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