DCT
4:24-cv-04864
PTO Solutions LLC v. C&K Mfg Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: PTO Solutions, LLC, et al. (Texas)
- Defendant: C&K Manufacturing, Inc., et al. (Texas/New Mexico)
- Plaintiff’s Counsel: Cabello Hall Zinda, PLLC
- Case Identification: 4:24-cv-04864, S.D. Tex., 12/11/2024
- Venue Allegations: Venue is alleged to be proper in the Southern District of Texas because Defendants have committed acts of patent infringement, including manufacturing and selling infringing products, in the district and maintain a regular place of business there.
- Core Dispute: Plaintiffs allege that Defendants’ quick-connect tractor power take-off (PTO) couplers are "copycat products" that infringe a patent covering Plaintiffs' own PTO Link™ system.
- Technical Context: The technology concerns mechanical couplers designed to simplify the difficult and often strenuous process of attaching agricultural implements to a tractor's power take-off shaft.
- Key Procedural History: The complaint alleges a prior business relationship where Defendant C&K Manufacturing, owned by Defendant Cedric Williams, served as a machine shop and drafting service for Plaintiffs starting in 2017. Plaintiffs allege this relationship gave Defendants access to proprietary designs and knowledge, which they later used to create competing products. The complaint also includes a count to correct the inventorship of a separate patent, U.S. Patent No. 11,746,831, which was filed by Defendant Williams and allegedly claims subject matter conceived by Plaintiff Kenneth Spector.
Case Timeline
| Date | Event |
|---|---|
| 2017-03-02 | U.S. Patent No. 11,313,417 Priority Date |
| 2017 | Plaintiffs engage Defendant C&K Manufacturing |
| 2019-07 | C&K begins providing drafting services to Plaintiffs |
| 2020-08-04 | Earliest alleged instance of consumer confusion |
| 2021-03-29 | Defendant Williams files application for '831 Patent |
| 2022-04-26 | U.S. Patent No. 11,313,417 Issues |
| 2022-08-11 | Alleged date of Plaintiffs' notice of infringement to Defendants |
| 2023-09-05 | U.S. Patent No. 11,746,831 Issues |
| 2024-12-04 | Copyright registrations for "Copyrighted Works" become effective |
| 2024-12-11 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,313,417 - "Tractor PTO Quick-Connect Device and Method of Use"
- Patent Identification: U.S. Patent No. 11,313,417, "Tractor PTO Quick-Connect Device and Method of Use," issued April 26, 2022 (the "’417 Patent").
The Invention Explained
- Problem Addressed: The patent’s background describes the difficulty, time, and frustration associated with manually securing implements to a tractor's Power Take-Off (PTO) shaft, a process that often occurs in confined areas and requires precise alignment (’417 Patent, col. 1:26-39).
- The Patented Solution: The invention is a two-part quick-release system. A first body, which attaches to the tractor's PTO shaft, features a series of shaped slots. A second body, which attaches to the implement, has a corresponding series of extensions. The two bodies can be quickly coupled by inserting the extensions into the slots and rotating the parts to a locked position, allowing them to transfer rotational power as a single unit (’417 Patent, Abstract; col. 3:30-52). This design is intended to make the connection process "rapid and effective" (’417 Patent, col. 1:35-37).
- Technical Importance: The technology aims to replace the conventional, strenuous, and often imprecise manual method of connecting PTO-driven implements with a safer and more efficient mechanical coupling system (Compl. ¶¶17-18; ’417 Patent, col. 1:26-39).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 8, 9, 11, and 12 (Compl. ¶¶43, 63).
- Independent Claim 1 recites the following essential elements:
- A first body having a first outer surface and a second outer surface and a first thickness disposed therebetween;
- A plurality of slots defined on the first body;
- A second body having a third outer surface and a fourth outer surface and a second thickness disposed therebetween;
- A plurality of extensions extending from the second body, configured to removably engage with the plurality of slots, and wherein the first and second bodies are configured to rotate together via this engagement;
- A housing secured to the first body and configured to removably engage with the tractor PTO shaft, the housing comprising a plurality of grooves; and
- An implement spline extending from the second body, configured to removably engage with an implement.
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are various models of a device called the "PTO Connect," including the PTO Connect Standard Adapter, Standard Easy Max Adapter, Universal Adapter, and Modified Adapter (Compl. ¶36).
Functionality and Market Context
- The complaint alleges the Accused Products are two-part couplers for tractor PTO shafts, where one connector attaches to the tractor and the other to the implement (Compl. ¶44). Marketing materials for the Accused Products, shown in the complaint, state that the "system prevents the need to twist the PTO shaft to line-up the splines" (Compl. p. 11). An image provided in the complaint depicts the accused device disassembled into a "First Body (left), Second Body (right)," illustrating its two-part construction (Compl. p. 14). The complaint alleges these products are "copycat products" intended to compete directly with Plaintiffs' PTO Link devices, leveraging a nearly identical trade name and mimicking product features, color schemes, and even lists of incompatible tractor models (Compl. ¶¶35, 50-53).
IV. Analysis of Infringement Allegations
’417 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first body having a first outer surface and a second outer surface... | The Accused Products allegedly have a first body, shown as the left-hand component in a product image. | ¶44 | col. 3:30-40 |
| a plurality of slots defined on the first body; | The first body of the Accused Products allegedly has a plurality of slots, described in the complaint as "the gaps between the teeth on the first body." | ¶44 | col. 3:41-47 |
| a second body having a third outer surface and a fourth outer surface... | The Accused Products allegedly have a second body, shown as the right-hand component in a product image. | ¶44 | col. 3:32-35 |
| a plurality of extensions extending from the second body, wherein the plurality of extensions are configured to removably engage with the plurality of slots; wherein the first body and the second body are configured to rotate together... | The second body allegedly has extensions that rotatably engage with the slots of the first body to transfer torque. | ¶44 | col. 3:45-52 |
| a housing secured to the first body and configured to removably engage with the tractor PTO shaft; wherein the housing comprises a plurality of grooves within the housing; | The first body allegedly "removably engages with the PTO shaft." An annotated close-up image points to the internal part of the first body that engages a "Standard Length PTO Output Shaft." | ¶44; p. 14 | col. 6:55-60 |
| an implement spline extending from the second body, wherein the implement spline is configured to removably engage with an implement... | The spline of the second body allegedly "removably engages with the implement tool." | ¶44 | col. 6:52-55 |
Identified Points of Contention
- Structural Questions: The claim recites "a housing secured to the first body." The patent specification and figures arguably depict the housing (203) and the first plate/body (209) as distinct components that are joined together ('417 Patent, Fig. 2; col. 6:18-22). A potential issue for trial is whether the accused product’s first component is a single, integrated piece or if it contains a distinct "housing" that is "secured to" a "first body" as claimed. A defense may arise if the accused structure is unitary, which may not meet this limitation.
- Scope Questions: The complaint characterizes the claimed "plurality of slots" as being met by "the gaps between the teeth on the first body" of the accused product (Compl. ¶44). This raises the question of whether a mere "gap" between protrusions constitutes a "slot" as defined and described in the patent, which details "teardrop, oblong, asymmetrical, or tapered openings or slots" ('417 Patent, col. 3:41-43).
V. Key Claim Terms for Construction
- The Term: "a housing secured to the first body"
- Context and Importance: This term is critical because it defines the structure of the tractor-side component of the device. The infringement analysis may turn on whether "secured to" requires two separate, physically attached components or if it can also read on a single, integrally formed part. Practitioners may focus on this term because if the accused product is a unitary component, it may not infringe this element of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party arguing for a broader view (i.e., that "secured to" can include integral formation) might contend that the terms "housing," "body," and "plate" are used to describe functional aspects of a single component, not necessarily physically separate pieces.
- Evidence for a Narrower Interpretation: The specification describes "joining or attaching at connection 232 to the body or receiver 207" ('417 Patent, col. 6:18-20). The use of terms like "joining" or "attaching," along with figures that label the housing (203) and first plate (209) with distinct reference numbers, may support an interpretation that the claim requires two separate components that are subsequently fixed together.
VI. Other Allegations
- Indirect Infringement: The complaint’s patent infringement count focuses on direct infringement under 35 U.S.C. § 271(a) (Compl. ¶63). However, the complaint includes extensive factual allegations that could potentially support a claim for induced infringement, such as screenshots of Defendants’ websites and marketing materials which allegedly instruct customers on how to use the Accused Products to achieve the patented result (Compl. pp. 11, 15).
- Willful Infringement: Willfulness is explicitly alleged. The claim is based on alleged pre-suit notice of the ’417 Patent sent to Defendants on or before August 11, 2022 (Compl. ¶64). The willfulness allegation is further supported by the narrative of a prior business relationship and deliberate, "copycat" conduct, including mimicking product lines and marketing materials (Compl. ¶¶32-35, 50-53). A side-by-side comparison image shows that Defendants' product allegedly uses the same red trim as Plaintiffs' corresponding model (Compl. p. 20).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to be driven by allegations of wholesale copying arising from a soured business relationship. The central questions for the court will likely be:
- A primary factual question will be one of copying and intent: to what extent does the evidence of the parties’ prior relationship, and the similarities in product design, branding, and marketing, demonstrate that Defendants deliberately copied Plaintiffs' patented invention? This will be central to the willfulness claim.
- A core legal issue will be one of structural identity: does the accused product’s construction literally meet every element of claim 1? Specifically, does the tractor-side component of the accused device consist of "a housing secured to the first body," as arguably required by the claim language and patent figures, or is it a single, unitary part that falls outside the claim’s scope?