Cambria Co LLC v. LX Hausys Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cambria Company LLC (Minnesota)
  • Defendant: LX Hausys, Ltd. (Korea); LX Hausys America, Inc. (New Jersey)
  • Plaintiff's Counsel: Winston Strawn LLP
• Case Identification: 4:26-cv-01032, E.D. Tex., 08/07/2026
• Venue Allegations: Venue is alleged to be proper for LX HAUSYS, LTD. as a foreign entity. For LX HAUSYS AMERICA, INC., venue is based on its alleged regular and established place of business within the district-a warehouse and showroom in Flower Mound, Texas-and acts of infringement committed therein.
• Core Dispute: Plaintiff alleges that Defendant's "Viatera" brand of engineered quartz slabs infringes two utility patents related to methods for creating veined patterns and one design patent for a specific slab appearance.
• Technical Context: The technology concerns the manufacture of engineered stone slabs with complex, through-body veining designed to emulate the aesthetic of high-end natural stone like marble.
• Key Procedural History: The complaint alleges Defendants had pre-suit knowledge of the patents. Awareness of the '303 and '626 utility patents is alleged since at least August 2022 from related litigation and from a direct notice letter in March 2026. Awareness of the D'336 design patent is alleged since at least February 2026, as it was cited on the face of one of Defendants' own issued design patents. The complaint also references a U.S. International Trade Commission (ITC) proceeding where Defendant LX allegedly admitted its "Macaubas Bianco" product bears "striking visual similarity" to the Cambria product embodying the D'336 patent.

Case Timeline

Date	Event
2014-08-19	Priority Date for '303 and '626 Patents
2015	Plaintiff Cambria introduces Brittanicca and Ella designs
2015-08-03	D'336 Design Patent Application Filing Date
2017-02-28	D'336 Patent Issue Date
2017-08-01	'303 Patent Issue Date
2019-05-28	'626 Patent Issue Date
2022-08-02	Alleged LXHA awareness of '303 and '626 Patents from prior litigation
2025-10-30	Accused Viatera Safety Data Sheet revised
2026-01-15	Accused Viatera Health Product Declaration published
2026	Launch of Accused Products (e.g., Ocean Ridge, Solea, Perla Verde)
2026-02	Alleged LX awareness of D'336 Patent from its own patent citation
2026-02-16	LXHL agrees to waive service in a prior federal lawsuit
2026-03-05	Cambria sends notice letter to LX regarding '303 and '626 Patents
2026-08-07	Complaint Filing Date

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

U.S. Patent No. 9,718,303 - "Processed Slabs, and Systems and Methods Related Thereto," issued August 1, 2017 ('303 Patent)

The Invention Explained

• Problem Addressed: The patent's background describes the high cost and natural pattern limitations of quarried stone slabs (e.g., marble, granite), while noting that existing engineered stone often fails to replicate the complex, textured look of these natural materials ʼ303 Patent, col. 1:29-44
• The Patented Solution: The invention is a system and method for creating engineered slabs with repeatable, complex veining that mimics natural stone ʼ303 Patent, abstract This is achieved by vertically dispensing different pigmented "particulate mineral mixes" in successive layers into a vertically-oriented mold, creating a predefined pattern ʼ303 Patent, col. 2:50-65 The mold is then shifted to a horizontal orientation for compression and curing, resulting in a slab with veins that extend through its entire thickness ʼ303 Patent, col. 4:45-49
• Technical Importance: This manufacturing process enabled the mass production of engineered quartz slabs with consistent and aesthetically complex marble-like veining, a significant commercial and design advancement over prior engineered stone products Compl. ¶¶15-16

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶36
• The essential elements of claim 1 include:
  • A processed slab with a major surface of at least 2x6 feet.
  • The surface has a first pigmented vein extending lengthwise from edge-to-edge that separates second and third lengthwise pigmented veins on opposing sides.
  • The first vein is defined by a first particulate mineral mix that forms a "substantially unmixed layer" with respect to a second particulate mineral mix defining the second vein.
  • The first and second veins have a thickness equal to and parallel to the slab thickness.
  • The second particulate mineral mix is different from the first. Compl. ¶37

U.S. Patent No. 10,300,626 - "Synthetic Molded Slabs, and Systems and Methods Related Thereto," issued May 28, 2019 ('626 Patent)

The Invention Explained

• Problem Addressed: Similar to the '303 Patent, the '626 Patent addresses the challenge of creating man-made slabs with the desirable aesthetic properties of expensive quarried stone ʼ626 Patent, col. 1:31-48
• The Patented Solution: The '626 Patent claims a processed slab featuring a "substantially bowed pigmented vein" that runs lengthwise ʼ626 Patent, col. 12:49-51 The invention is defined by the spatial relationship of the material compositions: a first particulate mineral mix defines the bowed vein and occupies the entire slab thickness in that region, while a second mix occupies the entire thickness in an adjacent region. Crucially, the first mix is "absent" from the second region, and the second mix is "absent" from the first, creating distinct, through-body veining ʼ626 Patent, col. 12:55-65 '626 Patent, col. 13:1-3
• Technical Importance: This technology provides a specific method for producing engineered slabs with distinct, flowing, through-body veins, further enhancing the realism and design possibilities compared to simpler engineered stone products Compl. ¶¶15-16

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶49
• The essential elements of claim 1 include:
  • A processed slab of quartz material with a major surface of at least 2x6 feet.
  • The surface has a first "substantially bowed pigmented vein" extending lengthwise from edge-to-edge, with a vein thickness equal to and parallel to the slab thickness.
  • The slab comprises at least two different particulate mineral mixes distributed in successive layers.
  • A first mix defines the bowed vein and occupies the entire slab thickness in a first region.
  • A second mix occupies the entire slab thickness in a second region.
  • The first mix is "absent from the second region" and the second mix is "absent from the first region." Compl. ¶50

U.S. Design Patent No. D780,336 - "Slab," issued February 28, 2017 (D'336 Patent)

• Technology Synopsis: The D'336 Patent claims the ornamental design for a slab D'336 Patent, claim The design, shown in the patent's sole figure, consists of a light-colored surface with a series of delicate, wavy, and generally parallel dark lines that create an appearance similar to Cambria's "Ella" product Compl. ¶17 D'336 Patent, FIGURE
• Asserted Claims: The complaint asserts infringement of the design patent's single claim for the ornamental design as shown Compl. ¶¶61-63
• Accused Features: The complaint alleges that the overall visual appearance of the "Macaubas Bianco" accused product infringes the D'336 patent's design Compl. ¶64

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are processed quartz slabs sold under the "Viatera" brand name, including the "Ocean Ridge," "Splendor," "Solea," "Cloud Ridge," "Perla Verde," and "Macaubas Bianco" product lines Compl. ¶25

Functionality and Market Context

The accused products are engineered surfaces used for applications such as countertops, floor tiles, and vanities Compl. ¶12 They are manufactured from quartz, resins, and pigments to create durable slabs with decorative veining Compl. ¶41 Compl. ¶51 The complaint alleges that these products were developed to compete with and copy Plaintiff's commercially successful designs Compl. ¶24 Marketing materials for the accused products describe their aesthetic features in detail; for example, the "Ocean Ridge" product is described as having "[f]ine navy veins rippl[ing] alongside soft, shadowy waves" Compl. p. 12 A "Dimensions" table in Defendant's marketing materials indicates the slabs are sold in large formats, such as 63" x 130" Compl. p. 12

IV. Analysis of Infringement Allegations

'303 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A processed slab, comprising: a major surface at least 2 feet wide by at least 6 feet long and extending perpendicularly to a slab thickness...	The Accused Products are marketed as slabs with dimensions such as 63 inches (5.25 ft) by 126 inches (10.5 ft), exceeding the claim's minimum dimensions. The complaint provides a "Dimensions" table from Defendant's materials. Compl. p. 12	¶38	col. 4:36-41
...the major surface having at least a first pigmented vein extending generally lengthwise from edge-to-edge that separates at least second and third pigmented veins extending generally lengthwise and positioned on opposing sides of the first pigmented vein...	On information and belief, the complaint alleges the Accused Products have this specific arrangement of a central vein separating two side veins, supported by product imagery.	¶39	col. 2:2-7
...wherein the first pigmented vein is defined by a first particulate mineral mix and at least the first particulate mineral mix is separated from and forms a substantially unmixed layer with respect to a second particulate mineral mix defining the second pigmented vein...	The complaint alleges on information and belief that the veins in the Accused Products are formed from different particulate mineral mixes that create a substantially unmixed layer.	¶40	col. 5:1-8
...such that each of the first and second pigmented veins has a vein thickness equal to and parallel to the slab thickness...	The complaint alleges the veins extend through the full thickness of the slab. This is supported by photographs showing the vein pattern visible on the edge of a sample of the "Viatera Ocean Ridge" product. Compl. p. 15	¶40	col. 4:45-49
...the second particulate mineral mix being different than the first particulate mineral mix.	The complaint cites Defendant's own Safety Data Sheets and Health Product Declarations, which list different material components (e.g., Quartz, pigmented polyester), as evidence that the veins are composed of different mineral mixes.	¶41	col. 5:15-20

'626 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A processed slab comprising a quartz material, comprising: a major surface at least 2 feet wide by at least 6 feet long...	The Accused Products are alleged to be composed of 87-93% quartz and are sold in dimensions (e.g., 63" x 130") that meet the claim's requirements.	¶51; ¶52	col. 12:45-48
...the major surface having a first substantially bowed pigmented vein that extends generally lengthwise from edge-to-edge...	The complaint alleges the Accused Products feature such veins and provides product images showing long, curving, or "bowed" patterns.	¶53	col. 14:7-12
...wherein the first particulate mineral mix occupies the entire slab thickness at a first region... and a second of the two different particulate mineral mixes occupies the entire slab thickness at a second region...	It is alleged on information and belief that the veins are formed by different mixes that each occupy the full slab thickness in their respective regions. The complaint includes photographs of the edge of the "Viatera Ocean Ridge" product to support this allegation. Compl. p. 28	¶54	col. 14:15-24
...the first particulate mineral mix being absent from the second region and the second particulate mineral mix being absent from the first region.	The complaint alleges on information and belief that the different mineral mixes are spatially distinct and mutually exclusive in their respective regions, as required by the claim.	¶54	col. 14:20-24

• Identified Points of Contention:
  • Evidentiary Questions: For both the '303 and '626 patents, the allegations regarding the internal composition, layering, and separation of "particulate mineral mixes" are made "on information and belief." A central factual dispute will be whether discovery and expert analysis can prove that the accused manufacturing process results in a "substantially unmixed layer" ('303) or regions where one mix is completely "absent" from another ('626).
  • Scope Questions: The infringement analysis for the '303 Patent will raise the question of whether the complex patterns in the accused products meet the specific geometric arrangement of a central vein that "separates" two side veins. For the '626 patent, a key question will be whether the accused products' veining patterns can be characterized as "substantially bowed," a term open to construction.

V. Key Claim Terms for Construction

• The Term: "substantially unmixed layer" ('303 Patent, Claim 1)

  • Context and Importance: This term is critical for defining the boundary between the different material mixes that form the veins. The degree of mixing allowed at the interface between vein and background will be a focal point of the infringement analysis.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes a process of pouring successive layers of particulate matter, which is then vibrated and compacted, suggesting that some incidental mixing is inherent to the process. The modifier "substantially" may support an interpretation that allows for a transitional or slightly mixed boundary rather than a perfectly sharp one ʼ303 Patent, col. 5:1-8 '303 Patent, col. 7:30-34
  • Intrinsic Evidence for a Narrower Interpretation: The patent figures depict distinct, sharply-defined layers, which may support an argument for a more limited degree of mixing ʼ303 Patent, FIG. 1A A defendant may argue that "unmixed layer" requires a clear, demonstrable separation between the compositions.

• The Term: "absent from the... region" ('626 Patent, Claim 1)

  • Context and Importance: This negative limitation sets a potentially high bar for infringement, as it requires proving the complete absence of one material mix in a region occupied by another. Practitioners may focus on this term because proving a negative is an evidentiary challenge.
  • Intrinsic Evidence for a Broader Interpretation: A plaintiff may argue that in the context of manufacturing with particulate materials, "absent" should be understood to mean not present in any meaningful or functional amount, allowing for trace or de minimis particles. The patent's goal of emulating natural stone, which itself has impurities, might be cited to support a less-than-absolute interpretation (ʼ626 Patent, col. 1:31-34).
  • Intrinsic Evidence for a Narrower Interpretation: The plain meaning of "absent" is "not present." A defendant will likely argue that the claim requires a complete lack of the first mineral mix in the second region, and vice versa. The patent does not explicitly define or qualify the term to suggest a threshold-based meaning (ʼ626 Patent, col. 13:1-3).

VI. Other Allegations

• Indirect Infringement: The complaint alleges Defendants induce infringement of the '303 and '626 patents by actively promoting, marketing, and distributing the Accused Products through their website and sales channels, which allegedly encourages others to make, use, import, and sell the infringing slabs Compl. ¶¶42-43 Compl. ¶¶55-56 Similar allegations are made for the D'336 patent Compl. ¶¶66-67
• Willful Infringement: Willfulness is alleged for all three asserted patents based on both pre-suit and post-suit knowledge.
  • For the '303 and '626 patents, pre-suit knowledge is alleged based on Defendants' involvement in prior litigation referencing the patents (dating to August 2022) and a specific notice letter sent by Cambria (March 2026) Compl. ¶30 Compl. ¶31
  • For the D'336 patent, pre-suit knowledge is alleged based on Defendants' own design patent, which issued in February 2026 and cited the D'336 patent on its face Compl. ¶32

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

1. A central evidentiary issue will be one of internal composition: Can the Plaintiff prove that the accused slabs' internal structures meet the specific and stringent limitations of the utility patent claims? This will require discovery into the defendants' manufacturing process and expert analysis to determine if the products contain a "substantially unmixed layer" ('303 Patent) or demonstrate the complete "absence" of one material mix in another's region ('626 Patent).
2. A key legal question will be one of definitional scope: How broadly will the court construe terms such as "substantially bowed" ('626 Patent) and the geometric requirement that a central vein "separates" two opposing veins ('303 Patent)? The infringement outcome for several of the accused product lines will likely depend on whether their naturalistic, irregular patterns fall within the court's interpretation of these phrases.
3. For the D'336 design patent, the case may turn on the weight given to prior admissions: How will the court treat the Defendant's alleged admission in a separate ITC proceeding that its "Macaubas Bianco" product bears "striking visual similarity" to the patented design? This admission could significantly streamline the "ordinary observer" test that governs design patent infringement.