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Lifetime Industries, Inc. v. Trim-Lok, Inc.

Fed Cir Clarifies Application of Iqbal/Twombly to Indirect Infringement

Lifetime Industries, Inc. v. Trim-Lok, Inc., 2017 U.S. App. LEXIS 17257 (Fed. Cir. Sept. 7, 2017) (LOURIE, Moore, O’Malley) (N.D. Ind.: Miller) (3 of 5 stars)

Fed Cir reverses dismissal of patent infringement complaint. The district court erred in concluding that Lifetime had failed to adequately state claims for direct and indirect patent infringement. Lifetime’s patent related to a two-part seal for the mobile living quarters that extends out from the side of an RV. The claims required both the seal, and the RV. As to direct infringement, Lifetime’s second amended complaint met Iqbal/Twombly pleading standards. Although Trim-Lok only manufactures seals, and not RVs, it was plausible that Trim-Lok had installed a seal onto an RV at some point so as to reach the claimed invention. The opinion rejects Trim-Lok’s argument that Lifetime’s complaint lacked sufficient detail in its allegation, noting that the complaint identified where the infringement occurred, when, by whom, and why. As to indirect infringement, the Iqbal/Twombly standard was also met. For inducement, Lifetime adequately pleaded that Trim-Lok had knowledge of the patent before directing the installation of the seal in question on an RV, thus supporting its allegations as to intent. For contributory infringement, Lifetime had adequately pleaded knowledge, which was all that was required, of both the patent and the infringement. The opinion also approves Trim-Lok’s pleading in the alternative as to whether the employees who installed the seals were Trim-Lok employees (in which case Trim-Lok would face direct infringement liability) or non-employees (in which case it would face indirect infringement liability).

KEYWORDS: PLEADING STANDARDS; PLAUSIBILITY; MOTION TO DISMISS