DCT

2:25-cv-00518

Kore Essentials Inc v. ZJH Holdings LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00518, D. Utah, 06/27/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendant's principal place of business is in the district, it conducts business and has committed the alleged acts of infringement there, and the action arises from those transactions.
  • Core Dispute: Plaintiff alleges that Defendant’s ratchet-style belts infringe a patent related to a specific multi-layer belt construction featuring a monolithic insert.
  • Technical Context: The technology relates to ratchet-style belts, which use a track of notches and a buckle mechanism for fine-tuned adjustment, as an alternative to traditional belts with holes and pins.
  • Key Procedural History: The patent-in-suit claims priority back to 2013 through a chain of continuing applications. The complaint alleges that Plaintiff notified Defendant of the infringement via counsel before filing the lawsuit, which may form a basis for a willfulness claim.

Case Timeline

Date Event
2013-10-28 Earliest Priority Date for ’522 Patent
2014-03-18 Filing date of related application mentioned in complaint
2016-01-27 Filing date of related application mentioned in complaint
2016-03-10 Filing date of related application mentioned in complaint
2018-03-20 ’522 Patent Issue Date
2025-06-27 Complaint Filing Date

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

U.S. Patent No. 9,918,522 - Ratchet Belt System and Related Accessories, issued March 20, 2018

The Invention Explained

  • Problem Addressed: The patent's background section notes that some conventional ratcheting belts have release levers that are "cumbersome and difficult to operate" and that existing designs are typically limited to a single, non-reversible track of notches. (’522 Patent, col. 2:35-43).
  • The Patented Solution: The invention is a ratchet belt system with a specific belt construction. The solution described in the asserted claim involves a belt made of a "first belt layer," a "second belt layer," and a "monolithic insert" that is embedded between the two layers. (’522 Patent, col. 6:58-65). This layered structure, held together by a "mating element" like stitching, is designed to incorporate the ratcheting notch strip while potentially adding rigidity and durability. (’522 Patent, col. 6:17-25, col. 7:1-2).
  • Technical Importance: This construction is described as providing "rigid support," with the patent noting its suitability for applications like "gun belts," which require a stiffer structure to support a firearm. (’522 Patent, col. 7:2-4).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶15).
  • Essential elements of Claim 1:
    • A belt with a first end and a second end, comprising a notch strip near the second end.
    • A buckle with a ratcheting mechanism that attaches to the first end and slideably receives the second end to create a releasable engagement.
    • The belt itself comprises a first belt layer, a second belt layer, and a "monolithic insert" disposed between the layers.
    • The layers are combined with a "mating element" to form the belt, embedding the monolithic insert.
  • The complaint reserves the right to assert other claims. (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

The "40 MM Alpha Charcoal Belt, 40 MM Ranger Black Belts, 40 MM Ranger Brown Belt, and 40 MM Alpha Tan Belt" are identified as the "Accused Products." (Compl. ¶11).

Functionality and Market Context

The complaint alleges these are ratchet-style belts sold by Defendant through its own website and other online retailers like Amazon.com. (Compl. ¶11). The complaint asserts that the Accused Products incorporate the patented technology and have generated "significant sales." (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products meet all limitations of claim 1 of the ’522 Patent. (Compl. ¶15). The complaint refers to a claim chart in an "Exhibit B" to support this allegation, but the exhibit was not filed with the public complaint. (Compl. ¶15). The complaint's narrative suggests its infringement theory centers on the construction of the accused belts, alleging they are configured with a "first belt layer, a second belt layer, and a monolithic insert disposed between the first and second layers," which maps directly to the language of asserted claim 1. (Compl. ¶10).

Identified Points of Contention:

  • Scope Questions: A central dispute may arise over the definition of "monolithic insert." The court may need to determine if the internal stiffening component of the Defendant's belts qualifies as a "monolithic insert" as the term is used and described in the patent, or if the patent requires a more specific structure.
  • Technical Questions: A key evidentiary question may be one of structural identity. What evidence does the complaint provide, beyond conclusory allegation, that the accused belts are in fact constructed from three distinct components—a first layer, a second layer, and a separate insert—as opposed to, for example, a single piece of material with different surface treatments or a different laminated construction?

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • The Term: "monolithic insert"
  • Context and Importance: This term appears in the characterizing clause of claim 1 and describes the core structural feature that distinguishes the claimed invention. (’522 Patent, col. 6:59). The infringement analysis for claim 1 will hinge on whether the internal component of the accused belts can be properly characterized as a "monolithic insert."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide an explicit definition of "monolithic insert." A party advocating for a broader scope may argue that "monolithic" simply means formed of a single, uniform piece of material, and "insert" means it is placed between the outer belt layers.
    • Evidence for a Narrower Interpretation: The patent states that the "monolithic insert is configured to provide rigid support of the belt" and suggests its use in "gun belts." (’522 Patent, col. 7:2-4). A party may argue this functional language limits the term to a stiff, structural core, not just any intermediate layer. Furthermore, dependent claims distinguish between embodiments where the notch strip is "integrated with the monolithic insert" (Claim 4) and where it is "distinct from the monolithic insert" (Claim 5), suggesting the "insert" is a structural body that may or may not include the notches itself, potentially narrowing its definition. (’522 Patent, col. 7:5-9).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant intentionally induced infringement by its customers who use the Accused Products. The factual basis for this claim is the allegation that Defendant placed the products into the stream of commerce for sale and use. (Compl. ¶19).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge. The complaint states, "Plaintiff informed Defendant of the Accused Products’ infringement of the ‘522 Patent via counsel prior to filing this Complaint." (Compl. ¶21).

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

  • A core issue will be one of claim construction: can the term "monolithic insert," which the patent links to providing "rigid support" for applications like gun belts, be construed to cover the internal stiffening layer of the accused consumer-grade belts?
  • A key evidentiary question will be one of structural identity: assuming a construction of "monolithic insert," the case will then turn on factual evidence dissecting the accused belts. Plaintiff will need to prove that the products are actually built with three distinct components (a first layer, a second layer, and an "insert" between them) that match the specific architecture required by Claim 1.