I4f Licensing NV v. Decno Group Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: i4F Licensing N.V. (Belgium) and Quickstyle Industries Inc. (Canada)
  • Defendant: Decno Group Ltd. (Wyoming); SHIJIAZHUANG DECNO, DECORATION MATERIAL CO., LTD. (China); and HEBEI DECNO HOME FURNISHING TECHNOLOGY GROUP CO., LTD. (China)
  • Plaintiff's Counsel: Hathaway & Kunz, LLP; THE WEBB LAW FIRM
• Case Identification: 1:26-cv-00111, D. Wyo., 03/24/2026
• Venue Allegations: Venue is alleged to be proper in the District of Wyoming because Defendant DECNO GROUP LTD. is a Wyoming corporation that resides in the district. The foreign-domiciled Chinese Defendants are alleged to be subject to personal jurisdiction in the district.
• Core Dispute: Plaintiffs allege that Defendants' stone plastic composite (SPC) flooring products infringe three U.S. patents related to flooring tiles featuring imitation grout lines.
• Technical Context: The technology concerns synthetic flooring tiles, specifically those made from stone plastic composite, which are designed to mimic the appearance of traditional ceramic or stone tiles without requiring manual grouting during installation.
• Key Procedural History: The complaint alleges that Plaintiff Quickstyle sent a pre-suit demand letter to Defendant Decno Group identifying the Asserted Patents and requesting that Defendants cease and desist their allegedly infringing activities. This allegation may be used to support claims of willful infringement.

Case Timeline

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

U.S. Patent No. 11,149,442 - "Tile with Imitation Grout Line"

• Patent Identification: U.S. Patent No. 11,149,442, entitled "Tile with Imitation Grout Line," issued October 19, 2021 (the "'442 Patent").

The Invention Explained

• Problem Addressed: The patent addresses the time-consuming, tedious, and costly process of installing traditional stone or ceramic tiles, which requires the use of spacers and the manual application of grout to create grout lines between tiles '442 Patent, col. 2:1-10 Existing imitation flooring products are described as often lacking realism, for instance by using flat, shaded lines to give an impression of depth '442 Patent, col. 2:29-35
• The Patented Solution: The invention is a multi-layered flooring tile, typically with a rigid core layer, that features a pre-fabricated, imitation grout line. This is achieved during the manufacturing process by removing a portion of the tile's top section along one or more sides to create an "exposed portion" '442 Patent, abstract This exposed portion is structured and textured to closely resemble the look and feel of an actual grout line, eliminating the need for manual grouting during installation '442 Patent, col. 4:1-12 '442 Patent, FIG. 1
• Technical Importance: This approach aims to combine the aesthetic appeal of traditional grouted tile with the installation efficiency of modern "click-lock" or panel flooring systems '442 Patent, col. 1:47-53

Key Claims at a Glance

• The complaint asserts dependent claims 7-9, 13, 14, 16, 17, 19, and 20, which depend from independent claim 1 Compl. ¶33 The analysis focuses on claim 7 as representative.
• Claim 7 (incorporating Claim 1):
  • A tile comprising:
  • a top section at least partially defining a top surface;
  • a rigid core layer joined to the top section;
  • a plurality of sides at least partially defined by the core layer;
  • at least one exposed portion configured to represent a grout line, disposed along at least one of the plurality of sides;
  • wherein the exposed portion is disposed within and exposes at least a portion of the top section; and
  • wherein the rigid core layer comprises a stone plastic composite material comprising polyvinyl chloride (PVC) in an amount between about 20% to 30%, calcium powder or stone dust in an amount between about 70% to 80%, and a chemical agent in an amount between about 0.5% to 5%.

U.S. Patent No. 10,132,088 - "Stone Plastic Composite (SPC) Tile with Imitation Grout Line"

• Patent Identification: U.S. Patent No. 10,132,088, entitled "Stone Plastic Composite (SPC) Tile with Imitation Grout Line," issued November 20, 2018 (the "'088 Patent").

The Invention Explained

• Problem Addressed: The patent identifies the labor and cost associated with installing traditional tile and creating grout lines '088 Patent, col. 1:56-61 It also notes that known imitation flooring products with interlocking mechanisms do not offer a structure that represents or resembles a real grout line '088 Patent, col. 2:10-16
• The Patented Solution: The patented solution is a tile with a top section and a rigid "stone plastic composite" (SPC) core layer of a specified density '088 Patent, claim 1 During manufacturing, a tool removes a portion of the tile's surface along an edge to create a textured "exposed portion" that simulates a grout line '088 Patent, col. 4:10-20 This exposed portion is defined within and exposes at least a portion of the core layer itself, which is a distinguishing feature of certain claims '088 Patent, claim 1 '088 Patent, FIG. 7-B
• Technical Importance: The invention provides a synthetic tile that is durable due to its SPC core while offering a realistic, three-dimensional imitation grout line, aiming to improve on prior imitation flooring that used purely optical effects '088 Patent, col. 2:16-20

Key Claims at a Glance

• The complaint asserts claims 1-3, 5-8, 12, 14, and 16 Compl. ¶33 Independent claims 1 and 12 are asserted. The analysis focuses on claim 1.
• Independent Claim 1:
  • A tile comprising:
  • a top section at least partially defining a top surface;
  • a rigid core layer joined to the top section, comprising a stone plastic composite (SPC) material with a density of about 1,500 kg/m³ to about 2,000 kg/m³;
  • a plurality of sides at least partially defined by the core layer;
  • at least one exposed portion comprising a textured surface structured to represent a grout line, disposed along one of the plurality of sides; and
  • the exposed portion is defined within and exposes at least a portion of the core layer.
• The complaint also reserves the right to assert dependent claims Compl. ¶33

U.S. Patent No. 12,392,139 - "Tile with Imitation Grout Line"

• Patent Identification: U.S. Patent No. 12,392,139, entitled "Tile with Imitation Grout Line," issued August 19, 2025 (the "'139 Patent").

Technology Synopsis

This patent describes a flooring tile with a multi-layered structure, including a top section and a rigid core layer, designed to imitate a real tile with a grout line Compl. ¶73 Compl. ¶74 A key technical aspect highlighted in the patent and the complaint is the relationship between the densities of the core layer and the top section, wherein the core layer's density is greater than that of the top section Compl. ¶75

Asserted Claims

Claims 1, 2, and 5-8 Compl. ¶33 Independent claim 1 is asserted.

Accused Features

The complaint alleges that the Accused Products' multi-layered construction, including a rigid SPC core layer and a PVC top section, infringes the '139 Patent Compl. ¶73 Specific infringement allegations relate to the product's structure and the relative densities of its core and top layers Compl. ¶73 Compl. ¶75

III. The Accused Instrumentality

Product Identification

• Defendants' stone plastic composite (SPC) flooring products sold under the brand names "Unigrout", "Grout Tech", and "Grout Tech Plus" (the "Accused Products") Compl. ¶19

Functionality and Market Context

• The complaint alleges the Accused Products are flooring tiles or planks with a multi-layered design, including a top section with a decorative polyvinyl chloride (PVC) layer and a rigid SPC core layer Compl. ¶27 A key feature is that a portion of the top layer is allegedly removed along the sides (and for some products, down the middle) to expose underlying layers, creating a textured feature that represents a grout line Compl. ¶27 Compl. ¶37 The products are also alleged to include "click-lock locking mechanisms" for installation Compl. ¶32 The complaint includes a description of a visual representation of the structure of the Accused Products, said to demonstrate a UV layer, a transparent PVC wear layer, a PVC decorative layer, and the SPC core layer Compl. ¶31
• Plaintiffs allege that Defendants manufacture, import, and sell these products in the United States, and that the U.S. is Defendants' largest market for such products Compl. ¶17 Compl. ¶18 Compl. ¶19

IV. Analysis of Infringement Allegations

'442 Patent Infringement Allegations

• Identified Points of Contention:
  • Factual Question: A primary evidentiary question will concern the specific material composition of the Accused Products' core layer. The infringement analysis for claim 7 will depend on whether the percentages of PVC, calcium powder, and chemical agents in the accused SPC material fall within the ranges recited in the claim.
  • Scope Question: The analysis may raise the question of whether the interconnecting locking mechanism on the sides of the accused planks is part of the "sides... defined by said core layer" as that phrase is used in the patent '442 Patent, claim 1

'088 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: A central point of contention may be whether the "exposed portion" in the Accused Products is "defined within and exposing at least a portion of said core layer," as required by Claim 1. The complaint alleges exposure of "a portion of the top section... and the core" Compl. ¶59, but the degree and nature of this core exposure will be a critical factual question for the infringement analysis.
  • Factual Question: The density of the accused SPC core layer will be a matter of technical evidence. While the complaint alleges a density that falls within the claimed range Compl. ¶65, this will require factual proof and expert testimony.

V. Key Claim Terms for Construction

• The Term: "exposed portion"

• Context and Importance: This term is the central feature of the invention across all three patents. Its definition-what it is made of, where it is located (e.g., within the top section vs. exposing the core), and how it is formed-is critical to determining the scope of the claims and whether the accused products infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specifications describe multiple embodiments, which may support a broader construction. For instance, the '088 Patent describes that the exposed portion may be formed on the PVC layer in some embodiments or on the core layer in others, suggesting the term itself is not inherently limited to one or the other unless specified in a particular claim '088 Patent, FIG. 7-A '088 Patent, FIG. 7-B
  • Evidence for a Narrower Interpretation: Specific claims explicitly narrow the term's scope. For example, Claim 1 of the '088 Patent requires that the exposed portion "exposes at least a portion of said core layer," which would support a narrower construction for that claim, excluding tiles where only the top PVC layer is exposed.

• The Term: "stone plastic composite (SPC) material"

• Context and Importance: This term defines the composition and properties of the rigid core, a key structural element. The infringement analysis will depend on whether the material used in the Accused Products meets the patents' definition of SPC material, particularly where claims recite specific compositions or densities.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The '088 Patent specification describes the material generally as a "mixture of polyvinyl chloride (PVC), as well as calcium powder, oil, and a foaming agent" '088 Patent, col. 9:30-34, which could be read as an exemplary, non-limiting definition.
  • Evidence for a Narrower Interpretation: Claim 7 of the '442 Patent recites a specific recipe for the SPC material, including weight percentages of PVC, calcium powder/stone dust, and a chemical agent. A defendant may argue that this specific definition, where claimed, limits the term's scope to materials meeting those precise compositional ranges.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that the "Chinese Defendants" induced infringement by "urging and/or causing Defendant Decno Group to import the Accused Products into and sell and/or offer to sell" them in the United States Compl. ¶52 Compl. ¶68 Compl. ¶81 Knowledge is alleged based on a pre-suit demand letter sent by Plaintiff Quickstyle Compl. ¶38 Compl. ¶66
• Willful Infringement: Willfulness is alleged for all three patents Compl. ¶54 Compl. ¶70 Compl. ¶83 The basis for willfulness appears to be alleged knowledge of the patents from the pre-suit demand letter Compl. ¶38 and a direct solicitation that Defendant Decno Group allegedly sent to Plaintiff Quickstyle promoting the Accused Products Compl. ¶34

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

• A central issue will be one of structural and material correspondence: Does the physical structure of the Defendants' "exposed" grout-line feature, and the material composition of their tile's core layer, map onto the specific requirements of the asserted claims? In particular, the question of whether the exposed portion reveals the "core layer" as required by claims of the '088 Patent, versus only upper PVC layers, will likely be a key point of technical dispute.
• A second key question will be one of knowledge and intent: What evidence supports the allegation that Defendants had pre-suit knowledge of the patents and their infringement? The resolution of this question, likely turning on the alleged demand letter and solicitation, will be determinative for the claims of willful and indirect infringement.
• Finally, the case may raise a question of claim differentiation: Given the overlapping subject matter across the three patents-in-suit, the court will need to determine whether the accused products infringe the distinct set of limitations recited in each patent's asserted claims, raising the possibility of a finding of infringement on some patents but not others based on fine technical distinctions.