the patented process and imported in violation of 35 U.S.C. § 271(g) (Compl. ¶31). A key challenge for the Plaintiff will be to gather evidence from the Defendant, whose manufacturing facilities may be located abroad, to prove that the specific, patented steps of "sequentially dispensing" through stencils are actually used.

V. Key Claim Terms for Construction

The Term: "vein" (’762 Patent, Claim 22)

  • Context and Importance: This term is central to defining the structure of the infringing product. Its construction will determine whether the claim requires only a visual appearance of a vein or a specific structural arrangement where a particular material mix (the "first mix") forms that feature. Practitioners may focus on this term because the mapping of the accused product's features (veins vs. background) to the claim's "first regions" and "second regions" is critical for infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent repeatedly states its goal is to create slabs that "emulate the appearance of a quarried stone slab" with "complex striations and veining patterns," which could support an interpretation based more on visual appearance than on which specific mix forms the feature (’762 Patent, col. 1:53-56).
    • Evidence for a Narrower Interpretation: Claim 22 explicitly links the "vein" to the "set of first regions" which are occupied by the "first particulate mineral mix." The specification further links these regions to the patterns created by the stencils used in the manufacturing process, suggesting a more structurally-defined and limited meaning (’762 Patent, col. 6:51-64; Fig. 1).

The Term: "sequentially dispensing" (’440 Patent, Claim 14)

  • Context and Importance: This term defines the core action of the asserted method claim. The dispute may turn on whether the accused manufacturing process meets this temporal requirement. If Defendant's process involves any simultaneous or overlapping dispensing of materials, it may argue it does not practice this element.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term itself does not explicitly forbid any minor overlap in time; one could argue it simply means the dispensing of the second mix begins after the dispensing of the first mix begins.
    • Evidence for a Narrower Interpretation: The specification's detailed description and flowchart (Fig. 7) depict a distinct, multi-step process: dispense first mix (704), remove positive stencil (706), position negative stencil (708), and only then dispense second mix (710). This clear separation of steps in the preferred embodiment may support a narrower construction requiring the first dispensing step to be completed before the second one commences.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement for all asserted patents. The allegations are based on Defendant’s active promotion, marketing, sales, and distribution activities, including through its website, which allegedly encourage others to import, sell, and use the accused products (Compl. ¶24-25, 32-33, 40-41).

Willful Infringement

  • The complaint alleges willful infringement based on Defendant’s knowledge of the patents as of the filing of the lawsuit. It alleges that Defendant's continuation of its allegedly infringing activities, despite this notice, constitutes willful, intentional, and deliberate disregard of Plaintiff’s patent rights (Compl. ¶28-29, 36-37, 44-45).

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

  • A central issue will be one of process evidence: for the asserted method claims (’440 Patent), can the Plaintiff secure sufficient evidence of the Defendant's overseas manufacturing process to prove that it performs the specific steps of "sequentially dispensing" materials through complementary stencils, as required for infringement under 35 U.S.C. § 271(g)?
  • A key legal question will be one of claim scope: can the product claims (’762 and ’718 Patents) be construed broadly to cover any slab with a veined appearance created by two distinct materials, or will they be limited to the specific structure where the "first" material mix as defined in the patent forms the "vein" and the "second" forms the background?
  • A significant procedural factor will be the impact of the parallel ITC investigation. The faster pace of the ITC and the threat of an importation ban could drive the timeline and settlement dynamics of this district court litigation, potentially resolving the dispute before the district court reaches the merits.