DCT
3:25-cv-03706
ASSA ABLOY Fenestration LLC v. Vision Industries Group
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
- Case Identification: 3:25-cv-03706, D.N.J., 05/01/2025
- Venue Allegations: Venue is alleged based on Defendant’s principal place of business being located in the District of New Jersey, as well as its alleged business activities and acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s window balance products infringe a patent related to a mounting bracket for a window balance assembly.
- Technical Context: The technology concerns mechanical hardware components, specifically constant force balance systems used to assist in opening and holding hung windows in a desired position.
- Key Procedural History: The patent-in-suit was issued on December 17, 2024, less than five months before the complaint was filed. The complaint does not mention any prior litigation, administrative proceedings, or licensing history related to the patent.
Case Timeline
| Date | Event |
|---|---|
| 2021-09-08 | '899 Patent Priority Date |
| 2024-12-17 | U.S. Patent No. 12,168,899 Issued |
| 2025-05-01 | 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 Invention Explained
- Problem Addressed: The patent’s background section describes known window balance assemblies where the components are pre-attached for simplified installation. However, it notes that disengaging the mounting bracket from the carrier during installation could require complex articulation or even "a material failure (e.g., a break, fracture, deformation or deflection)" of the components (’899 Patent, col. 2:54-62).
- The Patented Solution: The invention is a window balance assembly, and a mounting bracket for it, designed to be shipped as a complete unit. The mounting bracket includes specific features, such as a boss within a recessed portion and a covered slot, that engage the uncurled end of a curl spring (’899 Patent, col. 15:53-60). This design allows the spring to be securely attached to the bracket for shipping and then easily installed into a working configuration without requiring component breakage or complex assembly steps on-site (’899 Patent, col. 2:1-7).
- Technical Importance: This approach seeks to simplify the installation process for window manufacturers and installers by providing a pre-assembled, unitary product that avoids the drawbacks of prior art shipping configurations (’899 Patent, col. 2:46-54).
Key Claims at a Glance
- The complaint asserts independent claims 1, 10, and 18.
- Independent Claim 1 recites a window balance, including:
- A mounting bracket with a body having a front, rear, and lateral side.
- A carrier with a housing and a receiver.
- A constant force curl spring with a curled portion and an uncurled end portion.
- The lateral side of the mounting bracket comprises a "ledge" and a "slot" with first and second open ends and a "cantilevered surface".
- In an "uninstalled, assembled configuration," the uncurled end of the spring engages the "ledge" and is at least partially received in the "slot", with movement perpendicular to the lateral side being "substantially limited."
- Independent Claim 10 recites a window balance, including:
- A "symmetrical" mounting bracket with an opening for a fastener.
- A carrier with a housing and a receiver.
- A constant force curl spring.
- A lateral side of the mounting bracket comprises a "vertical slot" (with first/second open ends and a "cantilevered wall") and a "ledge".
- The uncurled end of the spring is received in the slot and extends from both open ends.
- The slot is "sized to closely fit" the spring's width or thickness and limits movement "generally perpendicular to the slot."
- Independent Claim 18 recites a window balance, including:
- A "symmetrical" mounting bracket.
- A carrier with a housing and a receiver.
- A constant force curl spring.
- A lateral side of the mounting bracket comprises a "ledge" and a "vertical slot" with a "cantilevered wall".
- The uncurled end of the spring is received in the slot and "coupled to the ledge."
- The slot "limits movement" of the spring "in a direction generally perpendicular to the slot."
III. The Accused Instrumentality
Product Identification
- Product Identification: The CF1004SC window balance product ("Accused Product") (Compl. ¶12).
Functionality and Market Context
- Functionality and Market Context: The complaint alleges the Accused Product is a window balance that includes a mounting bracket, a carrier with a housing, and a constant force curl spring (Compl. ¶13, ¶15). Figure 1 in the complaint provides an image of the accused CF1004SC window balance, showing the mounting bracket, carrier housing, and curl spring as an assembled unit (Compl. ¶13, p. 4). The mounting bracket is described as being "symmetrical about a plane" and having a "ledge and a vertical slot comprising a cantilevered wall" (Compl. ¶14). A top-down view of the accused mounting bracket is provided in Figure 2 of the complaint, and a side view in Figure 3 illustrates how the curl spring is allegedly received by the mounting bracket (Compl. ¶14, p. 5). The complaint alleges the slot is sized to fit the spring and limits its movement perpendicular to the slot (Compl. ¶16).
IV. Analysis of Infringement Allegations
'899 Patent Infringement Allegations
| Claim Element (from Independent Claim 18) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A window balance comprising: a mounting bracket; | The Accused Product includes a mounting bracket (Compl. ¶13). | ¶13, ¶14 | col. 13:21-24 |
| wherein the mounting bracket is symmetrical about a plane bisecting the mounting bracket; | The Accused Product’s mounting bracket is "symmetrical about a plane" (Compl. ¶14). | ¶14 | col. 8:26-30 |
| a carrier comprising a housing extending from a first end to a second end, the housing defining an interior space; a receiver supported by the carrier near the second end of the carrier; | The Accused Product includes "a carrier comprising a housing (having first and second ends and an interior space), and a receiver supported by the carrier near the second end of the carrier" (Compl. ¶13). | ¶13 | col. 6:41-43 |
| a constant force curl spring comprising a curled portion ... and an uncurled end portion...; | The Accused Product includes a "constant force curl spring having a curled portion at least partially located in the interior space of the housing and an uncurled portion extending outside of the interior space of the housing" (Compl. ¶15). | ¶15 | col. 6:54-57 |
| wherein a lateral side the mounting bracket comprises a ledge and a vertical slot comprising a cantilevered wall...; | The Accused Product includes a mounting bracket with "a ledge and a vertical slot comprising a cantilevered wall" (Compl. ¶14). | ¶14 | col. 14:55-60; col. 15:9-10 |
| 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 Accused Product's spring "is received in the slot and coupled to the ledge" (Compl. ¶15). | ¶15 | col. 16:37-41 |
| 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 of the Accused Product's bracket "limits movement of the uncurled portion of the curl spring relative to the mounting bracket in a direction generally perpendicular to the slot" (Compl. ¶16). | ¶16 | col. 24:1-4 |
Note: Allegations for claims 1 and 10 are substantially similar, based on the same paragraphs of the complaint and features of the Accused Product.
Identified Points of Contention
- Scope Questions: The dispute may center on whether the accused structure meets the specific definitions of the claimed terms. For example, does the feature identified as a "cantilevered wall" in the Accused Product (Compl. ¶14) correspond to the structure described in the patent, such as the "cantilevered slab" that forms a cover over the slot (’899 Patent, col. 15:9-10)? Similarly, does the accused "ledge" perform the function of being "coupled" to the spring in the manner taught by the patent?
- Technical Questions: A factual question concerns the degree of interaction between the spring and the slot. Claims 10 and 18 require the slot to limit movement in a specific direction. The complaint alleges this limitation is met (Compl. ¶16), but the case may require evidence demonstrating that the fit and geometry of the accused slot perform this specific limiting function, as opposed to merely containing the spring.
V. Key Claim Terms for Construction
The Term: "ledge"
- Context and Importance: This term appears in all asserted independent claims and defines a key point of interaction with the curl spring. The construction of "ledge" will be critical to determining whether the accused bracket, which is alleged to have a "ledge," infringes. Practitioners may focus on this term because its structural and functional scope (e.g., "coupled to the ledge," "engages the ledge") is central to the claimed invention.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is common, and the claims do not provide an explicit structural definition, which may support an interpretation covering any surface that protrudes to support or engage the spring.
- Evidence for a Narrower Interpretation: The specification describes the "ledge" (391) as a specific surface within a "groove" (392) on a "boss" (386) (’899 Patent, col. 14:58-62; Fig. 10A). This specific embodiment could be used to argue for a narrower construction that requires more than a simple protrusion.
The Term: "cantilevered wall" / "cantilevered surface"
- Context and Importance: This term is a key structural limitation of the "slot" in all asserted claims. The infringement analysis will depend on whether the accused slot is "at least partially bounded by" or "comprising" such a feature. Practitioners may focus on this term because "cantilevered" implies a specific structural engineering characteristic (supported at one end only).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition, potentially allowing the term to cover any wall or surface that overhangs the slot.
- Evidence for a Narrower Interpretation: The specification describes the "cover portion" (368) of the slot as a "cantilevered slab that extends from the rear surface" (’899 Patent, col. 15:9-10). This could support a narrower reading requiring the wall to be a distinct, overhanging cover feature, as depicted in figures like 9A and 11A.
VI. Other Allegations
Indirect Infringement
- The complaint alleges that Defendant induces infringement by "distributors, resellers, dealers and customers" to use and sell the Accused Product (Compl. ¶19). The complaint does not plead specific facts regarding the acts of inducement, such as referencing instructional materials or user manuals.
Willful Infringement
- The complaint alleges that Defendant has known of the ’899 Patent "since it issued in December 2024, or shortly thereafter," and acted despite an "objectively high likelihood" of infringement (Compl. ¶20). The willfulness claim appears to be based on knowledge acquired post-issuance of the patent, with notice being established at the latest by the service of the complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the general terms "ledge" and "cantilevered wall," as used in the claims, be construed to read on the specific physical structures of the accused CF1004SC mounting bracket, or will the court adopt a narrower construction tied to the detailed embodiments in the patent’s specification and figures?
- A key evidentiary question will be one of functional equivalence: does the interaction between the curl spring and the accused bracket's slot demonstrate the specific functional limitations of being "sized closely to fit" and "substantially limit[ing] movement" in a perpendicular direction, as required by the claims, or is there a material mismatch in technical operation?