Lifetime Products Inc v. Iceberg Enterprises LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lifetime Products, Inc. (Utah)
  • Defendant: Iceberg Enterprises LLC (Delaware)
  • Plaintiff’s Counsel: Maschoff Brennan Gilmore Israelsen & Mauriel LLP
• Case Identification: 1:25-cv-00087, D. Utah, 06/23/2025
• Venue Allegations: The complaint’s specific allegations supporting venue in the District of Utah are redacted.
• Core Dispute: Plaintiff alleges that Defendant’s blow-molded plastic tables infringe a patent related to structural designs for improving the strength and rigidity of such tables.
• Technical Context: The technology concerns the design and manufacture of lightweight, durable, and cost-effective furniture, specifically utility and folding tables intended for mass-market and institutional use.
• Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit. The patent-in-suit was subject to two Certificates of Correction, issued April 1, 2014, and May 11, 2021, which modified the language of certain claims, including the asserted independent claim.

Case Timeline

Date	Event
2011-04-25	'007 Patent Priority Date
2014-01-07	'007 Patent Issue Date
2025-06-23	Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 8,622,007 - "Table With Molded Plastic Table Top"

• Issued: January 7, 2014.

The Invention Explained

• Problem Addressed: The patent describes conventional banquet-style tables as often being heavy, difficult to move, and expensive due to their construction from materials like wood or metal ('007 Patent, col. 1:51-57). Lighter plastic alternatives often lack sufficient strength and rigidity, requiring reinforcement that adds cost and complexity, and are susceptible to bending or damage, particularly at the edges and where the frame attaches (col. 2:2-36).
• The Patented Solution: The invention is a table with a blow-molded plastic top that has a hollow interior, making it lightweight ('007 Patent, col. 3:10-24). To achieve strength and rigidity, the tabletop is integrally formed as a unitary piece with specific structural features on its lower surface. These include a grid of depressions ("tack-offs") that increase stability and a dedicated "frame receiving portion" designed to securely hold the table's frame, which itself may contain additional strengthening features like channels (col. 3:28-43; Fig. 5). This integrated design aims to create a strong, durable, and lightweight table that can be manufactured efficiently.
• Technical Importance: This integrated molding approach sought to provide the market with tables possessing the strength of traditional models but with the reduced weight and manufacturing advantages of plastic construction ('007 Patent, col. 3:1-7).

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶27).
• Claim 11, as corrected by the Certificate of Correction issued April 1, 2014, requires:
  • A molded plastic table top of unitary, one-piece construction with an upper surface, a lower surface, and a hollow interior portion.
  • A frame receiving portion integrally formed in the lower surface, which includes an upper surface and at least one side wall.
  • A plurality of depressions in the lower surface of the table top, with a majority extending in a first direction.
  • A plurality of channels in the upper surface of the frame receiving portion, with each channel extending in a second direction different from the first.
  • A first and a second support member (e.g., leg assemblies) connected to the table top.
• The complaint alleges infringement of "one or more claims (including, at least, claim 11)," suggesting the potential to assert other claims, including dependent claims, later in the litigation (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

The complaint identifies the infringing products as "Accused Products" (Compl. ¶28). Specific product names or model numbers are not provided in the body of the complaint.

Functionality and Market Context

The complaint alleges that Defendant Iceberg "is in the business of, among other things, blow molding, metal fabrication, and assembly," which are the core manufacturing processes for the type of products covered by the '007 Patent (Compl. ¶9). The complaint asserts that the Accused Products "are capable of performing and actually perform each limitation" of the asserted claim but does not describe the specific structure or features of these products (Compl. ¶31). It refers to an "exemplary Accused Product in Exhibit D," but this exhibit was not included with the complaint provided for analysis (Compl. ¶28).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed, element-by-element infringement analysis in the body of the document, instead referring to an unprovided exhibit (Exhibit D). Therefore, a claim chart summary cannot be constructed from the provided materials.

• Identified Points of Contention:
  • Structural Correspondence: A primary technical question will be whether the Accused Products contain the specific combination of structural features recited in Claim 11. The analysis will focus on whether the products have both a general "plurality of depressions" oriented in a "first direction" and a separate "plurality of channels" located specifically "in the upper surface of the frame receiving portion" and oriented in a "second direction different than the first." Evidence will be required to establish the existence, location, and orientation of these distinct features in the accused design.
  • Claim Language Discrepancy: A threshold issue may arise because the complaint quotes a version of Claim 11 containing the phrase "generally extending aligned," which was subsequently removed by a Certificate of Correction (Compl. ¶27; '007 Patent, Certificate of Correction, Apr. 1, 2014). The infringement analysis will depend on whether it is assessed against the claim language as pleaded in the complaint or the officially corrected version of the claim.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "frame receiving portion"

• Context and Importance: This term defines the specific, integrally molded structure on the tabletop's underside intended to interface with the frame. The existence and characteristics of this feature on the accused tables will be critical to the infringement analysis, as it serves as the location for the claimed "plurality of channels."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states the table top may include a "frame receiving portion sized and configured to receive an upper portion of the side rail of the frame" ('007 Patent, col. 8:56-59). Plaintiff may argue this supports a functional definition, covering any molded feature that receives the frame.
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures illustrate a specific embodiment of the "frame receiving portion" (74) as a recessed area with a distinct "upper surface" (76) and at least an "inner sidewall" (78) and "outer sidewall" (80) ('007 Patent, col. 20:30-35; Fig. 5). Defendant may argue the term should be limited to a structure with this multi-surfaced geometry.

• The Term: "plurality of channels"

• Context and Importance: This term is central to the novelty of the claimed structure, as it requires a second set of strengthening features distinct from the general "depressions." The dispute will likely focus on what constitutes a "channel" versus a "depression" and whether the accused product has such features in the claimed location.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Plaintiff may argue that "channels" should be given its plain and ordinary meaning of an elongated groove or recess, without further limitation.
  • Evidence for a Narrower Interpretation: The patent consistently depicts the "channels" (72) as structures located within the "frame receiving portion" (74) and distinct from the more numerous, dot-like "depressions" (60) that cover the main surface of the tabletop ('007 Patent, Fig. 5, col. 20:55-64). Defendant may argue that to have meaning, "channels" must be structurally different from "depressions" and must be located exclusively within the "frame receiving portion".

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement (inducement or contributory infringement).
• Willful Infringement: The complaint does not plead facts to support a claim of willful infringement or request enhanced damages. It does request that the court "find this case to be exceptional under 35 U.S.C. § 285," which relates to an award of attorneys' fees, but does not explicitly allege pre- or post-suit knowledge of infringement (Compl. p. 9).

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

• A core issue will be one of structural specificity: does the accused table’s design incorporate the two distinct and directionally different types of strengthening features—general "depressions" and localized "channels"—as precisely required by Claim 11? The case will likely require detailed factual evidence comparing the accused product's molded underside to the claim's specific geometric and locational limitations.
• The outcome may also depend on a question of definitional distinction: how will the court construe the terms "frame receiving portion", "depressions", and "channels"? A narrow construction, tied closely to the patent’s specific embodiments, could create a significant hurdle for the infringement claim, while a broader construction may favor the patentee. The relationship and differences between these claimed features will be a central point of legal and technical argument.