DCT

3:24-cv-00390

Rinamo Kim v. VNE Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:24-cv-00390, W.D. Wis., 06/11/2024
  • Venue Allegations: Venue is alleged to be proper based on the Defendant having an established place of business in the district and committing alleged acts of infringement within the district.
  • Core Dispute: Plaintiffs allege that Defendant’s unspecified products infringe a patent related to a universal, multi-jaw mechanical gripper.
  • Technical Context: The technology pertains to mechanical gripping devices designed for adaptability across various industrial and consumer applications, such as securing a stroller to a shopping cart.
  • 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
2016-04-07 '013 Patent Priority Date
2020-04-21 '013 Patent Issue Date
2024-06-11 Complaint Filing Date

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

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

The Invention Explained

  • Problem Addressed: The patent seeks to solve the problem of existing clamps and grippers being designed for specific, limited uses, which restricts their utility for handling a variety of longitudinal objects (e.g., pipes, beams) or for coupling different types of equipment, such as a pram and a shopping cart (’013 Patent, col. 1:11-28, 1:36-39).
  • The Patented Solution: The invention is a gripper comprising a main body, a fixed "first gripping jaw," and at least two additional movable jaws ("second" and "third"). These additional jaws are pivotably or detachably connected, allowing the gripper to open and close around an object. A "closing element" (e.g., a mechanical lock, magnet, or hydraulic actuator) secures the jaws, and the entire device can be mounted to a "holding body" like a vehicle, crane, or cart (’013 Patent, Abstract; col. 2:55-64; Fig. 5).
  • Technical Importance: The design's use of multiple, independently attached jaws aims to provide greater flexibility to accommodate objects of different shapes and sizes than conventional two-jaw clamps (’013 Patent, col. 4:58-62).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims, instead referencing an unattached exhibit (Compl. ¶13). The analysis below focuses on the patent’s sole independent claim, Claim 1.
  • Independent Claim 1 requires:
    • A body with an attachment for 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 concave grooves, whose proximal edges are pivotably or detachably attached to the first and second jaws, respectively.
    • A "closing element" for pressing the second jaw toward the first, where the element is operable "electrically, electromagnetically, mechanically, pneumatically or hydraulically."
    • A dimensional limitation where the distance between the longitudinal edges of the second jaw is smaller than that of the first jaw.
  • The complaint reserves the right to assert other claims (Compl. ¶13).

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify any accused product or service by name. It refers generically to "Exemplary Defendant Products" that are purportedly detailed in an unattached "Exhibit 2" (Compl. ¶13, 18).

Functionality and Market Context

  • The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality, features, or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts contained in an Exhibit 2, which was not filed with the complaint (Compl. ¶18, 19). The complaint’s narrative theory of infringement is limited to the conclusory statement that the "Exemplary Defendant 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:
    • Structural Mismatch: A primary question will be whether the accused products contain the specific structure of Claim 1, namely a three-jaw configuration ("first," "second," and "third" jaws). The patent itself depicts simpler two-jaw embodiments (e.g., Fig. 2), and a defense may arise if the accused products practice such a two-jaw design, which would not meet the limitations of Claim 1.
    • Evidentiary Burden: The complaint provides no factual allegations to support how any accused product meets any specific claim limitation. A threshold issue for the court will be whether the Plaintiffs can produce evidence demonstrating that the accused products contain, for example, the specific jaw configuration and dimensional limitations required by Claim 1.

V. Key Claim Terms for Construction

  • The Term: "at least one second and one third gripping jaw"
  • Context and Importance: This term appears in independent Claim 1 and is a central structural limitation of the invention as claimed. The infringement analysis will turn on whether an accused product has this specific multi-jaw configuration. Practitioners may focus on this term because its plain language suggests a three-part structure (one first, one second, one third jaw), which may be a significant point of distinction from more common two-jaw clamps.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue that the purpose of increasing the number of jaws is to "provide further flexibility" (’013 Patent, col. 4:60-61), suggesting the exact number and naming convention ("second and third") should be interpreted functionally rather than as a rigid structural requirement.
    • Evidence for a Narrower Interpretation: The claim’s explicit use of separate ordinals ("second" and "third") strongly implies two distinct elements in addition to the "first" jaw. This interpretation is supported by the embodiment shown in Figure 5, which depicts a first jaw (2) and two separate movable jaws (7, 19), which the specification describes as "at least two second gripping jaws" (’013 Patent, col. 4:52-54, 4:62-63).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" (’013 Patent, ¶16). The allegation of knowledge for inducement is based on the date of service of the complaint (Compl. ¶17).
  • Willful Infringement: The complaint alleges that service of the complaint and its attached (but un-filed) claim charts provides Defendant with "actual knowledge" and that any continued infringement is therefore willful (Compl. ¶15-16). The claim is based on post-suit knowledge, as no pre-suit knowledge is alleged.

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

  1. A central issue will be one of structural correspondence: Can Plaintiffs demonstrate that the accused products embody the specific three-part jaw structure ("a first gripping jaw," "at least one second and one third gripping jaw") required by the plain language of Claim 1, or do the products utilize a simpler design that falls outside the claim’s scope?

  2. A threshold question will concern pleading sufficiency: Does a complaint that provides no factual detail about the accused products or their operation—relying entirely on an unattached exhibit—satisfy the plausibility standard required to state a claim for patent infringement under federal pleading rules?