DCT

7:25-cv-00583

Cambria Co LLC v. Mohawk Industries Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00583, W.D. Tex., 12/19/2025
  • Venue Allegations: Venue is based on allegations that Defendant Dal-Tile maintains multiple regular and established places of business within the district, and that Defendant Mohawk Industries also has a regular and established place of business and pays taxes on properties located within the district.
  • Core Dispute: Plaintiff alleges that Defendants’ engineered quartz slab products infringe three patents related to the composition of processed slabs with veined appearances and the methods for manufacturing them.
  • Technical Context: The technology relates to engineered stone surfaces, specifically manufacturing processes that create complex and repeatable veined patterns in synthetic quartz slabs to emulate the aesthetic of high-end natural stone.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history involving the Asserted Patents.

Case Timeline

Date Event
2014-01-01 Plaintiff Cambria introduces its "Coastal Collection" embodying the patented technology
2015-01-30 Earliest Priority Date for ’762, ’440, and ’718 Patents
2019-02-05 ’762 Patent Issued
2019-04-09 ’440 Patent Issued
2025-07-29 ’718 Patent Issued
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 Feb. 5, 2019

  • The Invention Explained:
    • Problem Addressed: The patent’s background section notes that while engineered stone can offer improved physical properties over quarried stone, it often falls "noticeably short of the complicated look and texture of quarried stone" (’762 Patent, col. 1:33-37). Natural stone is also expensive and limited in its naturally occurring color schemes (’762 Patent, col. 1:26-29).
    • The Patented Solution: The invention provides for a synthetic molded slab and a method for its creation that produces repeatable, complex veining patterns. This is achieved by sequentially dispensing two or more differently pigmented particulate mineral mixes (e.g., quartz and a resin binder) into a mold through a series of complementary stencils. The stencils ensure that each colored mix is deposited into predefined, non-overlapping regions that, after compression and curing, form a slab with distinct background and vein patterns that extend through the thickness of the slab (’762 Patent, Abstract; col. 2:23-41; Fig. 4).
    • Technical Importance: This technology allows for the mass production of engineered stone slabs with a consistent, predefined, and aesthetically complex appearance that emulates high-end natural stone, a significant commercial objective in the decorative surfaces market (Compl. ¶13; ’762 Patent, col. 4:11-14).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 22 (Compl. ¶25).
    • The essential elements of claim 22 are:
      • A processed slab with a rectangular shape of at least 2 feet by 6 feet.
      • The major surface comprises a first particulate mineral mix and a second, different particulate mineral mix.
      • The first mix occupies the entire slab thickness at a "set of first regions," which includes both a "widthwise" and a "lengthwise" vein.
      • 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.

U.S. Patent No. 10,252,440, "Processed Slabs, and Systems and Methods Related Thereto," Issued Apr. 9, 2019

  • The Invention Explained:
    • Problem Addressed: As with the related ’762 Patent, the invention addresses the challenge of creating engineered stone that convincingly emulates the complex veining of natural quarried stone in a repeatable manufacturing context (’440 Patent, col. 1:33-37).
    • The Patented Solution: This patent claims the process of making the synthetic slab. The core of the patented method is the "sequentially dispensing" of at least a first and a second pigmented particulate mix into a slab mold. Each mix is dispensed through a corresponding stencil into a different set of regions within the mold. The combined mixes are then subjected to vibration and compaction to form the final, veined slab (’440 Patent, Abstract; col. 2:25-52).
    • Technical Importance: The claimed process provides a systematic and repeatable manufacturing method for creating engineered slabs with consistent and complex vein patterns, addressing a key production challenge in the industry (Compl. ¶13; ’440 Patent, col. 4:11-27).
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 14 (Compl. ¶33).
    • 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.
      • The first mix is dispensed into a "first set of regions," and the second mix is dispensed into a "second set of regions" that is different from the first.
      • Vibrating and compacting the mixes to form a slab of at least 3 feet by 6 feet.

Multi-Patent Capsule

  • Patent Identification: U.S. Patent No. 12,370,718, "Processed Slabs, and Systems and Methods Related Thereto," Issued Jul. 29, 2025 (Compl. ¶17).
  • Technology Synopsis: This patent claims a slab product defined by its specific visual and structural patterns. The claims recite a slab comprising a "main interconnected material" that forms an "irregular branching channel configuration" and a separate "plurality of interstitial material portions." This language describes the final appearance of a veined slab, where one material forms the continuous vein network (the channel) and the other material(s) fill the areas in between (’718 Patent, col. 14:8-23).
  • Asserted Claims: Independent claims 1 and 9 (Compl. ¶41).
  • Accused Features: The complaint alleges that the Accused Products, including the "Calacatta Wisteria" design, embody the claimed slab structure with its distinct interconnected vein pattern and interstitial background regions (Compl. ¶¶20, 41).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies processed slabs sold under the “Daltile” brand name, providing the “Calacatta Wisteria” design as a non-limiting example of the "Accused Products" (Compl. ¶20).
  • Functionality and Market Context: The Accused Products are described as engineered quartz surface products used in applications such as countertops, floor tiles, and vanities (Compl. ¶10). Their relevant functionality is their aesthetic appearance, which allegedly includes veining patterns designed to emulate natural stone. The complaint includes a photograph of the "Calacatta Wisteria" product, which shows a light-colored slab with prominent, branching, darker-colored veins (Compl. ¶21). This visual is presented as evidence that the Accused Products meet the elements of the Asserted Patents (Compl. ¶20).

IV. Analysis of Infringement Allegations

The complaint references exemplary and non-limiting claim charts attached as Exhibits D, E, and F for the ’762, ’440, and ’718 Patents, respectively; however, these exhibits were not provided with the complaint. The infringement analysis is therefore based on the narrative allegations in the complaint.

  • ’762 Patent Infringement Allegations: The complaint alleges that the Accused Products directly infringe at least claim 22 because they are processed slabs composed of different particulate mineral mixes that form distinct regions, including both widthwise and lengthwise veins that occupy the full thickness of the slab (Compl. ¶25).
  • ’440 Patent Infringement Allegations: The complaint alleges that the Accused Products are made by a process that infringes at least claim 14 of the ’440 Patent, thereby giving rise to liability under 35 U.S.C. § 271(g) (Compl. ¶33). The infringing process is alleged to involve the sequential dispensing of different pigmented mixes into a mold to form distinct regions, followed by vibration and compaction (Compl. ¶¶19, 33).
  • Identified Points of Contention:
    • Scope Questions: A central question for the ’762 and ’718 Patents will be whether the visual patterns on the Accused Products meet the specific structural and relational limitations of the claims, such as the presence of distinct "first and second regions" occupying the "entire slab thickness" (’762 Patent) or the characterization of the pattern as a "main interconnected material" forming a "branching channel" (’718 Patent).
    • Technical Questions: For the ’440 process patent, a key evidentiary question will be what manufacturing process Defendants actually use. The analysis will focus on whether that process involves "sequentially dispensing" different materials through stencils (or an equivalent mechanism) into "different" sets of regions, as required by the claim language.

V. Key Claim Terms for Construction

  • The Term: "vein" (’762 Patent, claim 22)

    • Context and Importance: The presence and characteristics of "veins" are central to the asserted product claims. The construction of this term—whether it is defined purely by its visual appearance or requires a specific underlying physical structure formed by a particular process—will be critical to the infringement analysis. Practitioners may focus on this term because its scope will determine whether the aesthetic features of the Accused Products meet the claim's structural limitations.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the invention’s goal as emulating the "veined appearance of natural quarried stone slabs such as granite or marble," which could support a construction based on the resulting visual effect rather than the method of formation (’762 Patent, col. 5:50-53).
      • Evidence for a Narrower Interpretation: The specification consistently describes the formation of veins by dispensing a particulate mix into regions defined by stencils, where the mix "occupies a full thickness" of the slab (’762 Patent, col. 3:41-50). This could support an argument that a "vein" is not just a surface pattern but a distinct, full-depth region of one material embedded within another.

  • The Term: "sequentially dispensing" (’440 Patent, claim 14)

    • Context and Importance: This term defines the core temporal element of the asserted process claim. Whether Defendants' manufacturing process can be characterized as "sequential" will be a primary point of dispute. Practitioners may focus on this term because if Defendants' process involves simultaneous, blended, or overlapping dispensing steps, it may fall outside the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The general description of using a first stencil and then a second stencil implies a sequence of operations, which could be construed broadly to cover any process where one material is deposited before another, regardless of the time interval (’440 Patent, col. 2:23-34).
      • Evidence for a Narrower Interpretation: Figure 4 depicts a manufacturing line with distinct, spatially separated distributors (460a, 460b), suggesting a process with discrete, non-overlapping steps. This may support a narrower construction requiring distinct actions separated in time and/or space (’440 Patent, Fig. 4; col. 8:50-64).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all three patents, asserting that Defendants encourage infringement by others through the active promotion, marketing, and sale of the Accused Products via materials on the Daltile website and through sales and distribution channels (Compl. ¶¶26-27, 34-35, 42-43).
  • Willful Infringement: Willfulness is alleged for all patents based on post-suit knowledge. The complaint asserts that Defendants have had actual knowledge of the patents and their infringement since at least the filing of the lawsuit and have continued their infringing activities despite this knowledge (Compl. ¶¶30-31, 38-39, 46-47).

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

  1. A core issue will be one of structural correspondence: Do the aesthetic patterns on the Accused Products satisfy the specific, claimed three-dimensional structure of distinct material regions occupying the "entire slab thickness" and forming both "widthwise" and "lengthwise" veins, as required by the ’762 Patent?
  2. A key evidentiary question will concern the manufacturing process: Can Plaintiff demonstrate that the Accused Products are made by a process that includes "sequentially dispensing" different materials into "different sets of regions," as mandated by the ’440 Patent, given that such manufacturing methods are typically proprietary?
  3. A central question of claim scope will be whether the visual elements of the accused slab can be properly characterized as a "main interconnected material" forming an "irregular branching channel" alongside separate "interstitial material portions," as those terms are understood in the context of the ’718 patent specification.