DCT

2:17-cv-00352

Electric Mirror LLC v. Majestic Mirror & Frame LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:17-cv-00352, W.D. Wash., 09/07/2017
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Washington because Defendant has purposefully availed itself of the district by selling and installing accused products to local customers, including several Seattle hotels; operating an interactive commercial website; attending local trade shows; and distributing products through Washington-based Amazon.com.
  • Core Dispute: Plaintiff alleges that Defendant’s backlit mirror products infringe a patent related to an internal mounting structure for mirror assemblies.
  • Technical Context: The technology concerns mounting systems for internally illuminated mirrors, a product category with significant application in the hospitality and high-end residential markets where aesthetic appearance and installation efficiency are paramount.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patent, obtained either from Plaintiff's public intellectual property website or from direct notification by the Plaintiff, which may form the basis for the willfulness allegation.

Case Timeline

Date Event
2005-11-23 ’414 Patent Priority Date
2010-12-14 ’414 Patent Issued
2017-09-07 First Amended Complaint Filed

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

U.S. Patent No. 7,853,414 - “Mounting Structure For A Mirror Assembly”

The Invention Explained

  • Problem Addressed: The patent describes conventional methods for mounting a mirror to a wall-mounted chassis as suffering from several drawbacks. These methods often rely on external brackets that are difficult to align, increase installation time, and are "unsightly." Furthermore, disassembling such mirrors for service is described as "cumbersome and difficult." (’414 Patent, col. 1:36-53).
  • The Patented Solution: The invention discloses an internal mounting structure that is hidden from view within the mirror assembly. The system uses a "hanger member" attached to the rear of the mirror platform and a corresponding "support member" attached to the chassis. The mirror platform can be hung on the chassis by removably securing the hanger member to the support member, concealing the entire mechanism within the assembly's interior. (’414 Patent, Abstract; col. 1:57-67, Fig. 1). This design allows the mirror to be mounted and removed in an "easy, aesthetically pleasing, reliable manner." (’414 Patent, col. 1:53-56).
  • Technical Importance: The patented approach sought to improve both the aesthetics and installation efficiency of lighted mirror assemblies by internalizing the mounting hardware. (’414 Patent, col. 1:53-56).

Key Claims at a Glance

  • The complaint asserts infringement of "at least one claim" without further specification (Compl. ¶12). Independent claim 1 is representative of the core invention.
  • The essential elements of independent claim 1 include:
    • A mirror platform with a front and rear surface.
    • A chassis that engages the mirror platform to define a "mirror assembly interior" and is mountable to a wall.
    • At least one electrical component (e.g., a light source) inside the assembly.
    • A mounting structure "disposed within the mirror assembly interior," which itself comprises a "support member" and a "hanger member."
    • The support member is mounted to one of (the mirror platform rear surface or the chassis), and the hanger member is mounted to the other.
    • The hanger member is "removably securable on the support member" to mount the mirror to the chassis "in alignment."
  • The complaint does not explicitly reserve the right to assert dependent claims, but the broad allegation of infringing "at least one claim" preserves this option.

III. The Accused Instrumentality

Product Identification

The complaint names the "Strand mirror" and other products in the "Backlit Mirrors" category offered by Defendant Majestic Mirrors & Frame, LLC (Compl. ¶13).

Functionality and Market Context

The accused products are described as lighted mirrors sold to commercial customers, including major hotels in the Seattle area (Compl. ¶3, ¶7). The complaint alleges that these products are made, used, sold, or offered for sale by Defendant and that infringement occurs, in part, through instructions and drawings provided on Defendant's website (Compl. ¶13, ¶18). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or sufficient technical detail to construct one. The infringement theory is articulated in general terms, alleging that Defendant's backlit mirrors incorporate the patented invention (Compl. ¶12-13). The core of the allegation is that the accused mirrors contain a mounting structure that performs the same function in the same way as the one claimed in the ’414 Patent.

Identified Points of Contention

  • Scope Questions: A primary issue will be whether the components of the accused mirrors meet the definitions of a "support member" and a "hanger member" that are "disposed within the mirror assembly interior." The litigation may focus on whether the accused mounting hardware is fully concealed from side views, a key aesthetic goal of the patent (’414 Patent, col. 4:31-34).
  • Technical Questions: A key evidentiary question is whether the accused products meet the specific structural arrangement of the claims, where one mounting component is on the mirror platform and the other is on the chassis (’414 Patent, col. 9:11-16). Plaintiff will need to provide evidence demonstrating that the accused products' components are not only structurally similar but are also "removably securable" in a manner that achieves "alignment," as required by the functional language of the claims (’414 Patent, col. 9:17-20).

V. Key Claim Terms for Construction

The Term: "support member" and "hanger member"

  • Context and Importance: These co-dependent terms define the heart of the patented mounting structure. Their construction will be dispositive for infringement, as the dispute will center on whether the brackets or other hardware used in Majestic's mirrors fall within the scope of these terms.
  • Intrinsic Evidence for a Broader Interpretation: The claims define these terms primarily by their function: one supports the other, and they are "removably securable" (’414 Patent, col. 9:17-18). The specification also uses the general terms "hanger members, or... hanger brackets" and "support members, or support brackets," which may suggest the terms are not limited to a single specific embodiment (’414 Patent, col. 3:37-39, col. 4:62-63).
  • Intrinsic Evidence for a Narrower Interpretation: The patent’s detailed description and figures disclose specific embodiments, such as L-shaped brackets and a post-and-slot engagement system (’414 Patent, Fig. 1-3, col. 3:37-39). A defendant could argue that the terms should be construed more narrowly to require these or structurally equivalent features, rather than covering any generic internal mounting system.

The Term: "disposed within the mirror assembly interior"

  • Context and Importance: This limitation is central to the patent's asserted aesthetic improvement over "unsightly" prior art with exposed brackets (’414 Patent, col. 1:40-42). Whether the accused mounting hardware is truly "within" the interior will be a critical factual and legal question.
  • Intrinsic Evidence for a Broader Interpretation: The "interior" is broadly defined by the claim as the space created when the "chassis [is] engageable with the mirror platform" (’414 Patent, col. 9:3-5). This could be argued to encompass any space behind the mirror's front reflective surface.
  • Intrinsic Evidence for a Narrower Interpretation: The specification states that because of the internal mounting, the brackets are "not exposed, thereby creating an aesthetically pleasing mirror assembly" (’414 Patent, col. 4:31-34). This statement, tied to the problem solved by the invention, could support a narrower construction requiring the components to be concealed from side views, not just from the front.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement to infringe, asserting that Defendant provides "drawings and/or instructions" on its website that actively encourage and instruct customers to assemble and use the accused products in an infringing manner (Compl. ¶13, ¶18).
  • Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge of the ’414 patent. The complaint states Defendant was aware of the patent through either Plaintiff’s public-facing intellectual property website or direct notification from Plaintiff, and thereafter refused to cease its allegedly infringing activities (Compl. ¶15).

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

  • A core issue will be one of claim construction: Can the functionally-defined terms "support member" and "hanger member", disclosed in the patent as specific L-shaped brackets and post-and-slot systems, be interpreted broadly enough to read on the mounting hardware used in Defendant’s accused mirrors?
  • A key evidentiary question will be one of structural and functional proof: Can Plaintiff produce sufficient evidence to show that the accused mirrors not only possess the claimed mounting components but that those components are arranged and operate as claimed—specifically, that they are fully "disposed within the mirror assembly interior" to achieve the "aesthetically pleasing" result central to the patent's purpose?
  • The viability of the willfulness claim will likely depend on what specific pre-suit notice Plaintiff can prove Defendant received and whether Defendant’s continued conduct in light of that notice can be characterized as objectively reckless.