Club Car LLC v. Teko Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Club Car, LLC (Delaware)
  • Defendant: Teko Inc. d/b/a TekoEV Inc. (Delaware) and Zhejiang Taotao Vehicles Co. Ltd. (China)
  • Plaintiff's Counsel: Womble Bond Dickinson (US) LLP
• Case Identification: 2:26-cv-00526, E.D. Tex., 06/30/2026
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant Teko Inc. maintains regular and established places of business within the district. For Defendant Zhejiang Taotao Vehicles Co. Ltd., a foreign entity, venue is alleged to be proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant's electric vehicles and an associated accessory clamp infringe two U.S. patents related to a convertible passenger seat/cargo bay and a system for mounting accessories to a vehicle.
• Technical Context: The technology relates to the design and functionality of personal utility vehicles, such as golf carts, focusing on modularity and accessory integration.
• Key Procedural History: The complaint alleges that Defendant Taotao was on notice of U.S. Patent No. 9,371,096 at least since June 13, 2025, due to a prior patent infringement suit filed by Club Car against Taotao's subsidiary, Denago, involving a substantially similar product. This prior litigation may be significant for allegations of willful infringement.

Case Timeline

Date	Event
2013-10-13	'096 Patent Priority Date
2016-06-21	'096 Patent Issue Date
2018-01-16	'795 Patent Priority Date
2020	Alleged launch year for Defendant Teko's operations
2025-06-13	Alleged notice date of '096 Patent to Defendant Taotao
2026-02-03	'795 Patent Issue Date
2026-06-30	Complaint Filing Date

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

U.S. Patent No. 12,539,795 - "PERSONAL TRANSPORTATION VEHICLE WITH PIVOTING SEAT AND CARGO BAY"

• Patent Identification: U.S. Patent No. 12,539,795, "PERSONAL TRANSPORTATION VEHICLE WITH PIVOTING SEAT AND CARGO BAY," issued February 3, 2026.

The Invention Explained

• Problem Addressed: The patent background notes that existing personal transport vehicles, like golf carts, have "various shortcomings" and implies a need for greater versatility in their configuration ʻ795 Patent, col. 1:23-29
• The Patented Solution: The invention describes a utility vehicle with a rear seat bottom that can pivot away from its normal seating position to form a vertical wall, thereby converting the passenger area into a cargo bay ʻ795 Patent, abstract In this configuration, the pivoted seat bottom and the existing seat back form two walls of the cargo area, with side rails forming the other two walls ʻ795 Patent, col. 2:43-49 ʻ795 Patent, FIG. 3
• Technical Importance: This design provides dual-use functionality, allowing a single vehicle to be easily converted between carrying additional passengers and hauling cargo, which enhances its utility.

Key Claims at a Glance

• The complaint asserts independent Claim 1 Compl. ¶29
• The essential elements of Claim 1 include:
  • A personal utility vehicle with a chassis, motive source, steering, and wheels.
  • A platform supported by the chassis.
  • A seat with a seat bottom and seat back, where the seat bottom is movable from a first passenger-seating position to a second position.
  • In the second position, the seat bottom and the platform define a portion of a cargo bay surface.
  • The platform includes a "movable portion bounded by an outer fixed portion positioned around the movable portion."

U.S. Patent No. 9,371,096 - "SYSTEM AND APPARATUS FOR UTILITY VEHICLE ACCESSORY MOUNTING"

• Patent Identification: U.S. Patent No. 9,371,096, "SYSTEM AND APPARATUS FOR UTILITY VEHICLE ACCESSORY MOUNTING," issued June 21, 2016.

The Invention Explained

• Problem Addressed: The patent background identifies a need for "further contributions" in the area of utility vehicles, suggesting a need for improved methods of securing cargo and accessories ʻ096 Patent, col. 1:24-27
• The Patented Solution: The patent discloses a system for mounting accessories to a utility vehicle's cargo bed. The system uses a specially designed side panel with a series of protrusions that form an "engagement interface" ʻ096 Patent, col. 3:1-12 A corresponding clamping device, featuring a plurality of "fingers," is designed to be inserted into this interface and actuated by a handle to securely lock an accessory in place ʻ096 Patent, abstract ʻ096 Patent, FIG. 3a
• Technical Importance: The invention provides a standardized, tool-less method for attaching and detaching accessories to a utility vehicle, offering more flexibility and a more secure attachment than generic straps or fasteners.

Key Claims at a Glance

• The complaint asserts independent Claim 11 Compl. ¶36
• The essential elements of Claim 11 include:
  • A clamping device for use in a cargo bed with protrusions forming an engagement interface.
  • The device comprises a handle, body, clamping mechanism with a plurality of fingers, and an interconnecting pull rod.
  • The clamping mechanism is inserted into the interface and actuated by the handle, causing the fingers to bear against the interface.
  • The fingers include a "first finger positioned above a second finger," with each finger having a specific geometry of arms, legs, and lips.
  • A specific geometric constraint: "the first leg and the second lip are substantially coplanar."

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are certain electric vehicles and an accessory clamp Compl. ¶13 The vehicles are identified as the "Turbo," "TurboLite," "Trophy Plus," and other similar products in the Teko EV line (collectively, the "Accused EVs") Compl. ¶11 The accessory is identified as the "Teko EV Clamp" Compl. ¶13

Functionality and Market Context

• The Accused EVs are described as "street-legal carts" that Teko assembles and sells Compl. ¶23 The complaint alleges these vehicles infringe the '795 Patent. The complaint provides an image showing the accused "Turbo" and "Turbolite" vehicles, which are personal transport vehicles similar in appearance to golf carts Compl. p. 5
• The Teko EV Clamp is an accessory that Teko assembles and sells Compl. ¶24 It is accused of infringing the '096 Patent, and the complaint alleges it is for use with the Accused EVs, which include an "attachment bar" with protrusions forming an engagement interface Compl. ¶54

IV. Analysis of Infringement Allegations

'795 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A personal utility vehicle comprising: a chassis having a motive source, a steering mechanism, and, a plurality of wheels; a platform supported by the chassis; and...	The Accused EVs are alleged to be personal utility vehicles (Compl. ¶31) comprising a chassis, motive source, steering mechanism, and wheels (Compl. ¶32), and a platform supported by the chassis (Compl. ¶33).	¶¶31-33	col. 2:10-17
a seat having a seat bottom and a seat back, wherein the seat bottom is movable with respect to the seat back, from a first position... to a second position where the seat bottom and the platform define a portion of a surface of a cargo bay...	The Accused EVs are alleged to have a seat with a movable seat bottom that pivots from a first seating position to a second position where the seat bottom and platform define a portion of a cargo bay surface.	¶34	col. 2:33-43
wherein the platform includes a movable portion bounded by an outer fixed portion positioned around the movable portion.	The Accused EVs are alleged to have a platform that includes a movable portion bounded by an outer fixed portion. The complaint alleges this element is met, referencing an external exhibit not included with the complaint.	¶34	col. 4:16-20

• Identified Points of Contention:
  • Technical Question: The final limitation of Claim 1 requires a very specific platform structure: a "movable portion bounded by an outer fixed portion." The complaint asserts this element is met but provides no specific factual allegations or visual evidence detailing how the accused platform is constructed. A central question will be whether discovery reveals that the Accused EVs contain this specific platform structure, as its absence could undermine the allegation of literal infringement.

'096 Patent Infringement Allegations

The complaint includes multiple photographs of the accused "Teko EV Clamp," showing it from different angles both uninstalled and attached to a vehicle Compl. p. 6 These visuals will be central to comparing the accused product's geometry against the claim limitations.

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A clamping device for use in a cargo bed having a plurality of protrusions forming a clamping device engagement interface adapted to align with the clamping device, comprising:	The Teko EV Clamp is alleged to be a device for use in a cargo bed with protrusions forming an engagement interface.	¶38	col. 2:38-44
a handle, a body, a clamping mechanism with a plurality of fingers, and a pull rod interconnecting the handle, body, and clamping mechanism;	The Teko EV Clamp is alleged to comprise a handle, body, clamping mechanism with fingers, and a pull rod interconnecting them.	¶39	col. 4:54-57
wherein the clamping mechanism is sized and shaped to be inserted into the clamping device engagement interface, and once within... the handle is actuated such that the plurality of fingers bears against the device engagement interface...	The Teko EV Clamp is alleged to have a clamping mechanism that is inserted into the interface and actuated by a handle to make the fingers bear against it.	¶40	col. 4:34-40
wherein the clamping mechanism further includes a back side and the plurality of fingers includes a first finger positioned above a second finger;	The Teko EV Clamp is alleged to have a clamping mechanism with a back side and a first finger positioned above a second finger.	¶41	col. 4:17-18
wherein the first finger comprises a first arm..., a first leg..., and a first lip...; wherein the second finger comprises a second arm..., a second lip...;	The first and second fingers of the Teko EV Clamp are alleged to comprise the specific structures of arms, legs, and lips as recited in the claim.	¶42; ¶43	col. 4:21-33
wherein the first leg and the second lip are substantially coplanar.	The Teko EV Clamp is alleged to comprise a first leg and second lip that are "substantially coplanar."	¶44	col. 9:16-17

• Identified Points of Contention:
  • Scope & Technical Question: Claim 11 requires that the "first leg" and the "second lip" of the clamping fingers be "substantially coplanar." This is a precise geometric relationship. The infringement analysis may turn on the construction of "substantially coplanar" and a factual determination of whether the accused clamp's components meet that definition. The patent's own figures do not appear to explicitly illustrate this coplanar relationship, which may suggest this limitation will be a significant point of dispute.

V. Key Claim Terms for Construction

For the '795 Patent

• The Term: "a movable portion bounded by an outer fixed portion positioned around the movable portion"
• Context and Importance: This term defines a specific structure within the vehicle's platform. Proving infringement of Claim 1 requires showing that the accused vehicle's platform has this exact structure. The construction of this phrase will determine whether a simple cargo lid suffices or if a more complex, framed structure is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term uses general language like "a movable portion," which may support an argument that it is not limited to any single embodiment.
  • Evidence for a Narrower Interpretation: The patent specification describes a specific embodiment of this feature, which includes a release handle (140) and hinges (142) for accessing a lower cargo region ʻ795 Patent, col. 4:20-29 ʻ795 Patent, FIG. 4 A party could argue that the term should be interpreted in light of this more detailed embodiment.

For the '096 Patent

• The Term: "substantially coplanar"
• Context and Importance: This term describes the geometric relationship between the "first leg" of the upper clamping finger and the "second lip" of the lower clamping finger. The viability of the infringement claim may depend entirely on whether the accused clamp exhibits this specific alignment. Practitioners may focus on this term because a strict interpretation could be dispositive if the accused product deviates from a perfectly planar alignment.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The word "substantially" inherently allows for some degree of tolerance and deviation from perfect mathematical planarity. A party might argue it means "generally in the same plane" to achieve the clamping function.
  • Evidence for a Narrower Interpretation: A party could argue that, in the context of the mechanical-locking function described, "substantially coplanar" requires a precise alignment necessary for the device to bear against the engagement interface as intended. The specification describes how the "second lip 222... protrudes downward... substantially coplanar to the surface 240 and the surface 242" ʻ096 Patent, col. 3:32-35, which describes a relationship to the vehicle wall, not to another part of the clamp. This may raise questions about the intended meaning of the claim term, which describes a different relationship.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced and contributory infringement of the '096 Patent Compl. ¶¶54-57 Inducement is based on allegations that Defendants "actively encourage their customers" to use the Teko EV Clamp with the Accused EVs in an infringing manner Compl. ¶54 Contributory infringement is based on allegations that the Teko EV Clamp is "specifically adapted for use in a manner that infringes" and is not a "staple article of commerce suitable for substantial noninfringing use" Compl. ¶57
• Willful Infringement: Willfulness is alleged for both patents. For the '795 Patent, knowledge is alleged "at least as early as the filing" of the complaint Compl. ¶49 For the '096 Patent, pre-suit knowledge is alleged based on Defendants' "monitoring of Club Car's patent portfolio" and, more specifically, a prior infringement suit against a subsidiary regarding the same patent, which allegedly put Defendant Taotao on notice as of June 13, 2025 Compl. ¶27 Compl. ¶59

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

1. A Structural Fact Question: For the '795 patent, a primary issue will be evidentiary. Does the platform of the accused "Teko" vehicles incorporate the claimed "movable portion bounded by an outer fixed portion"? The complaint's conclusory allegation on this point suggests this will be a key factual battleground.
2. A Definitional and Technical Question: For the '096 patent, the case may turn on the construction and application of the term "substantially coplanar." The central questions are: what degree of geometric precision is required by this term, and does the physical structure of the accused "Teko EV Clamp" meet that standard?
3. The Question of Willfulness: Given the allegation of a prior lawsuit against a subsidiary involving the '096 patent, a significant question will be whether any infringement of that patent, particularly after June 13, 2025, was willful, which could expose Defendants to enhanced damages.