Hanover Prest-Paving Co. v. Staten Island Building Products Dist Inc.
1:21-cv-01672
| M.D. Penn. | Jun 9, 2025Background
- Hanover Prest-Paving Company ("Hanover") owns a U.S. patent for a unique paver pedestal assembly system.
- Plastic Forward LLC, based in Uzbekistan, manufactured and sold a product allegedly infringing Hanover’s patent in Pennsylvania.
- Hanover notified Plastic Forward of the alleged infringement in March 2022, but Plastic Forward continued its activities.
- Hanover sued several defendants; all except Plastic Forward resolved or were dismissed from the case.
- Plastic Forward was served in October 2023 but did not appear or respond; default was entered and Hanover moved for default judgment and a permanent injunction.
- The opinion addresses these motions, plus subject matter and personal jurisdiction over Plastic Forward.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject Matter & Personal Jurisdiction | Federal patent law and Pennsylvania contacts justify U.S. jurisdiction | None presented | Court has jurisdiction |
| Entitlement to Default Judgment | Plastic Forward failed to appear; complaint well-pled | None presented | Default judgment granted |
| Adequate Pleading of Patent Infringement | Complaint satisfies all statutory and pleading requirements | None presented | Requirements are met |
| Permanent Injunction | Patent infringement causes irreparable harm, damages inadequate, equities and public interest favor injunction | None presented | Permanent injunction granted |
Key Cases Cited
- Emcasco Ins. Co. v. Sambrick, 834 F.2d 71 (3d Cir. 1987) (district courts have discretion in entering default judgments)
- Chamberlain v. Giampapa, 210 F.3d 154 (3d Cir. 2000) (three-factor test for default judgment)
- Daimler AG v. Bauman, 571 U.S. 117 (2014) (criteria for personal jurisdiction over foreign defendants)
- eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006) (four-factor test for granting permanent injunction in patent cases)
- Acumed LLC v. Stryker Corp., 551 F.3d 1323 (Fed. Cir. 2008) (irreparable injury from patent infringement)
- Robert Bosch LLC v. Pylon Mfg. Corp., 659 F.3d 1142 (Fed. Cir. 2011) (monetary damages generally inadequate for patent injury)
- Douglas Dynamics, LLC v. Buyers Prods. Co., 717 F.3d 1336 (Fed. Cir. 2013) (public interest in enforcing patents and promoting innovation)