Cambria Co LLC v. Caesarstone Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cambria Company LLC (Minnesota)
  • Defendant: Caesarstone Ltd. (Israel); Caesarstone USA, Inc. (California)
  • Plaintiff’s Counsel: Winston & Strawn LLP
• Case Identification: 3:25-cv-03494, N.D. Tex., 12/19/2025
• Venue Allegations: Venue is alleged to be proper for Caesarstone Ltd. as a foreign entity and for Caesarstone USA, Inc. based on a regular and established place of business, specifically a Dallas Distribution Center, within the judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s engineered quartz surface products infringe patents related to methods for manufacturing processed slabs with veined appearances that emulate natural stone.
• Technical Context: The dispute concerns the market for engineered stone slabs, a popular alternative to quarried stone like granite and marble for applications such as countertops, which relies on proprietary manufacturing processes to create complex and repeatable aesthetic patterns.
• Key Procedural History: No prior litigation, licensing history, or other significant procedural events between the parties are mentioned in the complaint.

Case Timeline

Date	Event
2014-01-01	Plaintiff Cambria introduces its Coastal Collection, which allegedly embodies the patented technology
2015-01-30	Earliest Priority Date for ’762, ’440, and ’718 Patents
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"

The Invention Explained

• Problem Addressed: The patent background describes the limitations of both quarried stone, which is expensive and has limited color schemes, and early engineered stone, which often failed to emulate the "complicated look and texture of quarried stone" (’762 Patent, col. 1:35-37).
• The Patented Solution: The invention is a processed slab and a method for making it that creates complex, repeatable veining patterns emulating natural stone. The solution involves sequentially dispensing two or more differently pigmented particulate mineral mixes (e.g., quartz and resin) into a mold using a series of complementary stencils (’762 Patent, col. 2:62-col. 3:19). This process ensures that each mix occupies the full thickness of the slab in its designated regions, creating veins that are visible even after cutting and polishing (’762 Patent, Fig. 6; col. 6:58-65). The complaint shows an image of a Cambria product that allegedly embodies this technology (Compl. p. 4).
• Technical Importance: The technology allows for the mass production of engineered stone slabs with consistent, complex, and natural-looking veining patterns, overcoming a key aesthetic limitation of earlier engineered materials (’762 Patent, col. 4:11-16).

Key Claims at a Glance

• The complaint asserts independent claim 22 (Compl. ¶25).
• The essential elements of claim 22 include:
  • A processed slab with a major surface defined by a set of particulate mineral mixes, having a rectangular shape of at least 2 feet by 6 feet.
  • The major surface comprises a first particulate mineral mix and a second, different particulate mineral mix.
  • The first mix occupies the entire slab thickness at a first set of regions, which includes a widthwise vein and a lengthwise vein.
  • The second mix occupies the entire slab thickness at a second set of regions.
  • The first mix is absent from the second regions, and the second mix is absent from the first regions.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

The Invention Explained

• Problem Addressed: The patent addresses the same technical problem as the ’762 Patent: the difficulty in creating repeatable, natural-looking veined patterns in engineered stone slabs (’440 Patent, col. 1:25-38).
• The Patented Solution: This patent focuses on the process of manufacturing the slabs. The claimed solution involves a multi-step method of sequentially dispensing different particulate mineral mixes through a series of stencils into a slab mold (’440 Patent, col. 2:25-56). After the mixes are dispensed according to predefined patterns, they are vibrated and compacted to form a cohesive slab with the desired veined appearance (’440 Patent, col. 2:50-54).
• Technical Importance: The patented process provides a systematic and repeatable manufacturing method for producing engineered stone slabs with complex aesthetics, enabling consistent quality control and appearance across many slabs (’440 Patent, col. 4:11-28).

Key Claims at a Glance

• The complaint asserts independent claim 14 (Compl. ¶33).
• The essential elements of claim 14 include:
  • A process of forming a processed slab by sequentially dispensing at least a first and a second pigmented particulate mineral mix into a slab mold.
  • The first mix is dispensed into a first set of regions.
  • The second mix, which is different from the first, is dispensed into a second set of regions that is different from the first.
  • The process includes vibrating and compacting the mixes in the mold to form a rectangular slab of at least 3 feet by 6 feet.
• The complaint does not explicitly reserve the right to assert dependent claims for this patent.

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

Technology Synopsis

This patent, part of the same family as the ’762 and ’440 patents, claims a slab product characterized by its specific vein structure. The claims describe a slab with a "main interconnected material" forming an irregular branching channel, and a plurality of "interstitial material portions" within that channel, creating a distinct visual pattern that extends through the thickness of the slab (’718 Patent, col. 14:4-24).

Asserted Claims

The complaint asserts independent claims 1 and 9 (Compl. ¶41).

Accused Features

The complaint alleges that the Accused Products, including the Calacatta Scoria design, embody the claimed slab structure with its background-defining pattern and plurality of veins (Compl. ¶20, ¶41).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are processed quartz slabs sold under the "Caesarstone" brand name, with the "Calacatta Scoria" design identified as a specific, non-limiting example (Compl. ¶20).

Functionality and Market Context

The Accused Products are engineered stone slabs used for countertops and other surfaces in homes and businesses (Compl. ¶10, ¶20). The complaint provides a visual of the accused Calacatta Scoria product, which displays a light-colored base material with dark, irregular, branching veins (Compl. p. 7). The complaint alleges that Defendant’s commercial activities were prompted by the success of Plaintiff’s patented products, suggesting the products compete in the same market for high-end engineered quartz surfaces (Compl. ¶19).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products infringe the Asserted Patents literally or under the doctrine of equivalents (Compl. ¶25, ¶33, ¶41). The complaint references exemplary claim charts attached as Exhibits D, E, and F, which were not provided with the complaint. The complaint does not provide sufficient detail for a tabular analysis of its infringement theories.

’762 Patent Infringement Allegations

The complaint alleges that Defendants infringe at least claim 22 of the ’762 Patent by making, using, importing, offering to sell, and selling the Accused Products (Compl. ¶25). The core of this allegation is that the Accused Products, such as the "Calacatta Scoria" slab shown in the complaint (Compl. p. 7), are processed slabs comprising at least two different particulate mineral mixes, where one mix forms a background and the other forms a veining pattern, with each mix occupying the entire thickness of the slab in its respective region, as recited in claim 22 (Compl. ¶20-21, ¶25).

’440 Patent Infringement Allegations

The complaint alleges that the Accused Products are made by a process that infringes at least claim 14 of the ’440 Patent (Compl. ¶19, ¶33). This process patent infringement allegation suggests that Defendants’ manufacturing method involves sequentially dispensing different mineral mixes into a mold and then vibrating and compacting them to form the final slab product (Compl. ¶33). The complaint asserts infringement under 35 U.S.C. § 271(g), which pertains to the importation of products made by a patented process (Compl. ¶33).

V. Key Claim Terms for Construction

’762 Patent

The Term: "occupies the entire slab thickness"

This term appears in claim 22 and is central to defining the three-dimensional structure of the claimed veins. Practitioners may focus on this term because the infringement analysis may turn on whether the veining material in the Accused Products extends fully from the front major surface to the rear major surface, or if it is a more superficial feature.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification does not appear to provide an explicit definition that would broaden the plain meaning. Parties arguing for a broader scope might contend that minor, incidental interruptions in the vein material through the thickness do not defeat the claim, as long as the vein substantially occupies the full thickness.
• Evidence for a Narrower Interpretation: The specification repeatedly emphasizes that the process results in veins that provide "a natural vein appearance even when the slab is cut and edged," which supports a requirement that the distinct mineral mixes extend through the full slab dimension to achieve this effect (’762 Patent, col. 6:61-65). Figure 6, showing a cut slab section, also depicts the veins (602, 606) extending through the entire thickness (610) from the top surface (612) to the bottom surface (614).

’440 Patent

The Term: "sequentially dispensing"

This term in process claim 14 defines the temporal relationship between the application of the different mineral mixes. The case may hinge on whether Defendant's manufacturing process involves distinct, ordered steps of dispensing the background material and the vein material, as the term "sequentially" suggests.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: A party could argue "sequentially" does not require a complete stop-and-start process, and could cover processes with some temporal overlap, as long as the dispensing of the second mix begins after the first.
• Evidence for a Narrower Interpretation: The patent describes a process where a first mix is dispensed through a first stencil, that stencil is removed, and a second stencil is positioned before the second mix is dispensed (’440 Patent, col. 12:20-47; Fig. 7). This detailed description of discrete, ordered steps may support a narrower construction requiring a clear separation in time between the dispensing acts.

VI. Other Allegations

Indirect Infringement

The complaint alleges active inducement of infringement for all three patents. The basis for these allegations is that Defendants "actively promote the sale, use, and importation of the Accused Products in marketing materials and web pages" and through sales and distribution channels that encourage infringing acts (Compl. ¶27, ¶35, ¶43).

Willful Infringement

Willfulness is alleged for all three patents. The complaint asserts that Defendants had knowledge of the patents "since at least the filing of this Complaint" and continued their infringing activities despite this knowledge, rendering the infringement willful, intentional, and deliberate (Compl. ¶30-31, ¶38-39, ¶46-47).

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

1. A central question will be one of structural scope: Does the veining material in Caesarstone’s "Calacatta Scoria" and other accused slabs in fact "occupy the entire slab thickness" as required by the product claims of the ’762 Patent, or is it a feature with a different physical structure?
2. A key evidentiary issue will concern the accused manufacturing process: Do Defendants employ a method of "sequentially dispensing" different particulate mineral mixes through separate stencils, as claimed in the ’440 Patent, or does their process achieve a veined look through a different technique that falls outside the claim scope?
3. A further question of definitional scope will arise under the ’718 Patent: Can the visual pattern of the Accused Products be properly characterized as a "main interconnected material" forming an "irregular branching channel" that contains separate "interstitial material portions," or does the claim language describe a specific topology that the accused design does not possess?