Geomatrix Systems, LLC v. Eljen Corporation

CourtDistrict Court, D. Connecticut
DecidedApril 11, 2023
Docket3:20-cv-01900
StatusUnknown

This text of Geomatrix Systems, LLC v. Eljen Corporation (Geomatrix Systems, LLC v. Eljen Corporation) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Geomatrix Systems, LLC v. Eljen Corporation, (D. Conn. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

Plaintiff GEOMATRIX SYSTEMS, LLC v. , Civil No. 3:20cv1900 (JBA)

Defendant ELJEN CORPORATION, April 10, 2023 . RULING ON PLAINTIFF’S MOTION TO AMEND

Markman The Court issued its Order on October 12, 2022 with its constructions of forty-two terms appearing throughout eighteen claims and four patents. Relevant to this motion, the Court rejected Plaintiff’s argument that the terms “spacing connectors” and “separation spacers” needed no construction and ruled instead that DefendMaanrtk’sm parno posed construction of each term as requiring “lines” and “anchors” was correct. ( Order [Doc. # 131].) Plaintiff Geomatrix now seeks to amend its infringement contentions to incorporate the Court’s constructions, but also seeks to add supplemental contentions based on the Court’s construction of “spacing connectors,” which it asserts constitutes good cause for amendment. (Pl.’s Mot. for Leave to Amend [Doc. # 140].) Defendant maintains that amendment would be futile because Plaintiff’s proposed supplemental infringement contentions are “meritless under the Court’s already-existing claim constructions” and di sputeBs atchke gerxoisutnendc e of good cause. (Def.’s Opp’n to Leave to Amend [Doc. # 143].) The Amended Complaint alleged infringement of claims across four patents: the U.S. Patent Nos. 9,174,863 (the “’863 Patent”); 9,650,271 (the “’271 Patent”); 10,065,875 (the “’875 Patent”); and 10,392,278 (the “’278 Patent”). Each of those patents is from the same patent “family” and stem from Patent Application ‘968, which became Patent ‘390 in 2006 (“the 2006 Patent”). The relevant passages of the “Specification” referenced throughout appear Ain. the sCpoeucrifti’csa Mtioanrsk mofa bno tRhu tlhine g2 0 06 Parent and the other patents in the family. Markman During the claim construction process, Defendant requested the construction of, among other terms, “spacing connector” as used in the ‘271 Patent, Claims 1 and 10, and separately requested the construction of the phrase following it, “connected to the first infiltrative channel and connected to the second infiltrative channel.” (Joint Claim Construction Statement [Doc. # 80] at 17, 21.) It also requested construction of the term “separation spacer” as used in the ‘875 Patent, Claim 1, ‘278 Patent, Claims 1, 22, and 33, and of the phrIdas. es that surrounded “separation spacer,” such as “having a length and a first anchor.” ( at 24.) Defendant proposed construing spacing connectors as “at least two lines, each line attached to a pair of anchors, attach ed to adjacent channels respectively,” while it proposed defining a separation spacer as M“aalriknme aanttached to a pair of anchors attached to adjacent channels respectively.” (Def.’s Brief [Doc. # 71] at 13.) The only distinction in the two proposed constructions was the difference in the contemplated number of lines. The Court categorized the disputed terms into groups, one of which is relevant here: Group E, which posed the question of whether the two terms “spacing connector” and “separation spacers” should be “interpreted in light of the Specification’s limited deMscarrikpmtioann of the invention as solely employing lines and anchors connected to the channels.” ( Order at 13.) Because the terms “spacing connectors” and “separation spacers” appear only in the claims of the respective patents, but nowhere in the Specification of any of the patents or anywhere at all in the original 2006 Patent, Defendant argued that the terms should be construed as a “pair of anchors” that are “attached to permeable sheeting on adjacent channels” and also attached to a “line” allowing the channels to be spaced a predetermined aImd.ount in the ground to facilitate the backfilling of the volumes between adjacent channels.”

( at 14.) Defendant’s basis for this argument was a paragraph from the Specification describing one of the embodiments, which read: Additionally, there are a plurality of pairs of anchors 240, attached to the permeable sheeting on adjacent channels. Each pair of anchors 240 is attached to a line 244. The anchors 240 and lines 244 are configured to allow the channels 228, 232, 236 to be spaced a predetermined amount in the ground to facilitate the backfilling of the volumes between adjacent channels 228, 232, 236 with sand, or other backfill. However since the lines 244 are attached to adjacent channels, the channels 228, 232, 236 may be collapsed (i.e. set close together) for shipping. The anchors 240 may be any suitable attaching device, including but not limited to staples, plastic staples, washers. The lines 244 may be any suitable line, including but not limited to nylon line, rope, twine, chain link. To install the disclosed conduit 244, the channels 228, 232, 236 are expanded to the maximum separation distance between them, given the length of the lines 244. Because Plaintiff had sought an effective date for its patents of 2006, thus requiring that the terms be interpreted in light of the 2006 Patent’s contents rather than the later embodiments or claims of the more recent patents, the Court found that “anchors” and lines” language must be used to define “spacing connectors” and “separation spacers” based on the absence of anything else in the 2006 Patent that could be construed as defining those terms. In the chart at the end of its order, the Court included a separate entry for “separation spacer” as used in both the ‘875 Patent, Claim 1, and the ‘278 Patent, Claims 1, 22, and 23, cMonasrtkrmuianng it as “a line connected to a pair of anchors connected to adjacent channels.” ( Order, 32.) It also construed “separation spacer” within the context of longer phrases, such as construing “separation spacer having a length and a first anchor” as “a line, connectedI dt.o pair of anchors connected to adjacent channels, having a length and a first anchor.” ( ) However, the Court’s order defined “spacing connector” only as part of a longer phrase: Original Text from 271 Patent, Claims 1 | Court’s Construction: and 10: “a first pair of spacing connectors | “a first pair of lines, each line attached to a connecting the first and second infiltrative | pair of anchors, connecting the first and channel, each connector of the first pair of | second infiltrative channel, each connector spacing connectors connected to the first | of the first pair of spacing connectors infiltrative channel and connected to the | connected to the first infiltrative channel second infiltrative channel” and connected to the second infiltrative channel”

B. Plaintiff's Prior Infringement Contention Plaintiff's initial infringement contentions identified the top cardboard edge spacers in certain of Defendant’s products as one variation of infringing “spacing connectors.” An example is shown by the diagram below: a first pair of spacing connectors connecting the first and second infiltrative channel, each “ The Prior Mantis 536-8 Senes includes a first pair of spacing connector of the first pair of spacing connectors connectors (.é., the upper edge spacers) connecting the first connected to the first infiltrative channel and and second infiltrative channel, each connector of the first pair connected to the second infiltrative channel and of spacing connectors connected to the first infittrative Configured to provide a spacing between the first channel and connected to the second infiltrative channel and infiltrative channel and the second infiltrative configured to provide a spacing between the first infiltrative channel, neither connector of the first pair of channel and the second infiltrative channel, neither connector spacing connectors comprising a pipe: of the first pair of spacing connectors comprising a pipe Fal ian = i / p7

First pair of —7 spacing — = connectors VA diemierenerts) Pemieniie a nian □□□

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Geomatrix Systems, LLC v. Eljen Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/geomatrix-systems-llc-v-eljen-corporation-ctd-2023.