DCT
3:23-cv-00006
Vincent Systems GmbH v. Fillauer Companies Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vincent Systems GmbH (Germany)
- Defendant: Fillauer Companies, Inc. (Tennessee)
- Plaintiff’s Counsel: Turner Boyd LLP
- Case Identification: 3:23-cv-00006, E.D. Tenn., 01/04/2023
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the district, has committed acts of infringement, and maintains a regular and established place of business in the District.
- Core Dispute: Plaintiff alleges that Defendant’s TASKA Hand prosthetic device infringes a patent related to the mechanical design of an individual prosthetic finger element.
- Technical Context: The technology relates to advanced, motorized prosthetic hands, focusing on creating durable, compact, and lifelike finger components.
- Key Procedural History: The complaint alleges that Defendant has had actual written notice of the patent-in-suit since at least August 31, 2022, a fact which may be material to the claim of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2008-11-08 | U.S. Patent No. 8,491,666 Priority Date |
| 2013-07-23 | U.S. Patent No. 8,491,666 Issues |
| 2022-08-31 | Alleged Date of Actual Notice to Defendant |
| 2023-01-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,491,666 - “Finger Element,”
Issued July 23, 2013
The Invention Explained
- Problem Addressed: The patent addresses the challenge of creating a prosthetic finger that can function as a self-contained, or "autarkic," unit. Prior designs were often either passive, too large for smaller hands (e.g., for women or children), or had drive mechanisms located outside the finger itself, limiting their application. Furthermore, designs where the motor shaft directly supported the drive gearing were susceptible to damage from external loads, reducing their lifespan (Compl. ¶¶ 13-14; ’666 Patent, col. 1:29-44).
- The Patented Solution: The invention discloses a compact finger element where the drive motor and gearing are housed within the finger's phalanges. A key aspect of the solution is the mechanical "decoupling" of the motor's drive shaft from the threaded screw of the worm gear. The patent teaches that the threaded screw is "axially movable" on the drive shaft and is instead supported by "separate guidances," which absorb external forces and prevent them from being transmitted to the motor. This design aims to improve durability and allow for a more resilient, lifelike motion (Compl. ¶15; ’666 Patent, col. 2:27-38, col. 2:55-62).
- Technical Importance: This approach allows for the creation of smaller, independently powered, and more robust prosthetic fingers that more closely mimic the dimensions and function of a natural finger (’666 Patent, col. 2:1-5).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶25).
- The essential elements of independent claim 1 are:
- a carrier component
- a first phalanx with a first hinge connection to the carrier
- a second phalanx with a second hinge connection to the first phalanx
- a servo drive for the first hinge, comprising a motor, drive shaft, and a worm gearing (with a threaded screw and cog segment)
- a coupling mechanism between the first and second hinge connections
- wherein the threaded screw is supported on the drive shaft form fittingly and is "axially movable" and also "guided in axial direction by separate guidances"
- The prayer for relief seeks a determination of infringement of "one or more claims," suggesting the potential assertion of other claims (Compl. p. 9).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the TASKA Hand prosthetic product (Compl. ¶19).
Functionality and Market Context
- The TASKA Hand is a multi-articulating prosthetic hand. The complaint alleges that Defendant Fillauer is the "exclusive distributor" for the product in the United States (Compl. ¶18).
- The complaint provides a marketing diagram of the TASKA Hand, which highlights features such as "Flexible Fingers," "Motorized thumb rotation," and "Superior Grip" (Compl. ¶24). This diagram, from the product's Specification Sheet, describes the fingers as flexible and able to "laterally spread to allow the hand to effectively grip a wide variety of objects firmly" (Compl. ¶24). The complaint does not, however, provide specific details on the internal drive mechanism of the accused product's fingers.
IV. Analysis of Infringement Allegations
The complaint alleges that the TASKA Hand meets every element of claim 1 but does not provide a detailed, element-by-element infringement analysis (Compl. ¶25). The following chart is based on the complaint's general allegations and public-facing descriptions of the accused product.
’666 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a) a carrier component | The complaint alleges the TASKA Hand contains a carrier component, which would be the base structure to which the fingers are attached. | ¶25 | col. 3:40-44 |
| b) a first phalanx with a first hinge connection to the carrier component | The TASKA Hand is depicted with multi-jointed fingers, which the complaint alleges include a first phalanx hinged to the carrier. | ¶24, ¶25 | col. 3:45-47 |
| c) a second phalanx with a second hinge connection to the first phalanx | The TASKA Hand is depicted with multi-jointed fingers, which the complaint alleges include a second phalanx hinged to the first. | ¶24, ¶25 | col. 3:47-49 |
| d) a servo drive for the first hinge connection with a motor with a drive shaft and a worm gearing with a threaded screw and a cog segment that engages to the threaded screw | The complaint alleges the TASKA Hand has a servo drive. Product marketing notes "Motorized" features, but the complaint provides no specific details on the internal drive components (e.g., motor, worm gearing, threaded screw). | ¶24, ¶25 | col. 3:60-64 |
| e) a coupling mechanism between the first hinge connection and the second hinge connection | The complaint alleges the TASKA Hand has such a mechanism but provides no details on its structure or operation. | ¶25 | col. 3:51-54 |
| f) the threaded screw is supported on the drive shaft form fittingly and axially movable as well as guided in axial direction by separate guidances | The complaint alleges the TASKA Hand meets this limitation but provides no evidence or specific allegations regarding the internal structure of the drive, such as whether a threaded screw is axially movable or has separate guidances. | ¶25 | col. 4:1-3 |
Identified Points of Contention
- Technical Question: A central evidentiary issue will be whether the TASKA Hand's internal drive mechanism practices limitation 1(f). The complaint does not provide any specific factual support showing that the accused device contains a threaded screw that is both "axially movable" relative to the drive shaft and "guided in axial direction by separate guidances." The resolution of this factual question will likely require discovery into the precise design and operation of the accused device.
V. Key Claim Terms for Construction
- The Term: "guided in axial direction by separate guidances"
- Context and Importance: This phrase appears to capture the core novelty of the invention—the "decoupling" of the drive screw from the motor shaft to enhance durability. Infringement will likely depend on whether the internal structure of the TASKA Hand is found to possess "separate guidances" as construed by the court. Practitioners may focus on this term because the complaint's infringement theory rests entirely upon it, yet the complaint offers no evidence to support its presence in the accused device.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the guidances "are arranged preferably in form of sliding guidances at both front edges of the threaded screw" (’666 Patent, col. 2:38-39). The patentee may argue that the use of the word "preferably" indicates that this specific arrangement is merely an exemplary embodiment and that the term should be construed more broadly to cover other structures that guide the screw separately from the motor shaft.
- Evidence for a Narrower Interpretation: A defendant may argue that the term requires a distinct structural element whose function is to guide the screw, as shown by guidances (14) in Figure 2. The specification repeatedly emphasizes the functional result of this feature is "a decoupling of drive shaft and threaded screw" (’666 Patent, col. 2:27-28). A defendant could argue that to qualify as "separate guidances," a structure must achieve this specific functional decoupling, thereby preventing axial loads from affecting the motor.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant encourages and instructs its subsidiary (Motion Control) and end-users to infringe by providing "technical, marketing, promotional, educational, and other product literature" and "instructions for use" for the TASKA Hand (Compl. ¶¶ 27, 29).
- Willful Infringement: The willfulness allegation is based on pre-suit knowledge. The complaint asserts that Defendant received "actual written notice" of its alleged infringement on "at least August 31, 2022," more than four months before the complaint was filed (Compl. ¶30).
VII. Analyst’s Conclusion: Key Questions for the Case
The dispute as framed by the complaint raises two central questions for the court:
A key evidentiary question will be one of technical fact: Does the internal mechanism of the accused TASKA Hand actually contain the structure recited in claim 1(f)? Specifically, discovery will be needed to determine if its drive system employs a threaded screw that is "axially movable" on the drive shaft and "guided in axial direction by separate guidances," as the complaint provides no direct evidence on this critical point.
The case will also likely involve a core issue of claim construction: What is the proper scope of the term "separate guidances"? The outcome may depend on whether the term is defined purely by its structure or if it also requires achieving the functional "decoupling" of the drive shaft from axial loads, as described in the patent's specification.