Lifetime Industries, Inc. v. Trim-Lok, Inc., No. 17-1096 (Fed. Cir. 2017)
Annotate this CaseLifetime’s patent describes a two-part seal for use in a mobile living quarters (recreational vehicle) with a slide-out room. A slide-out room is formed by extending a portion of the side wall of the RV outward to create extra interior space. The Federal Circuit reversed dismissal of Lifetime’s infringement suit against Trim-Lok. Lifetime adequately alleged that Trim-Lok directly infringed. Commercial manufacture is not the only way that a combination can infringe. Although Lifetime did not allege that Trim-Lok made the RV onto which it installed the seal, Lifetime did allege that that an agent of Trim-Lok installed the seal onto the RV, and that the resulting seal-RV combination infringed the patent. Lifetime also plausibly alleged that Trim-Lok induced infringement; it adequately pleaded that Trim-Lok had knowledge of the patent before the allegedly infringing act and that Trim-Lok had the intent to infringe.
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