DCT
2:26-cv-04644
Modular Closets LLC v. SL Intl Inc
Key Events
Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Modular Closets LLC (New Jersey)
- Defendant: SL International, Inc. d/b/a Klair Living (California)
- Plaintiff's Counsel: Bochner PLLC
- Case Identification: 2:26-cv-04644, C.D. Cal., 04/30/2026
- Venue Allegations: Venue is alleged to be proper in the Central District of California because the defendant is a California corporation with a principal place of business in the district and has allegedly committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant's "Prosper Wood Closet Systems" infringe two of its U.S. design patents covering ornamental designs for modular closet sections.
- Technical Context: The dispute is in the market for do-it-yourself (DIY), customizable modular closet and storage systems for homeowners.
- Key Procedural History: The complaint alleges that Plaintiff sent demand letters to at least two of Defendant's distributors, Home Depot and Lowe's, on February 23, 2026. On February 26, 2026, Home Depot allegedly informed Plaintiff it had contacted Defendant regarding the matter. Defendant subsequently sent a response letter to Plaintiff on March 11, 2026, denying infringement. This pre-suit correspondence establishes a date of alleged knowledge for Plaintiff's claims of willful and induced infringement.
Case Timeline
| Date | Event |
|---|---|
| 2015-07-28 | Priority Date for D776,465 and D791,518 Patents |
| 2017-01-17 | U.S. Design Patent No. D776,465 Issues |
| 2017-07-11 | U.S. Design Patent No. D791,518 Issues |
| 2024-02-10 | Alleged First Sale of Accused Products |
| 2026-02-23 | Plaintiff Sends Demand Letters to Defendant's Distributors |
| 2026-02-26 | Distributors Acknowledge Receipt of Letters; Defendant Notified |
| 2026-03-11 | Defendant Responds to Plaintiff, Denying Infringement |
| 2026-04-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Design Patent No. D791,518
- Patent Identification: U.S. Design Patent No. D791,518 ("MODULAR CLOSET SECTION"), issued on July 11, 2017 (the "'518 Patent"). Compl. ¶35
- The Invention Explained:
- Problem Addressed: The complaint suggests the patent was obtained to protect "unique closet and storage designs" developed by the plaintiff. Compl. ¶10 Design patents protect the ornamental appearance of an article, not its utility.
- The Patented Solution: The '518 Patent claims the specific ornamental design for a modular closet section as depicted in its figures. The design consists of a rectangular open-faced cabinet with two horizontal shelves that create three distinct storage compartments of varying heights. The side panels feature vertical rows of adjustment holes. The claim is for the overall visual impression of the article as shown in solid lines in the patent drawings. Compl. ¶37 '518 Patent, figs. 1-2
- Technical Importance: The design is positioned as part of Plaintiff's portfolio of proprietary designs for the affordable, DIY modular closet market. Compl. ¶¶8-10
- Key Claims at a Glance:
- Design patents contain a single claim for the ornamental design "as shown and described."
- The claim covers the visual appearance of the modular closet section depicted in the patent's figures, including the overall shape, the configuration of the two shelves, and the resulting proportions of the three open spaces. Compl. ¶37 '518 Patent, claim
U.S. Design Patent No. D776,465
- Patent Identification: U.S. Design Patent No. D776,465 ("MODULAR CLOSET SECTION WITH HANGING BAR"), issued on January 17, 2017 (the "'465 Patent"). Compl. ¶39
- The Invention Explained:
- Problem Addressed: The patent serves to protect what the plaintiff characterizes as one of its "unique closet and storage designs." Compl. ¶10
- The Patented Solution: The '465 Patent claims the ornamental design for a modular closet section featuring two hanging rods. The design consists of a rectangular open-faced frame with one rod positioned near the top and a second rod positioned below the vertical midpoint. This configuration creates two distinct hanging areas within the single unit. Compl. ¶41 '465 Patent, figs. 1-2
- Technical Importance: This design provides a specific aesthetic for a double-hang configuration within the plaintiff's modular system. Compl. ¶¶9-10
- Key Claims at a Glance:
- The patent asserts a single claim for the ornamental design "as shown and described."
- The claim covers the overall visual appearance of the closet section shown in the patent's figures, defined by the rectangular frame and the specific placement and appearance of the two hanging rods. Compl. ¶41 '465 Patent, claim
III. The Accused Instrumentality
- Product Identification: The accused instrumentalities are Defendant's "Prosper Wood Closet Systems," which are sold in various configurations and finishes. Compl. ¶¶2-3 Compl. ¶11 The complaint specifically identifies the "Prosper 32" Oak Wood Closet System" as an example of a product infringing the '518 Patent, and the "Prosper 32" Oak Wood 2 Rods Closet System" as an example infringing the '465 Patent. Compl. ¶24 Compl. ¶30
- Functionality and Market Context: The complaint alleges that Defendant is a furniture wholesaler that imports and sells these modular, DIY closet systems through major U.S. retailers, including Lowe's, Home Depot, Amazon, and OJCommerce. Compl. ¶¶12-15 The complaint provides an annotated image comparing the patented design to an accused product, which shows a closet section with a rectangular body and open appearance. Compl. ¶48
IV. Analysis of Infringement Allegations
The standard for design patent infringement is whether an "ordinary observer," giving such attention as a purchaser usually gives, would be deceived into purchasing the accused product believing it to be the patented design.
'518 Patent Infringement Allegations
The complaint provides an annotated diagram that breaks the design into several components to allege similarity.
| Claimed Design Feature (as annotated in Complaint) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| rectangular body | The accused product is alleged to have a visually similar rectangular body. | ¶48 | D'791,518 Patent, fig. 2 |
| upper back panel | The accused product is alleged to have a visually similar upper back panel. | ¶48 | D'791,518 Patent, fig. 2 |
| lower back panel | The accused product is alleged to have a visually similar lower back panel. | ¶48 | D'791,518 Patent, fig. 2 |
| rectangular negative space that is substantially open in appearance | The accused product is alleged to have two rectangular open spaces that create a similar visual impression of openness. | ¶48 | D'791,518 Patent, fig. 2 |
- Identified Points of Contention:
- Scope Questions: A primary point of contention may arise from the number of shelves. The '518 Patent claims a design with two shelves creating three open spaces. However, an unannotated photograph of an accused product in the complaint shows a unit with five shelves creating six open spaces. Compl. p. 12 This raises the question of whether an ordinary observer would find a design with three compartments to be substantially the same as one with six.
- Technical Questions: The infringement analysis may depend on which specific configurations of the "Prosper Wood Closet Systems" are at issue. The complaint's annotated comparison image shows an accused product with two shelves, matching the patent's configuration, which contrasts with the other photographic evidence provided. Compl. ¶48 The case may turn on evidence showing the range of accused product configurations actually sold.
'465 Patent Infringement Allegations
The complaint uses a similar annotated diagram to allege infringement of the '465 Patent.
| Claimed Design Feature (as annotated in Complaint) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| rectangular body | The accused product is alleged to have a visually similar rectangular body. | ¶66 | D'776,465 Patent, fig. 2 |
| first rod | The accused product is alleged to have a visually similar top hanging rod. | ¶66 | D'776,465 Patent, fig. 2 |
| second rod | The accused product is alleged to have a visually similar bottom hanging rod. | ¶66 | D'776,465 Patent, fig. 2 |
| Rectangular negative space that is substantially open in appearance | The accused product is alleged to have two rectangular open spaces for hanging that create a similar visual impression. | ¶66 | D'776,465 Patent, fig. 2 |
- Identified Points of Contention:
- Scope Questions: The visual similarity between the '465 Patent's design and the accused product shown appears more direct than for the '518 Patent. Compl. ¶66 The dispute will likely focus on whether minor differences in proportions, materials, finish, or the appearance of the rod-mounting hardware are sufficient to create a different overall visual impression for an ordinary observer.
- Technical Questions: The translation from the patent's line drawings to the physical embodiment of the accused product could be a point of analysis. For example, the court may need to consider whether differences in the visual details of the hardware used to mount the rods are significant enough to avoid infringement.
V. Key Claim Terms for Construction
In design patent cases, the "claim" is the visual design itself as depicted in the drawings, and formal claim construction is rare. The analysis focuses on the overall visual appearance. However, the parties may dispute the scope of the design and what features are most significant to an ordinary observer.
- The Term: The overall ornamental design "as shown."
- Context and Importance: The core of the dispute is the holistic comparison of the designs. For the '518 Patent, a critical question will be how much variation in the number and spacing of shelves is permissible before the accused product is no longer "as shown." For the '465 Patent, the question will be the significance of any minor differences in the proportions or hardware.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the patents use simple line drawings, unadorned with specific materials, textures, or colors, suggesting the design covers the depicted configuration regardless of finish. The focus on "substantially open in appearance" in the complaint's annotations suggests an argument centered on overall form rather than minute details. Compl. ¶48 Compl. ¶66
- Evidence for a Narrower Interpretation: Defendant may argue that the solid lines in the patent drawings fix the scope of the design precisely. For the '518 Patent, this would mean the claim is strictly limited to a two-shelf, three-compartment configuration. For the '465 Patent, this would limit the claim to the exact proportions and hardware appearance suggested by the drawings.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement against Klair Living. (Compl. ¶49; Compl. ¶50; Compl. ¶51; Compl. ¶52; Compl. ¶53; Compl. ¶54; Compl. ¶55; Compl. ¶56). The factual basis is that Klair Living, with knowledge of the patents as of February 26, 2026, continued to manufacture and sell the accused products to distributors like Lowe's and Home Depot, knowing and intending that they would be resold to end-users who would directly infringe. Compl. ¶49 Compl. ¶67
- Willful Infringement: The complaint alleges that Defendant's infringement has been willful, deliberate, and intentional since it gained knowledge of the patents on or about February 26, 2026. Compl. ¶60 Compl. ¶78 This allegation is based on Defendant's continued sale of the accused products after being notified of the alleged infringement.
VII. Analyst's Conclusion: Key Questions for the Case
This case presents several key questions typical of design patent litigation, focusing on visual comparison and the scope of the claimed aesthetic.
- A core issue for the '518 Patent will be one of configurational scope: does the claimed design for a closet section with two shelves and three open compartments create an overall visual impression that is substantially the same as an accused product that may have five shelves and six open compartments, in the eyes of an ordinary observer?
- A central question for both patents will be the application of the ordinary observer test. The court will need to determine whether the accused designs are similar enough to the patented designs to cause deception, or if differences in proportion, configuration, or hardware details are sufficient to distinguish them.
- A key legal and damages question will be one of culpability: did Defendant's continued sales of the accused products after receiving notice of alleged infringement via its distributors constitute inducement and willful infringement, potentially exposing it to enhanced damages and attorney's fees?
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