DCT
2:25-cv-03153
California Innovations Inc v. Fuse LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: California Innovations, Inc. (Ontario, Canada)
- Defendant: Fuse, LLC (Mississippi)
- Plaintiff’s Counsel: HAYNES AND BOONE, LLP
- Case Identification: 2:25-cv-3153, W.D. Tenn., 12/19/2025
- Venue Allegations: Venue is alleged to be proper in the Western District of Tennessee because Defendant Fuse, LLC resides in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Titan cooler product does not infringe Defendant's patent related to containers with integrated recesses for holding temperature-altering inserts, and further that the patent is invalid.
- Technical Context: The technology concerns insulated containers, such as soft-sided coolers, that incorporate features to hold removable functional components like ice packs.
- Key Procedural History: The complaint details extensive pre-suit correspondence initiated by Fuse, LLC, which accused California Innovations of infringement over an eight-month period. California Innovations alleges it provided detailed non-infringement and invalidity arguments to which FUSE did not substantively respond, creating the basis for an actual controversy sufficient for a declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2013-09-19 | ’235 Patent Priority Date |
| 2025-01-14 | ’235 Patent Issue Date |
| 2025-03-18 | FUSE sends first letter accusing California Innovations of infringement |
| 2025-05-07 | California Innovations responds with non-infringement and invalidity arguments |
| 2025-08-05 | FUSE reiterates infringement assertion |
| 2025-08-21 | California Innovations sends second letter denying infringement |
| 2025-10-20 | FUSE repeats infringement allegations |
| 2025-11-04 | California Innovations sends letter requesting substantive response |
| 2025-11-19 | FUSE responds via email repeating infringement assertion |
| 2025-12-19 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,195,235 - Container Apparatus and Method of Using Same
The Invention Explained
- Problem Addressed: The patent background describes a need for containers like insulated coolers or toolboxes to have removable functional accessories, such as lights or cooling elements, without requiring complex and expensive integrated wiring or permanent fixtures that are difficult to repair or service (’235 Patent, col. 2:45-58).
- The Patented Solution: The invention proposes a container with "at least one substantially concave recess formed in the interior surface" specifically designed to receive and releasably hold a functional insert assembly, such as a light or a temperature-altering element (’235 Patent, Abstract; col. 2:10-14). This design creates a built-in docking station for modular accessories. For example, Figure 1 depicts elongate recesses (31-34) formed in the interior corners of the container's sidewall to receive corresponding elongate members of an insert assembly (’235 Patent, Fig. 1; col. 7:15-24).
- Technical Importance: This approach allows for modular accessories to be securely held within a container during use while remaining easily removable for replacement, recharging, or cleaning, thereby enhancing functionality without the costs and serviceability issues of permanently integrated systems (’235 Patent, col. 8:21-34).
Key Claims at a Glance
- The complaint indicates that FUSE asserted independent claim 1 and dependent claims 2-7, 9, 11, and 12 pre-suit (Compl. ¶16). The complaint's substantive analysis focuses on independent claim 1.
- Essential elements of independent claim 1 include:
- A container apparatus comprising an enclosure and an insert assembly releasably retained within the enclosure,
- the enclosure defining an interior area for containing items and comprising a base, a sidewall, and a lid,
- wherein a substantially concave recess is formed in the enclosure and receives the insert assembly therein,
- the insert assembly comprising a temperature altering element. (Compl. ¶30).
III. The Accused Instrumentality
Product Identification
The "Titan by Arctic Zone Fridge Cold Lunch Box," referred to as the "Titan cooler" (Compl. ¶16).
Functionality and Market Context
The Titan cooler is a soft-sided lunch box that features two exterior zippered pockets designed to hold "Ice Walls®" ice packs (Compl. ¶31). The complaint includes a photograph of the Titan cooler showing an ice pack being inserted into one of these external pockets (Compl. p. 8). The stated purpose of placing the ice packs in external pockets is to "allow more room for food and drinks on the inside of the lunch box" (Compl. ¶38).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, outlining FUSE's alleged infringement theory and California Innovations' counterarguments. The analysis below summarizes the central dispute as framed by the complaint.
’235 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an enclosure defining an interior area for containing items therein | The main interior portion of the Titan cooler where food and beverages are placed. | ¶31 | col. 4:6-8 |
| an insert assembly... comprising a temperature altering element | The "Ice Walls®" ice packs provided with the Titan cooler. | ¶31 | col. 5:19-25 |
| a substantially concave recess is formed in the enclosure and receives the insert assembly therein | The exterior zippered pockets on the outside of the Titan cooler that receive the Ice Walls® ice packs. | ¶¶31, 35, 40 | col. 4:7-10 |
| releasably retained within the enclosure | The Ice Walls® ice packs being held by the exterior zippered pockets. | ¶34 | col. 3:29-31 |
Identified Points of Contention
- Scope Questions: The primary dispute concerns whether an "exterior zippered pocket" can satisfy the claim limitation "a substantially concave recess... formed in the enclosure." The complaint argues that the accused pockets are not "concave" but are "flat spaces" (Compl. ¶33), and critically, are not "in the enclosure" but are located on its exterior (Compl. ¶35). This raises a fundamental question of spatial scope. To illustrate this point, the complaint contrasts a photograph of the accused product's exterior pockets with Figure 1 from the '235 Patent, which depicts the claimed recesses as being inside the container (Compl. p. 8, p. 9).
- Technical Questions: A key technical question is what the term "formed in" requires. The complaint suggests that, in the context of the patent's disclosure of rigid structures, the term implies a molded, integral feature, which it alleges the soft-sided Titan cooler's sewn-on exterior pockets are not (Compl. ¶34).
V. Key Claim Terms for Construction
The Term: "substantially concave recess"
- Context and Importance: The definition of this term is critical, as the plaintiff contends the accused "exterior zippered pockets" are "flat spaces" and not "concave" (Compl. ¶33). The outcome of this construction could determine literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not provide a precise definition, which may support an argument that the term should be given its plain and ordinary meaning, potentially encompassing any indented space capable of receiving an object.
- Evidence for a Narrower Interpretation: The patent figures consistently depict the "recess" as an integral, molded indentation within a container's structure, such as in the corners or base ('235 Patent, Figs. 1, 3, 8, 25). Language describing the recess as "formed in the inner wall section" or "in the interior surface" may support a narrower construction requiring a specific shape and integral formation ('235 Patent, col. 7:15-16; col. 2:11-12).
The Term: "formed in the enclosure"
- Context and Importance: This term is central to the dispute over the location of the accused feature. The plaintiff argues that its exterior pockets are, by definition, not "in the enclosure" (Compl. ¶35). Practitioners may focus on this term because its spatial meaning appears dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "in" can mean "as a feature of" or "integrated with," rather than being strictly confined to the interior storage volume.
- Evidence for a Narrower Interpretation: The patent repeatedly describes the recess as being "formed in the interior surface of the enclosure" ('235 Patent, Abstract; col. 2:11-12; col. 4:7-9). Furthermore, Claim 1 requires the insert assembly to be retained "within the enclosure," which reinforces the interpretation that the recess holding it must also be located inside the enclosure's defined boundaries. The complaint highlights patent Figure 25, showing a recess formed in the interior surface of a lid, as further evidence that the invention contemplates internal, not external, features (Compl. p. 10).
VI. Other Allegations
Indirect Infringement
The complaint states that California Innovations has not contributed to or induced infringement, but it does not provide sufficient detail regarding FUSE's specific allegations of indirect infringement for analysis (Compl. ¶29).
Willful Infringement
The complaint does not address willfulness. Instead, it makes allegations that FUSE's pre-suit assertions were made in "bad faith" after being presented with non-infringement and invalidity arguments, which could form the basis for a motion for exceptional case status under 35 U.S.C. § 285 (Compl. ¶¶43-45; Prayer for Relief ¶C).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claim term "a substantially concave recess formed in the enclosure," which the patent specification consistently depicts as an integral feature of the container's interior, be construed to cover sewn-on, exterior pockets of a soft-sided cooler?
- A second central question involves the invalidity squeeze: if the claims are interpreted broadly enough to read on the accused exterior pockets, will that same broad construction cause the claims to be invalid as anticipated or rendered obvious by prior art that allegedly discloses coolers with external pockets for holding thermal items?