DCT
7:25-cv-00580
Cambria Co LLC v. Architectural Surfaces Group LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cambria Company LLC (Minnesota)
- Defendant: Architectural Surfaces Group LLC (Delaware)
- Plaintiff’s Counsel: Winston & Strawn LLP
- Case Identification: Cambria Company LLC v. Architectural Surfaces Group LLC, 7:25-cv-00580, W.D. Tex., 12/19/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant's principal place of business is located within the Western District of Texas and it has committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s engineered quartz slabs infringe three patents related to the appearance of processed slabs and the methods for their manufacture.
- Technical Context: The technology relates to manufacturing engineered stone surfaces with complex, repeatable veining patterns designed to emulate the aesthetic qualities of natural quarried stone.
- Key Procedural History: The complaint asserts compliance with statutory marking requirements for its own products that practice the asserted patents.
Case Timeline
| Date | Event |
|---|---|
| 2015-01-30 | Earliest Priority Date for All Patents-in-Suit |
| 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," issued February 5, 2019
The Invention Explained
- Problem Addressed: The patent’s background section notes that while quarried stone slabs are aesthetically appealing, they are expensive and limited to naturally occurring designs. It further states that existing engineered stones "fall noticeably short of the complicated look and texture of quarried stone" (’762 Patent, col. 1:35-37).
- The Patented Solution: The invention provides a synthetic molded slab product with complex veining patterns that emulate natural stone. The solution involves forming the slab from at least two different particulate mineral mixes that are placed in distinct regions but occupy the full thickness of the slab, creating a veined appearance that is visible even after the slab is cut or edged (’762 Patent, col. 6:61-65; Fig. 1). This allows for the mass production of slabs with consistent, repeatable, and aesthetically complex designs (’762 Patent, col. 2:56-61).
- Technical Importance: The technology enables the manufacture of engineered quartz slabs with consistent, predefined veining patterns that mimic the appearance of unique, high-end natural stone slabs (’762 Patent, col. 4:36-42).
Key Claims at a Glance
- The complaint asserts at least claim 22, which depends from independent claim 13 (Compl. ¶22).
- Essential elements of independent claim 13 include:
- A processed slab with a rectangular shape of at least 2 feet by 6 feet.
- The slab is composed of a first particulate mineral mix and a second, different particulate mineral mix, each comprising quartz and one or more binders.
- The first mix occupies the entire slab thickness at a "set of first regions."
- The second mix occupies the entire slab thickness at a "set of second regions."
- The first mix is absent from the second regions, and the second mix is absent from the first regions.
- The complaint’s use of "at least claim 22" may suggest an intent to assert other claims, including dependent claims, as the case develops (Compl. ¶22).
U.S. Patent No. 10,252,440 - "Processed Slabs, and Systems and Methods Related Thereto," issued April 9, 2019
The Invention Explained
- Problem Addressed: The patent addresses the same problem as its family member, the ’762 Patent: the difficulty of creating engineered stone that cost-effectively and repeatably mimics the complex visual texture of natural quarried stone (’440 Patent, col. 1:35-37).
- The Patented Solution: This patent claims the process for making the synthetic slabs. The core of the patented method is the sequential dispensing of different pigmented particulate mixes through complementary stencils into a mold. After the mixes are placed, they are vibrated and compacted to form the final slab (’440 Patent, col. 2:1-21; Fig. 7). This method ensures that the resulting patterns are repeatable across multiple slabs (’440 Patent, col. 4:11-18).
- Technical Importance: This process provides a systematic, repeatable manufacturing technique for producing engineered stone with intricate, through-body veining, a significant step beyond less predictable methods (’440 Patent, col. 4:11-18).
Key Claims at a Glance
- The complaint asserts independent claim 14 (Compl. ¶30).
- Essential elements of independent claim 14 include:
- A process of forming a processed slab.
- Sequentially dispensing at least a first and a second different pigmented particulate mineral mix into a slab mold.
- The first mix is dispensed into a "first set of regions" and the second mix is dispensed into a "second set of regions," with the regions being different.
- Vibrating and compacting the mixes to form a slab of at least 3 feet by 6 feet.
U.S. Patent No. 12,370,718 - "Processed Slabs, and Systems and Methods Related Thereto," issued July 29, 2025
- Patent Identification: U.S. Patent No. 12,370,718, "Processed Slabs, and Systems and Methods Related Thereto," issued July 29, 2025 (Compl. ¶14).
- Technology Synopsis: This patent claims a slab product characterized by its specific visual and structural features. It describes a "main interconnected material" that forms an "irregular branching channel configuration," which is in direct contact with a "plurality of interstitial material portions," creating a distinct veining pattern that is designed to emulate natural stone ('718 Patent, claim 9).
- Asserted Claims: Independent claims 1 and 9 (Compl. ¶38).
- Accused Features: The complaint alleges that the Accused Products, such as the "Atlas Ember" design, embody the claimed slab structure, including the background material and the plurality of veins that form specific patterns (Compl. ¶¶17-18, 38).
III. The Accused Instrumentality
Product Identification
The Accused Products are processed slabs sold under the "PentalQuartz" brand name, with the "Atlas Ember" design cited as a non-limiting example (Compl. ¶17).
Functionality and Market Context
- The Accused Products are engineered quartz slabs used for applications such as countertops and vanities (Compl. ¶7). The complaint provides a visual of the "Atlas Ember" design, which shows a slab with a light-colored body interspersed with prominent, dark, branching veins. This image of the accused "Atlas Ember" product shows a veined pattern on the slab's surface (Compl. p. 6).
- Plaintiff alleges that its own commercial success with products embodying the asserted patents prompted competitors to copy the patented designs, which is the alleged context for Defendant’s market entry with the Accused Products (Compl. ¶16).
IV. Analysis of Infringement Allegations
The complaint references but does not attach claim-chart exhibits. The following tables summarize the apparent infringement theories based on the complaint's narrative allegations, the patent claims, and the provided visual evidence.
U.S. Patent No. 10,195,762 Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A processed slab, comprising: a major surface defined by a set of particulate mineral mixes and having a rectangular shape that is at least 2 feet wide by at least 6 feet long... | The Accused Products are processed quartz slabs sold for use as countertops, which are rectangular and manufactured in standard slab dimensions. | ¶¶17, 22 | col. 6:55-58 |
| ...the major surface comprising a first particulate mineral mix and a second particulate mineral mix, the first and second particulate mineral mixes being different... | The "Atlas Ember" product visually depicts at least two different mixes: a light-colored background material (first mix) and a darker veining material (second mix). | ¶18, p. 6 | col. 6:58-61 |
| ...wherein the first particulate mineral mix occupies the entire slab thickness at a set of first regions, and wherein the second particulate mineral mix occupies the entire slab thickness at a set of second regions... | The complaint alleges that the Accused Products meet the elements of the claims, which suggests the different mixes extend through the entire thickness of the slab. | ¶¶17, 22 | col. 6:61-65 |
| ...the first particulate mineral mix being absent from the set of second regions and the second particulate mineral mix being absent from the set of first regions. | The visual appearance of the "Atlas Ember" product shows distinct regions where the background material is present and the veining material is absent, and vice versa. | ¶18, p. 6 | col. 7:1-4 |
- Identified Points of Contention:
- Structural Questions: A central technical question may be whether the veining material in the Accused Products in fact "occupies the entire slab thickness" as required by claim 13. The complaint does not provide evidence on the internal structure of the accused slabs, which could become a key point of dispute requiring expert analysis and discovery.
- Scope Questions: The definition of "a set of first regions" and "a set of second regions" may be contested. The infringement analysis will question whether the specific pattern of the "Atlas Ember" product maps onto the claimed structure, which is described in the patent as resulting from a specific stenciling process.
U.S. Patent No. 10,252,440 Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A process of forming a processed slab comprising, sequentially dispensing at least first and second pigmented particulate mineral mixes into a slab mold... | The complaint alleges that the Accused Products are "made with a process that infringes the '440 Patent," which implies the use of a sequential deposition process involving at least two different mixes. | ¶¶16, 30 | col. 14:15-18 |
| ...wherein the first pigmented particulate mineral mix is dispensed into the first set of regions of the slab mold, and the second pigmented particulate mineral mix is dispensed into the second set of regions... | The visible pattern of the "Atlas Ember" product is alleged to be the result of a process where different materials are placed into distinct, complementary regions of a mold. | ¶¶17, 18, 30 | col. 14:19-24 |
| ...vibrating and compacting the pigmented particulate mineral mixes arranged in the slab mold to form a processed slab that is generally rectangular and has a major surface with a width of at least 3 feet... | The complaint's allegation that Defendant infringes the process claim suggests that Defendant's manufacturing method includes industry-standard steps like vibration and compaction to create the final slab product. | ¶¶17, 30 | col. 14:26-31 |
- Identified Points of Contention:
- Evidentiary Questions: The '440 Patent claims a method of manufacture. A primary point of contention will be the evidence Plaintiff can produce to show that Defendant, or its suppliers, actually uses a process of "sequentially dispensing" materials through "stencils" (’440 Patent, claim 1), as opposed to another manufacturing method (e.g., printing, robotic deposition) that could achieve a visually similar outcome. The complaint does not detail the specific manufacturing process used for the Accused Products.
V. Key Claim Terms for Construction
For the ’762 Patent
- The Term: "occupies the entire slab thickness"
- Context and Importance: This term is critical to the scope of the product claim. The infringement analysis may turn on whether the veins in the Accused Products are merely superficial or if they extend completely from the top surface to the bottom surface of the slab.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's description that the method provides a "natural vein appearance even when the slab is cut and edged" supports a functional interpretation that the pattern must be consistent through the slab's depth to achieve this result (’762 Patent, col. 6:61-65).
- Evidence for a Narrower Interpretation: A defendant may argue that "entire" requires a mathematically perfect and uniform occupation of the vein material through the Z-axis of the slab, and that any deviation, tapering, or change in the pattern's internal structure would fall outside the scope of the claim.
For the ’440 Patent
- The Term: "dispensing ... through a ... stencil"
- Context and Importance: This term defines the specific manufacturing technique protected by the method claims. Practitioners may focus on this term because the infringement case depends on whether the defendant's actual manufacturing process uses a "stencil" as understood in the patent, or an alternative patterning technology.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes stencils as structures that define "complementary patterns of open spaces and occluded spaces" (’440 Patent, col. 3:24-26). A plaintiff may argue this term should cover any physical mask that serves this function.
- Evidence for a Narrower Interpretation: The patent’s figures depict large, physical templates that are laid over the entire mold (e.g., ’440 Patent, Figs. 2A, 3A). A defendant could argue the term "stencil" is limited to these specific embodiments and does not read on other methods like digitally-guided robotic deposition arms.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement for all three patents. The factual basis alleged is Defendant's active promotion of the sale, use, and importation of the Accused Products through marketing materials, web pages, and sales channels, which allegedly encourage infringing acts (Compl. ¶¶23-24, 31-32, 39-40).
Willful Infringement
Willfulness is alleged for all three patents based on Defendant’s knowledge of the patents and the alleged infringement from at least the date the complaint was filed. The allegations are based on post-suit conduct (Compl. ¶¶27-28, 35-36, 43-44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of evidentiary proof for the method claims: Can the plaintiff secure evidence through discovery demonstrating that the Accused Products are manufactured using the claimed process of "sequentially dispensing" materials "through a ... stencil," or will the defendant be able to show that its products are made by a different, non-infringing method?
- A key technical question will be one of internal product structure: For the product claims, does the veining in the accused slabs in fact "occupy the entire slab thickness" as required? The resolution of this issue will likely depend on expert testimony and analysis of physical product samples.
- The case may also raise a question of claim construction: How broadly will the court construe terms like "stencil" and "occupies the entire slab thickness"? The outcome of claim construction could be dispositive for both the method and product patent infringement analyses.