DCT
4:25-cv-00355
GoClips LLC v. Along Tools Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: GoClips LLC and Z Keepers LLC (Florida)
- Defendant: Along Tools, Inc. (Texas) and Rizhao Along Abrasive Tools Co., Ltd (People's Republic of China)
- Plaintiff’s Counsel: Pierson Ferdinand, LLP
- Case Identification: 4:25-cv-00355, S.D. Tex., 01/28/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants conduct regular business in the Southern District of Texas, a substantial part of the events giving rise to the action occurred in the district, and the case arises from acts of infringement committed within the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Quick Clips" sink anchoring devices infringe a patent related to clamps for undermounting sinks to hard countertop surfaces.
- Technical Context: The technology concerns mechanical hardware for the construction and remodeling industry, specifically devices that simplify the process of securing an undermount sink to the underside of a stone or solid-surface countertop.
- Key Procedural History: The complaint notes that prior to the patent's issuance, the Plaintiff's product packaging was marked "Patent Pending" and was updated to reflect the patent number after issuance, which may be relevant to marking requirements for damages.
Case Timeline
| Date | Event |
|---|---|
| 2014-12-10 | '754 Patent Application Filing Date |
| 2017-11-28 | '754 Patent Issue Date |
| 2025-01-24 | Date of Invoice for Accused Product |
| 2025-01-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,828,754 - "SINK CLAMP AND METHODS"
The Invention Explained
- Problem Addressed: The patent's background section identifies conventional methods of securing undermount sinks—such as drilling and using epoxy for threaded inserts, or hammering L-shaped clips—as time-consuming, difficult to perform in confined spaces, and risking damage to the countertop ('754 Patent, col. 1:11-64).
- The Patented Solution: The invention is a one-piece clamping device designed to be used with a pre-cut slot on the underside of the countertop. An "insertable end" or "binding lip" of the clamp inserts into the slot; a clamp screw is then tightened against the sink rim. This action causes the insertable end to bind within the slot, creating leverage that securely clamps the sink to the countertop, often with the aid of an integrated "clamping spring" to apply consistent force ('754 Patent, Abstract; col. 4:3-10; Fig. 1).
- Technical Importance: The described method aims to accelerate and simplify sink installation by eliminating the need for specialized on-site actions like drilling, gluing, or hammering into fragile countertop materials ('754 Patent, col. 6:61-65).
Key Claims at a Glance
- The complaint generally alleges infringement of the '754 Patent without specifying claims (Compl. ¶22). Independent claim 11, directed to the clamping device itself, is representative of the asserted technology.
- The essential elements of independent claim 11 are:
- A clamp body;
- An insertable end configured for upward insertion into a slot in a countertop;
- A clamping spring connected to the clamp body, which in a relaxed state has a deflectable portion extending at an upward angle;
- The deflectable spring portion is configured to contact a sink and be deflected to transmit an upward clamping force;
- The clamping spring has a hole and is connected to the clamp body by a fastener that is horizontally offset from the insertable end.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
The accused products are sink anchoring clamps named "Quick Clips," identified as "Small Quick Clips" (Item: AL0145) and "Large Quick Clips" (Item: AL0147) (Compl. ¶¶20-21).
Functionality and Market Context
The complaint alleges the "Quick Clips" are "knockoff devices" that are "identical in appearance, form and function" to Plaintiff's patented GoClips® products and are used to anchor undermount sinks (Compl. ¶¶5, 23). Plaintiff alleges these products are manufactured in China by Defendant Rizhao Along Abrasive Tools and imported, marketed, and sold in the U.S. by Defendant Along Tools, Inc. (Compl. ¶¶5, 6, 20). An image from Defendants' product catalog shows the accused devices (Compl. ¶21, Fig. at p. 9), and a sales invoice is provided as evidence of sale in the United States (Compl. ¶20, Fig. at p. 8).
IV. Analysis of Infringement Allegations
The complaint does not contain a formal claim chart. The following table summarizes the infringement theory based on the complaint's narrative allegations and supporting images.
'754 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a clamp body; | The primary structural component of the accused "Quick Clips" device. | ¶21, ¶22 | col. 4:14-17 |
| an insertable end of the clamp body, said insertable end being configured for insertion in an upward insertion direction into a slot in a bottom surface of a countertop...; | The upwardly bent tab on the accused "Quick Clips," which the complaint alleges is functionally identical to the patented device's means for engaging a countertop slot. A product image shows this feature (Compl. ¶21, Fig. at p. 9). | ¶21, ¶23 | col. 4:13-14 |
| a clamping spring connected to the clamp body, the clamping spring in a relaxed state including a deflectable portion extending at an upward angle...; | The angled metal component attached to the body of the accused device, which appears visually similar to the patented clamp's spring. Plaintiff's own marketing demonstrates this feature in use (Compl. ¶16, Fig. at p. 6). | ¶21, ¶23 | col. 4:54-56 |
| the deflectable spring portion...configured to contact a portion of the sink...and to be deflected by contact...to transmit an upward clamping spring force...; | The complaint alleges the accused products are identical in function, which includes contacting the sink to provide a clamping force (Compl. ¶5, ¶23). | ¶5, ¶23 | col. 5:1-10 |
| wherein the clamping spring has a hole and the clamping spring is connected to the clamp body by a fastener horizontally offset from the insertable end. | The product image of the "Quick Clips" shows a fastener (rivet) connecting the spring-like element to the body, and this fastener is located horizontally away from the insertable tab (Compl. ¶21, Fig. at p. 9). | ¶21, ¶22 | col. 4:50-53 |
Identified Points of Contention
- Technical Questions: A central question is whether the accused device's angled metal component performs the specific functions of a "clamping spring" as claimed—namely, being "deflected by contact" to "transmit an upward clamping spring force." The complaint relies on allegations of identical function and appearance without providing specific evidence of this deflection or force transmission.
- Scope Questions: The dispute may turn on whether the physical structure of the accused "Quick Clips" falls within the scope of the claim limitations. While visually similar, the court will need to determine if components like the "fastener" (a rivet in the accused product) and the "clamping spring" meet the definitions implicitly or explicitly provided in the '754 Patent.
V. Key Claim Terms for Construction
- The Term: "clamping spring"
- Context and Importance: This term is critical to the infringement analysis. The accused product has an angled metal piece attached to the body; whether this component meets the definition of a "clamping spring" that is "deflected...to transmit an upward clamping spring force" will likely be a core issue. Practitioners may focus on this term because Defendants could argue this component is merely a static bracket or standoff, not a dynamic spring as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification at times refers to the element as a "binding or clamping tab" ('754 Patent, col. 4:14-15), which could suggest a broader structural meaning. Dependent claim 8 further specifies the component as a "leaf spring," which could imply that the independent claim term "clamping spring" is intended to be broader than just that specific type.
- Evidence for a Narrower Interpretation: The claim language itself imposes functional requirements: the spring must have a "deflectable portion" and be "configured to...be deflected by contact...to transmit an upward clamping spring force" ('754 Patent, cl. 11). This functional language may support a narrower construction that requires the component to possess specific elastic properties and perform a dynamic, force-transmitting role.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges that the Defendants' products "have no alternate, non-infringing use," language that tracks the standard for contributory infringement (Compl. ¶35, ¶45).
- Willful Infringement: The complaint alleges that Defendants' infringement was "knowing, willful and deliberate" (Compl. ¶24). The basis for this allegation includes the assertion that the accused products are "near identical copies" of Plaintiff's patented devices and that Defendants were "placed on notice of the '754 patent" (Compl. ¶35, ¶36). The complaint does not specify the timing or method of this alleged notice.
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of functional proof: The complaint rests heavily on the assertion that the accused product is a "knockoff" that is "identical in...function." A central issue will be whether Plaintiff can provide evidence beyond visual similarity to demonstrate that the accused device's components actually perform the specific functions recited in the asserted claims, particularly the deflection and force-transmission of the "clamping spring."
- The case will likely involve a core issue of claim construction: The viability of the infringement claim may depend on whether the term "clamping spring" is construed broadly to cover the angled metal bracket on the accused device, or more narrowly to require specific, proven elastomeric and force-transmitting properties that the accused device may not possess.
- A significant factual dispute may concern willfulness: The complaint alleges Defendants had notice of the '754 Patent, a prerequisite for post-suit willfulness and potentially pre-suit willfulness. The circumstances surrounding this alleged notice—whether through a direct communication, knowledge of Plaintiff's patent-marked products, or other means—will be critical in determining if enhanced damages are a possibility.