Rinamo Kim v. Advance Fittings LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kim Rinamo, Janne Huovila, and Jörgen Johansson (Finland)
  • Defendant: Advance Fittings LLC (Wisconsin)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 3:24-cv-00389, W.D. Wis., 06/11/2024
• Venue Allegations: Venue is asserted based on the Defendant having an established place of business within the Western District of Wisconsin.
• Core Dispute: Plaintiffs allege that Defendant’s unspecified products infringe a patent related to a universal mechanical gripper.
• Technical Context: The technology concerns adjustable gripping devices for securing longitudinal objects, with applications ranging from industrial material handling to consumer products.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit. The filing of this complaint appears to be the first legal action involving this patent.

Case Timeline

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

• Patent Identification: U.S. Patent No. 10,627,013, "Universal Gripper," issued April 21, 2020 (the “’013 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section identifies a need for a versatile gripper capable of handling longitudinal objects of varying sizes and shapes, such as pipes or beams in industrial settings. It notes that existing devices are often designed for a specific use and are therefore limited. The patent also describes a "special adaptation" for locking two objects together, such as attaching a pram to a shopping cart ('013 Patent, col. 1:5-10, 1:36-39).
• The Patented Solution: The invention is a gripper with a main body, a first fixed jaw with a concave groove, and at least two additional movable jaws that are pivotably or detachably connected. A closing element, which can be operated mechanically or by other means, presses the movable jaws toward the fixed jaw to secure an object. This multi-jaw configuration is designed to accommodate objects of different shapes and provide a secure grip ('013 Patent, Abstract; col. 2:51-64). Figure 5, for example, illustrates an embodiment with longitudinally extended jaws (2, 7, 19) to provide greater support for moment loads ('013 Patent, col. 3:49-54).
• Technical Importance: The design aims to provide a single, adaptable tool for multiple purposes, from moving heavy industrial posts to securing consumer items like a pram handle to a shopping cart frame ('013 Patent, col. 2:51-56, col. 4:44-48).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '013 Patent Claims" in an external exhibit not provided with the complaint (Compl. ¶13). Independent claim 1 is analyzed here as a representative claim.
• Independent Claim 1 of the ’013 Patent recites:
  • A body comprising an attachment configured to attach the body to a holding body;
  • A first gripping jaw extending from the body with a concave groove;
  • At least one second and one third gripping jaw, each with a concave groove;
  • The proximal longitudinal edges of the first and second concave grooves are attached to each other "either pivotably or detachably";
  • The proximal longitudinal edges of the second and third concave grooves are attached to each other "either pivotably or detachably";
  • A closing element for pressing the second gripping jaw towards the first, where the closing element includes an apparatus operable "electrically, electromagnetically, mechanically, pneumatically or hydraulically"; and
  • A dimensional limitation wherein the distance between the longitudinal edges of the second gripping jaw is smaller than that of the first gripping jaw.
• The complaint does not explicitly reserve the right to assert dependent claims but refers generally to "one or more claims of the '013 Patent" (Compl. ¶13).

III. The Accused Instrumentality

• Product Identification: The complaint does not identify any specific accused products, methods, or services by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in charts incorporated into the complaint (Compl. ¶13), but those charts are not included in the publicly filed document.
• Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim charts in an external "Exhibit 2," which was not provided with the filed complaint (Compl. ¶19). Therefore, a detailed claim chart summary cannot be constructed. The complaint's narrative allegations are general, stating that Defendant’s products "practice the technology claimed by the '013 Patent" and "satisfy all elements of the Exemplary '013 Patent Claims" (Compl. ¶18). No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of representative Claim 1, the infringement analysis may raise several technical and legal questions:
  • Scope Questions: A central question will concern the structural configuration of the accused products. Specifically, does an accused product contain the claimed arrangement of a "first gripping jaw" and "at least one second and one third gripping jaw" connected in the manner recited by the claim ('013 Patent, col. 7:31-41)? The interpretation of what constitutes distinct first, second, and third jaws will be a key issue.
  • Technical Questions: What evidence demonstrates that the accused product meets the dimensional requirement that "the distance between the longitudinal edges of the second gripping jaw is smaller than the distance between the longitudinal edges of the first gripping jaw" ('013 Patent, col. 7:47-50)? Further, what evidence shows that the accused product’s tightening mechanism qualifies as a "closing element" that is "operable electrically, electromagnetically, mechanically, pneumatically or hydraulically" as broadly claimed ('013 Patent, col. 7:42-46)?

V. Key Claim Terms for Construction

• The Term: "holding body"

  • Context and Importance: This term defines the universe of structures to which the patented gripper can be attached. Its construction is critical to determining the overall scope of the invention and whether the accused product's intended use falls within that scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification explicitly defines "holding body" as a "movable or stationary element," including "mounting elements of articulated booms, excavators, hoists and cranes, movable vehicles or carts or solid structures" ('013 Patent, col. 2:46-50). This language supports a broad construction.
    • Evidence for a Narrower Interpretation: The patent highlights specific applications, such as attaching to a "wire frame of a shopping cart" ('013 Patent, col. 2:27-29) or a "coupler of an articulated boom" ('013 Patent, col. 2:19-21). A party could argue these specific examples should inform and potentially limit the term's otherwise broad definition.

• The Term: "pivotably or detachably"

  • Context and Importance: This term describes the nature of the connection between the multiple jaws. The physical mechanism of the accused product's jaws must conform to this limitation. Practitioners may focus on this term because it is central to the claimed multi-jaw articulation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain meaning of the words suggests any connection that allows either a rotational/hinge-like movement or a complete separation and re-attachment would satisfy the limitation.
    • Evidence for a Narrower Interpretation: The specification describes specific embodiments, such as a "hinge 6" ('013 Patent, col. 3:8, Fig. 2) or a mechanism that allows "detachment of the second jaw from the gripper and attaching it back" ('013 Patent, col. 5:56-59). An argument could be made that the term should be construed in light of these disclosed mechanical implementations.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users... to use its products in the customary and intended manner that infringes the '013 Patent" (Compl. ¶16). Knowledge is alleged to have started, at the latest, upon service of the complaint (Compl. ¶17).
• Willful Infringement: The willfulness allegation is based on post-suit conduct. The complaint alleges that "Despite such actual knowledge [from the service of the Complaint], Defendant continues to make, use, test, sell, offer for sale, market, and/or import" infringing products (Compl. ¶16).

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

• A primary issue will be one of evidentiary sufficiency: given the complaint's lack of specific factual allegations regarding the accused products, a threshold question is whether Plaintiff can produce discovery evidence to demonstrate that Defendant's products practice each structural and functional limitation of the asserted claims, particularly the specific multi-jaw arrangement and dimensional constraints.
• The case may also turn on a question of structural scope: can the configuration of the accused product be shown to meet the claim requirement for three distinct jaws—a "first," "second," and "third" gripping jaw—connected in the "pivotably or detachably" manner required by claim 1? The answer will depend on both the physical nature of the accused device and the court’s construction of the claim terms.
• A key evidentiary question will be one of functional operation: does the accused product’s tightening mechanism meet the definition of a "closing element" that is "operable electrically, electromagnetically, mechanically, pneumatically or hydraulically," or is there a fundamental mismatch between the accused mechanism and this broad but specific functional limitation?