DCT
2:19-cv-04566
Knoll Inc v. Senator Intl Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Knoll, Inc. (Delaware)
- Defendant: Senator International Limited d/b/a The Senator Group (United Kingdom)
- Plaintiff’s Counsel: Buchanan Ingersoll & Rooney PC
- Case Identification: 2:19-cv-04566, E.D. Pa., 10/02/2019
- Venue Allegations: Venue is alleged to be proper because Defendant has committed acts of infringement and conducts business in the district, and alternatively, because the general federal venue statutes do not apply to suits against foreign defendants.
- Core Dispute: Plaintiff alleges that Defendant’s "Array" line of office tables infringes its design patent covering the ornamental appearance of a table.
- Technical Context: The technology is in the field of office furniture, specifically focusing on the aesthetic and ornamental design of modern, mobile tables used in configurable office environments.
- Key Procedural History: The complaint alleges that Defendant exhibited the accused "Array" tables at the NeoCon tradeshow in Chicago in June 2019, approximately four months after the patent-in-suit issued.
Case Timeline
| Date | Event |
|---|---|
| 2016-05-27 | D'638 Patent Priority Date |
| 2019-02-05 | D'638 Patent Issue Date |
| 2019-06 | Accused "Array" tables exhibited at NeoCon tradeshow |
| 2019-07-17 | Earliest date Defendant allegedly had actual knowledge of the D'638 patent |
| 2019-10-02 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Design Patent No. D839,638, titled "TABLE", issued on February 5, 2019.
The Invention Explained
- Problem Addressed: Design patents protect the novel ornamental appearance of an article of manufacture rather than a functional solution to a technical problem. The patent seeks to protect a new, original, and ornamental design for a table (D’638 Patent, Title; Claim).
- The Patented Solution: The patent protects the specific visual design of a table. The claimed design, shown in solid lines in the patent's figures, consists of two opposing C-shaped leg assemblies, each having a single vertical support and a horizontal base fitted with casters. These assemblies are connected by a central horizontal support structure beneath the tabletop (D’638 Patent, Figs. 1, 6, 7). Crucially, the patent states that elements shown in broken lines, such as the tabletop itself and certain underlying mechanisms, "form no part of the claimed design" (D’638 Patent, col. 1:64-66). The protected design is therefore limited to the table's understructure.
- Technical Importance: The design represents a specific aesthetic within the competitive market for modern, flexible office furniture, where visual appearance is a key differentiator (Compl. ¶19).
Key Claims at a Glance
- Design patents contain a single claim. The asserted claim is: "The ornamental design for a table, as shown and described" (D’638 Patent, col. 1:50-51).
- The scope of this claim is defined by the solid-line drawings in the patent figures.
III. The Accused Instrumentality
Product Identification
- Defendant’s "Array" line of tables (Compl. ¶23).
Functionality and Market Context
- The complaint identifies the accused "Array" table as a "newly introduced" furniture product offered for sale by the Defendant (Compl. ¶23). The complaint alleges that the Array table was designed to "mimic the design of the Knoll's PIXEL table" and to compete with it at a "lower price point," suggesting a market position as a direct competitor to Plaintiff's commercial embodiment of the patented design (Compl. ¶40). The complaint includes an image of the accused Array table on display at a tradeshow, showing its overall configuration as a wheeled office table (Compl. ¶25).
IV. Analysis of Infringement Allegations
The complaint’s infringement theory rests on the "ordinary observer" test for design patents, alleging that the accused Array table is "almost identical" in appearance to the design claimed in the '638 Patent (Compl. ¶28, ¶49). To support this, the complaint provides side-by-side visual comparisons of the accused product and the patent figures. The complaint presents a chart juxtaposing photographs of the accused Array table with Figures 6 and 7 from the '638 Patent to illustrate the alleged visual similarity of the leg structures (Compl. ¶27).
D'638 Patent Infringement Allegations
| Claim Element (from Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| The ornamental design for a table, as shown and described. | The overall ornamental appearance of the Defendant's Array table is alleged to be "almost identical" to the patented design, such that an ordinary observer would be deceived. | ¶28; ¶30; ¶49 | col. 1:50-51 |
| A pair of opposing C-shaped leg assemblies, each comprising a single vertical support member and a horizontal base member. | The accused Array table incorporates a pair of opposing C-shaped leg assemblies with a profile, proportion, and construction that the complaint alleges is substantially the same as the patented design. | ¶27; ¶48 | Fig. 6; Fig. 7 |
| Casters affixed to the ends of the horizontal base members. | The accused Array table features casters at the ends of its horizontal base members in a visually similar arrangement to the patented design. | ¶26; ¶27 | Fig. 6; Fig. 7 |
| A central horizontal support structure connecting the two leg assemblies. | The accused Array table includes a central horizontal support beam connecting the two leg assemblies, which is alleged to be visually consistent with the patented design. | ¶26; ¶48 | Fig. 2 |
- Identified Points of Contention:
- Scope Questions: The primary dispute will likely center on the overall visual similarity under the "ordinary observer" test. A key question for the court will be whether the visual differences, if any, between the accused Array table and the patented design are significant enough to avoid infringement in the eyes of an ordinary observer familiar with the prior art.
- Technical Questions: A factual question will be the effect of prior art on the scope of the patented design. The infringement analysis depends on comparing the designs in the context of what was already known. The degree of similarity required for infringement may be higher if the prior art is crowded with similar designs, and the court will need to determine how novel the '638 Patent's design is when compared to earlier table designs.
V. Key Claim Terms for Construction
In design patent litigation, formal claim construction is less common than in utility patent cases, as the claim's scope is defined by the drawings. However, the interpretation of what those drawings cover is critical.
- The Term: "The ornamental design for a table, as shown and described."
- Context and Importance: The central issue is defining the boundaries of the intellectual property right. The dispute will turn on what specific visual features are protected by the solid lines in the patent drawings, and what is disclaimed by the broken lines. Practitioners may focus on this distinction because it determines whether similarities or differences in the disclaimed portions (like the tabletop) are relevant to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for broader scope might emphasize that the "overall visual impression" created by the combination of claimed features is what is protected, and that minor deviations in individual elements should not defeat a finding of infringement. The claim covers the "design for a table," suggesting the elements work together to create a single, holistic appearance (D’638 Patent, col. 1:50-51).
- Evidence for a Narrower Interpretation: The primary evidence for a narrow interpretation is the patent's express disclaimer: "The broken lines shown in the drawing Figures form no part of the claimed design" (D’638 Patent, col. 1:64-66). A party could argue that this explicitly limits protection to the precise shape and configuration of the leg assemblies and connecting structure as depicted in the solid-line drawings (e.g., Figs. 2, 6, 7), and that any ornamental feature not shown in solid lines is excluded from the scope of the patent.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces and contributes to infringement by "selling at least the Array table to customers for their possession and use" with knowledge of the '638 Patent (Compl. ¶46). The factual basis provided is the act of selling the allegedly infringing product to end-users.
- Willful Infringement: The complaint alleges that Defendant's infringement has been and continues to be willful, deliberate, and intentional (Compl. ¶42, ¶54). The allegations are based on purported pre-suit knowledge, including that Defendant knew of the '638 Patent "during development of the Array table," knew it protected Plaintiff's commercial product before a June 2019 tradeshow, and had actual knowledge of the patent "since at least as early as July 17, 2019" (Compl. ¶37-39). The complaint further alleges that Defendant intentionally designed the Array table to "mimic" the Plaintiff's product (Compl. ¶40).
VII. Analyst’s Conclusion: Key Questions for the Case
A core issue will be one of visual comparison: Applying the "ordinary observer" test, is the ornamental design of Defendant's Array table substantially the same as the design claimed in the '638 Patent? The outcome will depend on a direct comparison of the accused product with the patent’s solid-line drawings.
A second key question will be the impact of prior art: How does the universe of pre-existing table designs affect the scope of the '638 Patent and the infringement analysis? The significance of any similarities between the patented design and the accused product will be weighed in the context of what was already in the public domain.
Finally, if infringement is found, a critical question will be one of intent: Do the facts alleged in the complaint—particularly the claim of intentional "mimicking" for competitive purposes—support a finding of willful infringement, which could lead to enhanced damages or an award of the infringer's total profits?