CK Mfg LLC v. Design & Mfg Holding Co Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: CK Manufacturing, LLC (Colorado)
  • Defendant: Design & Manufacturing Holding Company, Inc. (Florida)
  • Plaintiff's Counsel: Martensen IP
• Case Identification: 8:26-cv-01051, M.D. Fla., 07/13/2026
• Venue Allegations: Venue is asserted based on Defendant having its principal place of business and headquarters in Tampa, Florida, within the Middle District of Florida, and being registered to do business in the state.
• Core Dispute: Plaintiff alleges that Defendant's configurable ammunition packaging machines infringe two patents related to modular, automated ammunition packaging technology.
• Technical Context: The technology provides a cost-effective, automated packaging system for smaller ammunition manufacturers, designed to be easily reconfigured to handle different ammunition calibers.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of U.S. Patent No. 11,226,186 since at least June 2022, following a discussion between the inventor and a Defendant executive at a trade show. Knowledge of U.S. Patent No. 12,007,215 is alleged since at least June 2024. Plaintiff also states it made informal requests for Defendant to cease its allegedly infringing conduct prior to filing the lawsuit.

Case Timeline

Date	Event
2019-01-17	Priority Date for '186 and '215 Patents
2022-01-18	U.S. Patent No. 11,226,186 Issued
2022-06	Alleged Date of Defendant's Knowledge of '186 Patent
2024-06-11	U.S. Patent No. 12,007,215 Issued
2024-06	Alleged Date of Defendant's Knowledge of '215 Patent
2026-07-13	Complaint Filing Date

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

U.S. Patent No. 11,226,186 - "Configurable Ammunition Packaging Apparatus"

• Patent Identification: U.S. Patent No. 11,226,186, "Configurable Ammunition Packaging Apparatus," issued January 18, 2022.

The Invention Explained

• Problem Addressed: The patent addresses a need for smaller ammunition manufacturers who cannot justify the "exorbitant costs" of large, single-caliber robotic loading machines. Existing lower-cost solutions are described as labor-intensive, caliber-specific, and unreliable for certain types of ammunition, such as rifle rounds or lightweight "frangible" rounds. ʼ186 Patent, col. 1:47-col. 2:4
• The Patented Solution: The invention is a modular apparatus that can be reconfigured for different ammunition calibers by swapping out component sets. The process involves an ammunition collator feeding rounds into a channel. A key component, a "flipper tray," moves laterally to receive individual rounds in its "furrows" and then rotates 90 degrees to deliver the rounds into a "down chute assembly," which in turn guides them into a packaging tray. ʼ186 Patent, abstract ʼ186 Patent, col. 2:31-48
• Technical Importance: The invention provides an "elegant solution" that simplifies the loading process, offering smaller manufacturers the flexibility to automate the packaging of different ammunition types with a single, adaptable machine. ʼ186 Patent, col. 2:5-11

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶20
• Essential elements of independent claim 1 include:
  • An ammunition collator;
  • An ammunition channel for receiving rounds in a horizontal orientation;
  • A "flipper tray" with multiple "furrows", movably positioned on a track to accept single rounds of ammunition;
  • A "down chute assembly" with multiple down chutes;
  • A "rotating device" coupled to the flipper tray, configured to "rotate the flipper tray 90 degrees" to deliver rounds into the down chutes; and
  • A movable ammunition tray with receptacles to accept the rounds from the down chutes.
• The complaint does not explicitly reserve the right to assert other claims, but this is standard practice.

U.S. Patent No. 12,007,215 - "Configurable Ammunition Packaging System"

• Patent Identification: U.S. Patent No. 12,007,215, "Configurable Ammunition Packaging System," issued June 11, 2024.

The Invention Explained

• Problem Addressed: The patent shares its specification with the '186 Patent and thus addresses the same problem: the need for a flexible, automated packaging solution for smaller ammunition manufacturers. ʼ215 Patent, col. 1:57-col. 2:4
• The Patented Solution: This patent claims a complete system for ammunition packaging. The claims focus on the combination of interchangeable hardware ("component sets" for different calibers) and the control system. The invention covers a system comprising a first component set, a second component set, and an apparatus that is reconfigured by physically "replacing" one set with another, all orchestrated by a "machine" executing software. ʼ215 Patent, col. 3:25-col. 4:21
• Technical Importance: The system-level invention provides not just the mechanical apparatus but a complete, software-integrated solution for rapid changeover between different ammunition packaging jobs. ʼ215 Patent, col. 10:46-60

Key Claims at a Glance

• The complaint asserts at least independent claim 1 Compl. ¶28
• Essential elements of independent claim 1 include:
  • A "first component set" associated with a first ammunition caliber;
  • A "second component set" associated with a second ammunition caliber;
  • An ammunition packaging apparatus that is reconfigured by "replacing" the first component set with the second; and
  • A "machine", executing software instructions, that controls the apparatus based on the selected caliber.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as "configurable ammunition packaging apparatuses," which are also referred to by Defendant as an "ammunition tray loading machine," a "tray packing machine," or a "tray loading machine" Compl. ¶17 The products are allegedly sold under the "D & M brand name" Compl. ¶18

Functionality and Market Context

The complaint alleges these products are sold in the United States, including through Defendant's online store Compl. ¶17 The core accused functionality involves "pushing the loaded ammunition over a curved surface" to transfer it for packaging Compl. ¶21 Compl. ¶29 This description suggests a mechanism for reorienting and transferring ammunition rounds, which is the same general purpose as the "flipper tray" in the patents-in-suit.

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint.

'186 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a flipper tray having a plurality of furrows in the horizontal orientation...	The complaint alleges that the Accused Products "utilize pushing the loaded ammunition over a curved surface" to perform the function of the claimed "flipper tray" element.	¶21	col. 7:63-col. 8:6
a rotating device coupled to the flipper tray and configured to rotate the flipper tray 90 degrees from the horizontal orientation to the vertical orientation...	The complaint alleges that the "curved surface" of the Accused Products achieves the same result as the claimed "rotating device coupled to the flipper tray" element.	¶21	col. 8:31-41

'215 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first component set associated with a first ammunition caliber and composed of... a first flipper tray...	The complaint alleges the Accused Products are "configurable" and that their "curved surface" functionality performs the role of the claimed "flipper tray," a required part of the component set.	¶17; ¶29	col. 15:2-6
an ammunition packaging apparatus reconfigured... by... replacing... the first component set with the second component set; and	The complaint identifies the Accused Products as "configurable ammunition packaging apparatuses," creating an inference that they are used in a manner that involves replacing components to handle different calibers.	¶17	col. 15:12-18

Identified Points of Contention

• Scope Questions: A central question will be whether the term "flipper tray", as described in the patent, can be construed to read on the accused "curved surface." The patent describes a tray with furrows that itself moves and rotates, which may present a definitional mismatch with a potentially stationary guide surface.
• Technical Questions: The complaint's phrasing-that the accused function is performed in "substantially the same way, to achieve substantially the same result"-explicitly raises the doctrine of equivalents Compl. ¶21 Compl. ¶29 A key technical question for the court will be whether guiding ammunition along a curved surface is substantially the same "way" as mechanically rotating a tray by 90 degrees.

V. Key Claim Terms for Construction

The Term: "flipper tray"

• Context and Importance: This term is at the heart of the dispute, as the complaint directly contrasts it with the accused "curved surface" Compl. ¶21 Compl. ¶29 The outcome of its construction could determine the viability of a literal infringement theory and will frame the analysis under the doctrine of equivalents.
• Evidence for a Broader Interpretation: The patent summary describes the flipper tray as having "several furrows or grooves" and moving "side-to-side (laterally) along a track" to accept rounds ʼ186 Patent, col. 2:31-36 A party might argue that any component that receives and helps transfer rounds along a track meets the general description.
• Evidence for a Narrower Interpretation: The claim itself requires a separate "rotating device" to be "coupled to the flipper tray" and "rotate the flipper tray 90 degrees" ʼ186 Patent, col. 15:17-24 This suggests the "flipper tray" is a distinct object that is acted upon, rather than a passive guide. The figures further depict a discrete, movable tray structure ʼ186 Patent, Fig. 1C

The Term: "replacing... the first component set with the second component set"

• Context and Importance: This limitation in claim 1 of the '215 Patent is critical for system-level infringement. Practitioners may focus on this term because it requires an affirmative act of physical reconfiguration. Proving infringement will require evidence that the accused systems are designed for, and that users perform, this specific swapping action.
• Evidence for a Broader Interpretation: A party could argue that "replacing" covers any form of modular adjustment, even if some core components remain. The patent notes that for some calibers, "hardware components may remain the same... requiring only minor timing adjustments via a software portion" ʼ186 Patent, col. 11:7-11
• Evidence for a Narrower Interpretation: The claim language is specific about "replacing... the first component set with the second component set" ʼ215 Patent, col. 15:16-18 This, combined with the detailed list of parts in each set (collator plate, channel, flipper tray, etc.), suggests a complete or near-complete substitution of the caliber-specific hardware is required.

VI. Other Allegations

• Willful Infringement: The complaint alleges willful infringement for both patents. For the '186 Patent, willfulness is based on alleged knowledge since at least June 2022, stemming from a conversation at an industry trade show Compl. ¶25 For the '215 Patent, knowledge is alleged since at least June 2024 Compl. ¶33 These allegations form the basis for Plaintiff's request for trebled damages Compl. Prayer for Relief, ¶c

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

• A primary issue will be one of functional equivalence: Does the accused "curved surface" mechanism perform substantially the same function, in substantially the same way, to achieve substantially the same result as the patented "flipper tray" and its associated "rotating device"? The case may turn on whether guiding a round along a static curve is judicially seen as the same "way" as mechanically rotating a tray holding the round.
• A second core issue will be one of definitional scope: Can the term "flipper tray"-described in the patent as a discrete, moving component with furrows-be construed to encompass the "curved surface" alleged to be used in the accused product? The answer will determine the path of the litigation, either toward a literal infringement argument or one relying entirely on the doctrine of equivalents.
• For the '215 system patent, a key evidentiary question will be one of reconfiguration: What proof will be presented to show that Defendant's system is used by "replacing" distinct, caliber-specific component sets as required by the claim, versus merely making software or minor hardware adjustments?