DCT

5:25-cv-00056

Stellar Industries Inc v. Faf TX Depot LLC

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:25-cv-00056, E.D. Tex., 11/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in Texas and a substantial part of the events giving rise to the claims occurred in the judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s custom work truck beds infringe its trade dress for distinctive side packs, constituting unfair competition and false designation of origin.
  • Technical Context: The dispute centers on the design features of side-mounted storage compartments ("side packs") used on utility and service trucks, a key component in the work truck industry.
  • Key Procedural History: The complaint does not assert any patents. It alleges that Plaintiff provided Defendant with written notice of its allegedly unlawful activities prior to filing suit. A patent document related to the same technology area was provided for this analysis but is not asserted in the complaint.

Case Timeline

Date Event
1990-01-01 Plaintiff Stellar Industries founded
2013-05-24 U.S. Patent No. 12,043,218 Priority Date
2024-07-23 U.S. Patent No. 12,043,218 Issue Date
2025-02-03 Defendant allegedly began offering the accused "Boxcar 55" product
2025-11-05 Complaint Filing Date

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

The complaint does not assert any patents. The following analysis is of a patent provided for technical context, U.S. Patent No. 12043218.

U.S. Patent No. 12043218 - "SIDE PACK WITH CHANNELS"

Issued July 23, 2024 (the ’218 Patent).

The Invention Explained

  • Problem Addressed: The patent describes a problem in the conventional art of mounting equipment, such as cranes, onto the top panels of utility truck side packs. The conventional method requires drilling holes into the top panel for nuts and bolts, meaning that relocating the equipment necessitates drilling new holes and plugging the old ones, which can compromise the side pack's integrity and protection from the environment (’218 Patent, col. 1:33-57). Furthermore, conventional flat top panels have a "relatively low section modulus" and thus "low resistance to bending loads," often requiring extra structural reinforcement (’218 Patent, col. 7:36-43).
  • The Patented Solution: The invention proposes a side pack with a top panel that includes integrated channels. Within these channels, tracks are installed. These tracks feature a C-shaped cross-section with lips that can engage securing members (e.g., a nut that can be turned 90 degrees to lock under the lips). This system allows equipment to be mounted, secured, and repositioned by sliding it along the tracks without drilling new holes (’218 Patent, Abstract; ’218 Patent, col. 5:1-14; ’218 Patent, Figs. 9A-9D). The channels also structurally reinforce the top panel, increasing its resistance to bending (’218 Patent, col. 7:41-43).
  • Technical Importance: This approach provides a non-destructive and adjustable method for mounting heavy equipment, increasing the flexibility and durability of utility truck systems (’218 Patent, col. 6:11-15).

Key Claims at a Glance

The complaint does not assert any claims of the ’218 Patent. For context, independent claim 1 is presented below.

  • Independent Claim 1:
    • A side pack for a vehicle comprising:
    • a top panel having a horizontal plane;
    • a first track attached to the horizontal plane of the top panel, the first track having a substantially C-shaped cross-section having a first lip and a second lip configured to engage first securing members; and
    • a second track attached to the horizontal plane of the top panel, the second track having a substantially C-shaped cross section having a third lip and a fourth lip configured to engage second securing members, wherein the first track and the second track are parallel to one another.

III. The Accused Instrumentality

Product Identification

Defendant's "Boxcar 55 Series custom work truck beds" and their associated side packs (Compl. ¶11).

Functionality and Market Context

The complaint alleges that Defendant manufactures, uses, distributes, and sells work trucks and utility vehicles featuring the accused side packs (Compl. ¶12). The allegations focus on the visual and design features of the side packs, which are alleged to be "nearly identical" and have the "same general visual appearance" as Plaintiff's products, competing directly with them in the marketplace (Compl. ¶¶21-22). The complaint does not describe the technical functionality of the Boxcar 55 side packs beyond their external appearance.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not allege patent infringement and therefore provides no basis for an infringement analysis or claim chart against the ’218 Patent or any other patent. The causes of action are limited to trade dress infringement, unfair competition, and false designation of origin under the Lanham Act (Compl. ¶¶3, 13-40).

V. Key Claim Terms for Construction

As the complaint does not allege patent infringement, there is no active dispute over claim construction. In a hypothetical infringement action involving the ’218 Patent, practitioners would likely focus on the following terms from independent claim 1.

  • The Term: "substantially C-shaped cross-section"

  • Context and Importance: This term defines the core functional geometry of the track that enables securing members to be captured. The scope of "substantially" will be critical to determining whether tracks with different but functionally similar profiles (e.g., U-shaped, V-shaped, or with non-parallel walls) would infringe.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests other shapes are contemplated, stating the track "may have another shape such as, but not limited to, a U, V, X, or L shape" (’218 Patent, col. 4:37-39). This could support a construction that is not strictly limited to a classic "C" shape but covers other geometries that perform the same capturing function.
    • Evidence for a Narrower Interpretation: The figures, such as Figure 6, consistently depict a distinct C-shape with curved lips (518, 519) that engage a securing member (’218 Patent, Fig. 6). An accused infringer might argue that "C-shaped" requires this specific structure with inwardly-curved lips, as distinguished from other track designs.

  • The Term: "attached to the horizontal plane of the top panel"

  • Context and Importance: This limitation describes the relationship between the track and the top panel. Its construction is key to determining whether infringement occurs if a track is integrated within a channel below the primary horizontal plane, versus being mounted directly on top of it.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language is simple and does not specify how the track is attached (e.g., on top of, inside of, welded, bolted). This may support a broad reading covering any form of connection to the panel's main plane. The specification also discloses embodiments where tracks are inserted into channels formed within the top panel itself (’218 Patent, Fig. 7A; ’218 Patent, col. 4:41-44).
    • Evidence for a Narrower Interpretation: A defendant might argue that "attached to the horizontal plane" requires a direct surface-to-surface connection, distinguishing it from systems where the track is seated within a recessed channel and is not co-planar with the primary top surface. The phrase could be argued to exclude integrally formed track features.

VI. Other Allegations

  • Indirect Infringement: The complaint does not allege indirect patent infringement.
  • Willful Infringement: The complaint alleges that Defendant's infringement of Plaintiff's trade dress is willful (Compl. ¶27, ¶40). The basis for this allegation is that "Stellar gave written notice to Defendant of its unlawful activities and yet Defendant continues to wantonly, vexatiously, intentionally, and willfully use the Boxcar 55 design" (Compl. ¶36).

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

As this is a trade dress case, not a patent case, the central questions for the court will not involve claim construction or technical infringement. The key questions will be:

  • A core issue will be one of protectability: has the Plaintiff's combination of design features for its side packs—such as its specific lock, drip rails, hinges, and fenderette—acquired the necessary secondary meaning in the marketplace to function as a source-identifier and thus constitute protectable trade dress?
  • A central factual question will be one of functionality: are the specific design elements claimed as trade dress primarily functional, or are they arbitrary and non-functional flourishes intended to distinguish the product's appearance? The complaint asserts the combination is non-functional (Compl. ¶17), a point likely to be contested.
  • A key evidentiary question will be one of consumer confusion: does the Defendant’s "Boxcar 55" design create a likelihood of confusion among consumers as to the source or affiliation of the products, as required to prove trade dress infringement?