National Products, Inc. v. ProClip USA, Inc.

CourtDistrict Court, W.D. Wisconsin
DecidedJune 27, 2022
Docket3:20-cv-00439
StatusUnknown

This text of National Products, Inc. v. ProClip USA, Inc. (National Products, Inc. v. ProClip USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Products, Inc. v. ProClip USA, Inc., (W.D. Wis. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

NATIONAL PRODUCTS, INC.,

Plaintiff, OPINION AND ORDER v. 20-cv-439-wmc PROCLIP USA, INC., and BRODIT AB.

Defendants.

Defendants ProClip USA, and Brodit AB moved for summary judgment on the grounds that (1) all of the patents-in-suit are invalid and (2) their products are non- infringing. (Dkt. #105.) Plaintiff National Products, Inc. (“NPI”), filed its own motion for partial summary judgment to resolve the patents’ priority dates before trial, as well as dispose of defendants’ indefiniteness defense.1 The court now takes up summary judgment, as well as some assorted evidentiary motions. For the reasons given below, the court denies in part and grants in part each parties’ motion for summary judgment. UNDISPUTED FACTS2 A. The Parties Defendant Brodit manufactures mounting solutions for electronic devices, such as phone, tablet or laptop cases that can easily clip onto a car dashboard and continue to

1 Plaintiff also moved to file a reply in support of its own proposed findings of fact (dkt. #152) which is granted here and was considered in deciding the parties’ summary judgment motions. 2 Unless otherwise noted, the following facts are material and undisputed. Given the voluminous number of proposed findings, the court limits this section to the key, overarching facts and addresses other undisputed facts as relevant to specific arguments addressed in the opinion that follows. function. ProClip is the exclusive importer and distributor of Brodit products in North America. Plaintiff NPI produces similar cases for electronic devices that allow for easy charging without removing the case (sometimes also described by NPI as the seeming

misnomer of a “cover”).

B. Patents-in-Suit NPI alleges that the defendants manufacture and sell products that infringe the following, three patents: 10,454,515 (“the ‘515 patent”), 9,706,026 (“the ‘026 patent”), and 10,778,275 (“the ‘275 patent”), collectively the “patents-in-suit.” Each patent describes cases for electronic devices that allow for easy charging. The ‘026 application issued July 11, 2017, from U.S. Application Serial Number 14/936,517 originally filed on November 9, 2015. The ‘515 application issued October

22, 2019, from U.S. Application Serial Number 16/233,635, filed on December 27, 2018. The ‘275 application issued September 15, 2020, from U.S. Application Serial Number 16/854,828, filed on April 21, 2020. Each of the patents-in-suit claim to be a continuation of provisional application No. 61/943,986 (“the ‘986 application”), which was originally filed on February 24, 2014. Finally, “Jeffrey D. Carnevali” is named as the sole inventor

of all three patents. NPI asserts infringement of the following claims in the patents-in-suit: Patent Claim(s) ‘026 1, 2, 4, 6, 10, 11, 14, 15, 17, 18 and 19 ‘275 1, 2, 3, 4, 5, 7, 8, 10, 11, 12, 13, 14, 15, 16, 17, 18 and 19 ‘515 1, 2, 3, 4, 8, 9, 11, 12, 13, 14, 18 and 19 However, defendants argue that NPI has failed to submit sufficient evidence to support any claim of infringement. In response to defendants’ motion, NPI not only disputes this, but has submitted additional, proposed findings of fact to support its infringement claims. (Pl.’s PFOFs (dkt. #104).) The parties also propose additional facts relevant to various of defendants’ invalidity challenges. As already explained above, the

court will address these proposed facts to the extent material to the court’s findings in the opinion below, rather than merely reciting them in detail out of context to the material issues at summary judgment.

OPINION I. Preliminary Matters A. Supplemental expert report As a preliminary matter, defendants ask for leave to supplement their designated

expert Jason Stigge’s report, adding some 3 pages of information in response to plaintiff’s supplemental infringement contentions. (Defs.’ Mot. (dkt. #119) 4.) Defendants further argue that they had already disclosed the information from this supplement to plaintiff, reducing the chance that the addition of this supplemental information to Stigge’s report is prejudicial. (Defs.’ Mot. (dkt. #119) 4.) Finally, defendants note that they did not rely

on this proposed supplement in seeking summary judgment and should not require any extra discovery. (Defs.’ Mot. (dkt. #119) 6.) In response, plaintiff argues that defendants’ wait of nearly a year before moving to supplement Stigge’s report with this information amounts to unfair surprise. Regarding timing, the fact that defendants had this allegedly relevant information for this supplement for months does not lean in defendants’ favor. The longer defendants waited, the more prejudicial the current motion would be to plaintiff. Even though plaintiff

was aware of the underlying information, they were also entitled to know whether or not an expert was going to opine on those infringement contentions in advance of dispositive motions. Plaintiff also notes that the Stigge supplement merely incorporates by reference defendants’ invalidity contention chart. (Pl.’s Opp’n. (dkt. #127) 2.) While the Seventh

Circuit has not spoken on this subject, several district courts have. See Promega Corp. v. Applied Biosystems, LLC., No. 13-CV-2333, 2013 WL 9988881, at *5 (N.D. Ill. May 28, 2013), aff'd sub nom. Promega Corp. v. Applied Biosystems, LLC, 557 F. App'x 1000 (Fed. Cir. 2014) (finding that, “[e]xperts may not merely rubber stamp a lawyer's argument”); Changzhou Kaidi Elec. Co. v. Okin Am., Inc., 112 F. Supp. 3d 330, 339 (D. Md. 2015) (preventing an expert from opining on invalidity contentions not in his original report

when he simply incorporated the contentions by reference); but see CoreLogic Info. Sols., Inc. v. Fiserv, Inc., No. 2:10-CV-132-RSP, 2012 WL 4761739, at *2 (E.D. Tex. Sept. 20, 2012) (allowing in the opinion but noting that, “[t]he Court finds it troubling that Dr. Snow relies on Defendants' invalidity contentions to satisfy” his written requirements). Given the cursory nature of Stigge’s disclosure, which provides almost no analysis beyond prior attorney argument, and the egregiously long time defendants waited to supplement, the

request to supplement is denied. B. Strike undisclosed expert report Second, defendants have moved to strike plaintiff’s late-disclosed expert report from James Babcock. (Defs.’ Br. (dkt. #138) 3.) The report is 121 pages long and was filed on

November 19, 2021, at the same time plaintiff filed its brief in opposition to defendants’ request for summary judgment. Defendants argue that the report is untimely and is not substantially justified or harmless. (Defs.’ Br. (dkt. #138) 3.) Given the weakness of plaintiff’s argument and the seemingly retaliatory nature of the report, the court agrees, and will strike the declaration of James Babcock. (Dkt. #129.) Under Rule 37(c)(1), “[i]f a party fails to provide information or identify a witness

as required by Rule 26(a) or (e), the party is not allowed to use that information . . . unless the failure was substantially justified or is harmless.” Here, the offered report is neither justified nor harmless. Notably, plaintiff practically acknowledges that it filed Babcock’s report as a retaliatory measure. In its brief, plaintiff stated that “the Court should exclude (1) ProClip’s invalidity contentions not contained in Mr. Stigge’s August 6 report, (2) the declarations and exhibits ProClip never previously disclosed, and (3) Mr. Stigge’s proposed

supplement. With these withdrawn, NPI will withdraw the Babcock Declaration.” (Pl.’s Opp’n (dkt. #150) 2-3.) While parties unfortunately do not always hew to this principle, motions to strike are not meant as a cudgel with which to bully the other side.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hogg v. Emerson
47 U.S. 437 (Supreme Court, 1848)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Warner-Jenkinson Co. v. Hilton Davis Chemical Co.
520 U.S. 17 (Supreme Court, 1997)
Edwards Lifesciences LLC v. Cook Inc.
582 F.3d 1322 (Federal Circuit, 2009)
PowerOasis, Inc. v. T-MOBILE USA, INC.
522 F.3d 1299 (Federal Circuit, 2008)
US Philips Corp. v. Iwasaki Elec. Co. Ltd.
505 F.3d 1371 (Federal Circuit, 2007)
Andersen Corp. v. Fiber Composites, LLC
474 F.3d 1361 (Federal Circuit, 2007)
Honeywell International, Inc. v. ITT Industries, Inc.
452 F.3d 1312 (Federal Circuit, 2006)
Microsoft Corp. v. i4i Ltd. Partnership
131 S. Ct. 2238 (Supreme Court, 2011)
Vitronics Corporation v. Conceptronic, Inc.
90 F.3d 1576 (Federal Circuit, 1996)
Lawrence B. Lockwood v. American Airlines, Inc.
107 F.3d 1565 (Federal Circuit, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
National Products, Inc. v. ProClip USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-products-inc-v-proclip-usa-inc-wiwd-2022.