Draexlmaier Automotive Of America LLC v. Faurecia Interieur Industrie

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lisa Dräxlmaier GmbH (Germany) and Draexlmaier Automotive of America LLC (South Carolina)
  • Defendant: Faurecia Interieur Industrie (France)
  • Plaintiff’s Counsel: Whiteford, Taylor & Preston, LLP
• Case Identification: 1:22-cv-01008, E.D. Va., 09/07/2022
• Venue Allegations: Venue is asserted based on the defendant being a non-resident patentee subject to personal jurisdiction in the district.
• Core Dispute: Plaintiff, an automotive parts supplier, seeks a declaratory judgment that its products do not infringe Defendant’s patent and that the patent is invalid, following accusations of infringement from the Defendant.
• Technical Context: The technology concerns features integrated into molded plastic parts, such as automotive interior panels, to facilitate easier and more reliable dimensional quality control using standard measurement tools.
• Key Procedural History: The action was precipitated by a series of communications, initiated by a December 8, 2021 letter from Defendant Faurecia accusing Plaintiff Dräxlmaier of infringing the patent-in-suit. In subsequent correspondence, Faurecia’s counsel identified Dräxlmaier’s Tesla Model Y door panel as an infringing product and specified that at least claims 1-6 and 8-10 of the patent appeared to be infringed. The complaint also asserts that Dräxlmaier is entitled to a prior commercial use defense under 35 U.S.C. § 273 based on prior work for a BMW "E70 project".

Case Timeline

Date	Event
2014-08-26	Priority Date for U.S. Patent No. 9,939,244
2018-04-10	U.S. Patent No. 9,939,244 issues
2021-12-08	Defendant Faurecia sends initial infringement notice letter
2022-02-01	Defendant's counsel identifies accused product and claims
2022-09-07	Complaint for Declaratory Judgment filed

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

• Patent Identification: U.S. Patent No. 9,939,244, “Molded Part and Its Manufacturing Method,” issued April 10, 2018.

• The Invention Explained:

  • Problem Addressed: The patent’s background section identifies the challenge of controlling the final dimensions of large molded plastic parts, which are subject to shrinkage during cooling. It notes that using custom, part-specific metrological instruments for quality control is "expensive, cumbersome and time-consuming" (’244 Patent, col. 1:15-34).
  • The Patented Solution: The invention proposes integrally molding specific "positioning relief portions" onto the surface of a plastic part. These portions are designed to function as reliable reference points, allowing a common measuring tool like a vernier caliper to be precisely positioned to measure the distance between them. This is intended to provide a simple, repeatable, and inexpensive method for quality control without needing specialized equipment (’244 Patent, Abstract; col. 2:36-51). Figure 2 of the patent illustrates a standard instrument (18) measuring the distance between two relief portions (14).
  • Technical Importance: The described solution aims to streamline the manufacturing and quality control process for large plastic components, common in the automotive industry, by replacing costly, custom metrology jigs with a system that uses standard, widely available tools (’244 Patent, col. 6:46-55).

• Key Claims at a Glance:
  The complaint states that Defendant’s counsel accused Dräxlmaier’s Tesla Model Y door panel of infringing "at least claims 1-6 and 8-10" of the ’244 patent (Compl. ¶5). The complaint also challenges the validity of claims 10 and 11 (Compl. ¶¶32, 35). The asserted independent claims appear to be 1, 9, and 10.

  • Independent Claim 1 (Product):

    • A molded part in plastic material comprising a body with a surface;
    • Two "positioning relief portions" formed on the surface, spaced apart along a measurement direction;
    • Each relief portion is integrally molded and has a "positioning protrusion" defining a "measurement surface";
    • The measurement surface "allow[s] the positioning of a sensor member of a distance measurement instrument" to bear against it;
    • This is done "in order to measure the distance between the positioning relief portions."

  • Independent Claim 9 (Product):

    • This claim adds further limitations to the molded part of claim 1, requiring each positioning relief portion to also comprise a "supporting protrusion" with an apex that defines a "supporting surface."
    • This supporting surface allows the sensor member to simultaneously bear upon both the measurement surface and the supporting surface.
    • The claim further requires the supporting protrusion to have a smaller height than the positioning protrusion.

  • Independent Claim 10 (Method):

    • A method for "dimensionally controlling" a molded part, comprising the steps of:
    • Molding the part to form a body and two positioning relief portions on its surface, with each defining a measurement surface; and
    • Measuring the distance between the relief portions using a measuring instrument by positioning each of its sensor members against a respective measurement surface.

III. The Accused Instrumentality

• Product Identification: The complaint identifies the accused instrumentality as the "Tesla Model Y door panel produced by Dräxlmaier" (Compl. ¶6).
• Functionality and Market Context: The complaint does not provide specific details regarding the technical features or functionality of the accused Tesla Model Y door panel. It notes that Dräxlmaier and Faurecia are competitors in the market for automotive interior parts, including door panels and consoles (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint is for a declaratory judgment of non-infringement and does not contain infringement contentions or a claim chart. The infringement theory described is that of the patentee, Faurecia, as conveyed during pre-suit negotiations (Compl. ¶8). The complaint reproduces Figure 1 of the patent, showing an exemplary molded part with two spaced apart positioning relief portions (14) (Compl. p. 5). It also includes Figure 5 from the patent, which depicts a cross-sectional view of the relief portions being measured by a measuring instrument (Compl. p. 6). Without a claim chart or specific allegations mapping claim elements to product features, a detailed infringement analysis is not possible.

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise over the definition of "positioning relief portion." The complaint alleges that the "use of spaced apart ribs" was "well known" prior to the invention (Compl. ¶17). This suggests the case may turn on whether the features on the accused door panel are merely conventional structural ribs, or if they meet the specific functional and structural limitations of a "positioning relief portion" as claimed in the ’244 Patent.
  • Technical Questions: A key factual question will be whether the accused door panel includes structures that meet all limitations of the asserted claims. For example, for claim 9, does the panel have features that can be characterized as both a "positioning protrusion" and a "supporting protrusion" with the claimed height relationship and function? The complaint does not provide evidence to answer this.

V. Key Claim Terms for Construction

The complaint explicitly challenges several terms as indefinite under 35 U.S.C. § 112 (Compl. ¶38). The construction of these terms will be critical.

• The Term: "positioning relief portion"

  • Context and Importance: This term is the core of the claimed invention. Its construction will determine whether the claims read on the accused product and whether they are valid over prior art that may include various types of ribs on molded parts. Practitioners may focus on this term because Dräxlmaier’s invalidity argument appears to hinge on equating these portions with "well known" prior art ribs (Compl. ¶¶17, 28).
  • Intrinsic Evidence for a Broader Interpretation: The patent summary uses functional language, describing the portion as having a protrusion that defines a surface "giving the possibility of positioning a sensor member" (’244 Patent, col. 2:45-48). This could be argued to encompass any structure that makes such positioning possible.
  • Intrinsic Evidence for a Narrower Interpretation: The detailed embodiments describe and depict very specific structures, including a T-shaped arrangement of a "positioning protrusion" (20) and a "supporting protrusion" (24), as well as "guiding protrusions" (28) that converge to guide a sensor (’244 Patent, Figs. 3-4; col. 4:12-30). This detail may support a narrower construction limited to structures with these specific combined features.

• The Term: "dimensionally controlling"

  • Context and Importance: This term from method claim 10 is alleged to be indefinite and not enabled (Compl. ¶¶35, 38). Its meaning is central to the scope of the method claims.
  • Intrinsic Evidence for a Broader Interpretation: The term could be interpreted broadly to mean any act of checking the dimensions of a part.
  • Intrinsic Evidence for a Narrower Interpretation: The specification places the term in the context of a "serial manufacturing" process to "check whether a shrinkage of the molded part... corresponds to the expected theoretical shrinkage" (’244 Patent, col. 6:10-36). This suggests a more specific meaning tied to post-molding quality control to validate a manufacturing process, rather than a general measurement.

VI. Other Allegations

• Indirect Infringement: The complaint seeks a declaratory judgment of non-infringement for both induced and contributory infringement (Compl. ¶22). However, as a declaratory judgment action filed by the accused infringer, it does not set forth the patentee's factual basis for such allegations.
• Willful Infringement: Willfulness is not alleged by the Plaintiff. However, the complaint establishes a date of first-knowledge of the patent: the warning letter of December 8, 2021 (Compl. ¶23). This date would be relevant should Faurecia counterclaim and allege willful infringement, as it distinguishes the periods of alleged pre-suit and post-suit knowledge.

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

1. A core issue will be one of claim scope versus prior art: Can the term "positioning relief portion", as defined in the claims, be distinguished from the "integrally molded ribs" that Dräxlmaier alleges were well-known and used in prior art projects like the "E70 project"? The viability of both the infringement and invalidity arguments will depend on whether this term is construed as a specific, novel structure or a more general feature.

2. The case raises a significant question of claim definiteness: Dräxlmaier has directly challenged terms like "allowing" and "dimensionally controlling" as indefinite under 35 U.S.C. § 112. The dispute may turn on whether these terms, viewed in light of the patent's specification, provide a person of ordinary skill with reasonable certainty regarding the boundaries of the claimed invention.

3. Finally, a key evidentiary question will be one of infringing functionality: Assuming the claims are deemed valid and definite, does any feature on the accused Tesla Model Y door panel actually meet the functional requirements of the claims? Specifically, is there evidence that the features are configured and used "in order to measure the distance," as Claim 1 requires, or is their primary purpose for another reason, such as structural reinforcement, with any utility for measurement being merely incidental?