Cambria Co LLC v. Arizona Tile LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cambria Company LLC (Minnesota)
  • Defendant: Arizona Tile LLC (Delaware)
  • Plaintiff’s Counsel: Winston & Strawn LLP
• Case Identification: 7:25-cv-00581, W.D. Tex., 12/19/2025
• Venue Allegations: Venue is alleged based on Defendant having a regular and established place of business within the district, specifically a tile showroom and slab warehouse located in Austin, Texas.
• Core Dispute: Plaintiff alleges that Defendant’s processed quartz slab products infringe patents related to the ornamental design and manufacturing methods for creating synthetic stone with complex, natural-looking vein patterns.
• Technical Context: The technology concerns the manufacturing of engineered quartz surfaces, a significant material in the market for countertops and architectural finishes, designed to emulate the aesthetic qualities of high-end quarried stone like marble.
• Key Procedural History: No significant procedural history is mentioned in the complaint.

Case Timeline

Date	Event
2015-01-30	Earliest Priority Date for ’762, ’440, and ’718 Patents
2017	Defendant's accused Austin Showroom opens
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 (e.g., granite, marble) 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. 1:21-37).
• The Patented Solution: The invention is a synthetic molded slab and a method for its creation that produces repeatable, complex veining patterns. The process involves sequentially dispensing two or more differently pigmented mineral mixes into a mold through a series of complementary stencils, which define where each mix is placed (’762 Patent, Abstract; col. 2:21-55). This technique creates slabs with intricate striations that can extend through the entire thickness of the slab, thereby closely emulating the appearance of natural stone (’762 Patent, col. 6:58-64).
• Technical Importance: This technology provides a manufacturing system for producing engineered quartz slabs with consistent, predefined, and complex visual patterns that were previously difficult to achieve at scale, offering an alternative to the variability and cost of natural quarried stone (’762 Patent, col. 4:9-14).

Key Claims at a Glance

• The complaint asserts independent claim 22 (Compl. ¶ 22).
• The essential elements of claim 22 are:
  • A processed slab with a rectangular shape of at least 2 feet by 6 feet.
  • The slab's major surface comprises a first and a second different particulate mineral mix.
  • The first mix occupies the entire slab thickness in a set of "first regions" which include a "first vein in a generally widthwise direction" and a "second vein in a generally lengthwise direction."
  • The second mix occupies the entire slab thickness in a set of "second regions."
  • The first mix is absent from the second regions, and the second mix is absent from the first regions.

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 technical problem as the ’762 Patent: the difficulty in manufacturing engineered stone that convincingly and repeatably emulates the complex veining of natural quarried stone (’440 Patent, col. 1:25-39).
• The Patented Solution: This patent focuses specifically on the process for creating the slabs. The claimed method involves sequentially dispensing a first pigmented mineral mix through a first stencil into a mold, followed by dispensing a second, different mix through a second stencil into the remaining regions of the mold (’440 Patent, col. 2:25-40). The combined mixes are then subjected to vibration and compaction to form the final, hardened slab with its predefined pattern (’440 Patent, col. 2:48-56; Fig. 7).
• Technical Importance: The invention provides a defined, repeatable industrial process for manufacturing engineered stone with intricate, multi-color designs, moving beyond prior art methods that may have produced less consistent or less complex patterns (’440 Patent, col. 4:11-25).

Key Claims at a Glance

• The complaint asserts independent claim 14 (Compl. ¶ 30).
• The essential elements of claim 14 are:
  • 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 having first and second sets of regions.
  • The first mix is dispensed into the first set of regions; the second mix is dispensed into the second set of regions.
  • Vibrating and compacting the mixes to form a rectangular 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

Technology Synopsis

This patent claims a synthetic slab product characterized by its internal structure. It describes a "main interconnected material" that forms an "irregular branching channel configuration," which is in contact with a "plurality of interstitial material portions" made of a different material (’718 Patent, Abstract; col. 1:21-37). This structural arrangement defines the slab's veined appearance, which the patent states extends from the front major surface to the rear major surface (’718 Patent, col. 14:30-33).

Asserted Claims

The complaint asserts independent claims 1 and 9 (Compl. ¶ 38).

Accused Features

The complaint alleges that Defendant's processed slabs, including the "Calacatta Divine" product, are structured with distinct regions of different materials that form veined patterns, thereby infringing the claims of the ’718 Patent (Compl. ¶¶ 17-18, 38).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are processed quartz slabs sold under the "Arizona Tile" brand name, with the "Calacatta Divine" design identified as a non-limiting example (Compl. ¶ 17).

Functionality and Market Context

The accused products are engineered slabs used in applications such as countertops and other surfaces in homes and businesses (Compl. ¶ 7). Their relevant technical function is their aesthetic appearance, which is alleged to feature veining and patterns that emulate natural stone (Compl. ¶¶ 17-18). A screenshot from Defendant’s website shows the 'Calacatta Divine' product, a processed slab with a light-colored background and darker, irregular veining (Compl. ¶ 18). The complaint alleges that Defendant’s products were developed to copy Plaintiff’s commercially successful products (Compl. ¶ 16).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as Exhibits D, E, and F, but these exhibits were not provided with the complaint. The infringement theories are therefore summarized based on the narrative allegations in the complaint body.

’762 Patent Infringement Allegations

The complaint alleges infringement of at least claim 22, asserting that the Accused Products, such as "Calacatta Divine," are processed slabs with a major surface defined by at least two different particulate mineral mixes (Compl. ¶¶ 17-18, 22). It alleges these mixes occupy the entire slab thickness in distinct, non-overlapping regions that form veins in both lengthwise and widthwise directions, thereby meeting the structural limitations of the claim (Compl. ¶¶ 18, 22). The infringement theory relies on the visual and structural composition of the accused "Calacatta Divine" slab, as depicted in the complaint (Compl. ¶ 18).

’440 Patent Infringement Allegations

The complaint alleges infringement of at least claim 14 under 35 U.S.C. § 271(g), which pertains to the importation, sale, or use of a product made by a process patented in the United States (Compl. ¶ 30). The theory is that the Accused Products are manufactured outside the U.S. using a process that meets the limitations of claim 14—namely, sequentially dispensing different pigmented quartz mixes into a mold using stencils, followed by vibrating and compacting them (Compl. ¶¶ 16, 30). The complaint further asserts that the imported products are not materially changed by subsequent processes, a required element for a claim under § 271(g) (Compl. ¶ 30).

Identified Points of Contention

• Scope Questions: A potential dispute may arise over the meaning of a "vein in a generally widthwise direction" and a "second vein in a generally lengthwise direction" as required by claim 22 of the ’762 Patent. The analysis could focus on whether the irregular, branching patterns in the accused "Calacatta Divine" design (Compl. ¶ 18) satisfy these specific directional requirements.
• Technical Questions: For the ’440 Patent, a central question is what evidence can establish that the accused imported slabs were made by the claimed process. The case may turn on evidence from discovery concerning the defendant’s or its suppliers’ overseas manufacturing methods to determine if the claimed sequence of "sequentially dispensing" materials through stencils was actually performed.

V. Key Claim Terms for Construction

’762 Patent: "first vein in a generally widthwise direction . . . and a second vein in a generally lengthwise direction" (from claim 22)

Context and Importance

The definition of these directional vein limitations is critical for the product claims. Practitioners may focus on this term because the defendant could argue that the organic, multi-directional patterns of its accused product do not meet what it may characterize as a more geometrically constrained claim limitation.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification’s overall goal is to create patterns that "emulate a quarried stone slab" (’762 Patent, col. 2:55), which inherently includes irregular and non-linear features. This context may support a construction that does not require perfectly straight or orthogonal veins, but rather general directional tendencies.
• Evidence for a Narrower Interpretation: The claim language itself specifies two distinct veins with different general directions ("widthwise" and "lengthwise"). Additionally, the specification's reliance on stencils to create the patterns (e.g., ’762 Patent, Figs. 2A, 3A) could be argued to produce more defined and directionally-oriented features than a random process, supporting a more limited construction.

’440 Patent: "sequentially dispensing" (from claim 14)

Context and Importance

This term is central to the asserted method claim. Infringement under 35 U.S.C. § 271(g) depends on whether the accused products were made using a process that includes this specific order of operations. The definition will be key to determining whether an overseas manufacturing process falls within the claim scope.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification describes a process where different particulate mixes are added at different times to create the final pattern, which could support a broad interpretation covering any non-simultaneous addition of materials (’440 Patent, col. 2:29-50).
• Evidence for a Narrower Interpretation: The process flow detailed in the specification shows discrete, separate steps: dispense first mix, remove first stencil, position second stencil, dispense second mix (’440 Patent, Fig. 7, steps 704-712). This could support a narrower construction requiring distinct, non-overlapping dispensing events.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement for all asserted patents, stating that Defendant actively encourages infringement by others through its marketing materials, website content, and sales and distribution channels (Compl. ¶¶ 23-24, 31-32, 39-40).

Willful Infringement

Willfulness is alleged for all asserted patents based on alleged post-suit knowledge. The complaint asserts that Defendant has been on notice of the patents and its infringement since at least the filing of the complaint and has failed to cease its infringing activities (Compl. ¶¶ 27-28, 35-36, 43-44).

VII. Analyst’s Conclusion: Key Questions for the Case

• A core issue will be one of definitional scope: can the claim terms of the ’762 Patent requiring veins in "generally widthwise" and "lengthwise" directions be construed to read on the organic, branching, and multi-directional patterns depicted in the accused "Calacatta Divine" slab?
• A key evidentiary question will be one of proof of process: for the method claims of the ’440 Patent, what evidence will Plaintiff be able to obtain to demonstrate that Defendant's imported products were manufactured overseas using the specific "sequentially dispensing" process required by the claim, a necessary showing for infringement under 35 U.S.C. § 271(g)?
• A third question concerns the scope of product-by-process protection: does the structure of the accused slabs, as sold, embody the specific "main interconnected material" and "interstitial material" limitations of the ’718 Patent, and can Plaintiff demonstrate that this structure results from the patented manufacturing process?