3:25-cv-00754
Stuck v. Toyota Motor Mfg West Virginia Inc
I. Executive Summary and Procedural Information
Parties & Counsel:
- Plaintiff: Michael Stuck (Pennsylvania)
- Defendant: Toyota Motor Manufacturing, West Virginia, Inc. (West Virginia)
- Plaintiff’s Counsel: Hendrickson & Long, PLLC; Forbes Law Offices, PLLC
Case Identification: 3:25-cv-00754, S.D. W. Va., 12/26/2025
Venue Allegations: Venue is alleged to be proper in the Southern District of West Virginia because a substantial part of the events, including the invention's development and use, occurred at Defendant’s manufacturing plant in Buffalo, West Virginia.
Core Dispute: Plaintiff seeks a declaratory judgment that he is the sole inventor of a patented manufacturing methodology, that Defendant has no "shop rights" to use it, and that any potential rights do not extend to Defendant's corporate affiliates.
Technical Context: The technology addresses a known problem in high-volume automotive manufacturing where automated inspection systems can incorrectly reject good parts, causing significant waste and production delays.
Key Procedural History: The complaint alleges that the Plaintiff, while a university co-op student working at Defendant’s facility, conceived and implemented the patented methodology. After the patent issued, Plaintiff notified Defendant of his rights, leading Defendant to assert partial ownership and "shop rights" and to threaten to challenge Plaintiff's sole inventorship at the U.S. Patent and Trademark Office, precipitating this lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2022-01-24 | Plaintiff begins Co-Op work at Defendant's Buffalo Plant. |
| 2022-04 | Plaintiff develops and installs the split bushing alignment methodology. |
| 2022-05-20 | Plaintiff's last day of work at the Buffalo Plant. |
| 2022-06-14 | Plaintiff contacts Defendant's employees regarding patenting the invention. |
| 2023-04-04 | '581 Patent Priority Date (Filing Date). |
| 2025-01-14 | U.S. Patent No. 12,194,581 issues. |
| 2025-08-07 | Plaintiff provides written notice of patent to Defendant. |
| 2025-09-26 | Defendant responds to notice, claiming partial ownership and "shop rights." |
| 2025-12-12 | Defendant's counsel threatens to challenge Plaintiff's inventorship claim. |
| 2025-12-26 | Complaint filed. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,194,581 - "Split Bushing Alignment Assembly and Method of Use"
- Patent Identification: U.S. Patent No. 12,194,581, "Split Bushing Alignment Assembly and Method of Use," issued January 14, 2025 (the ’581 Patent).
The Invention Explained
Problem Addressed: In automotive engine manufacturing, "split bushings" (metal tubes with a narrow gap or slit down one side) are pressed into connecting rods. An automated inspection machine then checks the bushing's dimensions using compressed air. The patent’s background section states that if the bushing's gap happens to align with one of the machine’s inspection points, the machine detects an air leak and incorrectly flags the part as defective, leading to wasted parts and production delays (’581 Patent, col. 2:3-25).
The Patented Solution: The invention is a method that solves this problem by proactively orienting the bushing before inspection. As the bushing falls through a "bushing receiver" on its way to being installed, the method uses precisely located jets of compressed air to rotate the bushing so that its gap is turned away from the known locations of the inspection machine's test points (’581 Patent, col. 2:42-55; FIG. 16). This ensures the gap will not cause a false rejection during the subsequent quality check (’581 Patent, col. 5:50-59).
Technical Importance: The method provides a solution that can be retrofitted onto existing manufacturing equipment without significant modification, addressing a persistent source of inefficiency in a high-tolerance, automated production environment (’581 Patent, col. 2:29-32).
Key Claims at a Glance
The complaint focuses on the "patented split bushing alignment methodology" generally and does not single out specific claims (Compl. ¶43). Independent method claim 1 is central to the patented process.
Essential elements of Claim 1 include:
- Determining the number and location of inspection areas on a part as checked by an inspection machine.
- Providing an assembly with a corresponding number and location of air vents.
- Providing an air supply to each vent.
- Feeding a split bushing into a receiver.
- Blowing a stream of air through the vents as the bushing travels through the receiver.
- Rotating the gap of the bushing away from a vent when the air stream contacts the gap.
The complaint does not mention dependent claims.
III. The Accused Instrumentality
Product Identification
The Defendant’s manufacturing process used to fabricate connecting rods at its Buffalo, West Virginia, plant (Compl. ¶¶14, 34). The complaint also alleges upon information and belief that the same methodology has been shared with and used by affiliated companies, such as a Toyota plant in Kentucky (Compl. ¶35).
Functionality and Market Context
The complaint alleges that Plaintiff developed the methodology to solve a high scrap rate issue that had "plagued the manufacturing line... for several years, causing severe losses in productivity" (Compl. ¶15). It further alleges that after Plaintiff installed a 3D-printed device to implement the methodology in April 2022, Defendant "continued to use the successful device and methodology" on its manufacturing line and continued this use after Plaintiff's departure (Compl. ¶¶19, 23).
IV. Analysis of Declaratory Judgment Allegations
This action does not allege patent infringement but instead seeks declaratory judgments regarding ownership and license rights. The complaint sets forth three primary controversies.
Count I: Sole Inventorship: Plaintiff seeks a declaration that he is the "true and sole inventor" of the patented methodology (Compl. ¶43). The complaint alleges that Plaintiff identified the problem and, "without the assistance of his mentor or any other Toyota WV or United Talent personnel, developed a split bushing alignment device and related methodology" (Compl. ¶17). The factual basis for this claim rests on the allegation that "No Toyota WV employee or agent contributed to the patented methodology's conception or reduction to practice" (Compl. ¶49).
Count II: "Shop Rights": Plaintiff seeks a declaration that the "shop rights" doctrine does not apply (Compl. ¶52). A shop right is an implied, non-exclusive license for an employer to practice an invention made by an employee. Plaintiff alleges this doctrine is inapplicable because he "was never an employee of Toyota WV" but was instead employed by a third-party staffing company, United Talent, pursuant to a university Co-Op Agreement (Compl. ¶¶10, 54, 56). Further, the complaint states that this Co-Op Agreement contained no provision assigning intellectual property rights to Defendant (Compl. ¶¶12, 58).
Count III: Scope of Rights: Plaintiff seeks a declaration that even if a shop right were found to exist, it would not permit Defendant to share the technology with its affiliates (Compl. ¶¶63, 69). The complaint alleges that any such right would be "limited to the specific entity operating the Buffalo Plant, where the invention was developed" and does not extend to "separate and distinct legal entities" such as Toyota Motor Manufacturing, Kentucky, Inc. (Compl. ¶¶65, 67).
No probative visual evidence provided in complaint.
V. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case appears to depend on the court's determination of three central questions rooted in patent and employment law.
A primary issue will be one of inventorship contribution: This is a factual question turning on whether any employee of the Defendant made a contribution to the "conception" of the invention as defined in the '581 Patent's claims. The dispute will require evidence regarding the communications and collaboration, or lack thereof, between Plaintiff and Defendant's personnel during the invention's development.
A second core issue will be the nature of the employment relationship: This is a mixed question of fact and law regarding whether Plaintiff’s status as a co-op student, formally employed by a third party but working full-time on-site using Defendant's resources, is sufficient to establish an implied "shop right" license in favor of the Defendant.
Finally, a key legal question will be the scope of the shop right doctrine: If a shop right is found to exist, the court will need to determine whether this implied license is strictly limited to the specific corporate entity and facility where the invention was made (Toyota WV), or if it can be extended to legally separate but affiliated corporate entities.