DCT

2:20-cv-00471

Snap Lock Industries v. Envison Marketing Events

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:20-cv-00471, D. Utah, 06/30/2020
  • Venue Allegations: Venue is alleged to be proper based on the defendant residing and being incorporated within the District of Utah.
  • Core Dispute: Plaintiff alleges that Defendant’s modular flooring systems, which are imported and sold in the U.S., infringe three patents related to modular floor tiles featuring multi-level shock absorption technology.
  • Technical Context: The technology concerns modular flooring systems, particularly for athletic surfaces, designed to provide enhanced shock absorption and user comfort through a combination of rigid and resilient support structures.
  • Key Procedural History: The complaint alleges that Defendant’s owners are former employees of the Plaintiff and were employed at the time Plaintiff introduced the patented technology. The complaint also notes prior state court litigation between Plaintiff and the individuals now owning the Defendant, which resulted in a settlement agreement concerning Plaintiff's confidential and proprietary information.

Case Timeline

Date Event
2005-06-02 Earliest Priority Date for ’863, ’333, and ’603 Patents
2007-01-01 Plaintiff introduced its patented Shock Tower® technology
2011-01-01 Plaintiff terminated Defendant's co-owner Sue Wollman
2012-01-01 Plaintiff terminated Defendant's co-owner Dan Wollman
2014-05-06 U.S. Patent No. 8,713,863 Issued
2015-07-14 U.S. Patent No. 9,080,333 Issued
2017-07-04 U.S. Patent No. 9,695,603 Issued
2020-06-30 Complaint Filed

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

U.S. Patent No. 8,713,863 - Modular Floor Tile With Resilient Support Members

The Invention Explained

  • Problem Addressed: The patent describes conventional interconnected modular tile systems as being "rigid and unforgiving," which can lead to user discomfort and joint pain during sports or dance activities due to a lack of impact absorption ('863 Patent, col. 1:40-49).
  • The Patented Solution: The invention is a modular floor tile with a multi-level support system. This system includes a primary set of "resilient support members" (e.g., elastomeric inserts) and a secondary set of "rigid supports." The resilient members extend further downward than the rigid supports, meaning they make initial contact with the ground and compress under a load, providing a cushioning effect before the more rigid structure engages the surface ('863 Patent, Abstract; col. 2:51-61).
  • Technical Importance: This design integrated a novel, two-stage shock absorption mechanism into modular flooring to improve user comfort and reduce the physical stress associated with activities on hard surfaces ('863 Patent, col. 1:50-54).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 9, 15, and 24, along with several dependent claims (Compl. ¶19).
  • Independent Claim 1 requires:
    • A tile component with an upward facing surface.
    • A plurality of first rigid supports that define a downward facing surface.
    • A plurality of resilient support members that extend downward from the upward surface, are disposed entirely below it, and extend further downward than the rigid supports when uncompressed.
    • The resilient support members are compressible against a support surface until the first rigid supports also contact that surface.
  • The complaint asserts dependent claims 2-5, 16-18, 20-22, and 24-25 ('863 Patent, Compl. ¶19).

U.S. Patent No. 9,080,333 - Modular Floor Tile With Resilient Support Members

The Invention Explained

  • Problem Addressed: As with the parent ’863 Patent, this patent addresses the problem of conventional modular floors being overly rigid and uncomfortable for athletic use ('333 Patent, col. 1:45-50).
  • The Patented Solution: The patent describes a floor tile assembly for providing impact absorption, comprising a rigid tile member with both "substantially rigid support members" and "flexible supports." The flexible supports are inserted between the rigid ones and have an uncompressed length greater than the rigid supports, allowing them to provide an initial cushioning layer that compresses under force before the rigid structure engages ('333 Patent, col. 20:44-51). Figure 13 illustrates this compression mechanism, showing the tile under load from a user's foot ('333 Patent, Fig. 13).
  • Technical Importance: This technology continues the development of multi-level suspension systems in modular flooring, aiming to enhance performance and user safety in sports and other high-impact activities ('333 Patent, col. 1:51-55).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-5 (Compl. ¶20).
  • Independent Claim 1 requires:
    • A floor surface comprising a plurality of tiles.
    • Each tile having an upward facing surface, a plurality of first rigid supports defining a downward facing support surface, and a plurality of resilient support members.
    • The resilient support members are "inserted between the plurality of first rigid supports" and extend below the downward facing support surface when uncompressed.
    • The resilient members are compressible to "cushion the floor surface during use."
  • The complaint asserts dependent claims 2-5 ('333 Patent, Compl. ¶20).

U.S. Patent No. 9,695,603 - Modular Floor Tile With Resilient Support Members

  • Technology Synopsis: Continuing the same technical theme, the ’603 Patent claims a floor tile with a two-part support system. It describes a first support layer that is permanently mounted to the tile and a second, "releasably mounted" support layer (e.g., the resilient members). The releasable second layer provides the initial compression and, upon removal of force, "automatically moves the first support layer out of contact with the support surface," highlighting the rebound characteristic of the cushioning system (’603 Patent, Abstract; col. 20:8-24).
  • Asserted Claims: The complaint asserts claims 16 and 18 (Compl. ¶21). Claim 16 is an independent claim.
  • Accused Features: The complaint alleges that the tiles used in the "Infringing Floor System" satisfy the limitations of the asserted claims, pointing to the tile's use of rigid supports and resilient shock pads (Compl. ¶¶ 6, 21).

III. The Accused Instrumentality

Product Identification

The "Comfort Plus flooring systems" and "Comfort Plus floor tiles," collectively referred to as the "Infringing Floor System" (Compl. ¶18).

Functionality and Market Context

The complaint alleges these are modular floor tiles manufactured by Inov4Sports in Portugal and imported and sold by Defendant SportPros (Compl. ¶¶ 6, 18). The core accused functionality is the use of "shock pads" in the tile structure to provide shock absorption (Compl. ¶18). The complaint provides visual evidence, described as "Pictures of the Infringing Floor System and the Infringing Floor Tile," as Exhibit D to support its allegations of the product's structure (Compl. ¶18). The products are alleged to be sold in "direct competition with Snap Lock" (Compl. ¶23).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶¶ 19-21). The narrative allegations suggest a theory of literal infringement for all asserted patents.

The complaint alleges that the accused "Comfort Plus" floor tiles embody the patented technology by incorporating a multi-level support structure (Compl. ¶¶ 19-21). The central allegation is that the accused tiles possess both rigid support legs and separate, more flexible "shock pads" that extend further from the tile's underside. This configuration allegedly mirrors the claimed invention, where the resilient members (the "shock pads") compress first under a load to provide cushioning, before the rigid supports engage the ground (Compl. ¶18). The complaint relies on pictures of the accused products to support this structural and functional mapping (Compl. ¶18, Exhibit D).

  • Identified Points of Contention:
    • Scope Questions: A primary question for the court will be whether the accused "shock pads" fall within the scope of the claimed "resilient support members." The analysis may focus on the specific materials, shapes, and attachment mechanisms of the accused pads compared to the language of the claims and the embodiments described in the patents.
    • Technical Questions: A key factual dispute may arise over whether the accused tiles actually perform the two-stage compression sequence required by the claims. Plaintiff will need to provide evidence, likely through expert testing and analysis, demonstrating that the accused "shock pads" compress until the tile's rigid supports make contact with the ground, as depicted in the patents' principles of operation.

V. Key Claim Terms for Construction

"resilient support members" (’863 Patent, Claim 1)

  • Context and Importance: This term is the central element of the invention, defining the shock-absorbing component. Its construction will be critical to the infringement analysis, as the court's definition will determine whether the accused "shock pads" meet this limitation. Practitioners may focus on this term because its scope will likely be a focal point of disagreement between the parties.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the members may be made of an "elastomer such as rubber" and "may include many different shapes," suggesting the term is not confined to a single embodiment (’863 Patent, col. 6:60-64).
    • Evidence for a Narrower Interpretation: The patent provides detailed descriptions and figures of specific embodiments, such as a member with an "undulating surface" or a "post or compressible column," which a defendant might argue implicitly limit the term's scope to structures with similar features (’863 Patent, col. 6:62-65; col. 16:6-12; Figs. 22-24).

"inserted between the plurality of first rigid supports" (’333 Patent, Claim 1)

  • Context and Importance: This phrase defines the spatial relationship between the resilient and rigid components. The infringement finding for the ’333 patent may turn on whether the accused "shock pads" are arranged "between" the rigid supports in the manner claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "between" could be given its plain and ordinary meaning, covering any arrangement where the resilient members are located in the spaces created by the grid of rigid supports.
    • Evidence for a Narrower Interpretation: The specification describes embodiments where the resilient inserts are "nested" in "receivers" formed by "clusters of three or four" rigid support legs (’333 Patent, col. 8:23-30; Fig. 15). A defendant could argue this implies a more specific structural arrangement than simply being located in a void.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead a separate count for indirect infringement, focusing instead on allegations of direct infringement through Defendant's importation, sale, and offers for sale of the accused products (Compl. ¶24).
  • Willful Infringement: The complaint alleges that Defendant's infringement was willful, demonstrating a "deliberate and conscious decision to infringe" or at least a "reckless disregard" of Plaintiff's patent rights (Compl. ¶26). This allegation is based on Defendant's alleged pre-suit knowledge of the patents, stemming from the fact that its owners were "employed with Snap Lock at the time the patented Shock Tower® technology was first marketed" (Compl. ¶¶ 22, 26).

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

  1. A central issue will be one of claim scope: Can the term "resilient support members," which is detailed in the patents with specific structural embodiments like undulating posts, be construed broadly enough to read on the accused "shock pads," the precise design of which is not detailed in the complaint?
  2. A key evidentiary question will be one of technical operation: Beyond visual similarity, what evidence will demonstrate that the accused floor tiles function according to the specific two-stage compression sequence that is a core limitation of the asserted claims?
  3. A significant legal and factual question will be that of willfulness: Given the alleged prior employment history of Defendant's owners at Plaintiff's company during the development of the patented technology, can Plaintiff prove that Defendant's alleged infringement was willful, thereby exposing it to a claim for enhanced damages?