Rinamo v. Hardware Factory Store OKC Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kim Rinamo, Janne Huovila, and Jörgen Johansson (Finland)
  • Defendant: Hardware Factory Store OKC, Inc. (Oklahoma)
  • Plaintiff’s Counsel: Helton Law Firm; Rabicoff Law LLC
• Case Identification: 4:24-cv-00341, N.D. Okla., 07/19/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant having an established place of business in the district and having committed alleged acts of infringement there.
• Core Dispute: Plaintiffs allege that Defendant’s unspecified "Exemplary Defendant Products" infringe a patent related to a universal gripping device.
• Technical Context: The technology concerns mechanical grippers or clamps designed to be adaptable for securing a wide variety of longitudinal objects, such as pipes, beams, or the handle of a baby carriage.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 10,627,013, “Universal Gripper,” issued April 21, 2020.

The Invention Explained

• Problem Addressed: The patent background describes a need for a versatile gripping device, noting that existing clamps, couplers, and grippers are often designed for a specific use and are therefore limited in their application (’013 Patent, col. 2:33-39). The patent identifies applications from heavy industry (handling pipes and beams) to consumer use (attaching a pram to a shopping cart) (’013 Patent, col. 2:7-29).
• The Patented Solution: The invention is a gripper designed for adaptability. It features a main body with a fixed first gripping jaw and at least two additional, smaller gripping jaws that are pivotably or detachably connected to the first jaw (’013 Patent, Abstract; col. 4:58-65). This multi-jaw design, combined with a closing element, allows the gripper to securely hold objects of various shapes and sizes by conforming to their contours (’013 Patent, col. 5:39-48). For example, Figure 5 shows an embodiment with a first jaw (2) and two second jaws (7, 19) connected by hinges (24, 25), allowing them to wrap around an object.
• Technical Importance: The described technical approach aims to provide a single, "universal" tool that can replace multiple specialized grippers, offering flexibility for both industrial and consumer applications (’013 Patent, col. 2:5-10).

Key Claims at a Glance

• The complaint asserts "one or more claims" without specifying them (Compl. ¶13). The sole independent claim is Claim 1.
• Independent Claim 1:
  • A gripper comprising: a body with an attachment configured to attach to a holding body;
  • a first gripping jaw extending from the body with a concave groove;
  • at least one second and one third gripping jaw, each having concave grooves;
  • wherein the second and third jaws are pivotably or detachably attached to the first jaw and to each other;
  • at least one closing element for pressing the second gripping jaw towards the first gripping jaw, where the closing element includes an apparatus operable electrically, electromagnetically, mechanically, pneumatically, or hydraulically;
  • wherein the distance between the longitudinal edges of the second gripping jaw is smaller than that of the first gripping jaw.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are allegedly identified in claim charts attached as Exhibit 2 (Compl. ¶13). However, Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context, as all such information is incorporated by reference from the unattached Exhibit 2 (Compl. ¶¶18-19).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes "at least the exemplary claims of the '013 Patent" by making, using, offering to sell, selling, and/or importing the "Exemplary Defendant Products" (Compl. ¶13). The complaint incorporates by reference, but does not include, claim charts in Exhibit 2 that purportedly detail how these products infringe (Compl. ¶¶18-19). Without these charts, a detailed element-by-element analysis is not possible based on the complaint alone.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of independent claim 1, several points of contention may arise.
  • Structural Questions: A central question will be whether the accused products possess the specific three-jaw structure recited in claim 1 (a "first gripping jaw" plus "at least one second and one third gripping jaw"). A potential dispute could arise if the accused products are conventional two-part clamps, which may not meet this limitation.
  • Scope Questions: The interpretation of the "closing element" limitation will be significant. Does the accused product’s locking mechanism qualify as an "apparatus operable" in one of the five listed ways (electrically, electromagnetically, mechanically, pneumatically, or hydraulically)? The breadth of the term "mechanically operable apparatus" could be a focal point of the dispute.

V. Key Claim Terms for Construction

• The Term: "at least one second and one third gripping jaw"

• Context and Importance: This term is the central structural feature of the claimed invention, distinguishing it from a simple two-piece clamp. The infringement analysis will depend entirely on whether the accused products can be shown to have this specific multi-part jaw configuration. Practitioners may focus on whether the "second" and "third" jaws must be distinct physical components.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification discusses flexibility, stating the gripper "may comprise two or more second jaws" to "provide further flexibility in use" (’013 Patent, col. 4:56-61). This could be used to argue for a more expansive reading of the multi-jaw requirement.
  • Evidence for a Narrower Interpretation: The plain language of Claim 1 explicitly requires both a "second" and a "third" jaw. Figure 5, which illustrates an embodiment with extended jaws, clearly depicts three distinct jaw components (2, 7, and 19), which may support a narrower construction requiring physically separate elements.

• The Term: "closing element including an apparatus operable...mechanically"

• Context and Importance: The scope of this term will determine what types of locking mechanisms are covered. If the accused product uses a simple, non-complex manual latch, Defendant may argue it is not an "apparatus," while Plaintiff may argue any mechanical means suffices.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes a simple "locking loop...made of steel wire" that engages with teeth on the jaw as one embodiment of the closing element (’013 Patent, col. 3:28-34). This could support a broad reading that encompasses simple mechanical interlocks.
  • Evidence for a Narrower Interpretation: The claim’s use of the word "apparatus" in a list with complex systems (e.g., "electrically," "pneumatically") could imply that a more sophisticated mechanism than a simple latch is required. The specification also describes more complex alternatives, such as an "electric magnet" (’013 Patent, col. 4:10-12), which could be used to argue the term implies more than a basic component.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating on information and belief that Defendant distributes "product literature and website materials inducing end users" to use the products in an infringing manner (Compl. ¶16). The claim is also based on post-suit conduct (Compl. ¶17).
• Willful Infringement: The complaint alleges willful infringement based on knowledge of the ’013 Patent obtained "at least since being served by this Complaint" (Compl. ¶¶15, 17). This frames the willfulness claim as arising from Defendant's continued alleged infringement after the lawsuit was filed.

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

1. A Structural Question of Identity: The primary issue will be whether the Defendant's unnamed products embody the specific multi-part jaw structure required by Claim 1—namely, a "first gripping jaw" combined with both a "second and one third gripping jaw"—or if they utilize a more conventional two-part clamp design that falls outside the claim's literal scope.
2. A Definitional Question of Scope: The case may turn on the construction of "closing element including an apparatus operable...mechanically." The key question for the court will be whether this term encompasses simple manual latches, as described in the patent's embodiments, or requires a more complex mechanical assembly, as the word "apparatus" might suggest.
3. An Evidentiary Question of Proof: Given that the complaint's infringement allegations rely entirely on an unattached exhibit, a threshold issue will be what evidence Plaintiffs can produce to demonstrate that the accused products actually perform the functions and possess the structures recited in the asserted claims.