DCT

2:26-cv-09471

Ultra Mek Inc v. Jiangsu Carya Smart Home Hardware Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:26-cv-09471, C.D. Cal., 08/24/2026
  • Venue Allegations: Venue is alleged based on several grounds: for foreign defendants, under 28 U.S.C. § 1391(c)(3); for domestic defendants, based on acts of infringement and having a regular and established place of business within the district (Irvine and Fontana, CA); and for one defendant, based on its incorporation in California.
  • Core Dispute: Plaintiffs allege that Defendants' powered rocker-recliner and glider-recliner seating units infringe four U.S. patents related to powered furniture linkage mechanisms.
  • Technical Context: The technology involves the mechanical linkages and power actuators that enable motion furniture, such as recliners, to both recline and provide a rocking or gliding motion.
  • Key Procedural History: The complaint alleges that two of the asserted patents (the '348 and '693 patents) were previously asserted in litigation against other parties, resulting in consent injunctions in 2017 and 2022. The complaint also asserts pre-suit knowledge based on correspondence sent to various defendants and their licensors in 2023 and 2025, which may be relevant to claims of willful infringement.

Case Timeline

Date Event
2008-11-24 Earliest Priority Date ('348, '693 Patents)
2010-01-15 Earliest Priority Date ('165, '168 Patents)
2011-09-13 '348 Patent Issued
2012-10-30 '693 Patent Issued
2013-03-19 '165 Patent Issued
2013-03-19 '168 Patent Issued
2017-03-17 Consent Injunction in Ultra-Mek v. Man Wah ('348, '693 Patents)
2022-11-17 Consent Injunction in Ultra-Mek v. United Furniture ('348, '693 Patents)
2023-02-23 Notice Letter Sent re: '348 Patent
2023-04-19 Notice Letter Sent re: '165 and '168 Patents
2023-07-10 Notice Letter Sent re: '165 and '168 Patents
2025-06-06 Notice Letter Sent re: '165 and '168 Patents
2025-09-09 Notice Letter Sent re: '348 and '693 Patents
2025-09-25 Notice Letter Sent re: '348 and '693 Patents
2026-08-24 Complaint Filed

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

U.S. Patent No. 8,016,348 - "Reciprocating Seating Unit with Power Actuator"

  • Patent Identification: U.S. Patent No. 8,016,348, "Reciprocating Seating Unit with Power Actuator," issued September 13, 2011.
  • The Invention Explained:
    • Problem Addressed: The patent's background section notes the popularity of both reclining chairs and gliding chairs, and the desire to combine these features. It suggests a need to provide "additional functionality to glider-recliners," implying the difficulty of motorizing a chair that has both reclining and gliding capabilities. ʼ348 Patent, col. 1:20-59
    • The Patented Solution: The patent describes a seating unit that incorporates three distinct mechanical systems: a reclining mechanism for changing the angle of the seat and backrest, a reciprocating (gliding) mechanism that allows the chair to move back and forth, and a power actuating unit. The power actuator is attached to the reclining mechanism to drive the chair between an upright, an intermediate "TV," and a fully reclined position, thereby automating the recline function in a chair that can also glide. ʼ348 Patent, abstract ʼ348 Patent, col. 2:6-22
    • Technical Importance: This approach provided a method for motorizing the recline function in a piece of furniture that also incorporates a separate gliding or rocking motion, a combination that presents complex mechanical challenges. ʼ348 Patent, col. 1:45-59
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1. Compl. ¶43
    • Independent Claim 1 Elements:
      • A seating unit comprising: a base unit; a generally horizontally-disposed seat; a generally upright backrest; an extendable ottoman;
      • a reclining mechanism attached to the seat, the backrest, the ottoman and the base unit, the reclining mechanism comprising a plurality of pivotally interconnected links;
      • a reciprocating mechanism attached to the base unit and the reclining mechanism, the reciprocating mechanism being configured to enable the seat, backrest and reclining mechanism to reciprocate relative to the base unit along a longitudinal path; and
      • a power actuating unit attached to the reclining mechanism, the actuating unit configured to move the seating unit between an upright position, an intermediate TV position, and a fully reclined position.
    • The complaint reserves the right to assert infringement under the doctrine of equivalents. Compl. ¶43

U.S. Patent No. 8,297,693 - "Reciprocating Seating Unit with Power Actuator"

  • Patent Identification: U.S. Patent No. 8,297,693, "Reciprocating Seating Unit with Power Actuator," issued October 30, 2012.
  • The Invention Explained:
    • Problem Addressed: As a continuation of the '348 patent, the '693 patent addresses the same technical challenge of integrating a powered reclining function into a chair that also has a reciprocating (gliding or rocking) motion. ʼ693 Patent, col. 1:21-63
    • The Patented Solution: The ʼ693 Patent refines the invention by claiming a specific kinematic sequence for the power actuator. It describes a "linear actuating unit" with "opposed first and second ends." The claim requires that as the chair moves from upright to the TV position (extending the ottoman), the actuator's first end moves forward; subsequently, as the chair moves from the TV to the fully reclined position, the actuator's second end moves rearward. This defines the specific push-pull sequence of the actuator's operation. ʼ693 Patent, claim 1 ʼ693 Patent, col. 2:13-33
    • Technical Importance: This patented solution provides a specific kinematic blueprint for how a linear actuator can achieve a multi-stage, sequenced motion (ottoman extension, then backrest recline) in a complex reciprocating chair linkage.
  • Key Claims at a Glance:
    • The complaint asserts at least independent claim 1. Compl. ¶55
    • Independent Claim 1 Elements:
      • A seating unit comprising a base, seat, backrest, ottoman, reclining mechanism, and reciprocating mechanism, similar to the '348 Patent.
      • A "linear actuating unit" configured to move the seating unit between an upright, an intermediate TV, and a fully reclined position.
      • A specific motion requirement: "wherein the linear actuating unit includes opposed first and second ends, and wherein the first end of the linear actuating unit moves forwardly as the seating unit moves from the upright position to the TV position, and wherein the second end of the linear actuating unit moves rearwardly when the seating unit moves from the TV position to the fully reclined position."
    • The complaint reserves the right to assert infringement under the doctrine of equivalents. Compl. ¶55

U.S. Patent No. 8,398,165 - "Powered Rocker Recliner Linkage Mechanism"

  • Patent Identification: U.S. Patent No. 8,398,165, "Powered Rocker Recliner Linkage Mechanism," issued March 19, 2013.
  • Technology Synopsis: The patent addresses the need for a simplified, compact linkage for powered rocker recliners that can be adjusted between closed, extended (TV), and reclined positions. ʼ165 Patent, col. 1:42-59 It discloses a mechanism powered by a linear actuator that operates in two distinct phases: a first phase extends the ottoman, and a second phase reclines the backrest, ensuring the actions are sequenced and not simultaneous. ʼ165 Patent, abstract
  • Asserted Claims: At least independent claim 1 is asserted. Compl. ¶67
  • Accused Features: The complaint alleges that the "Accused Seating Units and Accused Mechanisms that are capable of rocking" infringe the ʼ165 patent, identifying the Carya Smart powered rocker-recliner mechanism as an infringing component. Compl. ¶67 Compl. ¶70

U.S. Patent No. 8,398,168 - "Powered Glider Recliner Linkage Mechanism"

  • Patent Identification: U.S. Patent No. 8,398,168, "Powered Glider Recliner Linkage Mechanism," issued March 19, 2013.
  • Technology Synopsis: A companion to the '165 patent, this patent discloses a similar invention applied to glider recliners. It addresses the complexity of prior art glider-recliner linkages by providing a compact, actuator-driven mechanism. ʼ168 Patent, col. 1:48-59 The solution also employs a sequenced, two-phase motion where the ottoman extends first, followed by the recline of the backrest. ʼ168 Patent, abstract
  • Asserted Claims: At least independent claim 1 is asserted. Compl. ¶79
  • Accused Features: The complaint alleges that the "Accused Seating Units and Accused Mechanisms that are capable of gliding" infringe the ʼ168 patent, identifying the Carya Smart powered glider-recliner mechanism as an infringing component. Compl. ¶79 Compl. ¶82

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as the "Accused Seating Units." These include powered gliding-reclining and rocking-reclining chairs sold under the "COLAMY" and/or "Barcalounger" brands, with specific model numbers including "60399C", "HL-60399", and "60399". Compl. ¶40 The complaint further identifies the core infringing components as powered reclining mechanisms manufactured by Defendant Carya Smart, including model numbers 5115 (rocker) and 7115 (glider). (Compl. ¶¶40; Compl. ¶46).
  • Functionality and Market Context: The accused products are described as motion furniture that incorporates powered mechanisms for reclining. Compl. ¶¶39-40 The complaint alleges these products are manufactured, imported, distributed, and sold throughout the United States, including in California, through various channels such as e-commerce sites and furniture retailers. Compl. ¶¶21-24 Compl. ¶7 The "COLAMY" brand is allegedly sold via the website www.colamyhome.com, which is maintained by certain Defendants. Compl. ¶7 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not include the referenced claim chart exhibits. The following tables summarize the infringement theory for the lead patents based on the narrative allegations in the complaint and an analysis of the asserted claims.

U.S. Patent No. 8,016,348 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a reclining mechanism attached to the seat, the backrest, the ottoman and the base unit... The Accused Seating Units contain powered reclining mechanisms manufactured by Carya Smart, such as the 5115 and 7115 models. ¶40; ¶46 col. 2:3-5
a reciprocating mechanism attached to the base unit and the reclining mechanism... configured to enable the... mechanism to reciprocate... The Accused Seating Units are identified as "powered gliding-reclining and rocking-reclining seating units" that incorporate mechanisms enabling this motion. ¶40 col. 2:5-9
a power actuating unit attached to the reclining mechanism... configured to move the seating unit between an upright position... an intermediate TV position, and a fully reclined position... The complaint identifies the Accused Mechanisms as "powered" and alleges they infringe the patent, which requires movement between these three positions. ¶46 col. 2:9-22
  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the specific linkage design of the accused Carya Smart mechanisms (e.g., models 5115 and 7115) falls within the scope of the claim term "reciprocating mechanism" as defined and described in the '348 Patent.
    • Technical Questions: The analysis may focus on how the "power actuating unit" in the accused products is "attached to the reclining mechanism" and whether that attachment and its function correspond to the configuration claimed in the patent.

U.S. Patent No. 8,297,693 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a linear actuating unit attached to the reclining mechanism... The Accused Seating Units are alleged to contain powered mechanisms that infringe this claim. ¶55; ¶58 col. 2:13-14
wherein the linear actuating unit includes opposed first and second ends, and wherein the first end... moves forwardly... and wherein the second end... moves rearwardly... The complaint alleges that the Accused Seating Units infringe this claim but does not provide specific factual allegations detailing the kinematic movement of the actuator. Infringement is asserted "as shown in Exhibit 6," which was not provided. ¶55 col. 2:45-55
  • Identified Points of Contention:
    • Evidentiary Questions: The primary point of contention will likely be evidentiary. The complaint makes a conclusory allegation of infringement for the specific kinematic limitation of claim 1. The plaintiff will need to produce evidence demonstrating that the actuators in the accused products actually operate with the claimed two-stage forward and rearward motion of their "first and second ends."
    • Scope Questions: The definitions of "first end" and "second end" of the "linear actuating unit," and what constitutes moving "forwardly" and "rearwardly" relative to the base, will be critical for the court to construe.

V. Key Claim Terms for Construction

  • The Term: "reciprocating mechanism" ('348 Patent)
  • Context and Importance: This term is at the core of the '348 Patent's claimed invention, which combines a powered recliner with a chair that also reciprocates (glides or rocks). The breadth of this term's construction will determine whether the specific design of the accused Carya Smart mechanisms is covered by the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is broad, referring to a mechanism "configured to enable" reciprocation. ʼ348 Patent, col. 9:34-39 This functional language may support an interpretation that covers any structure achieving that result.
    • Evidence for a Narrower Interpretation: The specification primarily describes the reciprocating mechanism as a "gliding chair" structure comprising "a set of swing links." ʼ348 Patent, col. 1:30-44 A defendant may argue that the term should be limited to the pendulum-type swing-link embodiments disclosed.
  • The Term: "first end" and "second end" of the "linear actuating unit" ('693 Patent)
  • Context and Importance: Claim 1 of the '693 Patent depends entirely on the specific relative movements of these two "ends." How these terms are defined is dispositive for infringement, as the claim requires a specific sequence of forward and rearward motion.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not explicitly define "first end" and "second end." A plaintiff might argue for a functional definition, where the "ends" are the points on the actuator that interface with the linkage to produce the claimed motion, regardless of the actuator's internal components.
    • Evidence for a Narrower Interpretation: The specification describes the power unit as including a "motor unit" and a "sleeve" that receives a "retractable rod." ʼ693 Patent, col. 6:46-53 A defendant could argue that the "ends" must correspond to these specific structural components (e.g., the motor housing and the tip of the rod), potentially limiting the claim's scope.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement for all four patents.
    • Inducement: The inducement theory is based on allegations that Defendants encourage their customers (e.g., furniture retailers and end consumers) to directly infringe. Specific alleged acts include selling the accused products with the intent that they be used Compl. ¶49 Compl. ¶61, providing instruction manuals on assembly and operation Compl. ¶49 Compl. ¶61, and designing and selling the component mechanisms with the specific intent that they be incorporated into infringing chairs. Compl. ¶48 Compl. ¶60 The complaint also alleges Defendant Carya Smart copied Plaintiffs' mechanisms. Compl. ¶48 Compl. ¶60
    • Contributory Infringement: The complaint alleges the "Accused Mechanisms" are material components of the patented inventions, are especially made or adapted for use in an infringing manner, and are not staple articles of commerce suitable for substantial non-infringing use. Compl. ¶46 Compl. ¶58
  • Willful Infringement: Willfulness is alleged for all four patents. The allegations are based on Defendants' purported knowledge of the patents and their infringement. This knowledge is alleged to stem from awareness of prior litigations involving the patents Compl. ¶45 Compl. ¶57, direct notice letters sent to Defendants and their licensors Compl. ¶45 Compl. ¶69 Compl. ¶81, and continued infringement after receiving such notice. Compl. ¶52 Compl. ¶64

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

  1. A central issue will be one of evidentiary proof: For the '693 patent in particular, can the Plaintiffs demonstrate through technical evidence that the actuators in the accused products perform the specific, two-stage forward-and-rearward kinematic sequence required by claim 1? The complaint's allegations on this point are conclusory.
  2. A second key issue will be one of claim construction: Can the term "reciprocating mechanism", which is described in the context of pendulum-style gliders, be construed broadly enough to read on the specific designs of the accused Carya Smart rocker and glider mechanisms? The outcome of this construction will be critical to the infringement analysis for the '348 and '693 patents.
  3. The case also presents a significant question regarding willfulness: The complaint details a history of prior successful enforcement of the patents and alleges direct pre-suit notice. A key question for the court will be whether these facts, if proven, rise to the level of objective recklessness required to support a finding of willful infringement and potential enhanced damages.