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: 2:25-cv-00498, D. Utah, 06/23/2025
• Venue Allegations: The complaint’s specific allegations regarding personal jurisdiction and venue have been redacted.
• Core Dispute: Plaintiff alleges that Defendant’s blow-molded tables infringe a patent related to the structural design of molded plastic table tops.
• Technical Context: The technology concerns blow-molded plastic furniture, a field where innovations in structural reinforcement aim to produce lightweight yet strong and durable products suitable for mass-market and commercial use.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent, though the complaint does not specify the related patent. No other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2011-04-25	Earliest Priority Date for U.S. Patent No. 8,622,007
2014-01-07	U.S. Patent No. 8,622,007 Issued
2025-06-23	Complaint Filed

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 plastic tables as often requiring numerous parts and heavy reinforcing members to achieve sufficient strength, which increases manufacturing cost, complexity, and weight (’007 Patent, col. 2:1-24). It also notes that table tops can undesirably bend, deform, or sag under load, particularly at the outer portions not directly supported by a frame (’007 Patent, col. 2:29-37).
• The Patented Solution: The invention is a blow-molded plastic table top constructed as a unitary, one-piece structure with a hollow interior (’007 Patent, Abstract). To enhance strength and rigidity without adding separate parts, the design integrates specific structural features into the underside of the table top during the molding process. These include a "frame receiving portion" to secure the metal frame, a grid of "depressions" to add support across the main surface, and a series of "channels" within the frame receiving portion to provide reinforcement in a different direction, creating a more robust structure (’007 Patent, col. 20:28-40; Fig. 5).
• Technical Importance: This design approach seeks to create a table that is lightweight, durable, and cost-effective to manufacture, while also being strong enough to resist bending and twisting forces common in everyday use (’007 Patent, col. 3:12-20).

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶27).
• The essential elements of independent claim 11 are:
  • A table comprising:
  • a molded plastic table top including an upper surface, a lower surface and a hollow interior portion, all integrally formed during a molding process as part of a unitary, one-piece construction;
  • a frame receiving portion integrally formed in the lower surface of the table top, including an upper surface and at least one side wall;
  • a plurality of depressions in the lower surface of the table top, with at least a majority generally extending in a first direction;
  • a plurality of channels disposed in the upper surface of the frame receiving portion, with each channel generally extending aligned in a second direction different than the first direction;
  • a first support member connected to the table top; and
  • a second support member connected to the table top.
• The complaint reserves the right to assert other claims, stating Iceberg infringes "one or more claims (including, at least, claim 11)" (Compl. ¶30).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused products generally as "products ('Accused Products') that infringe at least claim 11 of the '007 patent" (Compl. ¶28). Specific product names are not provided in the unredacted portions of the complaint.

Functionality and Market Context

• The complaint alleges that the defendant, Iceberg, is in the business of "blow molding, metal fabrication, and assembly" (Compl. ¶9). The Accused Products are alleged to be tables that are made, used, sold, or imported by Iceberg (Compl. ¶28, ¶30). The complaint asserts that the Accused Products "are capable of performing and actually perform each limitation" of the asserted claims (Compl. ¶31). Further details regarding the products' specific features, operation, and market position are not available in the provided document.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or a detailed narrative explaining its infringement theory. It asserts that the Accused Products directly infringe at least Claim 11 of the ’007 Patent (Compl. ¶30). The complaint states that a more detailed analysis against an "exemplary Accused Product" is provided in Exhibit D (Compl. ¶28); however, Exhibit D was not attached to the publicly filed complaint. Without this exhibit or a more detailed pleading, a summary of the specific infringement allegations is not possible.

• Identified Points of Contention: Based on the language of the asserted claim, the dispute may focus on several key areas:
  • Structural Questions: A primary technical question will be whether the accused tables possess the specific, two-part reinforcement structure claimed: a "plurality of depressions" on the lower surface extending in a "first direction," and a distinct "plurality of channels" located specifically "in the upper surface of the frame receiving portion" and extending in a "second direction different than the first." The case may turn on evidence demonstrating the existence and orientation of these separate features.
  • Scope Questions: A central legal question may involve the scope of the term "integrally formed ... as part of a unitary, one-piece construction." The dispute may hinge on whether the Defendant's manufacturing process for its table tops qualifies as creating a single, unitary piece as defined by the patent, or if it involves post-molding assembly or bonding steps that could place the products outside the claim's scope.

V. Key Claim Terms for Construction

• The Term: "a plurality of channels disposed in the upper surface of the frame receiving portion"

  • Context and Importance: This term is critical because it defines a key strengthening feature and its precise location. Infringement will depend on whether the accused product has structures that are properly characterized as "channels" and whether they are located "in the upper surface of the frame receiving portion," as distinct from the "depressions" on the main lower surface of the table top. Practitioners may focus on this term because it requires a specific and complex structural arrangement that may not be present in all molded tables.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes strengthening members in various forms, including "depressions, ribs, channels and the like" (’007 Patent, col. 12:35-37), which could support an argument that "channel" should not be limited to a single, specific shape.
    • Evidence for a Narrower Interpretation: Figure 5 of the patent depicts distinct, elongated channels (72) located within the U-shaped frame receiving portion (74) and oriented differently from the larger depressions (60) (’007 Patent, Fig. 5). This embodiment, showing channels as separate and distinct features in a specific location, could support a narrower construction limited to such a structure.

• The Term: "integrally formed during a molding process as part of a unitary, one-piece construction"

  • Context and Importance: This limitation defines the manufacturing process required by the claim. The case may turn on whether the accused table top is created in a single molding operation or if it involves multiple pieces or steps that would negate its "unitary" nature.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent’s background criticizes conventional tables for requiring "additional parts," "extra fasteners," and "additional time to assemble" (’007 Patent, col. 2:5-11). This context could support a broader reading that the term is primarily intended to distinguish the invention from prior art tables requiring significant post-manufacturing assembly of separate components.
    • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes that the table top, including its upper and lower surfaces, hollow interior, and integrated features like depressions, is formed together in one process, such as blow-molding (’007 Patent, Abstract; col. 28:55-59). This could support a narrower definition requiring the entire table top structure to be formed simultaneously in a single mold.

VI. Other Allegations

• Willful Infringement: The complaint does not contain allegations of willful infringement or plead any facts related to pre-suit or post-suit knowledge by the Defendant. The prayer for relief requests that the court find the case "exceptional" for the purpose of awarding attorneys' fees under 35 U.S.C. § 285, but does not explicitly request enhanced damages for willfulness under § 284 (Compl., Prayer for Relief D).

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

• A core issue will be one of structural correspondence: Does the accused table's underside possess the specific two-part strengthening system required by Claim 11—namely, a "plurality of depressions" extending in one direction and a separate "plurality of channels" located within the frame-receiving portion and extending in a different direction? The resolution of this question will depend on a fact-intensive comparison of the accused product's physical structure to these distinct claim limitations.
• A key legal question will be one of process scope: How should the phrase "integrally formed ... as part of a unitary, one-piece construction" be construed? The court's interpretation will determine whether the defendant's specific manufacturing method falls within the scope of the claim, a determination that could be dispositive for the infringement analysis.