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R & R Packaging, Inc. v. Evenflo Company, Inc.
5:20-cv-05095
| W.D. Ark. | Apr 18, 2025
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Background

  • This is a patent infringement case involving child car seat technology that alerts users when a child may have been forgotten.
  • Plaintiff R&R Packaging, Inc. (d/b/a R&R Solutions) alleges Evenflo Company, Inc. infringed two of its patents (the '943 and '728 patents).
  • The Court previously dismissed R&R's direct infringement claims but allowed its indirect infringement claims to proceed to trial.
  • Evenflo filed a Motion for Clarification and Reconsideration, contesting two rulings from the Court's February 7, 2025 order.
  • The contested rulings concern (1) whether there is a triable issue about Evenflo’s sales of certain branded products, and (2) whether the term “distance” in the patent claims needs construction.
  • The motion is considered under the summary judgment and reconsideration standards set by Federal Rule of Civil Procedure 54(b).

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Triable issue of fact on sales of Cybex/CTP-branded products There are genuine issues of material fact requiring trial. No genuine factual dispute exists over sales; supports summary judgment. Dispute remains; issue goes to trial.
Construction of “distance” in patent claims "Distance" is well-understood and needs no special construction; expert testimony consistent. For first time, Evenflo seeks to narrow "distance" definition. No special construction needed; motion denied.

Key Cases Cited

  • Christianson v. Colt Indus. Operating Corp., 486 U.S. 800 (standard for reconsidering prior court decisions—revisions reserved for extraordinary circumstances)
  • Hagerman v. Yukon En. Corp., 839 F.2d 407 (motions for reconsideration only to correct manifest errors or consider new evidence)
  • Rothwell Cotton Co. v. Rosenthal & Co., 827 F.2d 246 (limited functions of motions for reconsideration)
  • Avenoso v. Reliance Standard Life Ins. Co., 19 F.4th 1020 (district courts should not weigh evidence or resolve factual disputes at summary judgment)
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Case Details

Case Name: R & R Packaging, Inc. v. Evenflo Company, Inc.
Court Name: District Court, W.D. Arkansas
Date Published: Apr 18, 2025
Docket Number: 5:20-cv-05095
Court Abbreviation: W.D. Ark.