Cambria Co LLC v. LX Hausys Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cambria Company LLC (Minnesota)
  • Defendant: LX Hausys, Ltd. (Korea); LX Hausys America, Inc. (New Jersey)
  • Plaintiff’s Counsel: Winston & Strawn LLP
• Case Identification: 3:25-cv-03493, N.D. Tex., 12/19/2025
• Venue Allegations: Venue for the foreign parent company, LX Hausys, Ltd., is alleged to be proper in any judicial district. Venue for the U.S. subsidiary, LX Hausys America, Inc., is based on its alleged "regular and established place of business" within the district, specifically a warehouse and showroom in Flower Mound, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s "Viatera" brand of engineered quartz slabs infringes three patents related to the methods and systems for manufacturing processed slabs with complex, veined appearances.
• Technical Context: The technology at issue involves methods for creating engineered quartz surfaces with intricate striations and veining patterns designed to emulate the aesthetic of natural quarried stone, a key feature in the market for countertops and other surfaces.
• Key Procedural History: The complaint alleges that the asserted patents are embodied in Plaintiff's "Coastal Collection" products, which have been marked with the relevant patent numbers. It also notes that one of the patents-in-suit recites only method claims, which may affect the analysis of damages and marking requirements.

Case Timeline

Date	Event
2014-01-01	Cambria launches initial Coastal Collection designs
2015-01-30	Priority Date for ’762, ’440, and ’718 Patents
2016-01-01	Cambria introduces additional Coastal Collection designs
2017-03-01	Cambria adds Beaumont and Kelvingrove to Coastal Collection
2019-02-05	U.S. Patent No. 10,195,762 issues
2019-04-09	U.S. Patent No. 10,252,440 issues
2025-07-29	U.S. Patent No. 12,370,718 issues
2025-12-19	Complaint Filed

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

U.S. Patent No. 10,195,762 - "Processed Slabs, and Systems and Methods Related Thereto," issued February 5, 2019

The Invention Explained

• Problem Addressed: The patent’s background section notes that while quarried stone slabs are aesthetically appealing, they are expensive and limited in color. It states that existing engineered stones "fall noticeably short of the complicated look and texture of quarried stone" (’762 Patent, col. 1:22-37).
• The Patented Solution: The invention provides a system and method for creating synthetic slabs with repeatable, complex veining. The process involves sequentially dispensing two or more differently colored particulate mineral mixes (e.g., quartz and resin) into a single slab mold using a series of complementary stencils. (’762 Patent, Abstract; col. 2:27-46). This creates distinct regions of color that extend through the slab's thickness, producing a final product that emulates the aesthetic of natural stone after being compacted, cured, and polished (’762 Patent, Fig. 7).
• Technical Importance: This technology allows for the industrial-scale production of engineered stone slabs with consistent and complex aesthetic patterns, offering a customizable alternative to naturally variable and expensive quarried stone (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts at least independent claim 22 (Compl. ¶25).
• Essential elements of claim 22 include:
  • A processed slab with a major surface of a specified minimum size (at least 2 feet wide by 6 feet long).
  • The slab is composed of at least a first and a second different particulate mineral mix.
  • The first mix occupies the entire slab thickness at a "set of first regions," which includes "a first vein in a generally width-wise direction" and "a second vein in a generally lengthwise direction."
  • The second mix occupies the entire slab thickness at a "set of second regions."
  • The first mix is absent from the second regions, and the second mix is absent from the first regions.
• It is standard practice for plaintiffs to reserve the right to assert additional claims, including dependent claims, as a case proceeds.

U.S. Patent No. 10,252,440 - "Processed Slabs, and Systems and Methods Related Thereto," issued April 9, 2019

The Invention Explained

• Problem Addressed: The ’440 Patent, which shares a specification with the ’762 Patent, addresses the same technical problem of creating engineered stone that convincingly mimics the complex appearance of natural stone (’440 Patent, col. 1:24-37).
• The Patented Solution: Rather than claiming the final slab product, this patent claims the process of manufacturing it. The claimed method involves "sequentially dispensing" different pigmented particulate mixes through different stencils into distinct regions of a slab mold, followed by "vibrating and compacting" the mixes to form the final slab (’440 Patent, Abstract; col. 2:25-58).
• Technical Importance: By claiming the manufacturing method, the patent provides a different basis for enforcement against competitors, including protection against the importation of products made abroad using the patented process.

Key Claims at a Glance

• The complaint asserts at least independent claim 14 (Compl. ¶33).
• Essential elements of claim 14 include:
  • A process of forming a processed slab.
  • "Sequentially dispensing" at least a first and a second different pigmented particulate mineral mix into a slab mold.
  • The first mix is dispensed into a "first set of regions" and the second mix is dispensed into a "second set of regions," with the sets of regions being different.
  • "Vibrating and compacting" the mixes to form the slab, which has a major surface of a specified minimum size (at least 3 feet wide by 6 feet long).
• It is standard practice for plaintiffs to reserve the right to assert additional claims.

U.S. Patent No. 12,370,718 - "Processed Slabs, and Systems and Methods Related Thereto," issued July 29, 2025

Technology Synopsis

The ’718 Patent, part of the same patent family, addresses the same problem of emulating natural stone. It claims a slab product defined by its structural and visual characteristics, specifically a "main interconnected material" that forms an "irregular branching channel configuration" and a "plurality of interstitial material portions" located within that channel, where the two materials provide a "noticeable contrast" (’718 Patent, col. 14:4-24).

Asserted Claims

Independent claims 1 and 9 (Compl. ¶41).

Accused Features

The complaint alleges that the structure and appearance of the Accused Products, such as the veining pattern of the "Calacatta Affogato" design, directly infringe the claimed slab configuration (Compl. ¶¶20, 41).

III. The Accused Instrumentality

Product Identification

• The complaint identifies processed slabs sold under the "Viatera" brand name, with the "Calacatta Affogato" design cited as a specific, non-limiting example of an Accused Product (Compl. ¶20).

Functionality and Market Context

• The Accused Products are engineered quartz surfaces used for applications such as countertops and vanities (Compl. ¶10). The complaint alleges that these products are manufactured, imported, and sold by the Defendants in the United States (Compl. ¶19). The complaint provides a full-slab view of an exemplary Accused Product, displaying a white or light gray background with prominent, dark, branching veins (Compl. p. 7). The plaintiff alleges that its own commercial success with its patented designs prompted competitors to copy them (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint references, but does not attach, claim charts detailing its infringement theories (Compl. ¶¶25, 33, 41). The narrative allegations are summarized below.

’762 Patent Infringement Allegations (Claim 22)

The complaint alleges that the Accused Products are processed slabs that meet all limitations of claim 22 (Compl. ¶25). The core of this theory is that the Accused Products, such as the "Calacatta Affogato" slab, possess a major surface composed of at least two different mineral mixes. One mix allegedly forms the background, while the other forms a veining pattern that includes components extending in both "generally width-wise" and "generally lengthwise" directions, consistent with the claim language. The visual evidence in the complaint shows a complex, branching vein network that traverses the slab in multiple directions (Compl. p. 7).

’440 Patent Infringement Allegations (Claim 14)

The complaint alleges that the Accused Products are made by a process that infringes claim 14 of the ’440 Patent, thus giving rise to liability for importation under 35 U.S.C. § 271(g) (Compl. ¶33). The plaintiff alleges on information and belief that the Defendants' manufacturing process involves the claimed steps of sequentially dispensing different pigmented quartz mixes into separate regions of a mold, followed by vibration and compaction (Compl. ¶¶19, 33).

Identified Points of Contention

• Scope Questions: The infringement analysis for the ’762 Patent may focus on the claim term "a first vein in a generally width-wise direction... and a second vein in a generally lengthwise direction." A question for the court could be whether an irregular, interconnected vein network, as depicted in the Accused Product, satisfies this limitation, or if the claim requires two structurally distinct and separable veins.
• Technical Questions: For the ’440 method patent, a key question will be evidentiary. What evidence does the complaint provide that the accused manufacturing process, which occurs abroad, uses the claimed "sequentially dispensing" and stencil-based method, as opposed to an alternative method for creating veined patterns that would not infringe?

V. Key Claim Terms for Construction

The Term: "a first vein in a generally width-wise direction... and a second vein in a generally lengthwise direction" (from claim 22 of the ’762 Patent)

Context and Importance

This term is central to defining the structure of the claimed product. Its construction will be critical to determining infringement, as the Defendant may argue its products feature a single, random, branching vein network that does not resolve into the two distinct directional veins required by the claim.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification's stated goal is to emulate "the complex striations and veining patterns... of a quarried stone slab," which are naturally irregular (’762 Patent, col. 2:54-56). The use of the modifier "generally" may suggest that the vein directions need not be perfectly orthogonal or straight, potentially covering segments of a single branching network.
• Evidence for a Narrower Interpretation: The patent's figures and description of the stencil-based manufacturing process show the creation of distinct, patterned regions of material (’762 Patent, Figs. 2A-3B, col. 8:28-67). This could support an argument that the claimed "first vein" and "second vein" must correspond to these separate, predefined patterns and cannot be merely portions of a single, randomly formed network.

The Term: "sequentially dispensing" (from claim 14 of the ’440 Patent)

Context and Importance

This term defines the temporal nature of the claimed manufacturing process. Infringement depends on whether the accused process involves discrete, ordered steps of depositing different materials, as opposed to a process where materials are deposited simultaneously or as a single blended mixture.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The term could be construed broadly to mean simply "not at the same time." The system diagram in Figure 4 depicts a continuous production line where a mold moves from a first distributor to a second, which could be a rapid sequence, supporting a broader meaning than two entirely separate events (’440 Patent, Fig. 4).
• Evidence for a Narrower Interpretation: The detailed description of the process in the specification outlines a series of discrete actions: dispensing a first mix, removing a first stencil, positioning a second stencil, and then dispensing a second mix (’440 Patent, col. 12:24-41). This language may support a narrower construction requiring distinct, separated steps with intervening actions.

VI. Other Allegations

Indirect Infringement

• The complaint alleges active inducement of infringement for all three patents. The stated basis is that Defendants encourage infringement by third parties through "marketing materials and web pages on the LX Hausys website, and through Defendants' sales and distribution channels" that promote the sale and use of the Accused Products (Compl. ¶¶27, 35, 43).

Willful Infringement

• Willfulness is alleged for all asserted patents based on Defendants' continued infringing activities after having "actual knowledge of the... Patent and their infringement thereof" from "at least the filing of this Complaint" (Compl. ¶¶30, 38, 46). The complaint does not allege pre-suit knowledge.

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

• A core issue will be one of definitional scope: Can the geometric language of the ’762 Patent, requiring distinct "width-wise" and "lengthwise" veins, be construed to read on the irregular, branching vein network of the accused "Calacatta Affogato" product, or is there a fundamental mismatch in the claimed structure versus the accused design?
• A key evidentiary question will be one of process proof: For the ’440 method patent, what evidence can be obtained through discovery to substantiate the allegation that the accused products, manufactured overseas, are made using the claimed "sequentially dispensing" multi-stencil process, rather than an alternative, non-infringing method for creating veins?