DCT
3:22-cv-00098
MasterCraft Boat Co LLC v. Malibu Boats LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: MasterCraft Boat Company, LLC (Delaware)
- Defendant: Malibu Boats, LLC (Delaware)
- Plaintiff’s Counsel: Neal & Harwell, PLC; Venable LLP
- Case Identification: MasterCraft Boat Company, LLC v. Malibu Boats, LLC, 3:22-cv-00098, E.D. Tenn., 03/15/2022
- Venue Allegations: Venue is alleged to be proper based on Defendant having committed acts of infringement and maintaining a regular and established place of business in the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s boats featuring transom lounge seating infringe a patent related to aft-facing boat seat designs.
- Technical Context: The technology concerns aft-facing lounge seats located at the transom (rear) of watersport boats, designed to allow occupants to comfortably and safely watch activities like wakeboarding and wake-surfing.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via a letter sent on August 25, 2021, which identified the patent-in-suit and the accused product category.
Case Timeline
| Date | Event |
|---|---|
| 2014-09-05 | U.S. Patent No. 11,091,230 Priority Date |
| 2021-07-08 | Defendant announces 2022 Wakesetter 25 LSV |
| 2021-08-17 | U.S. Patent No. 11,091,230 Issued |
| 2021-08-25 | Plaintiff sends letter to Defendant alleging infringement |
| 2022-03-15 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,091,230 - “Aft-Facing Transom Seating for a Boat”
The Invention Explained
- Problem Addressed: The patent’s background section notes that occupants of a towboat often desire to watch the watersports performer behind the boat, making aft-facing seats near the transom desirable. The technical challenge is to design such seating so it can be "safely occupied while the boat is moving." (’230 Patent, col. 1:36-42).
- The Patented Solution: The invention provides for a boat seat, particularly an aft-facing one, that includes a seat bottom and a leg rest. As detailed in the abstract and various embodiments, a key feature is that the leg rest extends outward and downward from the seat bottom, but is supported such that a "gap is present between the leg rest and a surface beneath the leg rest." (’230 Patent, Abstract; Fig. 15). This cantilevered design allows for a comfortable lounging position while ensuring the occupant is securely seated within the boat's structure. (’230 Patent, col. 6:32-41).
- Technical Importance: This seating configuration provides a dedicated, integrated, and safe solution for observing watersports from the transom, a key recreational feature in the modern towboat market. (’230 Patent, col. 1:42-45).
Key Claims at a Glance
- The complaint asserts independent claim 12 and dependent claims 13-15 and 17-19 (Compl. ¶15).
- Independent Claim 12 requires:
- A boat comprising:
- a hull including a bow and port and starboard sides; and
- a seat including a seat bottom and a leg rest,
- the leg rest extending in a direction that is at a downward angle relative to the seat bottom,
- the leg rest having an upper portion and a lower end,
- the leg rest being supported at the upper portion
- with a gap between the lower end of the leg rest and a surface beneath the leg rest such that the leg rest is not supported by the surface underneath the leg rest.
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s "boats with transom lounge seats," including but not limited to the Wakesetter 25 LSV (Compl. ¶15).
Functionality and Market Context
- The complaint alleges the accused boats include "all-new transom seat loungers" that feature "extendable back and leg rests for a true luxury experience." (Compl. ¶11). These loungers are described by Defendant as "[p]erhaps the most noticeable design feature" of the new model. (Compl. ¶11). An overhead view of the Wakesetter 25 LSV provided in the complaint shows seating located at the stern, facing aft over the swim platform. (Compl. ¶17).
IV. Analysis of Infringement Allegations
’230 Patent Infringement Allegations
| Claim Element (from Independent Claim 12) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a hull including a bow and port and starboard sides | The accused Wakesetter 25 LSV is a boat with a hull that includes a bow, a port side, and a starboard side, as shown in an annotated overhead image. | ¶17 | col. 4:20-22 |
| a seat including a seat bottom and a leg rest | The accused products feature a transom lounge seat that has a "seat bottom" and a "leg rest extending at downward angle," as identified in an annotated screenshot from a promotional video. | ¶18 | col. 16:13-15 |
| the leg rest extending in a direction that is at a downward angle relative to the seat bottom | The leg rest of the accused product's transom seat is shown in a screenshot to extend at a downward angle from the seat bottom. | ¶18 | col. 16:15-17 |
| the leg rest having an upper portion and a lower end | The accused product's leg rest is alleged to have a "supported upper portion" and a "lower end," as labeled in a screenshot from a product walkthrough video. | ¶19 | col. 16:17-18 |
| the leg rest being supported at the upper portion | The complaint alleges the leg rest is supported at its upper portion, as depicted in an annotated image from a product video. | ¶19 | col. 16:19-20 |
| with a gap between the lower end of the leg rest and a surface beneath the leg rest such that the leg rest is not supported by the surface... | The complaint provides a screenshot from a product video showing a person seated with the leg rest extended, explicitly labeling the "gap" between the "lower end" of the leg rest and the "surface underneath leg rest," which appears to be the boat's swim platform. | ¶20 | col. 16:20-24 |
- Identified Points of Contention:
- Technical Questions: A central question will be how the accused Malibu seat is mechanically "supported." The complaint relies on visual marketing materials (Compl. ¶¶18-20), but the actual internal structure will be determinative. The litigation will likely require evidence detailing the precise pivot points and load-bearing components of the accused seat to determine if it is "supported at the upper portion" in the manner claimed.
- Scope Questions: The complaint alleges the "surface beneath the leg rest" is the boat's swim platform (Compl. ¶20). The patent specification discusses a gap relative to the swim platform, but also mentions the possibility of a gap relative to a "portion of the deck." (’230 Patent, col. 12:26-30; col. 14:35-40). The scope of "surface beneath" may become a point of argument.
V. Key Claim Terms for Construction
- The Term: "...a gap between the lower end of the leg rest and a surface beneath the leg rest such that the leg rest is not supported by the surface underneath the leg rest."
- Context and Importance: This is a negative functional limitation that defines the core structural characteristic of the claimed invention: a cantilevered or suspended leg rest. The entire infringement analysis for claim 12 hinges on whether the accused product’s leg rest is unsupported from below. Practitioners may focus on this term because the complaint’s visual evidence of a "gap" (Compl. ¶20) does not definitively prove the functional aspect of being "not supported."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 12 itself does not specify a minimum size for the "gap," nor does it limit the "surface beneath" to any particular part of the boat, such as a swim platform. This may support an argument that any configuration where the leg rest is not in physical, load-bearing contact with any surface directly below it meets the limitation.
- Evidence for a Narrower Interpretation: The specification repeatedly depicts and describes a significant, visible gap over the swim platform (’230 Patent, Fig. 15; col. 12:26-30, "The leg rest 530 has a length that is such that a gap 506 is present between the lower, aft end of the cushion 532...and the upper surface 166 of the swim platform 160."). A party could argue that the context provided by these specific embodiments limits the claim to a leg rest that is structurally designed to clear the swim platform, rather than one that might have an incidental or minimal space underneath it.
VI. Other Allegations
- Indirect Infringement: The complaint does not plead a separate count for indirect infringement. It alleges direct infringement by "making, using, selling, and/or offering for sale" the accused products (Compl. ¶15). No specific facts are alleged to support inducement, such as citations to user manuals that instruct on an infringing use.
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving actual notice of the ’230 patent. The complaint states that a letter identifying the patent and the infringing products was sent to Defendant on August 25, 2021, and that Defendant continued to infringe despite this knowledge (Compl. ¶¶12, 13, 25).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: how will the court define the phrase "supported at the upper portion" and the negative limitation "not supported by the surface underneath"? The interpretation of these terms will determine the scope of the patent's protection and whether it reads on a competitor's design that may achieve a similar aesthetic result through different mechanical means.
- A key evidentiary question will be one of technical proof: beyond the marketing materials presented in the complaint, what evidence will demonstrate the actual, as-built mechanical structure and operation of the accused Wakesetter lounge seat? The case will likely turn on a factual comparison between the internal support mechanisms of the accused product and the specific structural requirements of the patent's claims.