DCT
2:09-cv-00935
Reliance Controls Corp v. Harbor Freight Tools USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Reliance Controls Corporation (Wisconsin)
- Defendant: Harbor Freight Tools USA, Inc. a/k/a Central Processing, LLC and Master Quality Tools and Machinery, Inc. (California)
- Plaintiff’s Counsel: BOYLE FREDRICKSON, S.C.
- Case Identification: 2:09-cv-00935, E.D. Wis., 09/28/2009
- Venue Allegations: Venue is alleged to be proper based on Defendant Harbor Freight conducting regular business, operating dealer locations, and actively marketing and selling the accused product within the Eastern District of Wisconsin.
- Core Dispute: Plaintiff alleges that Defendant’s power inlet box, sold as part of a manual transfer switch kit, infringes a patent related to the design of weatherproof electrical enclosures.
- Technical Context: The technology concerns outdoor-mounted electrical boxes that provide a safe and weatherproof connection point for linking a portable generator to a building's main electrical panel during a power outage.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 1997-12-31 | '719 Patent Application Filing Date |
| 1999-11-16 | '719 Patent Issue Date |
| 2009-09-28 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 5,984,719 - “Remote Power Inlet Box For An Auxiliary Power Supply System” (issued Nov. 16, 1999)
The Invention Explained
- Problem Addressed: The patent describes two primary problems with prior art power inlet boxes. First, their design, which typically provides access to the internal wiring cavity through only a single, front-facing opening, makes it "difficult to manipulate the wiring" during installation ('719 Patent, col. 1:40-45). Second, the joint between the cover and the housing is often a simple vertical seam, leaving an upward-facing edge "directly exposed to precipitation" and reliant on a gasket that can deteriorate over time, leading to water ingress ('719 Patent, col. 1:46-58).
- The Patented Solution: The invention proposes a power inlet box with a base member and a separate cover member. The base member features both a front opening and a top opening, which "increases the size and alters the configuration of the opening" to make it easier for an installer to manipulate wires connected to the socket ('719 Patent, col. 1:62-65). To improve weatherproofing, the cover includes a front wall and a top wall with downward-extending flanges that overlap the edges of the base member, creating a "shingle structure" that prevents moisture from entering the internal cavity without relying solely on a gasket ('719 Patent, col. 2:41-47; col. 6:46-50).
- Technical Importance: This design aimed to provide a more weather-resistant power inlet box that was simultaneously easier and faster for an electrician to install ('719 Patent, col. 1:59-2:5).
Key Claims at a Glance
- The complaint asserts infringement of the ’719 Patent generally, without specifying which of the 29 claims are at issue (Compl. ¶17).
- Independent claim 1, a representative apparatus claim, requires:
- a base member defining an internal cavity and adapted for mounting to a building;
- a cover member adapted for removable interconnection with the base member for enclosing the internal cavity;
- a power inlet mounted to the cover member such that the cover member and the inlet are removable as a unit from the base member;
- wherein the base member and cover member include an engagement structure that provides for engagement via a "combination movement" of the cover member, first in one direction toward the base member and then in a second, transverse direction.
III. The Accused Instrumentality
Product Identification
The accused instrumentality is the "power inlet box incorporated in Harbor Freight's Indoor Manual Transfer Switch Kit (Model No. 96425-4VGA)," referred to as the "Accused Product" (Compl. ¶3, ¶17).
Functionality and Market Context
The complaint alleges the Accused Product is a "power inlet box for use in a system for connecting an auxiliary power source, such as a power generator, to the electrical system of a building" (Compl. ¶18). The complaint does not provide specific technical details on the construction, materials, or assembly mechanism of the Accused Product, alleging more broadly that it "embodies the patented invention" claimed in the '719 Patent (Compl. ¶18).
IV. Analysis of Infringement Allegations
The complaint does not contain a detailed breakdown of its infringement theory or a claim chart. The allegations are made at a high level, stating that the Accused Product embodies the invention. No probative visual evidence provided in complaint.
'719 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a base member defining an internal cavity and adapted for mounting to the building; | The complaint alleges the Accused Product is a power inlet box for connecting an auxiliary power source to a building's electrical system and generally embodies the patented invention. | ¶18 | col. 8:36-39 |
| a cover member adapted for removable interconnection with the base member for enclosing the internal cavity; | The complaint alleges the Accused Product embodies the patented invention, which includes a cover member. | ¶18 | col. 8:40-43 |
| a power inlet mounted to the cover member such that the cover member and the inlet are removable as a unit from the base member; | The complaint alleges the Accused Product embodies the patented invention, which includes a power inlet mounted to the cover as a removable unit. | ¶18 | col. 8:44-47 |
| wherein the base member and the cover member include engagement structure providing engagement... via combination movement of the cover member in a first direction... and in a second direction transverse to the first direction. | The complaint does not describe the specific assembly mechanism of the Accused Product but alleges that the product as a whole embodies the patented invention, which would necessarily include this feature. | ¶18 | col. 8:48-55 |
Identified Points of Contention
- Scope Questions: The infringement analysis will turn on the proper construction of the phrase "combination movement... in a first direction toward the base member and in a second direction transverse to the first direction." The question for the court will be whether this language is limited to the specific inward-then-downward motion described in the patent's preferred embodiment or if it can be read more broadly to cover other multi-step engagement methods.
- Technical Questions: The complaint alleges the Accused Product "embodies the patented invention" without providing specific facts about how the product is constructed or assembled (Compl. ¶18). A key evidentiary question will be whether the Plaintiff can demonstrate that the Accused Product’s components and assembly method map onto the specific structural and functional limitations of the asserted claims.
V. Key Claim Terms for Construction
- The Term: "combination movement ... in a first direction toward the base member and in a second direction transverse to the first direction"
- Context and Importance: This limitation appears to be a primary point of novelty, describing the specific manner in which the cover engages the base to facilitate both easy installation and weatherproofing. Practitioners may focus on this term because the entire infringement case could depend on whether the accused product's assembly process falls within its scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party seeking a broader scope may argue that the claim language itself is not explicitly limited to any particular set of orthogonal directions and should cover any two-step connection process involving movement along two different vectors.
- Evidence for a Narrower Interpretation: The specification describes a specific sequence where the user "moves cover member 44 laterally inwardly toward base member 42" and then "moves cover member 44 downwardly relative to base member 42" ('719 Patent, col. 6:15-36). This detailed description of an inward-then-downward motion may be used to argue for a narrower construction limited to that specific type of engagement.
VI. Other Allegations
- Indirect Infringement: The complaint does not allege induced or contributory infringement. The allegations are restricted to direct infringement by "making, using, selling, offering for sale, and/or importing" the Accused Product (Compl. ¶17).
- Willful Infringement: The complaint makes a demand for a finding of willful infringement and treble damages in the prayer for relief (Prayer ¶A, ¶C). The body of the complaint, however, does not plead any specific facts to support this, such as alleging that Defendants had pre-suit knowledge of the '719 Patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the functional language "combination movement... in a first direction... and in a second direction transverse," which is described in the specification as a specific inward-then-downward action, be construed to cover the assembly mechanism of the accused power inlet box?
- A key evidentiary question will be one of functional proof: given the complaint’s conclusory allegations, what evidence will the plaintiff present to demonstrate that the accused product’s cover actually engages its base using the specific two-vector motion required by Claim 1, or does its mechanical operation differ in a way that is material to the claim language?