DCT
2:25-cv-01124
Kaprock Management LLC v. Home Depot USA Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Kaprock Management, LLC (Texas) and Eagle Industrial Group Inc. (California)
- Defendant: The Home Depot, Inc. (Delaware), Home Depot Product Authority, LLC (Georgia), and Home Depot U.S.A., Inc. (Delaware)
- Plaintiff’s Counsel: Gardella Alciati PA.
- Case Identification: 2:25-cv-01124, E.D. Tex., 11/14/2025
- Venue Allegations: Venue is alleged to be proper based on Defendants having a regular and established place of business within the district, specifically a retail store in Tyler, Texas, where acts of infringement have allegedly occurred.
- Core Dispute: Plaintiffs allege that Defendant’s HDX-branded steel wire storage rack infringes two U.S. design patents covering the ornamental appearance of a shelving unit, both with and without accompanying storage bins.
- Technical Context: The dispute concerns the ornamental design of consumer-grade home and garage organization products, a market where visual appearance and product differentiation are significant commercial drivers.
- Key Procedural History: The complaint alleges a sequence of events suggesting copying, including a competitor meeting where Plaintiff's product was photographed by a broker who also worked with Defendants, a subsequent warning to Plaintiff from that broker about infringing designs being manufactured for Defendants, and an initial limited "test run" of the accused product in Defendants' stores followed by a larger-scale product launch.
Case Timeline
| Date | Event |
|---|---|
| 2020-09-23 | D'165 and D'215 Patents Priority Date |
| 2024 | Eagle attends meeting where its product is allegedly photographed (Compl. ¶20) |
| 2024-07-23 | U.S. Design Patent D1,036,165 Issued |
| 2025-02 | Broker allegedly informs Eagle of infringing designs being produced (Compl. ¶21) |
| 2025-06 | Accused Product first observed in a Home Depot store (Compl. ¶22) |
| 2025-07-01 | U.S. Design Patent D1,081,215 Issued |
| 2025-10 | Eagle discovers Defendants resumed stocking the Accused Product (Compl. ¶23) |
| 2025-11-14 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D1,036,165 - "Shelving Unit"
- Patent Identification: D1,036,165, titled "Shelving Unit," issued July 23, 2024 (the “D’165 Patent”). (Compl. ¶29).
The Invention Explained
- Problem Addressed: Design patents protect ornamental appearance rather than solving a technical problem. The asserted design addresses the aesthetic challenge of creating a distinctive look for a common household item—a shelving unit. The complaint characterizes the commercial embodiment of the design as a "minimal, contemporary shelving system" that creates an "illusion of storage bins floating in air." (Compl. ¶16).
- The Patented Solution: The D’165 Patent claims the ornamental design for a shelving unit as depicted in its figures. (D’165 Patent, Figs. 1-6). The design consists of a wireframe rack with four vertical posts, a full wire shelf at the top and bottom, and two intermediate levels. These intermediate levels are not full shelves but rather pairs of horizontal rods designed to support the rims of storage bins, contributing to the "floating" appearance. (D’165 Patent, Fig. 1).
- Technical Importance: The commercial and aesthetic importance of the design is underscored by allegations that it gained significant social media attention, with one video reportedly reaching over 14 million views. (Compl. ¶17).
Key Claims at a Glance
- Design patents contain a single claim for the ornamental design as shown and described. (D’165 Patent, Claim). The core visual features of the asserted claim are:
- The overall rectangular, open-frame configuration.
- Four vertical support posts featuring repeating circumferential grooves.
- A full wire-grid shelf at the top and a matching full wire-grid shelf at the bottom.
- Two intermediate levels, each composed of parallel horizontal rods spanning the depth of the unit, configured to engage the lip of a bin rather than form a solid shelf surface.
U.S. Design Patent No. D1,081,215 - "Suspended Bin Rack"
- Patent Identification: D1,081,215, titled "Suspended Bin Rack," issued July 1, 2025 (the “D’215 Patent”). (Compl. ¶59).
The Invention Explained
- Problem Addressed: Similar to the D’165 Patent, the D’215 Patent protects an ornamental design, but its scope is different. It addresses the aesthetic of the shelving unit in combination with the storage bins it is designed to hold.
- The Patented Solution: The D’215 Patent claims the ornamental design for the combination of the rack and a set of suspended storage bins. (D’215 Patent, Figs. 1-14). Unlike the D’165 Patent, which claims the rack alone, this patent's claim includes the specific visual appearance of the bins (shown in solid lines) as they sit suspended on the intermediate support rods. The visual characteristics of the bins themselves—their proportions, lid design, and side indentations—are part of the claimed design. (D’215 Patent, Fig. 1).
- Technical Importance: The patent protects the overall visual impression of the complete, populated storage system, which is how the product is often marketed and sold. (Compl. ¶16).
Key Claims at a Glance
- The single claim covers the ornamental design for a suspended bin rack as shown and described. (D’215 Patent, Claim). The key visual features include:
- All the visual elements of the shelving unit from the D’165 Patent.
- The specific ornamental design of the storage bins, including their shape and lid configuration.
- The combined visual appearance of the bins being suspended by their rims on the rack's horizontal support rods.
III. The Accused Instrumentality
Product Identification
The "HDX Steel Wire Garage Storage Tote Rack," which is accused of infringement both as a standalone rack and in combination with storage totes. (Compl. ¶¶ 23-24).
Functionality and Market Context
The accused product is a metal wire shelving system sold in Home Depot stores and is designed for organizing storage totes in a garage or similar space. (Compl. ¶¶ 22, 32). The complaint provides a side-by-side comparison image of the accused rack and the D’165 Patent design. (Compl. p. 10). Another image shows the accused rack populated with black and yellow totes. (Compl. p. 16). Plaintiffs allege that Defendants are selling the accused product at a competitive price through the same wholesaler, posing a threat of price erosion and lost business opportunities. (Compl. ¶24).
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design.
D'165 Patent Infringement Allegations
| Key Ornamental Feature (from D'165 Patent) | Alleged Infringing Functionality | Complaint Citation |
|---|---|---|
| The overall visual impression of a rectangular, open-frame shelving unit. | The accused HDX rack is alleged to have the same or substantially identical overall design and appearance as the claimed shelving unit. | ¶32 |
| A full wire shelf at the top and bottom of the unit. | The side-by-side comparison image shows the accused product with a full wire shelf at the top and bottom. | p. 10 |
| Two intermediate levels, each composed of two horizontal support rods for suspending bins. | The visual evidence provided shows the accused rack incorporates two intermediate levels with a nearly identical horizontal rod configuration. | p. 10 |
D'215 Patent Infringement Allegations
| Key Ornamental Feature (from D'215 Patent) | Alleged Infringing Functionality | Complaint Citation |
|---|---|---|
| The combined ornamental design of the shelving unit and the storage bins together. | The accused products are alleged to be the same or substantially identical to the design claimed in the D'215 Patent. | ¶62 |
| The specific appearance of the bins suspended on the intermediate support rods by their rims. | A photograph in the complaint depicts the accused HDX rack with totes suspended in a visually similar manner to the patented design. | p. 16 |
| The ornamental design of the storage bins themselves, including their shape, proportions, and lid. | The complaint alleges that the accused combination of the HDX rack and its totes creates the same overall visual impression as the claimed design. | ¶63 |
- Identified Points of Contention:
- Scope Questions: A central question for the court will be whether the overall visual impression of the accused product is substantially the same as the patented designs. For the D’165 Patent, Defendants may argue that visual differences, such as the casters shown on the accused product (Compl. p. 10) but not in the patent, create a different overall appearance to an ordinary observer.
- Technical Questions: For the D’215 Patent, the dispute may focus on the specific design of the totes. The question will be whether the visual differences between the totes used with the accused HDX rack and the specific totes claimed in the patent are significant enough to avoid infringement in the eyes of an ordinary observer.
V. Key Claim Terms for Construction
Claim construction for design patents is atypical, as the figures themselves define the claim scope. However, disputes can arise over the interpretation of the design's overall appearance and the distinction between ornamental and functional features.
- The Term: "ornamental design for a shelving unit" and "ornamental design for a suspended bin rack"
- Context and Importance: The core of the case rests on the scope of the claimed ornamental designs. Practitioners may focus on whether the overall configuration is dictated by the function of holding standard-sized totes, which would narrow the scope of protection, or whether the specific visual execution creates a unique, non-functional aesthetic that the accused product misappropriates.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiffs may argue that the claim covers the overall aesthetic and visual impression of a minimalist rack with suspended bins, as shown in the patent figures. (D’165 Patent, Fig. 1; D’215 Patent, Fig. 1). They may contend that minor variations do not alter this fundamental protected design.
- Evidence for a Narrower Interpretation: Defendants may argue that the claim is limited to the precise visual details shown in the drawings, including specific proportions, wire patterns, and connection hardware. They may point to any visual difference in the accused product, however small, as evidence that it creates a different overall impression.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants induced infringement by instructing and encouraging customers to use the accused rack in an infringing manner through advertising, manuals, and other support materials. (Compl. ¶¶ 49-50, 79-80).
- Willful Infringement: Willfulness is alleged based on knowledge of the patents "by no later than the filing of this Complaint." (Compl. ¶¶ 36, 66). The complaint also alleges pre-suit knowledge, asserting that in February 2025 a broker informed Plaintiffs that Defendants' manufacturer was producing designs that "appeared to infringe." (Compl. ¶21). These allegations, if proven, may support a finding of deliberate or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of visual identity: applying the "ordinary observer" test, is the overall ornamental appearance of the accused HDX rack substantially the same as the design claimed in the D'165 Patent, or do minor differences, such as the presence of casters, create a distinct visual impression?
- A related question for the D’215 Patent will be the scope of the combination: is the ornamental design of the accused totes sold with the HDX rack sufficiently different from the totes depicted in the patent to create a different overall visual impression for the combined product, thereby avoiding infringement?
- A key factual question will center on evidence of intent: what evidence will discovery yield regarding the allegations that Defendants were aware of Plaintiffs' design and product before launching their own, and how might this evidence influence the analyses of willfulness and potentially infringement itself?