Sunlighten, Inc. v. Finnmark Designs, LLC

CourtDistrict Court, D. Nevada
DecidedMarch 31, 2022
Docket2:20-cv-00127
StatusUnknown

This text of Sunlighten, Inc. v. Finnmark Designs, LLC (Sunlighten, Inc. v. Finnmark Designs, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sunlighten, Inc. v. Finnmark Designs, LLC, (D. Nev. 2022).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Sunlighten, Inc., Case No.: 2:20-cv-00127-JAD-EJY

4 Plaintiff Order Granting in Part Defendant’s Motions for Summary Judgment and 5 v. Denying Plaintiff’s Motion for Summary Judgment 6 Finnmark Designs, LLC, [ECF Nos. 48, 66, 67] 7 Defendant

8 Sunlighten, Inc. brings this suit against Finnmark Designs, LLC for the alleged 9 infringement of its infrared-sauna patents and common-law trademarks.1 Finnmark moves for 10 summary judgment on all of Sunlighten’s claims, and Sunlighten moves for summary judgment 11 on its patent-infringement claims.2 Finnmark contends that Sunlighten’s patents cannot claim 12 priority to the filing date of their first applications and are invalidated by Sunlighten’s sale of the 13 patented products prior to their later claim-priority date. Finnmark alternatively argues that even 14 if Sunlighten is entitled to the earlier claim-priority date, one of its patents is anticipated by prior 15 art. Sunlighten also moves for summary judgment on the merits of its patent-infringement 16 claims. 17 Finnmark separately moves for summary judgment on Sunlighten’s trade-dress 18 infringement claim, contending that Sunlighten cannot prove that its sauna design has achieved 19 secondary meaning such that potential customers would associate its features exclusively with 20 Sunlighten. And Finnmark moves for summary judgment on Sunlighten’s federal unfair- 21 competition, Nevada deceptive-trade-practices, and Nevada trademark-infringement claims 22

23 1 ECF No. 1 (complaint). 2 ECF No. 48; ECF No.66; ECF No. 67. 1 relating to Sunlighten’s alleged trademark “Empower” because Sunlighten cannot prove actual 2 damages or Finnmark’s willful use of that mark. 3 I grant Finnmark summary judgment on Sunlighten’s patent-infringement claims because 4 Sunlighten is not entitled to the priority filing date of the patents’ parent applications, and 5 Sunlighten sold its saunas one year prior to the filing date of the patent’s later-filed applications.

6 Because those patents are invalid, I deny as moot Sunlighten’s motion for summary judgment on 7 the merits of its patent-infringement claims. I grant Finnmark’s motion as to the trade-dress 8 infringement claim because Sunlighten has failed to produce evidence demonstrating secondary 9 meaning. And I grant Finnmark summary judgment to the extent it precludes a finding of actual 10 damages because there is no evidence to support such damages, but deny it with respect to the 11 remedies of disgorgement of profits and injunctive relief. So this case will proceed only on 12 Sunlighten’s trademark-infringement claims related to the Empower mark. But first, I order the 13 parties to a mandatory settlement conference with the magistrate judge. 14 Background

15 I. The ‘972 patent 16 Sunlighten filed patent application 29/356,445 (the ‘445 application or ‘972’s parent 17 application) for the design of two of its saunas on February 10, 2010.3 The patent examiner 18 noted that the application initially included two embodiments of the design in violation of 35 19 U.S.C. § 121, and after a conversation with Sunlighten’s attorney, the U.S. Patent and Trademark 20 21 22 23

3 ECF No. 1-1 at 2; ECF No. 48-5 (portions of the ‘445 application). 1|| Office (USPTO) examiner withdrew the second embodiment.* That second embodiment 2|| included the following drawings:° SSS 1 |). RDK—?Ra™! SS SS SS □ AW

SH Ak | | Yih 7 ¢ lA | (fm) | Ls 4” ee I pi 1 i a Se) A] z PSSSictocooe OL. YY 7" Wee Se . JA “ a So “A es — os 10 PKL OF er RE 11 ° FIG. © FIG. 7 12 _— 13 JE Yb 14 : 15 1 ca > hy i | Fe | 2 | ]| 18 Vf 19 eee (oo 0 FIG. 8 FIG. 9 21 22 23||4 ECF No. 48-5 at 11-12. > Id. at 21-23.

1 On June 29, 2012, Sunlighten filed application 29/426,034 (the ‘034 application) to 2|| patent that second embodiment.® But the examiner objected to Sunlighten’s characterization of the application as a continuation of the ‘445 application because “it contains matter not disclosed in the prior-filed application,” and the examiner required Sunlighten to change the relationship to “continuation-in-part” of the parent application.’ The examiner explained the differences in 6]| these images:® 7 . 6: coat Ralentapphesan inatant application The specific boundary demarcation is not i re 6. i | FIG. | shown in the parent application 9 E>. aS ye “RES See Sa, get PEPE paw | SSE 7 rie | PEER ge |p PEGE dD Lb Pod 11 Lae PEEL Deigdort FDR, □□ Ae mig 2 / i i i oe hits TEP SE Ube Me TE Ed a Pope | ee Late Me □□ □□ Yea 13 pe SA A \ Pili og Fomneatioe is not ca □□□□□□□□□□□□□□□□□□□□□□□ . shown in the parent, 1G 15 application FIG.

16 17|| Sunlighten acquiesced and changed the application to a continuation-in-part while submitting 18]| that the ‘034 application “does not include any new matter by including boundary lines that were 19]| not included in the parent application.”? The examiner declined to determine claim priority 20 21 0 ° ECF No. 48-6 (portions of the ‘034 application). 1 Id. at 6. Id. at 7-8. ? Id. at 4.

1| because there was no evidence of prior art necessitating that determination at the time.!° The 2|| patent office otherwise accepted the application and issued the ‘972 patent with the following images: !! 4 A □□ SN SQ. Za wb a fo AA 7 x | ST | work Jeet th | | Hon pr Pa

9 1of SF | “ UN oN I 11 SUS b FIG. 2 FIG. 3

13 B. The ‘033 Patent 14 Sunlighten also filed patent application 29/356,440 (‘440 application or ‘033’s parent 15]| application) on February 10, 2010.'* The examiner again cancelled one set of drawings because 16]| the application included two distinct embodiments of the design.'? Sunlighten then filed 17]| application 29/4267,271 (the ‘271 application) on July 16, 2012.'* Again, the examiner objected 18]|to Sunlighten’s characterization of the ‘271 application as a continuation of ‘440 application, 19} noting that “the application contains matter not disclosed in the prior-filed application” because 20 Id. at 7. ECF No. 31-1 (the ‘972 patent). ECF No. 48-7 (portions of the ‘440 application). Id. at 4-5. ECF No. 48-8 (portions of the ‘271 application).

it “does not disclose changes in appearance of certain areas and additional separated features 2|| shown in the instant application.”!> The examiner showed the changes in the following images: !° 4 The features on the top of the sauna are. The fetures shown on the top of the sauna, missing. the seat, the floor, the lower right part of the wall and the interior frame within the floor and 5 ceiling, are not shown in the instant \ poe Se application. 6 2 ae ff tbs —\.. Potts oy & “Sop foe Log By ig arrrry wr ae Be : The boundaries Raye EY) Be of theses areas we ft 4 dey ip Bok 8 are not shown ut Re ie oF in the instant f i : wk LA af ie HE: application. od nee a a HE i by gf Sk Oe Ff Big yO □□□ ue 7 □□ 10 Se 4 RSS| Se LE fe Vooresitcmone

FIG. | FIG. 2 12 13 These features are not shown in Embodiment 2 of the parent application. Oe RSQ 15 SS fe. ’ [| 16 | Ve | sek, bed re ; a i 5 17 2 ae Le a ay 18 ~—" FIG. 3 FIG. & ONS

20 Lod ABRs

22 FIG. S FIG. 6 Td. at 15. '6 Td. at 16-18.

The examiner also objected to the application because it was “indefinite and nonenabling” and 2|| required Sunlighten to file new images that corrected the noted deficiencies.!’ Sunlighten filed replacement images in response to the examiner’s objections, and the USPTO issued the ‘033 A|| patent with the following images:'® 5 forwy ste ee SS A (ne,

lo Hy wi) Sn | lea

12 SS] | | eee oS 13 SE FIG. 2 FIG. | 14 15 A BS SON a - RSA SN PN EE a aS SS mL | 6 _<® eS | BS MS, ee

18) if | Se

20) | = SS | PoE SSS SS) Ia | FIG. 3 FIG. & FIG. 5 22 Id. at 19. '8 ECF No. 31-2 at 3-6 (the ‘033 patent).

1 III.

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Bluebook (online)
Sunlighten, Inc. v. Finnmark Designs, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sunlighten-inc-v-finnmark-designs-llc-nvd-2022.