DCT
3:24-cv-00567
Golden Tech Inc v. Pride Mobility Products Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Golden Technologies Inc. (Pennsylvania)
- Defendant: Pride Mobility Products Corporation (Pennsylvania)
- Plaintiff’s Counsel: Myers, Brier & Kelly, LLP; Volpe Koenig
- Case Identification: 3:24-cv-00567, M.D. Pa., 04/03/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, has committed alleged acts of infringement in the district, and maintains a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s VivaLift! Ultra lift chair infringes a patent related to recliner chair mechanisms that provide a separate, actuator-driven cradling or tilting motion.
- Technical Context: The technology concerns powered lift and recliner chairs, a mature market where innovations often focus on providing users with a wider range of motion, enhanced comfort positions, and improved lift functionality.
- Key Procedural History: The complaint notes that the patent-in-suit, U.S. Patent No. 11,412,853, successfully underwent a supplemental reexamination, with a Reexamination Certificate issued on December 14, 2023. The asserted claims were confirmed as patentable during this proceeding. The complaint also details four separate pre-suit infringement notices sent to the Defendant between November 2022 and January 2024.
Case Timeline
| Date | Event |
|---|---|
| 2017-02-10 | ’853 Patent Priority Date |
| 2021-03-12 | ’853 Patent assigned to Plaintiff |
| 2022-08-16 | ’853 Patent Issue Date |
| 2022-11-22 | First pre-suit notice of infringement sent to Defendant |
| 2023-01-13 | Second pre-suit notice, including a detailed claim chart, sent to Defendant |
| 2023-02-09 | Third pre-suit notice sent to Defendant |
| 2023-03-24 | Supplemental Reexamination of ’853 Patent requested |
| 2023-12-14 | Reexamination Certificate for ’853 Patent issued |
| 2024-01-09 | Fourth pre-suit notice sent to Defendant following reexamination |
| 2024-04-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,412,853 - "RECLINER OR LIFT AND RECLINER CHAIR WITH VARIABLE LIFT PROFILE", issued August 16, 2022
The Invention Explained
- Problem Addressed: The patent’s background section notes that conventional lift and recliner chairs, while useful, are often "limited by the specific travel path of the lift and recline mechanism" and may not provide sufficient lift or additional comfort positions for all users (’853 Patent, col. 1:63-67).
- The Patented Solution: The invention introduces a "cradle assembly" as a distinct sub-mechanism underneath a conventional recline mechanism. This assembly includes its own base ("cradle base") and a dedicated actuator that pivots the entire upper chair mechanism ("recline base") forward and backward about a single pair of pivot axes (’853 Patent, Abstract; col. 3:26-44). This creates an independent "cradling" motion that can be used alone or in combination with the standard recline and lift functions to achieve new positions or enhance existing ones (’853 Patent, Fig. 1; col. 8:30-43).
- Technical Importance: This additional axis of movement allows the chair to achieve an "enhanced zero gravity mode," provide a "straight lift mode" with greater vertical height, and manage wall clearance during recline, addressing specific limitations of prior art designs (’853 Patent, col. 8:40-59).
Key Claims at a Glance
- The complaint asserts independent claim 12 and dependent claims 13, 14, 16, 18, 19, and 20 (’853 Patent, col. 18:12-46; Compl. ¶17).
- Independent claim 12 requires:
- a recline chair mechanism providing a reclining movement, the recline chair mechanism having a recline base;
- a seat and a back connected to the recline chair mechanism;
- a cradle assembly, including a cradle base and one pair of aligned pivot axes on the cradle base;
- the recline base being pivotably connected to the cradle base at the one pair of aligned pivot axes;
- a cradle actuator connected between the cradle base and the recline base for pivoting the recline base about the one pair of aligned pivot axes; and
- a controller that controls movement of the cradle actuator.
III. The Accused Instrumentality
Product Identification
- The Pride VivaLift! Ultra lift chair (Compl. ¶7).
Functionality and Market Context
- The complaint describes the accused product as a "5-MOTOR RECLINER" that features an "Exclusive VivaLift! Tilt" function (Compl. ¶19, p. 5). The infringement allegations center on the mechanical assembly that provides this "Tilt" capability. The complaint alleges this tilt mechanism corresponds to the patented "cradle assembly," which provides a tilting or cradling motion separate from the chair's standard recline functions (Compl. ¶¶22-25). A marketing photo in the complaint shows the accused chair, which includes an "ergonomically designed toggle remote" for controlling its various motorized functions (Compl. ¶19, p. 5).
IV. Analysis of Infringement Allegations
’853 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A recliner chair, comprising: | The accused product is marketed and sold as a recliner chair. | ¶19 | col. 1:15-18 |
| a recline chair mechanism providing a reclining movement, the recline chair mechanism having a recline base; | An underside photograph identifies the accused product's "recline chair mechanism" and the "recline base" as the upper moving portion of the assembly. | ¶20 | col. 7:11-20 |
| a seat and a back connected to the recline chair mechanism, with the back being effectively connected relative to the seat; | A product photograph shows the upholstered seat and back connected to the underlying mechanical frame. | ¶21 | col. 7:31-34 |
| a cradle assembly, including: a cradle base; one pair of aligned pivot axes on the cradle base; | A photograph of the chair's undercarriage identifies a "cradle assembly," a "cradle base" (the lower frame), and a "pivot axis." | ¶22 | col. 7:42-48 |
| the recline base being pivotably connected to the cradle base at the one pair of aligned pivot axes; | An image of the mechanism shows a "hinge" that allegedly creates a pivotable connection between the recline base and the cradle base. | ¶23 | col. 4:51-53 |
| a cradle actuator connected between the cradle base and the recline base for pivoting the recline base about the one pair of aligned pivot axes; | A photograph identifies a "Cradle actuator" positioned between the alleged cradle base and recline base to effect the tilting motion. | ¶24 | col. 8:15-20 |
| a controller that controls movement of the cradle actuator. | An image of the handheld, wired remote is identified as the "controller" used to operate the chair's motors, including the cradle actuator. | ¶25 | col. 8:21-23 |
Identified Points of Contention
- Technical Questions: The complaint provides annotated photographs to support its infringement theory. A central question for the court will be whether the accused product’s mechanism operates as alleged. For example, does the accused "cradle actuator" in fact cause the entire "recline base" to pivot about the single "one pair of aligned pivot axes" as required by the claim? The static images may not fully capture the kinematics of the mechanism, raising the question of what further evidence will be needed to prove the precise nature of the mechanical movement.
- Scope Questions: A likely point of dispute will be the interpretation of the claim’s structural elements. The case may turn on whether the accused product's "Tilt" mechanism can be properly characterized as having a distinct "recline base" and "cradle base" that interact as claimed, or if the defendant can argue its product uses a different, more integrated design that does not map onto the two-part structure recited in the patent.
V. Key Claim Terms for Construction
The Term: "recline base"
- Context and Importance: This term defines the entire upper portion of the chair mechanism that is pivoted by the cradle actuator. The distinction between this moving "recline base" and the stationary "cradle base" is fundamental to the claimed invention. Practitioners may focus on this term because the infringement analysis depends on identifying a corresponding, discrete "recline base" in the accused product that pivots as a single unit.
- Intrinsic Evidence for a Broader Interpretation: The specification refers to the "lift and recline chair mechanism 20" and its "lift-recline base 26" as being potentially consistent with known mechanisms, suggesting the term could be construed to cover a variety of upper mechanism designs and not just the specific one detailed in the figures (e.g., ’853 Patent, col. 7:11-20).
- Intrinsic Evidence for a Narrower Interpretation: The figures and the accompanying detailed description illustrate a specific, complex linkage system constituting the "lift-recline base 26" (’853 Patent, Figs. 1-3). A party could argue that the term is implicitly limited by this detailed disclosure to a structure of similar complexity.
The Term: "pivotably connected to the cradle base at the one pair of aligned pivot axes"
- Context and Importance: This limitation defines the specific point of rotation for the entire cradling motion. The construction of "at the one pair" will be critical. It raises the question of whether this language limits the connection to only that single pair of axes, or if other connections could exist.
- Intrinsic Evidence for a Broader Interpretation: Claim 12, which was confirmed during reexamination, recites this language. By contrast, amended claim 1 was narrowed to read "pivotably connected to the cradle base only at the one pair of aligned pivot axes..." (’853 Patent C1, col. 2:19-21, emphasis added). Under the doctrine of claim differentiation, a court may find that the absence of the word "only" in claim 12 implies a broader scope that does not exclude other potential points of contact or connection, so long as the primary pivot occurs at the recited axes.
- Intrinsic Evidence for a Narrower Interpretation: A party could argue that the functional language of the claim—requiring the actuator to pivot the recline base "about" the one pair of axes—implies that this pair of axes must be the sole pivot point for the claimed cradling motion to be possible as described.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant induces and contributes to infringement (Compl. ¶15). It alleges that Defendant provides product brochures and manuals that instruct customers on how to use the accused product in an infringing manner, specifically by operating the "VivaLift! Tilt" feature (Compl. ¶16).
- Willful Infringement: The complaint alleges that Defendant’s infringement has been willful, particularly after receiving notice (Compl. ¶37). The allegations are supported by a detailed history of pre-suit contact, including an initial notice on November 22, 2022, a subsequent notice with a detailed claim chart on January 13, 2023, and a fourth notice sent on January 9, 2024, after the patent successfully emerged from supplemental reexamination (Compl. ¶¶32-35).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural and functional correspondence: does the accused "VivaLift! Tilt" mechanism embody the claimed structure of a "recline base" pivoting as a unit relative to a separate "cradle base" at a single pair of pivot axes, or does it achieve its tilting motion through a different mechanical arrangement that falls outside the scope of the claim language?
- A second key question, particularly relevant to willfulness and potential damages enhancement, will be the reasonableness of Defendant's conduct. Given the allegations of extensive pre-suit notice, including notice that the patent’s asserted claims were confirmed in a reexamination proceeding, the court will likely scrutinize the objective and subjective basis for Defendant's decision to continue selling the accused product.