DCT
4:25-cv-00077
Ring Container Tech LLC v. CKS Packaging Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ring Container Technologies, LLC (Tennessee)
- Defendant: C.K.S. Packaging, Inc. (Georgia)
- Plaintiff’s Counsel: Kilpatrick Townsend & Stockton LLP
- Case Identification: 4:25-cv-00077, N.D. Tex., 01/29/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the district, specifically a manufacturing plant in Fort Worth, and has committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s “container-in-box” packaging systems infringe two patents related to ergonomic designs for large plastic containers.
- Technical Context: The technology concerns large-format packaging for liquids, such as edible oils, designed to improve ergonomics and allow users to pour contents withoutremoving the inner container from its protective outer box.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of infringement of the patents-in-suit on September 13, 2024. It also notes that a key customer of the accused products, Marina Foods, is a former customer of the Plaintiff, a fact that may be used to support allegations of copying.
Case Timeline
| Date | Event |
|---|---|
| 2006-09-25 | '503 & '939 Patent Priority Date |
| 2010-06-01 | '503 Patent Issue Date |
| 2013-02-05 | '939 Patent Issue Date |
| 2024-09-13 | Plaintiff provides Defendant with notice of infringement |
| 2025-01-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,726,503, “Ergonomic Plastic Container and Package System,” issued June 1, 2010
The Invention Explained
- Problem Addressed: The patent describes a problem with conventional large containers, which can be difficult for a user to handle for both carrying and pouring, especially when heavy. Furthermore, composite packaging systems often require the inner container to be removed from its protective outer box to be used, which is inconvenient and negates the benefits of the box (’503 Patent, col. 1:28-46).
- The Patented Solution: The invention is a packaging system comprising an inner container with specific ergonomic features housed in an outer box. The container features a primary front-to-back handle, a second transverse handle (creating a "T-shape"), and a grip on the container's bottom. The outer box has corresponding openings that expose these handles and the grip, allowing a user to carry and pour from the container without removing it from the box (’503 Patent, Abstract; col. 2:7-24).
- Technical Importance: This design allows a heavy, bulk container to remain supported and protected by its outer box during dispensing, improving stability, handling, and ergonomic function (’503 Patent, col. 4:35-42).
Key Claims at a Glance
- The complaint asserts one or more claims, including exemplary Claim 29, but provides a detailed infringement analysis for independent Claim 21 (Compl. ¶¶26, 28).
- Essential elements of independent Claim 21 include:
- A packaging comprising a "container in a box."
- The container must have a top, bottom, sides, a spout, a "first handle portion" (extending front-to-back), a "second handle portion" (extending transverse to the first), and a bottom "grip."
- The box must have a top cover, bottom cover, and side portions, with "one or more openings on the top cover" to expose the spout and second handle portion, and an "opening in the bottom cover" to expose the bottom grip.
- The complaint reserves the right to assert additional claims (Compl. ¶26).
U.S. Patent No. 8,365,939, “Ergonomic Plastic Container and Package System,” issued February 5, 2013
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’503 patent, this patent addresses the same ergonomic and usability challenges with large-format packaging (’939 Patent, col. 1:40-52).
- The Patented Solution: This invention refines the concept, focusing on the interaction between the box and a single handle on the container. It describes a packaging system where the box top has a "U-shape opening." This opening is positioned so its open end faces the container's spout, and its closed end is located over the distal end of the container's handle, creating a feature that is "configured to be grasped by one hand" (’939 Patent, Abstract; col. 6:1-8).
- Technical Importance: This configuration provides an integrated solution where the box itself helps form the functional handle access, enabling the "pour-in-box" capability with a specific structural arrangement (’939 Patent, col. 1:53-58).
Key Claims at a Glance
- The complaint asserts one or more claims, including exemplary independent Claim 1 (Compl. ¶¶44, 46).
- Essential elements of independent Claim 1 include:
- A packaging comprising a container (with a top, spout, and a "first handle portion") disposed inside a box.
- The box comprises a "box top" and a "U-shape opening in the box top."
- The "U-shape opening" must have an open end that "opens toward the spout."
- The "U-shape opening" must have a "closed end" that is "at or near the distal end of the first handle portion" and is "configured to be grasped by one hand."
- The complaint reserves the right to assert additional claims (Compl. ¶44).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Accused Products" as packaging and containers manufactured and sold by Defendant C.K.S. Packaging, Inc. (Compl. ¶20). A specific example provided is the container and packaging system used by third-party Marina Foods for its "MARINA® Pure Peanut Oil 2.5 gallon product," which is alleged to be a "copy" of Plaintiff's own product (Compl. ¶¶18, 21). The complaint also identifies Defendant's "35 # Handle Oil - 9505" product from its website (Compl. ¶24, p. 8).
Functionality and Market Context
The Accused Products are described as "container in a box" systems for bulk liquids (Compl. ¶29). A photograph shows Defendant's accused "35 # Handle Oil - 9505" bottle is manufactured at its Fort Worth, TX plant (Compl. p. 8). The complaint alleges that Defendant’s customer, Marina Foods, is a former customer of Plaintiff, positioning the dispute in a context of direct competition (Compl. ¶21). Photographs in the complaint depict a plastic jug within a cardboard box that has cutouts aligned with the jug's spout and handle structures (Compl. ¶¶29, 47).
IV. Analysis of Infringement Allegations
'503 Patent Infringement Allegations
| Claim Element (from Independent Claim 21) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A packaging comprising: a container in a box; | The accused product is a packaging system comprising a plastic container disposed within a cardboard box. A photograph shows the accused container inside the accused box (Compl. p. 10). | ¶29 | col. 2:7-8 |
| the container comprising: a top; a bottom; sides...; a spout; | The accused container is alleged to have a top, bottom, sides, and a spout. Photographs with labels point to the top and front side (Compl. p. 10) and the spout (Compl. p. 11). | ¶¶30-31 | col. 3:1-4 |
| a first handle portion on the top and extending generally in the direction front to back; | The accused container has a handle portion alleged to extend from front to back, as depicted in a labeled photograph (Compl. p. 11). | ¶32 | col. 3:4-6 |
| a second handle portion on the top and extending in a direction transverse to the first handle portion, wherein the second handle portion is configured to be grasped by one hand; | The accused container has a portion of its handle structure that extends transversely to the first handle portion, which the complaint alleges is a second handle portion. A labeled photograph shows this feature (Compl. p. 12). | ¶33 | col. 3:6-9 |
| a grip for manually gripping on the bottom of the container; | The accused container's bottom surface includes a recessed area alleged to be a grip, as shown in a labeled photograph of the container's underside (Compl. p. 12). | ¶34 | col. 3:9-10 |
| the box comprising: ...one or more openings on the top cover that exposes the spout...and for accessing the second handle portion... | The accused box has a top opening that exposes the container's spout and handle structure for gripping. A photograph illustrates this top opening (Compl. p. 13). | ¶36 | col. 2:17-23 |
| an opening in the bottom cover that exposes the bottom grip. | The accused box has a bottom opening that exposes the container's bottom grip. A photograph shows this bottom opening and the underlying grip (Compl. p. 14). | ¶37 | col. 2:23-24 |
'939 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A packaging comprising: a container comprising: a container top; a spout; and a first handle portion extending away from the spout... | The accused product includes a container with a top, a spout, and a handle. A labeled photograph shows the container top and spout within the box (Compl. p. 16). | ¶47 | col. 5:17-21 |
| the packaging further comprising a box, wherein the container is disposed inside of the box... | The accused container is shown disposed inside the accused box. A labeled photograph identifies both the container and the box (Compl. p. 17). | ¶49 | col. 5:22-24 |
| the box comprising: a box top; and a U-shape opening in the box top; | The top of the accused box is alleged to have a "U-shape opening." A photograph shows the top of the box with a cutout, which is labeled as the "U-Shape Opening" (Compl. p. 18). | ¶50 | col. 6:1-2 |
| wherein an open end of the U-shape opening opens toward the spout; and wherein a closed end of the U-shape opening is at or near the distal end of the first handle portion and is configured to be grasped by one hand. | The opening in the accused box top is shown with its open side facing the spout and its closed side located over the container handle, allegedly for grasping. A labeled photograph illustrates this orientation (Compl. p. 18). | ¶51 | col. 6:3-8 |
Identified Points of Contention
- Structural Questions: A likely point of dispute for the '503 patent is whether the accused container's integrated, T-shaped handle constitutes both a "first handle portion" and a "second handle portion" as recited in the claim, or if it is a single, unitary handle. For the '939 patent, the analysis may turn on whether the accused box's rectangular cutout meets the geometric and functional requirements of a "U-shape opening."
- Functional Questions: Regarding the '939 patent, a key question will be whether the closed end of the accused opening is "configured to be grasped by one hand" in the manner claimed. The complaint asserts this functionality, but it remains a factual question for the court to resolve based on evidence of the product's design and use.
V. Key Claim Terms for Construction
The Term: "a second handle portion ... extending in a direction transverse to the first handle portion" (’503 Patent, Claim 21)
- Context and Importance: The infringement case for the ’503 patent depends on mapping two distinct claim elements—a "first" and "second" handle portion—onto the accused product's single, integrated T-shaped handle. Practitioners may focus on this term because Defendant could argue that its product has only one handle, not the two distinct portions required by the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states that "the first handle portion and the second handle portion may be connected to form a 'T'-shape" (’503 Patent, col. 2:63-65). This language suggests that an integrated, T-shaped structure falls within the scope of the invention.
- Evidence for a Narrower Interpretation: The use of separate terms, "a first handle portion" and "a second handle portion," could imply two structurally distinct or separately identifiable components. A defendant might point to the discrete numbering of these features in the patent's figures (e.g., handle 8 and handle 9 in Fig. 1) to argue that they must be more than just different vectors of a single molded piece.
The Term: "a U-shape opening" (’939 Patent, Claim 1)
- Context and Importance: This term is central to the ’939 patent infringement allegation, as the specific geometry and function of the box cutout are claimed. The dispute will likely focus on whether the accused product's cutout, which appears somewhat rectangular in the complaint's photograph (Compl. p. 18), can be properly characterized as "U-shape."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "U-shape opening." Plaintiff may argue that any opening that is open on one side (towards the spout) and closed on the other (forming a graspable boundary over the handle) meets the functional and contextual meaning, regardless of whether its corners are rounded or square. Fig. 5 of the patent shows opening 15 as having a generally rectangular appearance.
- Evidence for a Narrower Interpretation: The term "U-shape" has a common geometric meaning that implies a curved bottom. A defendant could argue that if the accused product's opening has sharp, 90-degree corners, it is rectangular or square, not U-shaped, and therefore does not meet the literal claim language.
VI. Other Allegations
Indirect Infringement
The complaint alleges both induced and contributory infringement for both patents. The allegations state Defendant provides the Accused Products to customers (e.g., Marina Foods) with the knowledge and intent that they will be combined with other products and resold, thereby causing direct infringement by those customers (Compl. ¶¶38, 52). Contributory infringement is alleged on the basis that the products are especially made for an infringing use and have no substantial non-infringing uses (Compl. ¶¶39, 53).
Willful Infringement
Willfulness is alleged for both patents based on Defendant’s awareness of the patents "since at least September 2024," the date Plaintiff allegedly sent a notice letter (Compl. ¶¶40, 54). The complaint’s repeated assertion that the accused product is a "copy" of Plaintiff's patented product further supports the claim of deliberate and willful conduct (Compl. ¶18).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction and structural interpretation: can the specific claim terms "second handle portion" (’503 patent) and "U-shape opening" (’939 patent) be construed to read on the physical structures of the accused product? The case may turn on whether an integrated T-handle embodies two distinct "portions" and whether a rectangular cutout can be considered "U-shaped" in the context of the patent.
- A key question of fact will revolve around the allegations of copying. The complaint establishes a narrative that Defendant, a competitor, began supplying a "copy" of Plaintiff's product to one of Plaintiff's former customers. Evidence supporting or refuting this narrative will likely be critical for the jury's assessment of secondary infringement claims and, especially, willfulness and potential enhanced damages.