Blue Box Air Inc v. Biocoil Pro LP

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Blue Box Air, Inc. (Delaware)
  • Defendant: BioCoil Pro, LP (Texas); Ross Lampe (Texas)
  • Plaintiff's Counsel: Foley & Lardner LLP
• Case Identification: 4:26-cv-00498, N.D. Tex., 04/22/2026
• Venue Allegations: Venue is alleged to be proper in the Northern District of Texas because the Defendants reside in the district and Defendant BioCoil Pro, LP maintains its principal place of business there.
• Core Dispute: Plaintiff alleges that Defendants' HVAC coil cleaning products and services infringe a patent relating to a method of using a cleaning foam that is applied to and passed through HVAC coils by the system's own airflow.
• Technical Context: The technology addresses the deep cleaning of heat-transfer coils in large-scale heating, ventilation, and air conditioning (HVAC) systems to improve energy efficiency and indoor air quality.
• Key Procedural History: The complaint alleges that Defendant Ross Lampe is a former employee of Plaintiff Blue Box Air, Inc. and that he had access to Plaintiff's confidential information and knowledge of its patented technology prior to founding the competing entity, BioCoil Pro, LP.

Case Timeline

Date	Event
2015-09-29	'875 Patent Priority Date
2016-09-29	'875 Patent Application Filing Date
2019-11-19	'875 Patent Issue Date
2020-04-11	Plaintiff allegedly began public notice of patented technology
2022-02-11	Date Plaintiff alleges Defendant Lampe had knowledge of the '875 Patent
2025-03-01	Alleged launch date (no later than) of Accused Product
2026-04-22	Complaint Filing Date

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

U.S. Patent No. 10,480,875 - "Method and system for cleaning heating, ventilation and air conditioning systems" (Issued Nov. 19, 2019)

The Invention Explained

• Problem Addressed: The patent's background describes the difficulty in cleaning modern HVAC systems, whose heat-transfer coils are often deep and densely packed with fins Compl. ¶10 '875 Patent, col. 2:3-6 This density causes coils to accumulate performance-degrading contaminants like dirt and microbial biofilms deep within the structure, where conventional cleaning methods like pressure washing or steam are ineffective and potentially damaging Compl. ¶10 '875 Patent, col. 2:30-44
• The Patented Solution: The invention is a method for deep cleaning these coils using a specialized cleaning foam Compl. ¶13 The foam, containing agents such as enzymes, is applied at low pressure to the front (air intake side) of the coils. Crucially, the HVAC system's own fan is used to create airflow that draws or pushes the foam completely through the coil structure, allowing it to break down and carry away debris from deep within the coils before exiting the back side Compl. ¶14 '875 Patent, col. 7:50-60 This process can be performed while the HVAC system remains operational '875 Patent, abstract
• Technical Importance: The patented method allows for the deep, restorative cleaning of previously inaccessible internal coil surfaces without requiring a full system shutdown or risking damage from high-pressure liquids. Compl. ¶11 '875 Patent, col. 3:31-37

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 4 Compl. ¶28
• The essential elements of independent claim 4 are:
  • A method for cleaning an HVAC system.
  • Applying a cleaning foam that contains enzymes to the front side of the heat-transfer coils.
  • During the HVAC system's operation, causing or allowing the foam to pass through the spaces within the coils.
  • The foam breaking down and removing dirt or debris, with enzymes assisting in breaking down any biofilm present.
  • The foam carrying the removed debris away and exiting the back side of the heat exchange system.

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the "BioCoil HOME" and "BioCoil Pro" products and associated HVAC cleaning services Compl. ¶26

Functionality and Market Context

• The complaint alleges the Accused Product is a "beneficial bacterial coil cleaner" marketed as a "thick foam powered by biology" Compl. ¶7 Compl. ¶30 It is allegedly applied to HVAC coils to enhance performance and improve air quality Compl. ¶25 The complaint asserts the product contains "probiotics with enzymes that break down biofilm" and is designed to be used with the HVAC unit's own airflow to "help distribute the product evenly across the coil surfaces and reach deeper areas" Compl. ¶31 Compl. ¶33 The complaint positions the Accused Product as a "copycat product" competing directly with the Plaintiff's patented service Compl. ¶24 Compl. ¶62

IV. Analysis of Infringement Allegations

'875 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
applying a cleaning foam containing enzymes that break down biofilm into a plurality of spaces between or within one or more heat-transfer coils ... wherein the cleaning foam is applied to the front side of the heat exchange system;	The Accused Product is a foam applied to coil surfaces and is alleged to contain "probiotics with enzymes that break down biofilm." The complaint includes a screenshot from Defendants' brochure showing instructions to "Spray BioCoil Home evenly onto the coil surfaces."	¶29; ¶31	col. 13:35-43
during operation of the HVAC system, causing or allowing the cleaning foam to pass through the plurality of spaces;	Defendants' instructions allegedly state to "use mechanical agitation such as the unit's airflow to help distribute the product evenly across the coil surfaces and reach deeper areas." A visual from Defendants' brochure supporting this is included in the complaint.	¶33; ¶35	col. 13:44-46
the cleaning foam breaking down and removing dirt or debris from surfaces adjacent to the plurality of spaces, the enzymes assisting in breaking down biofilm if present;	The Accused Product is described as using enzymes produced by probiotics to "break down the organic matter such as skin cells, oils, and residue trapped in dust that biofilms rely on to grow." A screenshot of Defendants' marketing materials is provided to support this allegation.	¶36	col. 13:47-51
the cleaning foam carrying away the removed dirt or debris, and biofilm if present, from the plurality of spaces and exiting the back side of the heat exchange system with the removed debris.	The Accused Product is allegedly designed as a "leave in place coil cleaner," where the running HVAC system pushes the foam and removed debris through the coils, with "No rinsing is needed." A video still shows the product being applied with the instruction to "walk away."	¶37; ¶14	col. 13:52-56

• Identified Points of Contention:
  • Scope Questions: Claim 4 recites causing the foam to pass through the coils "during operation of the HVAC system." The complaint cites Defendants' instructions, which state the product can be applied "while your HVAC unit is running (optional)" Compl. ¶29 This raises the question of whether a process step described as "optional" in an accused infringer's instructions can satisfy a mandatory limitation in a patent claim.
  • Technical Questions: What evidence demonstrates that the "probiotics" and "beneficial bacteria" in the Accused Product perform the specific function of the claimed "enzymes that break down biofilm"? The complaint alleges this connection through Defendants' marketing materials Compl. ¶31 Compl. ¶36, but the precise biochemical mechanism and its equivalence to the claimed function may become a point of technical dispute.

V. Key Claim Terms for Construction

• The Term: "during operation of the HVAC system"

• Context and Importance: This phrase appears in the "causing or allowing" step of claim 4 and is central to the patent's described advantage of not requiring a system shutdown. Its interpretation is critical because the Defendants' instructions allegedly describe this step as "optional" Compl. ¶29 Practitioners may focus on this term because the infringement analysis for both direct and induced infringement could hinge on whether an optional step meets this limitation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent specification repeatedly emphasizes harnessing the HVAC system's own blower to either "draw or push" the foam through the coils, suggesting that any method that leverages the system's fan for this purpose falls within the invention's scope '875 Patent, col. 7:5-8 '875 Patent, col. 7:50-54
  • Evidence for a Narrower Interpretation: The detailed description consistently frames the use of system airflow as an integral, active part of the inventive process '875 Patent, col. 3:9-16 A defendant might argue this implies the method must be dependent on the system's operation, not merely compatible with it, and that an "optional" use does not meet this requirement.

• The Term: "cleaning foam"

• Context and Importance: The physical nature of the foam is fundamental to how the invention works, enabling it to cling to surfaces, carry debris, and be propelled by air. The complaint alleges the accused product is a "thick foam" Compl. ¶30, making the definition of "foam" relevant to the infringement analysis.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides a general composition of "water, air, surfactant, and enzymes and/or chemical(s)" '875 Patent, col. 5:28-30, which could be interpreted to encompass a wide variety of foam formulations.
  • Evidence for a Narrower Interpretation: The specification describes creating different foam consistencies, from "very thick" to "very thin, or soupy" '875 Patent, col. 8:6-10, and notes that a thick foam "clings to metal surfaces" '875 Patent, col. 7:35-37 A party could argue that the term should be limited to foams possessing the specific physical properties (e.g., viscosity, bubble structure, residence time) described as necessary to achieve the invention's results.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b). It pleads that Defendants provide instructional materials, including brochures, websites, and videos, that allegedly direct and encourage end-users to perform the patented method, such as by using the HVAC unit's airflow to distribute the foam Compl. ¶¶39, 41, 47
• Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. The basis for this allegation is that Defendant Ross Lampe, the founder of BioCoil, is a former Blue Box employee who allegedly knew of the '875 Patent and its associated technology since at least February 2022 Compl. ¶¶21, 44, 60 The complaint further supports this allegation by claiming Defendants copied Plaintiff's marketing language, such as using the terms "penetrate" and "deep in the coils" Compl. ¶63

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

• A core issue will be one of definitional scope: can the claim limitation "during operation of the HVAC system" be met when the accused product's instructions describe the use of the system's airflow as "optional"? This question will likely be central to both direct and induced infringement arguments.
• A second pivotal question will relate to intent and evidence of copying: given Defendant Lampe's alleged prior employment with the Plaintiff, to what degree will evidence of his knowledge of the patent and similarities between the products' marketing language be used to establish the requisite intent for willful infringement?
• A key evidentiary question will be one of functional equivalence: does the accused product's use of "probiotics" and "beneficial bacteria" perform the same function in the same way to achieve the same result as the claimed "enzymes that break down biofilm," or is there a fundamental mismatch in technical operation that a defendant could leverage?