DCT

3:25-cv-00283

Affordable Wire Management LLC v. Cambria County Association for Blind Handicapped Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:25-cv-00283, W.D. Pa., 09/03/2025
  • Venue Allegations: Venue is alleged to be proper in the Western District of Pennsylvania because the Defendant is incorporated and resides in Johnstown, Pennsylvania, which is within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s ModulAir cable hanger products, used in the solar energy industry, infringe a patent related to a modular cable hanger system.
  • Technical Context: Cable management systems are essential components for organizing and supporting high-ampacity electrical cables in utility-scale solar power installations to ensure safety and operational efficiency.
  • Key Procedural History: The asserted patent issued in May 2025. On September 3, 2025, the same day the complaint was filed, Plaintiff’s counsel allegedly sent a letter to Defendant providing actual notice of the asserted patent and the alleged infringement.

Case Timeline

Date Event
2020-03-XX Plaintiff AWM founded
2020-04-17 ’206 Patent Priority Date (Provisional App. 63/011,623)
2020-XX-XX Plaintiff’s "Arden" product first commercially released
2024-09-XX Defendant’s accused "ModulAir" product launched
2025-05-06 ’206 Patent issued
2025-09-03 Plaintiff sent notice letter of infringement to Defendant
2025-09-03 Complaint filed

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

U.S. Patent No. 12,294,206 - "Cable Hangers"

  • Patent Identification: U.S. Patent No. 12,294,206, "Cable Hangers", issued May 6, 2025 (’206 Patent).

The Invention Explained

  • Problem Addressed: The complaint alleges that prior cable management systems for utility-scale solar projects were stagnant designs that failed to solve the problem of decreased ampacity (current-carrying capacity) caused by cable overheating (Compl. ¶¶ 19, 22). The patent specification further notes that conventional hangers with passive attachments can become unsecured in high-wind environments, potentially reducing electrical bonding and leading to material failure from UV exposure ( ’206 Patent, col. 4:50-65, col. 5:8-24).
  • The Patented Solution: The invention is a modular cable hanger system designed to provide flexibility in cable grouping and spacing (Compl. ¶ 20). The patented solution comprises a primary cable hanger with its own saddles and a distinct "saddle extension" that can be attached to the primary hanger to add more saddles and increase carrying capacity ( ’206 Patent, col. 10:50-65; FIG. 7). This modularity allows for improved airflow and organization, addressing the ampacity issue (Compl. ¶¶ 22, 28).
  • Technical Importance: This modular approach allegedly gives solar project designers the flexibility to increase cable ampacity, which is described as an "extremely important factor in the commercial viability" of a project (Compl. ¶ 18).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶ 42).
  • Claim 1 recites:
    • A cable hanger comprising a first support member with a first hook, a first saddle, and a second saddle positioned horizontally adjacent to the first saddle.
    • The hanger further comprises a "saddle extension," which itself includes a second support member, a third saddle, and a second hook.
    • The "second hook" is configured to attach to the first saddle, thereby connecting the saddle extension to the main body of the hanger.
  • The complaint does not explicitly reserve the right to assert dependent claims but seeks judgment on "one or more claims" of the patent (Compl., Prayer for Relief ¶ A).

III. The Accused Instrumentality

Product Identification

  • Defendant CAB's "ModulAir" cable hanger product and system (Compl. ¶ 28).

Functionality and Market Context

  • The complaint alleges the ModulAir product is advertised as a "modular, tiered system for cable separation" that provides "better airflow around the cables" and "flexibility to maximize the ampacity potential of the cables" (Compl. ¶¶ 28-29). The complaint asserts that the ModulAir product directly competes with Plaintiff's "Arden" product line in what it characterizes as an "effectively two-player market" for cable management systems in utility-scale solar projects (Compl. ¶¶ 30, 33-34).

IV. Analysis of Infringement Allegations

The complaint references a claim chart in Exhibit 2, which was not provided with the filed complaint; therefore, the infringement theory is summarized below in prose.

Plaintiff AWM alleges that Defendant CAB’s ModulAir product directly infringes at least claim 1 of the ’206 Patent (Compl. ¶ 42). The complaint’s theory suggests that the ModulAir product embodies the patented invention’s core concept of a modular hanger system. The allegations focus on the accused product's marketed features of "modularity and design flexibility" and its ability to achieve "higher ampacity" (Compl. ¶ 36). The complaint posits that the accused ModulAir product consists of "similar structures (modular hangers with multiple saddles) that serve identical functions (routing solar system cables and wiring)" as the patented technology (Compl. ¶ 35). The complaint provides a visual from the patent, FIG. 12, to illustrate an embodiment of the patented hanger design featuring a main body and an attachable saddle extension (Compl. p. 6, FIG. 12). The infringement theory appears to map the "modular, tiered system" of the ModulAir product onto the claimed structure of a main hanger body combined with a separate, attachable "saddle extension" (Compl. ¶¶ 28, 41).

  • Identified Points of Contention:
    • Structural Questions: A potential point of contention is whether the accused ModulAir product is constructed with the specific two-part structure required by claim 1—a primary hanger with saddles and a distinct "saddle extension" connected via a "second hook"—or if it achieves modularity through a different physical arrangement that falls outside the claim's scope.
    • Scope Questions: The dispute may turn on the construction of claim 1's connection mechanism. A key question will be whether the means by which the ModulAir product’s components connect constitutes a "second hook arranged on the proximal end of the saddle extension and configured to attach to the first saddle," as specifically claimed (’206 Patent, col. 21:32-35).

V. Key Claim Terms for Construction

  • The Term: "saddle extension"

  • Context and Importance: This term is central to the patent’s modularity concept and is a standalone element with its own recited components. The definition of what constitutes a "saddle extension" versus an integrated part of a single, multi-level hanger will be critical to the infringement analysis.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes various ways to add capacity, including "additions 720" and "additions 820," which could suggest that "saddle extension" is a representative term for various add-on components designed to increase capacity (’206 Patent, col. 10:50-55; col. 11:1-4).
    • Evidence for a Narrower Interpretation: Claim 1 itself explicitly defines the "saddle extension" as "comprising: a second support member...; a third saddle...; and a second hook..." (’206 Patent, col. 21:26-37). This language may support a narrower construction that limits the term to only those add-on components that contain all of these specific sub-elements.

  • The Term: "a second hook...configured to attach to the first saddle"

  • Context and Importance: This phrase defines the specific mechanism for connecting the modular "saddle extension" to the main hanger body. Practitioners may focus on this term because the infringement analysis will require a direct comparison between the connection mechanism of the accused ModulAir product and this claimed functional and structural language.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The term "hook" is not explicitly defined, which might support an interpretation covering any feature that mechanically engages, latches, or connects to the first saddle to perform the attachment function.
    • Evidence for a Narrower Interpretation: The patent figures depict specific embodiments of the connection, such as the structure of addition 1220 attaching to the main hanger in FIG. 12 (’206 Patent, FIG. 12). A party could argue that the term "hook" should be construed in light of these specific visual examples, limiting its scope to similar physical structures.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that CAB induces infringement by selling ModulAir components to customers and end users, knowing that their use will "practice the invention claimed" (Compl. ¶ 57). It also pleads contributory infringement, alleging the ModulAir components are "especially made for or adapted for infringing use" and are not staple articles of commerce (Compl. ¶¶ 55-56).
  • Willful Infringement: Willfulness is alleged based on CAB's purported actual knowledge of the ’206 Patent as of September 3, 2025, the date of a notice letter and the complaint filing (Compl. ¶¶ 48-50). The complaint also pleads that CAB's infringement was objectively reckless (Compl. ¶ 51).

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

  • A central issue will be one of structural correspondence: does the accused ModulAir product achieve its modularity using the specific two-part structure recited in claim 1—a main hanger body with an attachable "saddle extension" connected by a "second hook"—or does it employ a different modular design, such as interlocking identical units or a single-piece tiered construction, that may not read on the claim?
  • The case will also likely involve a key question of definitional scope: can the term "hook," which defines the connection mechanism, be construed broadly to cover any form of mechanical interlock between modular components, or will its meaning be narrowed by the patent's figures to the specific latching structures depicted in the preferred embodiments?