DCT
2:20-cv-00351
Coleman Co Inc v. Team W
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: The Coleman Company, Inc. (Delaware)
- Defendant: Team Worldwide Corporation (Taiwan)
- Plaintiff’s Counsel: Christian & Barton, LLP; Meunier Carlin & Curfman LLC
- Case Identification: 2:20-cv-00351, E.D. Va., 06/29/2020
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation, which may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s inflatable air mattresses infringe a patent related to an internal side support beam structure designed to limit outward bulging.
- Technical Context: The lawsuit concerns the structural design of consumer air mattresses, a market where comfort and durability are key differentiators, particularly for "double-height" models that emulate traditional beds.
- Key Procedural History: The complaint alleges that Defendant Team Worldwide Corporation is the assignee of U.S. Patent No. 10,104,967, which disclosed the patent-in-suit in an information disclosure statement (IDS) during its prosecution. This allegation directly supports the claim of pre-suit knowledge and willfulness.
Case Timeline
| Date | Event |
|---|---|
| 2003-06-18 | Priority Date for U.S. Patent No. 7,089,618 |
| 2006-08-15 | U.S. Patent No. 7,089,618 Issued |
| 2020-06-29 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,089,618 - “Air Mattress,”
- Patent Identification: U.S. Patent No. 7,089,618, “Air Mattress,” issued August 15, 2006.
The Invention Explained
- Problem Addressed: The patent describes issues with prior art air mattresses, particularly taller "double-height" models. When a user lies on such a mattress, the increased air pressure causes the sidewalls to bulge outwards, making the mattress less stable and comfortable (’618 Patent, col. 2:7-17). Existing solutions were often complex, involved multiple separate air chambers, or were otherwise inadequate for controlling this sidewall expansion (’618 Patent, col. 2:18-51).
- The Patented Solution: The invention proposes a single-chamber air mattress with a novel internal support structure. It uses at least one "side support beam"—a flexible strip of material—that is attached along one edge to the inside of the mattress’s vertical side panel and along a second edge to the inside of the top or bottom panel (’618 Patent, col. 3:1-8). This beam is arranged so that a section of it is unattached between its two edges. When the mattress is inflated and a load is applied, this unattached section goes into tension, acting like a tether to limit the outward expansion of the side panel, thereby maintaining the mattress's shape (’618 Patent, col. 9:1-5; Fig. 7).
- Technical Importance: This design offers a way to improve the stability of a tall, single-chamber air mattress without resorting to more complex and potentially leak-prone multi-chamber constructions (’618 Patent, col. 5:6-11).
Key Claims at a Glance
- The complaint asserts independent claim 13 (’618 Patent, col. 8:51-col. 9:5; Compl. ¶27).
- The essential elements of independent claim 13 are:
- An air mattress with a top panel, a spaced bottom panel, and at least one side panel joined to define an air chamber.
- At least one internal side support beam extending lengthwise.
- The beam has a first edge affixed to an inside of the side panel.
- The beam has a second edge affixed to an inside of at least one of the top and bottom panels.
- There is a section of the beam between its first and second edges that is attached to neither the side panel nor the top/bottom panel.
- This structure is arranged such that when inflated, the unattached section is in tension and limits the outward expansion of the side panel.
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶6).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "inflatable devices" and "air mattresses" sold by Defendant TWW under numerous brands, including Serta, Insta-Bed, Air Cloud, ALPS Mountaineering, Cozelle, and others (Compl. ¶4, ¶22). The complaint specifically identifies Serta SKU Nos. 85001714, ST840017, ST840011, ST840015, ST840018 and Insta-Bed SKU Nos. 84003115, 840017G as the "’618 Accused Products" (Compl. ¶23, ¶28).
Functionality and Market Context
The complaint alleges, on information and belief, that these products embody the patented invention (Compl. ¶23). It specifically alleges that the accused Serta and Insta-Bed products possess a "triple-bump external appearance on the side panel" which is attributed to the use of "at least two internal side support beams" that meet the elements of claim 13 (Compl. ¶28). The complaint alleges these products are sold online and at various retail establishments in the district (Compl. ¶24).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint. The infringement allegations are based on textual descriptions and product identifiers.
- Claim Chart Summary: The complaint provides a narrative breakdown of its infringement theory, which is summarized in the table below.
’618 Patent Infringement Allegations
| Claim Element (from Independent Claim 13) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An air mattress, comprising: a top panel and a spaced bottom panel; at least one side panel extending between the top panel and the bottom panel; the at least one side panel, the top panel, and the bottom panel being joined to one another along their common peripheral edges to define an air chamber therebetween; | The accused products are alleged to be air mattresses having a top panel, a spaced bottom panel, and at least one side panel joined to define an air chamber. | ¶28 | col. 4:7-14 |
| and at least one internal side support beam extending in the lengthwise direction of the at least one side panel, | The accused products allegedly include "at least one internal side support beam extending in the lengthwise direction of the at least one side panel." | ¶28 | col. 7:27-30 |
| the at least one internal side support beam having a first edge affixed to an inside of the at least one side panel, | The accused products' internal side support beam allegedly has "a first edge affixed to an inside of the at least one side panel." | ¶28 | col. 7:30-33 |
| a second edge affixed to an inside of at least one of the top panel and the bottom panel, | The accused products' internal side support beam allegedly has "a second edge affixed to an inside of at least one of the top panel and the bottom panel." | ¶28 | col. 7:33-35 |
| and a section between the first edge and the second edge where the first side support beam is attached neither to said at least one side panel nor said at least one of the top panel and the bottom panel, | The accused products allegedly have "a section between the first edge and the second edge where the first side support beam is attached neither to said at least one side panel nor said at least one of the top panel and the bottom panel." | ¶28 | col. 8:60-68 |
| the internal side support beam being arranged such that when the air chamber is filled with air, the section of the internal side support beam is in tension and the internal side support beam limits outward expansion of said at least one side panel. | The accused products' internal side support beam is allegedly "arranged such that when the air chamber is filled with air, the section of the internal side support beam is in tension and the internal side support beam limits outward expansion of said at least one side panel." | ¶28 | col. 9:1-5 |
- Identified Points of Contention:
- Evidentiary Question: The complaint's allegations regarding the internal structure of the accused products are made "on information and belief" (Compl. ¶23). A central question for the case will be whether discovery and expert analysis confirm that the accused mattresses possess the specific internal beam structure required by the claims. The "triple-bump" appearance is circumstantial evidence that will require substantiation (Compl. ¶28).
- Scope Question: The claim requires a "section... attached neither to said at least one side panel nor said at least one of the top panel and the bottom panel." The case may turn on what constitutes an "attachment" and whether the accused products' internal structure meets this negative limitation.
V. Key Claim Terms for Construction
- The Term: "a section between the first edge and the second edge where the first side support beam is attached neither to said at least one side panel nor said at least one of the top panel and the bottom panel"
- Context and Importance: This negative limitation defines the structurally independent portion of the support beam that creates the tension element. Its construction is critical because it distinguishes the invention from other internal support structures, such as simple I-beams or fully connected webbing. Whether the accused products meet this limitation will likely be a primary point of dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is the primary support. It uses general terms like "section" and "attached neither," which could be argued to cover any structure that has a functionally unattached portion, regardless of its specific geometry or formation. The specification describes the function broadly: "to limit the outward expansion of the at least one side panel" (’618 Patent, col. 3:9-11).
- Evidence for a Narrower Interpretation: Figure 7 depicts a specific embodiment where the support beam forms a triangular cross-section with the side and top/bottom panels. A defendant may argue that the term should be construed in light of this embodiment. The specification also describes the function in specific terms: "the section of the internal side support beam is in tension" (’618 Patent, col. 9:2-4), which could be argued to require a structure capable of bearing a tensile load in a specific way, potentially limiting the scope of qualifying structures.
VI. Other Allegations
- Willful Infringement: The complaint alleges that TWW's infringement has been willful (Compl. ¶31). This allegation is based on TWW’s alleged pre-suit knowledge of the ’618 Patent, evidenced by the fact that the patent was cited in an Information Disclosure Statement during the prosecution of U.S. Patent No. 10,104,967 and U.S. Patent Application No. 14/927,438, for which TWW is the assignee (Compl. ¶31).
VII. Analyst’s Conclusion: Key Questions for the Case
- An Evidentiary Question of Structure: The case’s foundation rests on an issue of fact: what is the actual internal construction of the accused Serta and Insta-Bed mattresses? The plaintiff's "information and belief" pleading, based on external appearance, will need to be substantiated through discovery and product teardowns to prove the existence of the claimed internal support beam.
- A Definitional Question of Scope: The dispute will likely focus on the claim construction of the negative limitation "a section... attached neither to..." How the court defines "attached" will be critical. This will determine whether the specific internal connections within the accused products, if any, fall inside or outside the scope of the patent's claims.
- A Question of Intent: Given the allegation that the patent-in-suit was cited during the prosecution of the defendant's own patent, the willfulness claim appears to have a factual basis for pre-suit knowledge. A key question will be whether the defendant can establish it had a good-faith belief of non-infringement or invalidity, despite this knowledge.