24-CV-1281 Champion Power Equipment Inc v. Generac Power Systems Inc

Decision and Order

The court denied a motion to dismiss under Rule 12(b)(6) and a motion for a more definite statement under Rule 12(e). The court’s opinion on the motion to dismiss addressed the pleading standard applicable to claims of patent infringement. In particular, the court determined that when the patent claims relate to simple mechanical systems and nothing in the complaint indicates that all claim elements would not be found in the accused product, the plaintiff does not have to explain in the complaint exactly how the accused product might infringe. To plead a plausible claim, it is enough for the complaint to allege that all claim elements are found in the accused product, either literally or equivalently.  In denying the motion for a more definite statement, the court determined that the defendant was not entitled to receive the plaintiff’s theories of claim construction and infringement before filing an answer. Those details would come in the ordinary course of discovery, and the defendant did not show that the lack of such details hindered its ability to file an answer.