O'Reilly Winship LLC v. Snaprays LLC

CourtDistrict Court, N.D. Texas
DecidedNovember 18, 2024
Docket3:21-cv-02719
StatusUnknown

This text of O'Reilly Winship LLC v. Snaprays LLC (O'Reilly Winship LLC v. Snaprays LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Reilly Winship LLC v. Snaprays LLC, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

O’REILLY WINSHIP, LLC, § § Plaintiff, § § v. § Civil Action No. 3:21-CV-02719-N § SNAPRAYS, LLC, § § Defendant. §

MEMORANDUM OPINION AND ORDER

This Order addresses Plaintiff O’Reilly Winship, LLC’s (“OWL”) motion for summary judgment [51] and Defendant Snaprays, LLC’s (“SnapPower”) motion for partial summary judgment [48]. Because the Court finds there is no genuine dispute of material fact and OWL’s Accused Products do not infringe SnapPower’s patents, the Court grants OWL’s motion for summary judgment. The Court also grants SnapPower’s motion for summary judgment as to OWL’s tortious interference claim, but otherwise denies SnapPower’s motion. I. ORIGINS OF THE DISPUTE This is a patent infringement case. After a dispute arose between OWL and SnapPower over their respective products, OWL filed this lawsuit seeking a declaratory judgment of noninfringement and invalidity as to SnapPower’s patents, and a claim for tortious interference. Compl. ¶¶ 16–53 [1]. In return, SnapPower asserts counterclaims for patent infringement of its two patents — U.S. Patent No. 9,035,180 (“’180 Patent”) and U.S. Patent No. 9,871,324 (“’324 Patent”). Answer 12–18 [9]. It also asserts a counterclaim for violation of the Texas Citizens Participation Act (“TCPA”). Id. at 18. The two patents are both titled “Active Cover Plates.” They relate to a cover for

an electrical box, such as an outlet or light switch, where the cover is configured to make an electrical connection with the device in the box. The electricity can then be used to power electrical loads built into the cover, such as a night light. OWL’s Mot. Summ. J. 1 [52]. SnapPower asserts that OWL’s Accused Products infringe claims 1, 2, 3, 5, 6, 11, 12, 13, and 15 of the ’180 Patent and claims 1, 2, 4, 8, 9, 10, 13, 14, 15, 17, 19, 20, 23,

and 25 of the ’324 Patent. SnapPower’s Resp. 2 [55]. OWL now moves for summary judgment of noninfringement on all patent claims. OWL’s Mot. 8 [52]. SnapPower moves for partial summary judgment of infringement on claims 1, 2, 5, 11, 12, 13, and 15 of the ’180 Patent and claims 1, 2, 8, 13, 14, and 15 of the ’324 Patent. SnapPower’s Br. Supp. Partial Summ. J. 4–15 [49].

II. LEGAL STANDARDS A. Summary Judgment Standard

Courts “shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). In making this determination, courts must view all evidence and draw all reasonable inferences in the light most favorable to the party opposing the motion. United States v. Diebold, Inc., 369 U.S. 654, 655 (1962). The moving party bears the initial burden of informing the court of the basis for its belief that there is no genuine issue for trial. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). When a party bears the burden of proof on an issue, “he must establish beyond

peradventure all of the essential elements of the claim or defense to warrant judgment in his favor.” Fontenot v. Upjohn Co., 780 F.2d 1190, 1194 (5th Cir. 1986). When the nonmovant bears the burden of proof, the movant may demonstrate entitlement to summary judgment either by (1) submitting evidence that negates the existence of an essential element of the nonmovant’s claim or affirmative defense, or (2) arguing that

there is no evidence to support an essential element of the nonmovant’s claim or affirmative defense. Celotex, 477 U.S. at 322–25. Once the movant has made this showing, the burden shifts to the nonmovant to establish that there is a genuine issue of material fact so that a reasonable jury might return a verdict in its favor. Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S.

574, 586–87 (1986). Moreover, “[c]onclusory allegations, speculation, and unsubstantiated assertions” will not suffice to satisfy the nonmovant’s burden. Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1429 (5th Cir. 1996) (en banc), superseded by statute on other grounds, 28 U.S.C. § 636(b)(1). Factual controversies are resolved in favor of the nonmoving party “only when an actual controversy exists, that is, when both

parties have submitted evidence of contradictory facts.” Olabisiomotosho v. City of Houston, 185 F.3d 521, 525 (5th Cir. 1999) (quoting McCallum Highlands, Ltd. v. Washington Capital Dus, Inc., 66 F.3d 89, 92 (5th Cir. 1995)). B. Patent Infringement Standard

Courts use a two-step process to analyze patent infringement. Dow Chem. Co. v. Sumitomo Chem. Co., 257 F.3d 1364, 1372 (Fed. Cir. 2001). First, the Court must construe the patent claims to determine their scope. Id. Second, the Court compares the construed claims to the accused product. Id. Infringement can take the form of literal infringement or infringement by equivalents. Id. Literal infringement occurs when “the accused product meets all the limitations of the asserted claims.” E.I. du Pont de Nemours & Co. v. Unifrax I LLC, 921 F.3d 1060, 1073 (Fed. Cir. 2019). There is no

literal infringement if any claim limitation is not met. Id. Infringement by equivalents occurs when each element of the accused product “performs substantially the same function, in substantially the same way, to achieve substantially the same result” as each element of the patented product. Lockheed Martin Corp. v. Space Systems/Loral, Inc., 324 F.3d 1308, 1320 (Fed. Cir. 2003) (citing Warner-

Jenkinson Co. v. Hilton Davis Chem. Co., 520 U.S. 17, 40 (1997)). However, under the vitiation doctrine, there can be no infringement by equivalents if the infringement theory “renders a claim limitation inconsequential or ineffective.” Akzo Nobel Coatings, Inc. v. Dow Chem. Co., 811 F.3d 1334, 1342 (Fed. Cir. 2016). This doctrine works to ensure that infringement by equivalents does not effectively eliminate an element of a claim.

Edgewell Personal Care Brands, LLC v. Munchkin, Inc., 998 F.3d 917, 923 (Fed. Cir. 2021). “Claim vitiation is a legal determination that ‘the evidence is such that no reasonable jury could determine two elements to be equivalent.’” Id. (quoting Deere & Co. v. Bush Hog, LLC, 703 F.3d 1349, 1356-57 (Fed. Cir. 2012), abrogated on other grounds by Nautilus, Inc. v.

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Related

United States v. Diebold, Inc.
369 U.S. 654 (Supreme Court, 1962)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
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520 U.S. 17 (Supreme Court, 1997)
Sitrick v. DREAMWORKS, LLC
516 F.3d 993 (Federal Circuit, 2008)
Marian Fontenot, Etc. v. The Upjohn Company
780 F.2d 1190 (Fifth Circuit, 1986)
Deere & Co. v. Bush Hog, LLC
703 F.3d 1349 (Federal Circuit, 2012)
Akzo Nobel Coatings, Inc. v. Dow Chemical Company
811 F.3d 1334 (Federal Circuit, 2016)
E.I. Du Pont De Nemours & Co. v. Unifrax I LLC
921 F.3d 1060 (Federal Circuit, 2019)
Wilfred Jones v. United States
936 F.3d 318 (Fifth Circuit, 2019)
Edgewell Personal Care Brands v. Munchkin, Inc.
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