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Arlington Industries, Inc. v. Bridgeport Fittings, Inc.

United States District Court, M.D. Pennsylvania

April 24, 2014



CHRISTOPHER C. CONNER, Chief District Judge.

Presently before the court is Arlington Industries, Inc.'s ("Arlington") motion (Doc. 429) for summary judgment. Arlington claims that defendant Bridgeport Fittings, Inc.'s ("Bridgeport") Whipper-Snap Duplex Connectors ("Duplex Connectors"), catalog numbers 3838ASP and 3838SP, infringe Arlington's patent number 5, 266, 050 ("the 050 patent"). For the reasons that follow, the court will grant the motion.

I. Background

Arlington and Bridgeport are fierce competitors in the electrical conduit fitting industry. This case concerns a particular type of electrical conduit fitting with a snap-in feature. Litigation between the parties over the patent underlying this type of fitting has been ongoing since 2001. See Arlington Indus., Inc. v. Bridgeport Fittings, Inc., Civ. A. No. 3:01-CV-0485 (M.D. Pa.) (hereinafter "Arlington I"). The Arlington I litigation instituted in 2001 originally concerned only Bridgeport's Single Connector snap-in products. The Duplex Connectors that form the basis of Arlington's present motion for summary judgment were first asserted as infringing products in the above-captioned case in 2006 ("Arlington II"). (Doc. 3). The Duplex Connectors became a part of the Arlington I litigation during the discovery phase of that litigation, but after the same claim was asserted in the instant litigation. Unbeknownst to Honorable A. Richard Caputo, who was initially assigned to the above-captioned case, [1] and the undersigned, who presided over the Arlington I litigation, the Duplex Connectors were subject to litigation in two cases for identical allegations of infringement of Claim 8 of the '050 patent. Through oversight or inadvertence, neither party found it necessary to seek immediate consolidation, and this matter and Arlington I proceeded on parallel tracks. Suffice it to say that the procedural path leading to the instant motion has been rather complicated.

A. Arlington's '050 Patent

In 1992, Arlington developed and manufactured a new type of electrical conduit fitting, intended to replace previous units whose installation required the use of two hands to screw the device into an electrical junction box.[2] (See Doc. 102, Ex. B). This connector features a circular spring metal adaptor, to which at least two outwardly sprung members are attached at the trailing end. (See id. at col. 10). When the adaptor is inserted into the knockout hole of an electrical junction box, its outwardly sprung members lock the adaptor into place. (See id.) Thus, Arlington's connector allows a user to quickly connect the device to a junction box using one hand instead of two, thereby reducing the time and effort required during installation. (See id. at col. 1).

On December 15, 1992, Arlington was awarded United States Patent Number 5, 171, 164 ("the '164 patent") which covered the design of the above-described device. (Arlington I, Doc. 404 ¶ 2; Doc. 432 ¶ 2). Arlington acquired the '050 patent the following year. (Doc. 102, Ex. B). The '050 patent is a "continuation patent, " meaning that it shares a common specification with the '164 patent, but includes different claims. (Arlington I, Doc. 404 ¶ 2; Doc. 432 ¶ 2.) The '050 patent encompasses eight claims, only one of which is the focus of the instant litigation. The claim at issue-Claim 8-reads as follows:

A quick connect fitting for an electrical junction box comprising:

a hollow electrical connector through which an electrical conductor may be inserted having a leading end thereof for insertion in a hole in an electrical junction box;
a circular spring metal adaptor surrounding said leading end of said electrical connector which has a leading end, a trailing end, and an intermediate body;
at least two outwardly sprung members carried by said metal adaptor near said trailing end of said adaptor which engage the side walls of the hole in the junction box into which said adaptor is inserted;
at least two spring locking members carried by said metal adaptor that spring inward to a retracted position to permit said adaptor and locking members to be inserted in a hole in an electrical junction box and spring outward to lock said electrical connector from being withdrawn through the hole; and
an arrangement on said connector for limiting the distance said connector can be inserted into the hole in the junction box.

In 1999, Bridgeport introduced its own product line of quick-connect fittings called the "Snap-In Fitting." (See Arlington I, Doc. 170 at 7-10). The "Snap-In Fittings" were designed with characteristics nearly identical to those featured in Arlington's patented products. (See Arlington I, Doc. 310 ¶ 2.5). Arlington filed the Arlington I litigation in March 2001, alleging ...

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