DCT

1:26-cv-01002

Continuous Composites Inc v. Anisoprint SARL

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:26-cv-01002, D. Del., 08/07/2026
  • Venue Allegations: Venue is alleged to be proper as Defendants are organized under the laws of foreign jurisdictions and are not residents of the United States. The complaint also alleges Defendants have conducted business in Delaware through distributors and online retailers and actively solicit orders from the United States and Delaware.
  • Core Dispute: Plaintiff alleges that Defendants' continuous fiber 3D printers and associated manufacturing processes infringe ten U.S. patents related to continuous fiber additive manufacturing technology.
  • Technical Context: The lawsuit concerns continuous fiber 3D printing, a technology that embeds a a continuous structural fiber within a polymer matrix during the printing process to create composite parts that are stronger and lighter than those made with traditional 3D printing methods.
  • Key Procedural History: The complaint highlights Plaintiff's prior successful litigation against Markforged, Inc., which resulted in a jury verdict of infringement of one of the asserted patents ('660 Patent), an award of over $17.3 million, and a subsequent $25 million license settlement. Plaintiff also notes it prevailed in seven inter partes review (IPR) proceedings initiated by Markforged, where the Patent Office either denied institution or found no challenged claims unpatentable. The complaint also details extensive pre-suit licensing negotiations with the current Defendants beginning in 2023, which it alleges were unsuccessful.

Case Timeline

Date Event
2012-08-29 Earliest Priority Date for all Asserted Patents
2016-12-06 U.S. Patent No. 9,511,543 Issued
2020-03-31 U.S. Patent No. 10,603,836 Issued
2020-08-18 U.S. Patent No. 10,744,708 Issued
2020-09-01 U.S. Patent No. 10,759,109 Issued
2021-07-07 Plaintiff filed lawsuit against Markforged, Inc.
2021-11-16 U.S. Patent No. 11,173,660 Issued
2023-01-01 Plaintiff began licensing discussions with Defendants (approx. "Since 2023")
2023-02-14 U.S. Patent No. 11,577,455 Issued
2023-02-21 U.S. Patent No. 11,584,069 Issued
2023-02-28 U.S. Patent No. 11,590,699 Issued
2023-07-18 Alleged "Notice Date" for infringement of several patents
2024-04-01 Jury verdict in Markforged litigation (approx. "April 2024")
2024-06-15 Plaintiff sent licensing term sheet to Defendants
2025-01-24 Plaintiff's counsel sent letter to Defendants
2025-03-13 Plaintiff's counsel sent second letter to Defendants
2025-03-25 U.S. Patent No. 12,257,772 Issued
2025-08-13 Defendants began marketing the "FibreSeeker 3" product
2025-09-01 Defendants planned Kickstarter launch for FibreSeeker 3 (approx. "September 2025")
2025-09-02 U.S. Patent No. 12,403,651 Issued
2025-12-12 Alleged "Notice Date" for infringement of '772 and '651 Patents
2026-08-07 Complaint Filed

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

U.S. Patent No. 9,511,543 - "Method and Apparatus for Continuous Composite Three-Dimensional Printing"

  • Issued: December 6, 2016

The Invention Explained

  • Problem Addressed: The patent describes conventional additive manufacturing methods, such as stereolithography (SLA) and selective laser sintering (SLS), as building parts in discrete slices, which creates weak joints between layers and results in relatively weak parts ʼ543 Patent, col. 1:17-48
  • The Patented Solution: The invention proposes a method called "Continuous Composite Three Dimensional Printing (CC3D)" that abandons the "slicing" paradigm in favor of "pathing" ʼ543 Patent, col. 2:7-13 It involves simultaneously extruding two or more materials-a liquid primary material (e.g., a curable resin) and a solid continuous strand secondary material (e.g., carbon fiber)-as a single composite path where the strand is fully encased in the liquid '543 Patent, abstract '543 Patent, col. 2:19-28 A means for curing, such as a UV light shown in Figure 5, hardens the composite material as it is extruded, creating a structurally continuous object '543 Patent, col. 2:28-32 '543 Patent, Fig. 5
  • Technical Importance: This method enables the creation of stronger, lighter parts by incorporating a continuous mechanical structure, offering greater flexibility in design than traditional layer-by-layer 3D printing '543 Patent, col. 2:13-18

Key Claims at a Glance

  • The complaint does not specify which claims of the '543 Patent are asserted, but analysis of independent claim 1 is representative:
  • Independent Claim 1:
    • extruding through one or more openings at least one path comprising at least one primary material (a liquid) and at least one secondary material (a strand);
    • extruding the materials contemporaneously;
    • encasing at least a portion of the secondary material in the primary material;
    • coupling a portion of the path to an anchor point;
    • pulling the path through the openings by moving the openings and/or the anchor point;
    • adjusting the path's orientation to adjust its shape;
    • hardening at least a portion of the primary material; and
    • forming a portion of the object from the path as it is extruded.

U.S. Patent No. 10,603,836 - "Method and Apparatus for Continuous Composite Three-Dimensional Printing"

  • Issued: March 31, 2020

The Invention Explained

  • Problem Addressed: The patent addresses the need for additive manufacturing techniques that can build parts faster and stronger than existing slicing methods, which produce relatively weak, homogeneous parts '836 Patent, col. 2:1-5
  • The Patented Solution: The '836 Patent refines the CC3D method by claiming a process that specifically uses a pre-impregnated continuous strand. The method involves directing this pre-impregnated strand (saturated with a first polymer) and a separate second polymer into a heated extruder, where the strand is coated with the second polymer before being discharged as a composite path '836 Patent, claim 1 This process is illustrated in configurations like Figure 1, which shows a pre-pregged carbon fiber encased in a polymer resin '836 Patent, Fig. 1, element 101
  • Technical Importance: Using a pre-impregnated strand with a secondary polymer coating allows for greater flexibility in material combinations and improved control over the final composite's properties, enabling the design of parts with enhanced strength and functionality '836 Patent, col. 2:52-67

Key Claims at a Glance

  • The complaint asserts at least claims 1, 6, and 8 Compl. ¶77
  • Independent Claim 1:
    • pre-impregnating a continuous strand material with a first polymer;
    • directing the pre-impregnated strand into an extruder nozzle;
    • directing a second polymer into the extruder;
    • heating the extruder;
    • coating the pre-impregnated strand with the second polymer;
    • discharging a path of the resulting composite material from the extruder; and
    • moving the extruder in multiple dimensions during discharge.

Multi-Patent Capsule: U.S. Patent No. 10,744,708

  • Patent Identification: U.S. Patent No. 10744708, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued August 18, 2020. This patent disclaimed claims 13-19 in 2023 '708 Patent, Disclaimer
  • Technology Synopsis: The '708 Patent claims a method of emitting a composite path (continuous strand in a primary material) and pulling the path out of the extruder during manufacturing '708 Patent, claim 1 This "pulling" action, which creates tension in the path, is a key feature.
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶86
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process used by Defendants' printers is accused of infringement Compl. ¶86

Multi-Patent Capsule: U.S. Patent No. 10,759,109

  • Patent Identification: U.S. Patent No. 10759109, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued September 1, 2020. This patent disclaimed claims 10-15 in 2022 '109 Patent, Disclaimer
  • Technology Synopsis: The '109 Patent claims an apparatus for additive manufacturing. The apparatus includes an extruder and a motion system (e.g., robotic arm) configured to move the extruder such that the continuous strand is pulled from the extruder by the movement '109 Patent, claim 1
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶95
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process and associated printers are accused of infringement Compl. ¶95

Multi-Patent Capsule: U.S. Patent No. 11,173,660

  • Patent Identification: U.S. Patent No. 11173660, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued November 16, 2021.
  • Technology Synopsis: This patent claims an apparatus for 3D printing that includes a device for hardening the polymer (e.g., a UV light or heater) that is attached to and moveable with the extruder '660 Patent, claim 1 This ensures the curing source is always positioned correctly relative to the extrusion point.
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶104
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process and associated printers are accused of infringement Compl. ¶104

Multi-Patent Capsule: U.S. Patent No. 11,577,455

  • Patent Identification: U.S. Patent No. 11577455, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued February 14, 2023.
  • Technology Synopsis: This patent claims a method where a pre-pregged fiber strand is dispensed from a first port while a separate supply of polymer is dispensed from a second port '455 Patent, claim 1 The two materials are combined and then hardened to form the object.
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶113
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process is accused of infringement Compl. ¶113

Multi-Patent Capsule: U.S. Patent No. 11,584,069

  • Patent Identification: U.S. Patent No. 11584069, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued February 21, 2023.
  • Technology Synopsis: Similar to the '455 patent, this patent claims a printing method using a pre-pregged fiber strand and a separate polymer supply, but focuses on the control and sequencing of forming distinct layers of the object '069 Patent, claim 1
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶122
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process is accused of infringement Compl. ¶122

Multi-Patent Capsule: U.S. Patent No. 11,590,699

  • Patent Identification: U.S. Patent No. 11590699, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued February 28, 2023.
  • Technology Synopsis: This patent claims a method that involves providing a pre-pregged fiber and a separate polymer to an extruder, heating them, and dispensing them via a computer-controlled system to form an object '699 Patent, claim 33
  • Asserted Claims: The complaint does not specify which claims are asserted Compl. ¶131
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process is accused of infringement Compl. ¶131

Multi-Patent Capsule: U.S. Patent No. 12,257,772

  • Patent Identification: U.S. Patent No. 12257772, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued March 25, 2025.
  • Technology Synopsis: The '772 Patent claims a method of dispensing a heated thermoplastic from a first opening and a pre-pregged continuous fiber from a second opening, where the fiber is dispensed against the already-dispensed thermoplastic '772 Patent, claim 16
  • Asserted Claims: At least claims 1-6 and 10 are asserted Compl. ¶140
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process is accused of infringement Compl. ¶140

Multi-Patent Capsule: U.S. Patent No. 12,403,651

  • Patent Identification: U.S. Patent No. 12403651, "Method and Apparatus for Continuous Composite Three-Dimensional Printing," issued September 2, 2025.
  • Technology Synopsis: This patent claims a method of dispensing a heated thermoplastic and a continuous fiber (not necessarily pre-pregged) through separate openings, with the fiber being dispensed against the thermoplastic to form the composite object '651 Patent, claim 1
  • Asserted Claims: At least claim 6 is asserted Compl. ¶149
  • Accused Features: The "Composite Fiber Co-extrusion (CFC)" process is accused of infringement Compl. ¶149

III. The Accused Instrumentality

Product Identification

  • The Accused Products are the Anisoprint Composer A3, Anisoprint Composer A4, Anisoprint Composer Nova, and FibreSeeker 3 printers Compl. ¶9 Compl. ¶10

Functionality and Market Context

  • The complaint alleges that the Accused Products operate using a technique Defendants call "Composite Fiber Co-extrusion" or "CFC" Compl. ¶53 This process is described as employing an extruder with two inlets and a single nozzle. A "composite fiber is directed through one channel and is coated in molten plastics supplied through another channel, forming a composite part reinforced with continuous fibers" Compl. ¶53
  • Plaintiff alleges these are Defendants' flagship products and primary revenue contributors Compl. ¶10 The FibreSeeker 3 is specifically marketed as a low-cost "First Consumer Continuous Fibre 3D printer" that "places full-length fibers precisely where strength is needed - layer by layer" Compl. ¶63
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The following analysis is based on the narrative infringement theory presented in the complaint.

U.S. Patent No. 9,511,543 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
extruding...at least one path comprising at least one primary material...and at least one secondary material The CFC process allegedly extrudes a composite path containing a fiber and molten plastic Compl. ¶53 ¶53 col. 2:19-22
wherein the at least one primary material comprises a liquid material The CFC process allegedly uses "molten plastics" Compl. ¶53 ¶53 col. 2:22-24
wherein the at least one secondary material comprises at least one strand The CFC process allegedly uses a "composite fiber" Compl. ¶53 ¶53 col. 2:24-26
encasing at least a portion of the at least one secondary material in the at least one primary material The CFC process allegedly "coat[s]" the fiber in "molten plastics" Compl. ¶53 ¶53 col. 2:26-28
coupling a portion of the at least one path to an anchor point The complaint generally alleges the CFC process infringes but does not provide specific facts mapping to this limitation Compl. ¶68 ¶68 col. 9:62-65
pulling the at least one path through the one or more openings The complaint does not provide specific facts mapping to this limitation Compl. ¶68 ¶68 col. 10:5-9
hardening at least a portion of the at least one primary material The CFC process allegedly forms a "composite part," which implies hardening of the molten plastic Compl. ¶53 ¶53 col. 2:28-32

U.S. Patent No. 10,603,836 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
pre-impregnating a continuous strand material with a first polymer The complaint does not provide sufficient detail for analysis of whether the accused "composite fiber" is pre-impregnated. ¶77 col. 11:1-3
directing the pre-impregnated continuous strand material into an extruder nozzle The CFC process allegedly directs a "composite fiber" through a channel in an extruder Compl. ¶53 ¶53 col. 11:4-6
directing a second polymer into the extruder The CFC process allegedly supplies "molten plastics" through another channel into the extruder Compl. ¶53 ¶53 col. 11:7-8
heating the extruder The complaint alleges the use of "molten plastics," which implies heating, but does not explicitly state the extruder is heated Compl. ¶53 ¶53 col. 11:9
coating the pre-impregnated continuous strand material with the second polymer The CFC process allegedly "coat[s]" the fiber in "molten plastics" Compl. ¶53 ¶53 col. 11:10-12
discharging from the extruder a path of composite material... The Accused Products allegedly form a "composite part reinforced with continuous fibers" Compl. ¶53 ¶53 col. 11:13-17
  • Identified Points of Contention:
    • Scope Questions: A primary question for the '543 Patent will be whether the accused CFC process performs the claimed steps of "coupling" to an "anchor point" and "pulling" the path. The complaint's general description of the accused process does not contain facts that directly map to these specific tension-related limitations.
    • Technical Questions: For the '836 Patent, a critical factual dispute will be whether the "composite fiber" used by Defendants is "pre-impregnat[ed] with a first polymer" as required by claim 1. The complaint's description of the accused CFC process Compl. ¶53 does not specify that the fiber is pre-treated, suggesting a potential mismatch with this core claim element.

V. Key Claim Terms for Construction

The Term: "anchor point" ('543 Patent, claim 1)

  • Context and Importance: The infringement analysis for the '543 Patent may turn on the construction of "anchor point." This term is central to the claimed method of initiating and tensioning an extruded path. If construed narrowly, it could be a key point of non-infringement, as the complaint does not allege a specific anchoring mechanism in the accused process.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that "Any surface or point may provide an anchor point" '543 Patent, col. 9:64-65 This language could support an argument that merely starting an extrusion on the printer's build plate satisfies the limitation.
    • Evidence for a Narrower Interpretation: Figure 9 depicts the "anchor" ("903") as a distinct vertical structure used to initiate a "tension path" ("901") that extends horizontally into free space '543 Patent, Fig. 9 This may support a narrower construction requiring a specific structure used for creating tension, rather than just any starting surface.

The Term: "pre-impregnating" (['836 Patent, claim 1](https://ex:cit:10))

  • Context and Importance: This term is the first limitation of independent claim 1 of the '836 patent, making its definition critical. Practitioners may focus on this term because the infringement case for this patent depends entirely on whether the fiber used in the accused CFC process is considered "pre-impregnated."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification defines a pre-pregged secondary material as one that is "saturated with another material" '836 Patent, col. 3:43-44 This could be argued to encompass a process where the fiber is wetted with a polymer immediately before or upon entering the extruder nozzle, not necessarily as a separate, prior manufacturing step.
    • Evidence for a Narrower Interpretation: The specification describes pre-pregged carbon fiber where the resin is "only partially cured to allow for ease of handling" and notes the importance of keeping it "cool and away from light to prevent premature curing prior to extrusion" '836 Patent, col. 3:45-50 This suggests "pre-impregnating" refers to a distinct manufacturing step that results in a stable, handleable raw material, not an in-line wetting process.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges both induced and contributory infringement for all ten asserted patents. Inducement allegations are based on Defendants providing instructions, guides, manuals, and training courses that allegedly instruct customers on how to use the Accused Products in an infringing manner (Compl. ¶¶54; 69; 78). Contributory infringement is based on the allegation that Defendants provide the "composite extruder," which is a material component especially made for use in the infringing CFC process and not suitable for a substantial non-infringing use (Compl. ¶¶70; 79).

Willful Infringement

  • Willfulness is alleged for all ten asserted patents. The claims are based on alleged pre-suit knowledge stemming from repeated licensing discussions beginning in 2023, during which Plaintiff allegedly provided exemplary claim charts and notified Defendants of the outcome of its successful litigation against Markforged Compl. ¶¶57-62 For patents issued more recently ('772 and '651 Patents), the complaint alleges Defendants were at a minimum willfully blind to their existence and infringement Compl. ¶65

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

  • A central evidentiary question will be one of material composition: Does the "composite fiber" used in Defendants' CFC process meet the "pre-impregnating" limitation required by the '836 patent and several others? The resolution will depend on evidence showing whether the fiber is supplied as a pre-treated raw material or is wetted with a polymer as part of the extrusion process itself.
  • A core issue will be one of claim construction and scope: Can the "anchor point" and "pulling" limitations of the '543 patent family be read onto the accused process? The case may turn on whether these terms are construed broadly to cover the basic mechanics of 3D printing or narrowly to require a specific tensioning mechanism that the complaint does not allege is present in the accused systems.
  • A key question for damages will be one of willfulness: Given the complaint's detailed allegations of extensive pre-suit notice, including providing claim charts and knowledge of prior litigation, a jury will have to determine whether any infringement was willful, which could expose Defendants to treble damages.
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