4:25-cv-04954
Component Mfg Corp v. Rectorseal LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Component Manufacturing Corp. (Texas)
- Defendant: RectorSeal, LLC (Delaware)
- Plaintiff’s Counsel: Bowick & Laney, PLLC
- Case Identification: 4:25-cv-04954, S.D. Tex., 10/17/2025
- Venue Allegations: Venue is alleged to be proper in the Southern District of Texas because Defendant has a regular and established place of business in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s tankless water heater drain pan infringes a design patent covering the ornamental appearance of a basin.
- Technical Context: The dispute concerns plumbing accessories, specifically drain pans used with modern tankless water heaters to prevent water damage from leaks or drips.
- Key Procedural History: The complaint alleges that Defendant was notified of the patent-in-suit and its alleged infringement on August 8, 2025, prior to the filing of the lawsuit. It also includes emails from third-party industry participants dated in September and October 2025, which allegedly demonstrate that the accused product is "nearly identical" to Plaintiff's product.
Case Timeline
| Date | Event |
|---|---|
| 2021-06-22 | U.S. Patent No. D989,939 Priority Date (Application Filing) |
| 2023-06-20 | U.S. Patent No. D989,939 Issued |
| 2025-08-08 | Plaintiff allegedly informed Defendant of infringement |
| 2025-09-05 | Email from industry participant noting similarity of products |
| 2025-10-02 | Second email from industry participant noting similarity of products |
| 2025-10-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. D989,939 - "Basin"
The Invention Explained
- Problem Addressed: The complaint states that prior drain basins for tankless water heaters required a "high back wall," and the inventor sought to create a "unique drain basin" specifically for this type of heater (Compl. ¶¶11-12).
- The Patented Solution: The patent protects the specific ornamental design for a basin. The design, as illustrated in the patent's figures, features a rectangular pan with rounded front corners, a low, uniform-height back wall, and a distinctive undulating or ribbed pattern on its front and bottom surfaces (D989,939 Patent, Figs. 1-7). The complaint emphasizes the "low back" as a key design feature (Compl. ¶12).
- Technical Importance: The complaint alleges this was the "first" such low-back design for a tankless water heater drain pan and that it "gained industry recognition" (Compl. ¶¶12-13).
Key Claims at a Glance
- The single claim of the patent is asserted.
- The claim states: "The ornamental design for a basin, as shown and described" (D989,939 Patent, p. 3).
III. The Accused Instrumentality
Product Identification
- RectorSeal's "Tankless Water Heater Drain Pan" (the "Accused Product") (Compl. ¶14).
Functionality and Market Context
- The Accused Product is described as an "easy and inexpensive way to prevent water damage" by catching leaks, spillage, or drips from a tankless water heater (Compl. p. 6). The complaint includes a product data sheet for the Accused Product. This data sheet shows an image of the drain pan, which is a key piece of visual evidence (Compl. p. 6). The complaint alleges that Defendant copied Plaintiff's design to "capitalize on its hard work" after Plaintiff's product became commercially successful (Compl. ¶14).
IV. Analysis of Infringement Allegations
Design patent infringement is assessed from the perspective of an "ordinary observer." The central question is whether this observer, familiar with the prior art, would be deceived into believing the accused design is the same as the patented design. The complaint alleges that the Accused Product's design is "substantially the same" as the design protected by the ’939 Patent (Compl. ¶16).
The complaint presents several images to support its infringement theory. A photograph of what is described as Plaintiff's commercial embodiment is shown adjacent to FIG. 1 from the ’939 Patent, illustrating the patented design (Compl. p. 4). A separate product data sheet provides a clear image of the Accused Product (Compl. p. 6). A visual comparison of these images suggests a similar overall shape, low back wall, and ribbed features on the front and bottom surfaces. The complaint further supports its claim of substantial similarity by including emails from third parties who allegedly observed that the Accused Product is an "almost an exact replica" and "nearly identical" to Plaintiff's product (Compl. p. 7).
- Identified Points of Contention:
- Scope Questions: The primary question for the court will be whether an ordinary observer would find the overall visual impression of the Accused Product to be substantially the same as the claimed design in the ’939 Patent. The analysis will focus on the design as a whole, not on a direct comparison of isolated features.
- Technical Questions: A potential issue may be the extent to which features of the basin are dictated by function versus ornamental choice. For example, a court may have to consider whether elements like the rectangular shape, drain placement, or mounting holes are primarily functional and should therefore be given less weight in the infringement analysis.
V. Key Claim Terms for Construction
In design patent litigation, there are typically no textual "terms" to construe as in utility patent cases. The single claim covers the "ornamental design ... as shown and described" (D989,939 Patent, p. 3). The scope of the claim is therefore defined by the visual appearance of the basin depicted in the patent's drawings. The analysis will not focus on defining words but on interpreting the overall visual impression conveyed by the solid lines in the patent's figures. The complaint does not provide sufficient detail for analysis of any specific disputed visual elements.
VI. Other Allegations
- Indirect Infringement: The complaint does not allege indirect infringement.
- Willful Infringement: The complaint alleges willful infringement based on two main assertions. First, it alleges Defendant has a "history of copying products in the plumbing industry" (Compl. ¶18). Second, and more specifically, it alleges that Defendant had actual knowledge of the ’939 Patent and its infringement as of August 8, 2025, but "undaunted, has continued to offer for sale and sell its Accused Product" (Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to center on straightforward, though potentially fact-intensive, questions of design patent law. The key issues for the court will likely be:
- A core issue will be one of visual comparison: Applying the "ordinary observer" test, is the overall ornamental design of RectorSeal’s drain pan substantially the same as the design claimed in the ’939 Patent, such that a purchaser would be deceived? The emails included in the complaint suggest Plaintiff will argue that actual confusion or perceived identity exists in the market.
- A second issue will be the role of functionality: To what extent, if any, are the shared design features between the patented design and the Accused Product dictated by the function of a drain pan for a tankless water heater? The answer may influence the scope of protection afforded to the patented design.
- A third issue relates to remedies and willfulness: If infringement is found, a key question will be whether Plaintiff can prove willfulness based on Defendant’s alleged continuation of sales after receiving notice of infringement. This could lead to enhanced damages. Furthermore, the claim for Defendant’s "total profits" under 35 U.S.C. § 289, a remedy unique to design patents, will be a central focus of the damages phase.