Holley Performance Products Inc v. Aces Fuel Injection Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Holley Performance Products Inc. (Delaware)
  • Defendant: Aces Fuel Injection, Inc. (Tennessee)
  • Plaintiff's Counsel: Miller & Martin PLLC; Brooks Kushman P.C.
• Case Identification: 1:26-cv-00059, E.D. Tenn., 03/06/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Tennessee because the Defendant's principal place of business is located in Chattanooga, Tennessee, which is within the district.
• Core Dispute: Plaintiff alleges that Defendant's electronic fuel injection systems infringe four patents related to the mechanical design and fuel delivery architecture of throttle body assemblies, and that Defendant's product manual infringes Plaintiff's copyrighted installation manual.
• Technical Context: The technology at issue involves electronic fuel injection (EFI) systems designed as aftermarket replacements for older, mechanically controlled carburetors, primarily for high-performance and classic automobiles.
• Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the patents-in-suit, or prior licensing history.

Case Timeline

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

U.S. Patent No. 11,118,515 - Electronic Fuel Injection Throttle Body Assembly (Issued Sep. 14, 2021)

The Invention Explained

• Problem Addressed: The patent describes the difficulty of retrofitting older, carbureted engines with modern electronic fuel injection (EFI) systems due to physical space constraints and the need to maintain performance and efficiency across various operating conditions (e.g., cold starts, idle, wide-open throttle) '515 Patent, col. 1:31-48
• The Patented Solution: The invention is a self-contained throttle body assembly that integrates an electronic control unit (ECU) and a specific fuel delivery architecture into a single unit designed to replace a carburetor '515 Patent, col. 1:17-23 A key aspect of the claimed design is the spatial arrangement of its components, with a fuel component cover on one side and an ECU cover on another side, positioned approximately 90 degrees from each other '515 Patent, claim 9 Fuel is routed internally from an inlet through a "cross-channel passageway and a vertical passageway" to feed one or more fuel injectors, which in turn direct fuel into a distribution ring inside the air intake bore '515 Patent, claim 9 '515 Patent, col. 6:56-65
• Technical Importance: This integrated design approach aimed to simplify the conversion of carbureted engines to EFI by providing a compact, "drop-in" replacement that managed both air/fuel mixing and electronic control in a single assembly '515 Patent, col. 4:40-51

Key Claims at a Glance

• The complaint asserts independent claim 9 Compl. ¶34
• Essential Elements of Claim 9:
  • A throttle body with an upper inlet and lower outlet for mounting to an engine.
  • At least one bore extending through the throttle body.
  • A fuel component cover on a first side and an electronic control unit (ECU) cover on a second side, where the first side is "about 90 degrees from" the second side.
  • At least one fuel injector parallel to the throttle body's mounting base and in electrical communication with the ECU.
  • A connecting fuel passage within the fuel component cover, comprising a "cross-channel passageway and a vertical passageway," which is in fluid communication with a first and a second fuel injector.
  • The at least one fuel injector directs fuel into a fuel distribution ring, which has multiple apertures for directing fuel into the bore.
• The complaint also alleges infringement of other, unspecified claims of the patent Compl. ¶36

U.S. Patent No. 11,333,083 - Electronic Fuel Injection Throttle Body Assembly (Issued May 17, 2022)

The Invention Explained

• Problem Addressed: The patent addresses the same general problem as the '515 Patent: creating an effective and compact EFI system to replace traditional carburetors on a variety of engines '083 Patent, col. 1:24-34 '083 Patent, col. 1:49-54
• The Patented Solution: This invention claims a more specific throttle body configuration, tailored for a four-bore setup often found on V8 engines '083 Patent, claim 1 It requires two separate fuel component covers located on opposite sides of the throttle body, with each cover associated with two of the four bores. The claims specify that a fuel injector for each bore "extends horizontally into said throttle body" and that a throttle shaft is "perpendicular to a horizontal direction between a first end and a second end of each of said first fuel injectors" '083 Patent, claim 1 This defined geometric relationship suggests a design optimized for specific engine intake manifold layouts.
• Technical Importance: By creating a modular design with opposing fuel component covers for a four-barrel throttle body, the invention provides a scalable and adaptable EFI solution that can mimic the form and function of high-performance carburetors '083 Patent, col. 4:40-51

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶42
• Essential Elements of Claim 1:
  • A throttle body with an upper inlet and lower outlet.
  • Four bores extending through the throttle body.
  • A first fuel component cover on a first side (associated with two bores) and a second fuel component cover on an opposite side (associated with the other two bores).
  • A first fuel injector for each of the four bores that "extends horizontally into said throttle body."
  • At least one connecting fuel passage (including a cross-channel and vertical passageway) within each fuel component cover.
  • Each fuel injector directs fuel into a fuel distribution ring having multiple apertures.
  • A throttle shaft that is "perpendicular" to the horizontal direction of the fuel injectors.
• The complaint also alleges infringement of other, unspecified claims of the patent Compl. ¶44

U.S. Patent No. 11,409,894 - Fuel Injection Throttle Body (Issued August 9, 2022)

• Technology Synopsis: This patent addresses the problem of poor fuel atomization in aftermarket EFI systems that use horizontally mounted injectors '894 Patent, col. 1:47-60 The invention discloses a fuel delivery mechanism using an "annular ring" positioned inside the air intake. This ring forms a fuel channel and sprays fuel through a plurality of orifices around its circumference, which is intended to improve the fuel-air mixture before it enters the engine '894 Patent, abstract '894 Patent, claim 1
• Asserted Claims: At least independent claim 1 Compl. ¶50
• Accused Features: The complaint accuses the Aces Killshot Fusion EFI System and the Deuces Wild 2-bbl EFI system of infringing this patent Compl. ¶49

U.S. Patent No. 12,203,434 - Fuel Injection Throttle Body (Issued January 21, 2025)

• Technology Synopsis: Belonging to the same family as the '894 Patent, this patent also describes a fuel injection throttle body with an annular fuel delivery system '434 Patent, col. 1:6-14 The claimed invention combines an air intake, a fuel port receiving fuel from an injector, a fuel channel, and "a plurality of orifices disposed annularly about said air intake" to pass fuel into the airflow, along with a throttle plate and an electronic controller to manage the system '434 Patent, claim 1
• Asserted Claims: At least independent claim 1 Compl. ¶58
• Accused Features: The complaint accuses the Aces Killshot Fusion EFI System and the Deuces Wild 2-bbl EFI system of infringing this patent Compl. ¶57

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Defendant's "Killshot Fusion EFI System" and "Deuces Wild 2-bbl EFI system" Compl. ¶25

Functionality and Market Context

The complaint alleges these are electronic fuel injection systems designed to compete with Plaintiff's own EFI products in the automotive aftermarket Compl. ¶27 The complaint provides images of the accused products, which depict integrated throttle body assemblies intended for installation on internal combustion engines Compl. ¶25 An image in the complaint shows the accused Aces Killshot Fusion EFI System, a throttle body assembly with four visible air intake bores and side-mounted components Compl. ¶25 The complaint alleges these products are sold online through Defendant's website and various third-party automotive parts distributors Compl. ¶26

IV. Analysis of Infringement Allegations

The complaint does not include the referenced claim chart exhibits. The following tables summarize the infringement allegations for the lead patents based on the asserted claims quoted in the complaint.

'515 Patent Infringement Allegations

'083 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A primary question may be the interpretation of relational terms. For the '515 Patent, the scope of "about 90 degrees" will be critical; the court will need to determine how much deviation from a true right angle is permissible. For the '083 Patent, the definitions of "horizontally" and "perpendicular" create precise geometric limitations that will be central to the infringement analysis.
• Technical Questions: The infringement allegations will depend on a factual investigation of the accused products' internal structures. Key questions will be whether the Aces systems contain internal fuel passages that meet the "cross-channel and vertical passageway" limitation of both patents, and whether their fuel delivery mechanism constitutes a "fuel distribution ring" as described in the specifications.

V. Key Claim Terms for Construction

"about 90 degrees" (['515 Patent, claim 9](https://ex:cit:3))

• Context and Importance: This term defines the spatial relationship between the fuel component cover and the ECU cover. The breadth of its construction is critical, as it determines whether a product with a similar but not perfectly orthogonal layout infringes. Practitioners may focus on this term because its ambiguity could be a primary non-infringement argument if the accused device deviates from a strict 90-degree angle.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification describes the overall goal of a "compact" design suitable for many vehicle types, suggesting the exact angle may be less important than the general function of packaging components on different faces of the throttle body '515 Patent, col. 4:40-51 The use of the word "about" itself suggests the patentee did not intend to be limited to a precise 90-degree angle.
  • Evidence for a Narrower Interpretation: The figures provided in the patent consistently depict a square-like, orthogonal arrangement of the side components relative to the front and rear components '515 Patent, Figs. 2-4 A defendant may argue that the term should be construed in light of these preferred embodiments to mean an arrangement that is substantially a right angle.

"extends horizontally into said throttle body" (['083 Patent, claim 1](https://ex:cit:10))

• Context and Importance: This term dictates the orientation of the fuel injectors relative to the throttle body. Infringement will turn on the factual question of whether the injectors in the accused systems are truly horizontal or are canted at an angle.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term could be interpreted relative to the throttle body's mounting base. The specification for the parent '515 patent, for example, describes injectors as "parallel to the base 122 of the throttle body 120" '515 Patent, col. 7:21-24, suggesting "horizontally" may mean parallel to the engine mounting plane rather than perfectly level.
  • Evidence for a Narrower Interpretation: The claim language further recites that the throttle shaft is "perpendicular to a horizontal direction between a first end and a second end of each of said first fuel injectors" '083 Patent, claim 1 This explicit geometric relationship reinforces a specific, precise definition of "horizontally" as the baseline from which perpendicularity is measured.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant induced and contributorily infringed the patents-in-suit Compl. ¶29 The complaint's detailed, side-by-side comparison of the parties' installation manuals may be offered as evidence of Defendant's intent to encourage and instruct its customers on how to use the accused products in an infringing manner Compl. ¶15

Willful Infringement

The complaint alleges that Defendant had pre-suit knowledge of the patents-in-suit and Holley's products Compl. ¶22 Compl. ¶30 For each of the four asserted patents, the complaint specifically alleges that Defendant has "actual knowledge" of the patent and its infringement, and that the continued infringement is therefore willful Compl. ¶37 Compl. ¶45 Compl. ¶53 Compl. ¶61

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

• A central issue will be one of geometric scope: can the asserted claims, which recite precise spatial relationships like "about 90 degrees" ('515 Patent) and injectors that extend "horizontally" and "perpendicular" to a throttle shaft ('083 Patent), be proven to read on the physical construction of the accused Aces EFI systems?
• The case will also involve a core question of component equivalence: does the internal architecture of the accused products contain structures that function as the claimed "cross-channel passageway and a vertical passageway" and the "fuel distribution ring," or is there a fundamental difference in their method of fuel delivery?
• A key factual question will be one of knowledge and intent: what evidence, such as the allegedly copied installation manuals, can Plaintiff present to establish that Defendant had pre-suit knowledge of the patents, which would be essential to proving the allegations of willful infringement?