DCT
2:23-cv-01436
Fantasia Trading LLC v. Slice Engineering LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fantasia Trading, LLC d/b/a AnkerDirect (Delaware)
- Defendant: Slice Engineering LLC (Florida)
- Plaintiff’s Counsel: Savitt Bruce & Willey LLP
- Case Identification: 2:23-cv-01436, W.D. Wash., 09/13/2023
- Venue Allegations: Plaintiff alleges venue is proper because Defendant purposefully directed activities at residents of the district, including by sending infringement communications to Amazon.com, which is headquartered in Washington, and because a substantial part of the events giving rise to the claim occurred in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its AnkerMake M5C 3-D printer does not infringe U.S. Patent No. 11,660,810, and that the patent is invalid.
- Technical Context: The technology concerns the design of extrusion heads (or "hot ends") for 3D printers, which are critical components for melting and precisely depositing plastic filament.
- Key Procedural History: The complaint states this action was precipitated by Defendant's infringement report to Amazon.com concerning Plaintiff's product. This report initiated Amazon's APEX Patent Evaluation process, which threatened removal of Plaintiff's product listings unless Plaintiff filed a declaratory judgment action within three weeks, thereby creating the basis for a justiciable controversy.
Case Timeline
| Date | Event |
|---|---|
| 2017-05-17 | '810 Patent Priority Date |
| 2023-05-30 | '810 Patent Issue Date |
| Prior to 2023-08-24 | Defendant allegedly sent infringement communications to Amazon.com |
| 2023-08-24 | Plaintiff received an email from Amazon.com regarding Defendant's infringement claim |
| 2023-09-13 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,660,810 - Adaptable High-Performance Extrusion Head for Fused Filament Fabrication Systems
- Patent Identification: U.S. Patent No. 11,660,810, issued May 30, 2023.
The Invention Explained
- Problem Addressed: The patent's background describes a fundamental design conflict in prior art "all-metal" 3D printer extrusion heads. The component that thermally isolates the hot melting section from the cold filament-feeding section (the "heat break") must also provide the mechanical structure connecting the two sections. This requires the heat break to be strong, but a strong structure typically conducts more heat, compromising the thermal isolation needed for high-quality printing ('810 Patent, col. 7:31-44).
- The Patented Solution: The invention decouples the thermal isolation and mechanical support functions. It proposes using an extremely thin-walled metal "feed tube" to guide the filament, which provides excellent thermal isolation due to its minimal cross-section. The mechanical load is instead borne by a separate, rigid "bridge" structure, composed of spacers or tension members, that connects the heater and cooler while being physically separate from the feed tube ('810 Patent, Abstract; col. 9:57-col. 10:11). Figure 9 of the patent illustrates this concept, showing the feed tube (104) passing through a central gap while a separate bridge (117) provides the structural connection.
- Technical Importance: By separating these functions, the design allows the thermal-isolating feed tube to be made much thinner than in conventional designs, potentially improving thermal efficiency and print quality without sacrificing the mechanical rigidity needed for reliable operation ('810 Patent, col. 8:26-42).
Key Claims at a Glance
- The complaint asserts non-infringement of the patent generally, with a focus on independent claim 1 (Compl. ¶20). It also seeks a declaration of invalidity for claims 1-20 (Compl. ¶28).
- Essential elements of Independent Claim 1 include:
- A generally axially extending metal feed tube for filament.
- A heater coupled to the downstream portion of the feed tube.
- A cooler coupled to the upstream portion of the feed tube and spaced axially from the heater, creating a gap.
- A bridge that traverses the gap, is spaced radially from the feed tube, provides a rigid mechanical connection, and "at least partially reduces mechanical loading on the feed tube."
- The bridge itself comprises "a first structural component" and "a second structural component," each having portions that bear against the heater and the cooler.
- The complaint does not explicitly reserve the right to assert dependent claims but seeks a declaration of non-infringement and invalidity for all claims.
III. The Accused Instrumentality
Product Identification
- The AnkerMake M5C 3-D printer (Compl. ¶12).
Functionality and Market Context
- The complaint identifies the Accused Product as a 3-D printer sold by Plaintiff in the United States, including via listings on Amazon.com (Compl. ¶12). It alleges that the threatened removal of these listings would cause substantial harm to its business (Compl. ¶18). The complaint does not provide specific technical details about the operation of the Accused Product's extrusion head, other than to deny that it incorporates the features of the asserted patent (Compl. ¶¶ 21-23).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes Plaintiff's specific denials regarding the elements of Claim 1.
U.S. Patent No. 11,660,810 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (Plaintiff's Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a cooler thermally coupled with the upstream portion for reducing upstream heat transfer, the cooler spaced generally axially upstream from the heater | Plaintiff alleges the Accused Product does not comprise "a cooler … spaced generally axially upstream from the heater" as described and shown in the patent. | ¶21 | col. 9:51-54 |
| a generally axially extending gap, bound by a bridge traversing the gap between the cooler and the heater | Plaintiff alleges the Accused Product does not comprise "a generally axially extending gap, bound by a bridge traversing the gap between the cooler and the heater" as described and shown in the patent. Figure 9 of the patent, a cross-sectional view referenced in the complaint's allegations, illustrates the claimed bridge (117) and gap (116) as distinct features. | ¶22 | col. 9:55-58 |
| the bridge ... comprises: a first structural component ... having a first portion bearing against the heater and a second portion bearing against the cooler...; and a second structural component ... having a first portion bearing against the heater and a second portion bearing against the cooler | Plaintiff alleges the Accused Product does not comprise a bridge with a "first structural component ... having a first portion bearing against the heater" as described and shown in the patent. | ¶23, ¶20 | col. 10:1-11 |
Identified Points of Contention
- Structural Questions: The central dispute appears to be factual: does the AnkerMake M5C printer's extrusion head physically embody the specific architecture of claim 1? Plaintiff’s denials suggest that its product may use a more conventional design where a single, multifunctional heat break connects the hot and cold ends, rather than the claimed "bridge" that is "spaced radially and apart from the metal feed tube."
- Functional Questions: A key question for the court will be whether the Accused Product's structure performs the function of having a bridge that "at least partially reduces mechanical loading on the feed tube." Resolving this will likely require expert analysis of the forces within the AnkerMake M5C's extrusion head during operation.
V. Key Claim Terms for Construction
Term: "bridge"
- Context and Importance: This term defines the core inventive concept of a separate mechanical support structure. The outcome of the infringement analysis will hinge on whether the structure connecting the hot and cold ends of the Accused Product meets the definition of the claimed "bridge."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires the bridge to comprise "a first structural component" and "a second structural component" ('810 Patent, col. 10:2-11). A party could argue that any connecting architecture with at least two distinct structural elements or points of contact that provides rigidity could meet this definition.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the bridge in terms of discrete components like "at least one spacer 107 or at least one tension member 108" ('810 Patent, col. 5:37-38) and notes that prototypes used "stainless steel screws and tubular standoffs" ('810 Patent, col. 9:7-8). This may support an interpretation that the "bridge" must be an assembly of separate parts rather than an integrated component.
Term: "at least partially reduces mechanical loading on the feed tube"
- Context and Importance: This functional limitation is critical for distinguishing the invention from prior art where the heat break bore the full mechanical load. Practitioners may focus on this term because infringement depends on whether the accused structure performs this specific function, which may be a matter of degree.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any connecting structure that adds any amount of rigidity between the heater and cooler inherently "partially reduces" the load on the feed tube compared to a hypothetical design where the feed tube is the sole connector.
- Evidence for a Narrower Interpretation: The patent explains the objective is to relieve the feed tube of loading so its wall thickness "can be greatly reduced to improve its thermal isolation performance" ('810 Patent, col. 8:28-31). This suggests the reduction in loading must be significant enough to enable the stated technical benefit, not merely incidental.
VI. Other Allegations
Indirect Infringement
- The complaint seeks a declaratory judgment of non-infringement of any claims "contributorily, by inducement... or jointly" (Compl., Prayer ¶a). However, the complaint pleads no specific facts regarding these forms of infringement.
Willful Infringement
- The complaint seeks a declaration that it has not "willfully" infringed (Compl., Prayer ¶a). The basis for potential knowledge of the patent is established by the Defendant's notice to Amazon, which was communicated to the Plaintiff on August 24, 2023 (Compl. ¶17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural identity: does the physical assembly of the AnkerMake M5C's extrusion head contain a "bridge" that is structurally distinct and "spaced radially and apart from the metal feed tube," as required by the claims, or does it utilize a conventional, integrated heat break that performs both thermal and mechanical functions?
- A key evidentiary question will be one of functional performance: assuming a structure exists that could be characterized as a bridge, does it "at least partially reduce[] mechanical loading on the feed tube" in a manner consistent with the patent's teachings, or is the feed tube itself the primary load-bearing component?
- A central question for the invalidity case will be one of anticipation and obviousness: do the prior art references cited in the complaint, such as Wolf et al. (US 2016/0236408), disclose every element of the asserted claims, including the specific architecture of a separate, load-bearing "bridge" that allows for a mechanically unloaded, thin-walled feed tube? The complaint’s conclusory allegations will need to be substantiated with detailed claim charts and expert analysis.