Stellar Industries Inc v. Faf TX Depot LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Stellar Industries, Inc. (Iowa)
  • Defendant: FAF TX Depot, LLC d/b/a Service Truck Depot (Texas)
  • Plaintiff’s Counsel: Brown, Winick, Graves, Gross and Baskerville, P.L.C.; Spencer Fane LLP
• Case Identification: 5:25-cv-00056, E.D. Tex., 11/05/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant resides in Texas and a substantial part of the events giving rise to the claims, specifically the operation of a service truck retail business, occurred in the district.
• Core Dispute: Plaintiff alleges that Defendant’s custom work truck beds infringe a patent related to side packs featuring integrated tracks for mounting equipment and accessories.
• Technical Context: The technology relates to storage and equipment-mounting systems for utility and service vehicles, a market where modularity and the ability to securely and flexibly attach tools, cranes, and other hardware are significant functional attributes.
• Key Procedural History: The operative complaint is a Second Amended Complaint, suggesting prior pleadings were amended, potentially to refine allegations or add claims.

Case Timeline

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

• Patent Identification: U.S. Patent No. 12,043,218, "SIDE PACK WITH CHANNELS," issued July 23, 2024 (the "’218 Patent").
• The Invention Explained:
  • Problem Addressed: The patent’s background section describes a drawback of conventional utility vehicle side packs: mounting equipment like cranes requires drilling holes into the top panel. If the equipment needs to be moved or replaced, new holes must be drilled, and the old holes must be plugged to protect the side pack’s contents from the environment, a process that is inefficient and compromises the structure. (’218 Patent, col. 1:39-57).
  • The Patented Solution: The invention is a side pack for a utility vehicle that incorporates channels or tracks directly into its top panels. These tracks are configured with lips that can engage securing members (e.g., threaded nuts), allowing equipment to be clamped down securely. This system permits equipment to be attached, repositioned, or removed without drilling, providing a modular and non-destructive mounting platform. (’218 Patent, Abstract; col. 2:18-22; Fig. 11A-11E).
  • Technical Importance: This approach provides a reconfigurable and structurally sound method for mounting various accessories onto service trucks, enhancing their versatility and preserving the integrity of the storage compartments. (’218 Patent, col. 2:1-4).
• Key Claims at a Glance:
  • Asserted Independent Claim(s): 1
  • Claim 1 of the ’218 Patent recites the following essential elements:
    • 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.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

• Product Identification: The accused products are the "Boxcar 55 Series custom work truck beds" and associated "side packs" (collectively, "Boxcar 55"). (Compl. ¶11, ¶20).
• Functionality and Market Context:
  • The complaint alleges that the Boxcar 55 side packs are of a similar nature, form, and purpose as those sold by Plaintiff. (Compl. ¶20). The key technical feature identified is a "top panel with parallel tracks." (Compl. ¶21.h).
  • The complaint positions the accused Boxcar 55 as being in direct competition with Plaintiff’s products, alleging they have the "same or similar forms, purposes, look, and feel." (Compl. ¶20).

IV. Analysis of Infringement Allegations

• No probative visual evidence provided in complaint.
• Claim Chart Summary: The complaint alleges infringement through conclusory statements rather than a detailed element-by-element breakdown. The following chart synthesizes the core allegations against Claim 1 of the ’218 Patent.

’218 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Questions: The complaint alleges the accused product has "parallel tracks" but provides no details regarding their structure. A primary question will be evidentiary: do the accused tracks have a "substantially C-shaped cross-section" with "lips configured to engage... securing members" as required by the claim? The complaint provides no specific facts to support this crucial limitation.
  • Scope Questions: The interpretation of "attached to" may become a central issue. The court will need to determine whether this term requires two separate components to be joined (e.g., by welding or bolting) or if it can also read on tracks that are integrally formed as a single piece with the top panel.

V. Key Claim Terms for Construction

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

  • Context and Importance: This term defines the core functional geometry of the patented tracks. Infringement will hinge on whether the accused Boxcar 55 tracks meet this structural definition. Practitioners may focus on this term because any significant deviation in the shape of the accused tracks could be a basis for a non-infringement argument.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of "substantially" indicates that the shape does not need to be a perfect geometric 'C'. The specification discloses alternative track embodiments, such as elongated protrusions (552, 554), which could support a construction that focuses on the functional presence of lips for engagement rather than a strict C-shape. (’218 Patent, Fig. 14).
    • Evidence for a Narrower Interpretation: The primary embodiment shows a distinct C-shape with inwardly curved lips. (’218 Patent, Fig. 6). A defendant may argue that the term should be construed as being limited to this disclosed shape or ones very similar to it, excluding other track profiles like T-slots.

• The Term: "attached to"

  • Context and Importance: This term is critical to defining the structural relationship between the tracks and the top panel. The method of manufacture of the accused product—whether the tracks are separate components added to the panel or are formed as part of the panel itself—will determine the importance of this term's construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discloses an embodiment where the "top panel 110 and the first side wall 105 may be formed as a single integral piece through a casting process." (’218 Patent, col. 7:12-14). This could support an argument that "attached to" is a broad term of relationship that includes integral formation.
    • Evidence for a Narrower Interpretation: The detailed description of the primary embodiments repeatedly describes the tracks (510, 520) as separate components that are "inserted into" channels in the top panel and then connected via means like welding. (’218 Patent, col. 4:51-61; Fig. 7A). This might support a narrower construction requiring two distinct components being joined.

VI. Other Allegations

• Indirect Infringement: The complaint does not provide sufficient detail for analysis of indirect infringement.
• Willful Infringement: The complaint alleges that Plaintiff "gave written notice to Defendant of its unlawful activities" and that Defendant's continued use of the accused design is "wanton[], vexatiously, intentionally, and willfully" done. (Compl. ¶36). This allegation appears to be based on pre-suit knowledge derived from the written notice.

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

• A key evidentiary question will be one of structural identity: does the accused Boxcar 55 product, alleged only to have "parallel tracks," actually incorporate tracks with the "substantially C-shaped cross-section" required by Claim 1? The complaint’s lack of specific technical allegations on this point makes it a central vulnerability and a likely focus of discovery.
• The case may also turn on a core issue of claim construction: will the term "attached to" be interpreted broadly to include tracks that are integrally formed with a top panel, or will it be limited to the joining of separate components? The resolution of this question could be dispositive depending on the manufacturing process of the accused product.