DCT

2:26-cv-04904

i4F Licensing NV v. Haining Mingyuan Decorative Materials Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-04904, C.D. Cal., 05/08/2026
  • Venue Allegations: Venue is asserted based on the California-based defendants, Welleast and 365 Construction, residing and maintaining regular and established places of business within the district. The complaint further alleges that all defendants committed acts of infringement within the district, including importation, use, sale, and offers for sale of the accused products.
  • Core Dispute: Plaintiff alleges that Defendants' stone plastic composite (SPC) floor panels infringe three U.S. patents related to the composition, structure, and manufacturing processes of composite flooring panels.
  • Technical Context: The lawsuit concerns the technology of multi-layer composite flooring, specifically SPC flooring, which is a popular category of rigid core luxury vinyl flooring known for its durability and water resistance.
  • Key Procedural History: The complaint alleges that Defendant Mingyuan is a current licensee of other, non-asserted i4F patents and had a previous business relationship with i4F, which Plaintiff asserts made Mingyuan aware of i4F's broader patent portfolio. Plaintiff also claims to have sent a demand letter to Mingyuan approximately four months prior to filing the complaint, which may be relevant to allegations of willful infringement.

Case Timeline

Date Event
2015-01-16 Earliest Priority Date for '918 Patent
2016-06-28 Earliest Priority Date for '396 Patent
2016-06-28 Earliest Priority Date for '753 Patent
2021-08-17 '918 Patent Issued
2023-10-24 '396 Patent Issued
2025-09-30 '753 Patent Issued
2026-01-25 Demand Letter Sent to Mingyuan
2026-05-08 Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,091,918 - "Covering Panel and Process of Producing Covering Panels," issued August 17, 2021 (['918](https://ai-lab.exparte.com/patent/11091918) Patent)

The Invention Explained

  • Problem Addressed: The patent background describes a tendency for multi-layer laminate covering panels to "curl" due to temperature changes, as different layers expand or shrink at different rates, which compromises the durability and visual appearance of the installed flooring U.S. Patent No. 11,091,918, col. 1:41-54
  • The Patented Solution: The invention proposes a process for producing a covering panel with a substrate that has increased rigidity to resist curling. This is achieved by mixing a synthetic polymer material with a specific, high-percentage range of a filler material (15% to 75% by weight) and then extruding the mixture to form the substrate '918 Patent, abstract '918 Patent, col. 2:1-8 The process also involves attaching a top layer at a specific temperature range-above the polymer's softening point but below its melting point-and annealing the panel to remove stress '918 Patent, claim 1
  • Technical Importance: The technology provides a method to enhance the dimensional stability of composite flooring, reducing defects like curling without necessarily relying on traditional reinforcement layers like glass fiber nonwovens.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 and dependent claim 8 Compl. ¶37
  • Independent Claim 1 (a process claim) includes the essential elements:
    • Mixing a synthetic material and a filler material, where the filler is 15-75 wt.% of the mixture.
    • Extruding the mixture to obtain a substrate.
    • Laminating the substrate to a top layer.
    • Annealing the covering panel.
    • Attaching the substrate to the top layer at a temperature higher than the principal polymer's softening point but lower than its melt temperature.
  • The complaint does not explicitly reserve the right to assert other claims but makes allegations as to at least claims 1 and 8 Compl. ¶37

U.S. Patent No. 11,794,396 - "Method of Producing a Glueless Dustless Composite Flooring Material System," issued October 24, 2023 (['396](https://ai-lab.exparte.com/patent/11794396) Patent)

The Invention Explained

  • Problem Addressed: The patent background identifies several issues with prior art flooring: materials with compressed sawdust or dust cores are susceptible to water damage; materials using glue or adhesives are prone to delamination; and finishing coatings often require long curing times, creating manufacturing bottlenecks U.S. Patent No. 11,794,396, col. 1:21-50
  • The Patented Solution: The invention is a multi-layer composite flooring segment and a method for producing it. The segment comprises a waterproof base layer (PVC resin and calcium carbonate), a waterproof face layer (with decorative and wear sublayers), and a cured waterproof coating layer. Critically, the layers are "fused onto a top face of said flooring base layer by hot-melt overlaying" without glue, and the top coat is a UV-cured plastic resin for rapid manufacturing U.S. Patent No. 11,794,396, abstract '396 Patent, col. 8:14-20 Figure 8 of the patent illustrates the multi-step manufacturing flow, from forming the base layer to the final UV curing '396 Patent, Fig. 8
  • Technical Importance: This technology aims to create a fully waterproof, durable flooring product through a glueless fusion process and rapid UV curing, designed to be more efficient and reliable than methods using adhesives or moisture-sensitive components.

Key Claims at a Glance

  • The complaint asserts infringement of at least claims 1-4 and 6-11 Compl. ¶37
  • Independent Claim 1 (a product claim) includes the essential elements:
    • A flooring base layer comprising a mixture of PVC resin and calcium carbonate, which is free of glue.
    • A waterproof flooring face layer with a decorative sublayer and a wearing sublayer, which is textured and fused onto the base layer by "hot-melt overlaying."
    • A cured waterproof flooring coating layer, which is the result of coating the face layer with a UV-curing plastic resin and exposing it to UV light.
  • The complaint asserts infringement of several dependent claims covering specific compositions, features like being free of compressed cellulose, and specific layer properties Compl. ¶¶68-70

U.S. Patent No. 12,427,753 - "Glueless Dustless Composite Flooring Material System," issued September 30, 2025 (['753](https://ai-lab.exparte.com/patent/12427753) Patent)

  • Technology Synopsis: This patent describes a composite flooring segment similar to the '396 Patent, focusing on a multi-layer, waterproof, glueless, and dustless construction. It details a structure with a PVC and calcium carbonate base layer, a face layer with decorative and wearing sublayers fused together via hot-melt overlaying, and a final coating layer. The claims emphasize specific features like decorative texturing, the absence of compressed cellulose, and the inclusion of an underlayment layer U.S. Patent No. 12,427,753, abstract '753 Patent, claim 1
  • Asserted Claims: The complaint asserts infringement of at least claims 1-5, 8-10, 14, 17-19, and 21-24 Compl. ¶37
  • Accused Features: The complaint alleges that the Defendants' SPC flooring products embody the claimed combination of a PVC/calcium carbonate base layer, a multi-part face layer fused without adhesives, a UV-cured coating, an underlayment layer, and coupling profiles for installation Compl. ¶¶79-90

III. The Accused Instrumentality

Product Identification

The Accused Products are identified as "stone plastic composite (SPC) floor panels or tiles utilizing the Lox locking system" Compl. ¶11 These products are marketed and sold by Defendants under trade names such as "Mayer Floors" Compl. ¶17

Functionality and Market Context

The complaint alleges the Accused Products are multi-layer flooring planks consisting of a core made from a mixture of PVC and calcium carbonate, a decorative film layer, a wear layer, and a UV coating Compl. ¶27 The complaint includes an exploded diagram of the product's layered construction, labeling the "SPC CORE," "DECOR FILM LAYER," "WEAR LAYER," and "UV COATING" Compl. ¶27 The complaint alleges these products are manufactured by Defendant Mingyuan in China and imported, distributed, and sold in the United States by all Defendants through various channels, including online platforms like "Made-in-China.com" and retailers like 365 Construction Compl. ¶¶20-21 Compl. ¶25

IV. Analysis of Infringement Allegations

'918 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a process of producing covering panels... comprising the steps of: mixing said synthetic material and said filler material... Mingyuan allegedly manufactures the Accused Products by mixing a synthetic material (PVC) with a filler material (calcium carbonate) (Compl. ¶28; Compl. ¶52). ¶52 col. 2:21-24
wherein said filler material is mixed with said synthetic material in an amount from 15 to 75 wt. %... The mixture allegedly contains calcium carbonate in an amount from 15 to 75 wt.% (Compl. ¶52). ¶52 col. 2:6-8
extrusion of said mixture, thereby obtaining a substrate; The resulting mixture is allegedly extruded to obtain an SPC substrate (Compl. ¶52). ¶52 col. 2:24-25
optionally, laminating said substrate to a top layer; A top layer is allegedly applied to the substrate through a hot-melt overlaying process (Compl. ¶31; Compl. ¶53). ¶53 col. 2:25-26
wherein said substrate is attached to said top layer at a temperature higher than the softening point... but lower than the melting temperature... The complaint alleges on information and belief that the substrate is heated to a temperature above the softening point of PVC but lower than its melting point (Compl. ¶53). ¶53 col. 24:31-38
and... annealing the covering panel The complaint alleges on information and belief that the panel is annealed after the top layer is applied (Compl. ¶53). The complaint includes a video still of this alleged process (Compl. ¶53). ¶53 col. 23:32-47
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether the defendants' manufacturing, alleged on "information and belief," meets the specific temperature parameters required by the claim ("higher than the softening point but lower than the melt temperature"). Evidence of the actual process temperatures will be critical.
    • Technical Questions: The complaint relies on video evidence to support its allegations regarding the manufacturing process, including annealing Compl. ¶53, Ex. F A point of contention could be whether the activities shown in the video, such as panels moving along a conveyor after heating, constitute "annealing" as defined by the patent, which is a process to "remove stress and achieve dimensional stability" '918 Patent, col. 23:32-34

'396 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a flooring base layer comprising a mixture of PVC resin and calcium carbonate, wherein said mixture is free of glue The Accused Products are alleged to be composite flooring with an SPC core or base layer comprising a mixture of PVC and calcium carbonate, and to be "free of glue" ('396 Patent, claim 1) Compl. ¶62 ¶62 col. 5:40-42
a waterproof flooring face layer comprising a decorative face sublayer and a wearing face sublayer fused onto a top face of said decorative face sublayer The Accused Products allegedly have a face layer with a decorative sublayer and a wearing sublayer fused on top (Compl. ¶64). The complaint provides an exploded product diagram showing a "DECOR FILM LAYER" and "WEAR LAYER" (Compl. ¶62, Ex. C). ¶64 col. 7:30-41
where said flooring face layer is textured The face layer of the Accused Products is alleged to be textured (Compl. ¶65). ¶65 col. 8:40-44
and fused onto a top face of said flooring base layer by hot-melt overlaying of said layers The face layer is allegedly fused to the SPC base layer via a "hot-melt overlaying" process, which involves bringing the layers into contact and simultaneously heating and applying compression to fuse them together Compl. ¶66 The complaint provides video stills purporting to show this process (Compl. ¶66, Ex. F). ¶66 col. 8:14-20
a cured waterproof flooring coating layer, applied on top of said flooring face layer... [resulting from]... coating said flooring face layer with a UV-curing plastic resin and UV curing said coating... by exposure to UV light A cured, waterproof UV plastic resin coating is allegedly applied to the face layer and cured by exposure to UV light (Compl. ¶67). The complaint includes a screenshot from a video titled "UV Coating" allegedly showing this step (Compl. ¶67, Ex. H). ¶67 col. 9:1-10
  • Identified Points of Contention:
    • Scope Questions: A primary dispute may center on the term "fused... by hot-melt overlaying." The court will need to determine if the defendants' manufacturing method of bringing layers together with heat and pressure, as alleged, falls within the scope of this term, especially given the patent's emphasis on a glueless process.
    • Technical Questions: The allegation that the product is "free of glue" Compl. ¶62 is a factual question. The defense may argue that bonding agents or components used in their process do not constitute "glue" as contemplated by the patent, or that trace amounts are present for other reasons.

V. Key Claim Terms for Construction

'918 Patent: "attached to said top layer at a temperature higher than a softening point but lower than a melt temperature of a principal polymer" (from Claim 1)

  • Context and Importance: This term defines a critical process window for lamination. Infringement will depend on whether the defendants' manufacturing process, which is alleged on "information and belief" (Compl. ¶53), operates within this specific temperature range. Practitioners may focus on this term because it is a precise technical limitation that requires specific evidence to prove.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not appear to provide language that would substantially broaden this specific temperature window, as it is presented as a key technical feature.
    • Evidence for a Narrower Interpretation: The patent explicitly defines "softening point" by referencing the Vicat method (ASTM-D1525 or ISO 306) and defines "principal polymer" as the "major or predominant part of all polymer material in said substrate composition" '918 Patent, col. 24:35-43 This detailed reference to industry standards and specific compositional analysis suggests the term should be narrowly and technically construed.

'396 Patent: "fused... by hot-melt overlaying" (from Claim 1)

  • Context and Importance: This term is central to the patent's "glueless" inventive concept. The dispute will likely turn on whether the defendant's method for joining the core and face layers constitutes "hot-melt overlaying" as claimed. The complaint alleges this process involves bringing layers into contact and applying heat and compression simultaneously Compl. ¶66
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the process in functional terms as fusing layers "without the use of glue or adhesive" '396 Patent, col. 8:14-20 A party could argue any heat- and pressure-based lamination process that avoids traditional liquid adhesives meets this definition.
    • Evidence for a Narrower Interpretation: The patent describes the process as "bringing the sublayers and layers into contact with one another in the proper order, and simultaneously heating and applying compression to the stack to fuse the layers together" '396 Patent, col. 8:14-20 The use of "simultaneously" could be interpreted narrowly to require a specific type of single-pass heating and compression, potentially excluding multi-stage processes.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant Mingyuan induced infringement by "urging or encouraging" its co-defendants to import and sell the Accused Products in the U.S., with knowledge or willful blindness that their conduct constituted infringement Compl. ¶55 Compl. ¶72 Compl. ¶92
  • Willful Infringement: Willfulness is alleged against Mingyuan based on its "previous relationship with i4F" as a licensee of other patents, which allegedly provided awareness of i4F's portfolio, and its continued sales after receiving a demand letter on January 25, 2026 Compl. ¶¶39 Compl. ¶41-43 Willfulness is alleged against the other defendants from the date of service of the complaint Compl. ¶44 Compl. ¶57 Compl. ¶74

VII. Analyst's Conclusion: Key Questions for the Case

  1. Process Verification: A central evidentiary issue will be establishing the precise nature of the defendants' manufacturing process. Can the plaintiff prove, beyond "information and belief," that the lamination occurs within the specific temperature window claimed in the '918 patent and that the layer fusion method qualifies as "hot-melt overlaying" as required by the '396 and '753 patents?
  2. Definitional Scope: The case may turn on claim construction, particularly the meaning of "fused... by hot-melt overlaying." A key question for the court will be whether this term simply means "joined by heat without glue" or if it requires a more specific, simultaneous application of heat and pressure that may or may not describe the accused process.
  3. State of Mind: A significant question related to damages will be willfulness. Can the plaintiff demonstrate that Mingyuan's prior licensing relationship for different patents put it on notice of the asserted patents, and does its alleged failure to respond to a demand letter prove a "wanton and malicious" state of mind sufficient for enhanced damages?
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