SQIP, LLC v. Cambria Company LLC
- Laura Provinzino
- 0:24-cv-01111
- U.S. District Court · District of Minnesota
- 40
In SQIP, LLC v. Cambria Company LLC, Judge Provinzino issued a claim construction order defining the term 'first device' in SQIP's quartz manufacturing patent, while ruling that other disputed terms — including 'computer processor' in two claims and color-related phrases in two other claims — are not indefinite and require no special construction.
Companies that manufacture or own patents relating to engineered quartz surface products (such as countertops), and parties involved in patent disputes concerning claim construction — particularly those litigating whether patent terms invoke means-plus-function or step-plus-function treatment under 35 U.S.C. § 112(f), and whether broad claim language renders patent claims indefinite.
What happened
In SQIP, LLC v. Cambria Company LLC, SQIP sued Cambria Company LLC alleging that Cambria infringed two of SQIP's patents covering methods and equipment for manufacturing engineered quartz surface products — the kind used for kitchen countertops, bathroom surfaces, and similar applications. The central question before the court was what specific technical meanings certain disputed words and phrases in those patents carry, a process called claim construction that judges (not juries) must perform before a patent infringement case can proceed to trial.
The court addressed four groups of disputed terms. For the term 'first device' in one patent claim describing the machine used to deposit a quartz-resin mixture into a mold, the parties disagreed sharply: Cambria argued it should be limited to one specific combination of hoppers, belts, and rollers, while SQIP argued it covers a broader range of equipment configurations described in the patent. The court sided largely with SQIP, finding that Cambria's proposed definition would improperly exclude several equipment configurations that the patent specification clearly describes. The court also considered whether the term 'computer processor' should be treated as a special type of claim — called a 'means-plus-function' or 'step-plus-function' claim — that would limit the patent's scope to only the specific structures described in the patent document; and whether certain color-related phrases in another patent were too vague to be enforceable. Cambria also argued that SQIP raised new legal arguments and evidence too late in the process, which the court addressed before the merits.
Judge Provinzino ruled that the term 'first device' means a system of one or more hoppers combined with funnels or belts and rollers (with motors and optional valves), plus a driving mechanism that creates relative motion between the mold and the hoppers. The court found that 'computer processor' is not a vague stand-in term requiring special treatment under patent law and is not too indefinite to be enforceable — in both the apparatus claim and the method claim — and therefore requires no special construction. The court also declined to find the color-related phrases in the '912 Patent indefinite, though it rejected Cambria's indefiniteness challenge to claim 5 of that patent without prejudice, meaning Cambria may raise that argument again later after more expert discovery. Finally, while the court found that SQIP had violated the pretrial scheduling order by disclosing new arguments and expert evidence late, it excused that violation as harmless because Cambria had an opportunity to respond — but warned SQIP that future noncompliance will be closely scrutinized.
The detailed version
CASE: SQIP, LLC v. Cambria Company LLC, No. 24-cv-1111 (LMP/DJF), U.S. District Court for the District of Minnesota. JUDGE: Laura M. Provinzino, United States District Judge. DATE: October 21, 2025.
BACKGROUND: Plaintiff SQIP, LLC ('SQIP') owns U.S. Patent Nos. 9,511,516 (the ''516 Patent') and 10,376,912 (the ''912 Patent'), both relating to methods and equipment for manufacturing engineered quartz surface products (e.g., countertops). SQIP alleges that Defendant Cambria Company LLC ('Cambria') — itself a maker of quartz products and owner of a related patent (U.S. Patent No. 9,186,819) — has infringed claims 1 and 14 of the '516 Patent and claims 3 and 5 of the '912 Patent.
CLAIM CONSTRUCTION STANDARDS: The court applied Federal Circuit law. Claim terms receive their ordinary meaning as understood by a person of ordinary skill in the art (POSITA) at the time of the invention, based primarily on intrinsic evidence (the claim language itself, the patent specification, and the prosecution history — the complete record of proceedings before the U.S. Patent and Trademark Office (PTO)). Extrinsic evidence (expert testimony, dictionaries, etc.) is considered but is less reliable. Under 35 U.S.C. § 112(f), a claim element expressed as a 'means' or 'step for' performing a function without reciting structure is a 'means-plus-function' or 'step-plus-function' limitation, construed to cover only structures or acts disclosed in the specification. Terms lacking 'means' or 'steps for' are presumed not to invoke § 112(f). A patent claim is invalid for indefiniteness if it fails to give a POSITA reasonable certainty about the scope of the invention, and the party challenging validity must prove indefiniteness by clear and convincing evidence.
PROCEDURAL ISSUE — WAIVER: Cambria argued that SQIP should be barred from raising new proposed constructions and relying on a previously undisclosed expert declaration because these were not disclosed in the parties' Joint Claim Construction Statement, as required by the pretrial scheduling order. The court found that SQIP did violate the scheduling order but declined to exclude the late-disclosed material, finding the violation harmless: Cambria had the opportunity to respond in a reply brief (which the briefing schedule — proposed jointly by the parties — allowed), and SQIP's new positions were largely responsive to Cambria's opening arguments rather than introducing an entirely new theory. The court issued a warning to SQIP that future violations will be closely scrutinized and may result in sanctions.
DISPUTED TERMS — '516 PATENT:
1. 'First Device' (Claim 1): The parties agreed this is a means-plus-function limitation under § 112(f), with three agreed-upon functions: supplying a quartz-resin mixture to a mold through specific regions of the mold's top opening during different operational states, under computer processor control. The dispute was which structures disclosed in the '516 Patent correspond to those functions. Cambria proposed limiting the term to a single combined structure (hopper, belt, and rollers) that moves to different stopped positions along the mold opening, arguing SQIP's prosecution history amendments cited only Figure 1 (showing that structure) and thus disclaimed other embodiments. SQIP proposed a broader construction encompassing hoppers combined with funnels or belts/rollers (with motors and optional valves), plus a driving mechanism for relative motion between the mold and the hoppers. The court sided largely with SQIP, finding: (a) Cambria's construction improperly excluded embodiments clearly described in the specification (including hopper/funnel configurations shown in Figures 3–5); (b) the prosecution history did not unequivocally disavow those other embodiments — SQIP used permissive 'for example' language when citing Figure 1; and (c) the specification clearly links the broader set of components to the claimed functions. The court adopted a modified version of SQIP's construction: 'a system of one or more hoppers in combination with any of, or a plurality of any of, (a) one or more funnels with a motor and, optionally, one or more valves, or (b) one or more belts and rollers with a motor and, optionally, one or more valves; and further comprising a driving mechanism with a motor which provides a force resulting in relative motion between the mold and the one or more hoppers.'
2. 'Computer Processor' (Claim 1 — apparatus claim): Cambria argued this is a means-plus-function limitation (a nonce term lacking structure) and that the '516 Patent fails to disclose sufficient structure, rendering Claim 1 indefinite. The court disagreed. Applying the presumption against § 112(f) (no 'means' language used), the court found Cambria did not rebut it: 'computer processor' is not a nonce word — Federal Circuit precedent has implied 'processor' is not a nonce word; the term describes a class of structures (synonymous with 'microprocessor,' widely used in manufacturing for decades); and the specification describes how the computer processor communicates with and controls the 'first device.' The PTO examiner's non-objection during prosecution was noted as instructive though not binding. Because § 112(f) does not apply, Cambria's indefiniteness argument (which was premised solely on § 112(f) applying) also fails. The court also rejected Cambria's alternative construction (limiting the term to a 'computer-controlled motor') as importing unsupported limitations. RULING: No construction necessary; term is not a means-plus-function limitation and is not indefinite.
3. 'Computer Processor' (Claim 14 — method claim): Cambria argued this is a step-plus-function limitation under § 112(f) and that the patent lacks sufficient 'acts' to perform the claimed functions, rendering Claim 14 indefinite. The court disagreed. Step-plus-function claiming is unusual and requires showing the claim contains no 'act.' The court found 'using a computer processor to controllably supply' a mixture to specific mold regions is an act — it describes how the ultimate function (producing patterned quartz slabs) is accomplished — not merely a bare function. The PTO examiner also did not flag this as a step-plus-function limitation. RULING: No construction necessary; term is not a step-plus-function limitation and is not indefinite.
DISPUTED TERMS — '912 PATENT:
4. 'A Second Material Having a Color' and 'The Color of the Second Material' (Claim 3): Cambria argued these phrases are indefinite because it is unclear whether the 'color of the second material' must differ from the 'color of the first material' referenced in the parent Claim 1. SQIP argued a plain reading makes clear the second color must be different. The court found SQIP's reading was not supported by the specification — which uses permissive 'could be different' language, suggesting the colors may or may not be the same. However, the court found this breadth does not equate to indefiniteness: a POSITA would understand the scope of the claim with reasonable certainty. Breadth is not indefiniteness. RULING: No construction necessary; phrases are not indefinite.
5. 'A Material Having a Color' and 'A Color of a Deposited Material' (Claim 5): Cambria argued these phrases in Claim 5 (which depends from Claim 1 and covers multiple additional cracks and veins) are even more ambiguous than Claim 3 because Claim 5 does not specify whether 'a material' is the same as or different from the 'first material' in Claim 1. The court acknowledged this is a much closer question than Claim 3 and that SQIP could have drafted the claim more precisely, but found the clear-and-convincing evidence standard for indefiniteness was not met — at least at this stage of the litigation. RULING: Cambria's indefiniteness argument as to Claim 5 is rejected without prejudice; Cambria may raise it again after additional expert discovery.
SUMMARY OF RULINGS: - 'First device' (Claim 1, '516 Patent): Construed as described above. - 'Computer processor' (Claim 1, '516 Patent): Not means-plus-function; not indefinite; no construction necessary. - 'Computer processor' (Claim 14, '516 Patent): Not step-plus-function; not indefinite; no construction necessary. - 'A second material having a color' / 'the color of the second material' (Claim 3, '912 Patent): Not indefinite; no construction necessary. - 'A material having a color' / 'a color of a deposited material' (Claim 5, '912 Patent): Not indefinite at this stage; no construction necessary; Cambria's challenge rejected without prejudice.
Reviewer note from the AI+
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