DCT

3:19-cv-01104

Stoett Industries Inc v. Irvine Shade & Door Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:19-cv-01104, N.D. Ohio, 05/16/2019
  • Venue Allegations: Venue is asserted based on the Defendant allegedly doing business, committing acts of infringement, and maintaining a regular and established business in the Northern District of Ohio.
  • Core Dispute: Plaintiffs allege that Defendant’s shower screens, sold under the SLOW-ROLL trademark, infringe a patent directed to replaceable, pre-tensioned, retractable shower screen assemblies.
  • Technical Context: The technology pertains to retractable shower screens, particularly those designed to be user-replaceable and suitable for space-constrained applications such as recreational vehicles.
  • Key Procedural History: The complaint states that Plaintiff Newline International is the owner of the patent-in-suit and Plaintiff Stoett Industries is the exclusive licensee in the United States under a 2012 agreement.

Case Timeline

Date Event
1998-11-23 ’511 Patent Priority Date
2002-10-29 ’511 Patent Issued and Assigned to Plaintiff Newline
2012-12-02 Licensing Agreement between Newline and Stoett
2019-05-16 Complaint Filed

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

U.S. Patent No. 6,470,511 - "SHOWER SCREENS"

The Invention Explained

  • Problem Addressed: The patent identifies a market need between flimsy, conventional shower curtains and expensive, rigid glass shower doors (’511 Patent, col. 2:15-27). A particular challenge addressed is the difficulty of replacing a worn or damaged retractable screen and ensuring the replacement has the correct spring tension for proper operation (’511 Patent, col. 2:43-48).
  • The Patented Solution: The invention is a shower closure system featuring a "replaceable shower screen assembly" (’511 Patent, col. 2:32-34). This assembly contains a semi-rigid screen on a spring-loaded roller. Crucially, the spring is "pre-wound to an appropriate tension for the dimensions of the shower enclosure" before it is sold, simplifying installation (’511 Patent, col. 2:43-48). The system also includes a surrounding frame with a housing that has a "door" to provide easy access for swapping out the entire pre-tensioned screen assembly (’511 Patent, col. 5:29-37).
  • Technical Importance: This design modularizes the most failure-prone component of a retractable screen, allowing for easy, tool-less replacement by end-users, which is particularly useful in environments like campervans or mobile homes (’511 Patent, col. 5:12-14).

Key Claims at a Glance

  • The complaint alleges infringement of "the claims of the patent-in-suit" without specifying which of the three claims are asserted (Prayer for Relief, ¶A). The analysis focuses on the sole independent claim, Claim 1.
  • The essential elements of independent Claim 1 are:
    • A "shower entrance surround" and a "replaceable shower screen assembly" for use in combination.
    • The surround includes a "housing" for the assembly, a "door" on the housing for access, top and bottom rails, and an "engagement means" to hold the screen closed.
    • The replaceable assembly includes a "spring loaded roller with a polyester shower screen," a "rigid, elongate support member" attached to the screen's leading edge, and top/bottom "guide members" on the support member that ride in grooves in the rails.
    • The spring is "pre-wound to an appropriate tension."
    • The surround and replaceable assembly are "packaged together, with instructions for replacing the shower screen assembly."

III. The Accused Instrumentality

Product Identification

The complaint identifies "shower screens sold under the SLOW-ROLL trademark" as the infringing products (Compl. ¶24).

Functionality and Market Context

The complaint does not provide a detailed technical description of the SLOW-ROLL product's operation or components. It alleges in a conclusory manner that the products "practice the invention claimed in the ’511 patent" (Compl. ¶24). The complaint provides photographs of the accused shower screen in an exhibit, which may illustrate its features (Compl. ¶20, Exhibit E). The complaint also alleges that Defendant entered into contracts to "make and/or sell infringing shower screens" which has resulted in lost sales for the Plaintiffs (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the ’511 patent but does not provide a detailed, element-by-element mapping of the accused SLOW-ROLL product to the limitations of any specific claim. The infringement theory is stated in conclusory terms, asserting that the accused products "practice the invention claimed in the ’511 patent" (Compl. ¶24). No claim chart is provided or referenced. The complaint does include "Photographs of the infringing shower screen" as Exhibit E, which presumably depict the accused product's structure (Compl. ¶20).

Identified Points of Contention

  • Technical Questions: A central factual dispute will concern whether the accused SLOW-ROLL product embodies the specific structural elements required by Claim 1. For example, does its housing incorporate a "door for providing access" to the roller mechanism? Is its screen assembly sold as a distinct "replaceable" unit? Is its roller spring "pre-wound" at the factory to a set tension, or is it a generic, adjustable mechanism? The complaint does not provide specific factual allegations to answer these questions.
  • Scope Questions: The claim limitation requiring the "shower entrance surround and replaceable shower screen assembly" to be "packaged together" raises a significant question of claim scope. The court may need to determine if this requires the components to be sold in a single retail package to an end-user, or if it could be met by bulk shipment of components to a distributor or installer.

V. Key Claim Terms for Construction

"replaceable shower screen assembly"

  • Context and Importance: This term is at the heart of the invention's stated purpose of providing an easily serviceable unit. The outcome of the case may depend on whether the accused product's screen-and-roller mechanism is considered a distinct "assembly" designed for replacement, as opposed to an integral part of the overall device.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification defines the term as referring to "the shower screen which is able to cover an open face of the shower enclosure, and its attachments which facilitate replacement of one shower screen assembly with another" (’511 Patent, col. 4:36-40). This functional language could support a construction covering any modular screen cartridge.
    • Evidence for a Narrower Interpretation: The summary of the invention and the claims repeatedly tie the assembly to a "spring loaded roller" that is "pre-wound to an appropriate tension" (’511 Patent, col. 2:43-46; col. 8:32-34). A defendant may argue that to be a "replaceable shower screen assembly" under the patent, the component must be a self-contained, pre-tensioned unit, not just any screen that can be technically replaced.

"packaged together"

  • Context and Importance: Practitioners may focus on this term because it introduces a non-structural, commercial-practice limitation into an apparatus claim. Infringement may turn entirely on how the Defendant sells its products. If the surround and screen assembly are sold as separate SKUs, it could provide a basis for non-infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff might argue that "packaged together" is satisfied if the components are shipped in the same master carton for a particular installation, even if they are not in a single consumer-facing box.
    • Evidence for a Narrower Interpretation: The full limitation reads "packaged together, with instructions for replacing the shower screen assembly as desired" (’511 Patent, col. 8:36-39). This context suggests a single retail unit intended for purchase and installation by a user who would need the instructions, pointing toward a narrower construction requiring a single retail package.

VI. Other Allegations

Indirect Infringement

The complaint alleges contributory and induced infringement (Compl. ¶24). The factual basis alleged is that the Defendant has "entered into contracts or relationships with certain third-parties to make and/or sell infringing shower screens" (Compl. ¶18). No specific actions constituting inducement, such as providing user manuals instructing on an infringing use, are detailed.

Willful Infringement

The complaint pleads that Defendant acted "knowingly, willingly, and intentionally" and seeks treble damages for "willful infringement" (Compl. ¶¶19, 35; Prayer for Relief, ¶D). The complaint does not specify the basis for alleging pre-suit knowledge of the ’511 patent or the alleged infringement.

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

  • A core issue will be one of evidentiary proof: Given the complaint’s lack of specific factual allegations mapping the product to the claims, a key challenge for the Plaintiffs will be to produce evidence demonstrating that the accused SLOW-ROLL product contains each specific structural element recited in Claim 1, such as the "door for providing access" and the "pre-wound" spring mechanism.
  • A dispositive issue may be one of claim scope and commercial practice: The case could turn on the construction of the term "packaged together." The court’s interpretation of whether this requires components to be sold in a single retail kit will be critical, as it may create a straightforward path to proving infringement or non-infringement based on the Defendant’s sales and distribution model.