Little Giant Ladder Systems, LLC v. Tricam Industries, Inc.

U.S. District Court, District of Minnesota

Little Giant Ladder Systems, LLC v. Tricam Industries, Inc.

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Little Giant Ladder Systems, LLC,        No. 20-cv-2497 (KMM/ECW)        

          Plaintiff,                                                     

v.                                                                       

ORDER

Tricam Industries, Inc.,                                                 

          Defendant.                                                     


    This matter is before the Court on the parties’ competing proposals concerning the 
appropriate disposition of Defendant Tricam Industries, Inc.’s counterclaim seeking a 
declaration of invalidity of United States Patent No. 10,767,416 (the ’416 patent). Plaintiff 
Little Giant Ladder Systems, LLC argues that the Court should dismiss Tricam’s invalidity 
counterclaim without prejudice so that a final judgment can be entered in this case without 
further delay. Pl.’s Letter (Doc. 216). Tricam asserts that the Court should address the 
merits of its invalidity counterclaim now based on Little Giant’s recent conduct concerning 
a newly issued patent within the same patent family. Def.’s Letter (Doc. 217). For the 
reasons  that  follow,  the  Court  dismisses  Tricam’s  invalidity  counterclaim  without 
prejudice.                                                                
    On March 28, 2024, the Court entered an Order denying Little Giant’s motion for 
summary judgment and granting Tricam’s motion for summary judgment. The Court found 
that no reasonable jury could conclude that Tricam’s accused ladders have the “cavity” 
limitation found in the ’416 patent’s sole independent claim. Based on that finding of non-
infringement, the Court stated that the issues of invalidity the parties had raised in their 
motions were rendered “moot.” Summ. J. Order 48–49 (Doc. 208). The Clerk of Court 
entered judgement consistent with the March 28th Order.                   

    The parties jointly notified the Court that the non-infringement ruling did not, in 
fact, moot Tricam’s invalidity counterclaim. Joint Letter (citing Cardinal Chemical Co. v. 
Morton International, Inc., 
508 U.S. 83, 98
 (1993); Fort James Corp. v. Solo Cup Co., 
412 F.3d 1340
, 1348–49 (Fed. Cir. 2005)) (Doc. 210). As a result, the Court issued an Order 
vacating the Judgment and set a status conference. (Doc. 213, 214). During the status 

conference, the Court and the parties discussed whether it would be appropriate for the 
Court to decline to exercise its jurisdiction and dismiss the invalidity counterclaim without 
prejudice. In particular, the Court directed the parties’ attention to the Federal Circuit’s 
decisions in SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical Ltd., 
59 F.4th 1328
 (Fed. Cir. 2023) and AstraZeneca LP v. Breath Ltd., 542 Fed. App’x 971 

(Fed. Cir. 2013). The Court instructed the parties to file letter briefs setting forth their 
respective positions on what should be done with the invalidity counterclaim if they were 
unable to reach an agreement. Minute Entry (Doc. 215).                    
    Tricam brings its invalidity counterclaim under the Federal Declaratory Judgment 
Act, 
28 U.S.C. §§ 2201
 and 2202.1 Generally, district courts have discretion to decline to 

exercise jurisdiction over claims brought under the Declaratory Judgment Act. WMC 
Mortg.,  LLC  v.  J.P.  Morgan  Mortg.  Acquisition  Tr.  2006-WMC4,  No.  12-cv-3146 


    1 Countercl. ¶ 5 (Doc. 17).                                          
(DWF/AJB), 
2013 WL 3808004
, at *3 (D. Minn. July 22, 2013) (“District courts ‘possess 
discretion in determining whether and when to entertain an action under the Declaratory 
Judgment  Act,  even  when  the  suit  otherwise  satisfies  subject  matter  jurisdictional 

prerequisites.’”) (quoting Wilton v. Seven Falls Co., 
515 U.S. 277, 282
 (1995)). This 
includes  discretionary  authority  to  decline  to  exercise  jurisdiction  over  an  accused 
infringer’s invalidity counterclaim in patent cases. SSI Techs., 59 F.4th at 1338–39. Indeed, 
the Federal Circuit has “repeatedly held that a district court ‘faced with an invalidity 
counterclaim challenging a patent that it concludes was not infringed may either hear the 

claim or dismiss it without prejudice.’” 
Id.
 (quoting Liquid Dynamics Corp. v. Vaughan 
Co., 
355 F.3d 1361, 1371
 (Fed. Cir. 2004), and citing Flexuspine, Inc. v. Globus Med. Inc., 
879 F.3d 1369, 1376
 (Fed. Cir. 2018); Phonometrics, Inc. v. N. Telecom Inc., 
133 F.3d 1459, 1468
 (Fed. Cir. 1998); Nystrom v. TREX Co., 
339 F.3d 1347
, 1351 & n.* (Fed. Cir. 
2003); Benitec Australia, Ltd. v. Nucleonics, Inc., 
495 F.3d 1340
, 1353 & n.4 (Fed. Cir. 

2007) (Dyk, J., dissenting); AstraZeneca LP, 542 Fed. App’x at 981–82).   
    District courts should exercise their discretion “consistent with the purposes of the 
Declaratory  Judgment  Act  and  considerations  of  wise  judicial  administration.” 
AstraZeneca, 542 Fed. App’x at 981 (quotation omitted). A court should provide “well-
founded reasons for declining to entertain a declaratory judgment action.” 
Id.
 (quoting 
Capo, Inc. v. Dioptics Med. Prods., Inc., 
387 F.3d 1352, 1355
 (Fed. Cir. 2004)).2 It is a 
“sufficient reason to decline jurisdiction” where the accused infringer fails to “show[] how 
a judgment of invalidity would provide any additional benefit” following a determination 

of non-infringement that “firmly and clearly resolves the case[.]” 
Id.
 (internal quotation 
marks).  The  Federal  Circuit  has  also  indicated  that  a  court’s  “discretion  to  dismiss 
invalidity counterclaims at later stages in the proceedings may be more limited” than it is 
when a district court “grants summary judgment of noninfringement.” Flexuspine, Inc., 
879 F.3d at 1376
.                                                         

    Tricam argues that adjudication of its invalidity counterclaim now will provide 
Tricam with additional benefit because Little Giant has obtained a new patent—United 
States Patent No. 11,788,351 (the “’351 patent”)—and informed Tricam that it believes 
Trimcam’s ladders are infringing that new patent. The ladders alleged to be infringing the 
new patent are the same Tricam ladders that are at issue in this case. Tricam points out that 

Little Giant drafted some claims in the ’351 patent specifically to get around certain 
arguments Tricam raised in this litigation regarding the ’416 patent—substituting the 
claimed “cavity” in the ’416 patent with a “recess” limitation in the ’351 patent. But the 
’351 patent still includes the same “at least one retaining mechanism” language that is 

    2 In practice, courts need not provide lengthy explanations of their reasoning. E.g., Thought, 
Inc. v. Oracle Corp., No. 12-cv-5601-WHO, 
2016 WL 3230696
, at *14 (N.D. Cal. June 13, 2016) 
(dismissing invalidity counterclaim sua sponte because “the non-infringement judgment resolves 
this case and appears to extinguish any threat of future enforcement of the claims or litigation 
against Oracle.”); SSI Techs., LLC v. Dongguan Zhengyang Elec. Mech. LTD, 
559 F. Supp. 3d 821
, 835 (W.D. Wis. 2021) (“Nothing in DZEM's complaint or any of the parties’ briefing suggests 
that DZEM faces any risk of future prosecution under either of the patents-in-suit, so there is no 
need for the court to determine whether the patents are invalid.”), aff’d in relevant part, 
59 F.4th 1328
 (Fed. Cir. 2023).                                                    
found in the ’416 patent, and that retaining-mechanism limitation is the subject of several 
of Tricam’s invalidity arguments in this case.3 Therefore, according to Tricam, a ruling in 
this case that the ’416 patent is invalid will preclude Little Giant from relitigating the issue 

of invalidity in its threatened infringement action under the ’351 patent. 
    Although the Court appreciates Tricam’s interest in obtaining a ruling on invalidity, 
the Court finds that considerations of wise judicial administration  weigh in favor of 
declining  to  exercise  jurisdiction  over  the  declaratory  invalidity  counterclaim.  As 
discussed, the Court has found that Tricam is entitled to judgment in its favor on the issue 

of infringement. Tricam has not identified any current threat of liability arising from the 
patent-in-suit in this case, aside from the possibility of an appeal of the Court’s non-
infringement ruling. Instead, Tricam has argued that the Court should rule on an invalidity 
claim that may have benefit to it in a future, hypothetical suit regarding a patent that is not 
at issue in this case. Tricam has not cited, and this Court’s own research has not located, a 

case in which a Court has exercised discretionary jurisdiction over a declaratory invalidity 
counterclaim based on that type of possible future benefit regarding a patent that is not a 
patent-in-suit. Moreover, the parties do not even agree on whether a determination of 
invalidity of the ’416 patent in this case would have preclusive effect on any future 



    3 In its summary judgment briefing, Tricam argues that a prior art reference—U.S. Patent 
No. 6,220,389 (“Krause”)—anticipates the ’416 patent because it discloses the “at least one 
retaining mechanism” limitation. Def.’s Summ. J. Mem. 23–26 (Doc. 169). In addition, Tricam 
raised arguments concerning lack of written description, lack of enablement, and indefiniteness 
defenses all relating to the retaining-mechanism limitation (including the “detent,” which is the 
structure that corresponds to that means-plus-function term) in its briefing. Def.’s Summ. J. Opp’n 
27–40 (Doc. 188).                                                         
litigation involving the ’351 patent. Compare Pl.’s Letter 3–4 n.2 (suggesting that a finding 
of invalidity would be “persuasive” or “advisory” with regard to future suits on a different 
patent) with Def.’s Letter 2 (arguing that collateral estoppel would bar relitigation of the 

invalidity issues in a future suit over the ’351 patent). Therefore, it is uncertain at best that 
any invalidity judgment in this case would give Tricam the additional benefit it argues 
would be obtained by addressing the counterclaim now, and the Court will not offer an 
advisory opinion on that issue.                                           
    Relying on Cardinal Chemical Co., Tricam also argues that the Court should decide 

the invalidity issues now because failing to do so will permit Little Giant to threaten 
improper monopoly rights based on a patent that Tricam believes is invalid. Def.’s Letter 
at 2–3 (citing Cardinal Chem. Co., 508 U.S. at 100–01). In Cardinal Chemical Co., the 
Supreme Court held that the Federal Circuit’s prior uniform practice of declaring any 
already-issued judgment of invalidity moot whenever it affirmed a district court judgment 

of non-infringement was erroneous because there still existed an actual case or controversy. 
508 U.S. 96–98. But  even the  Cardinal  Chemical Co. Court recognized that it was 
addressing a separate question from a district court’s discretion to decline to exercise 
discretion over claims for a declaratory judgment. 
Id.
 at 95 & n.17 (“As we have noted, the 
Declaratory Judgment Act affords the district court some discretion in determining whether 

or not to exercise that jurisdiction, even when it has been established.”). And in the three 
decades since Cardinal Chemical Co. was decided, district courts have routinely dismissed 
invalidity counterclaims without prejudice under circumstances like those present here. 
E.g., PayRange, Inc. v. KioSoft Techs., LLC, No. 1:20-cv-20970-LFL, 
2023 WL 6310230
, 
at *3 (S.D. Fla. June 27, 2023) (dismissing invalidity counterclaims without prejudice 
because “the anticipated benefit of exercising jurisdiction over the invalidity counterclaims 
[appeared] hypothetical”).                                                

    Ultimately,  the  Court  finds  that  declining  to  exercise  its  jurisdiction  over  the 
invalidity counterclaim serves the interests of judicial economy. True, if Little Giant 
appeals the finding of non-infringement and prevails, there is a possibility that this case 
could be remanded for further proceedings. That might result in additional litigation in this 
Court and, potentially, the Court might have to address invalidity at that time. However, it 

is neither certain that Little Giant will appeal; nor that it would prevail; nor that, in the 
event both of those things occur, the parties wouldn’t find a way to resolve their differences 
around the ’416 patent rather than continue this litigation. But in the event the case were to 
return to this Court after a successful appeal of the non-infringement ruling, the parties and 
the Court would not be forced to return to square one. Rather, we would have the benefit 

of the work the parties have already performed in this litigation regarding the invalidity 
issues.                                                                   
    On the other hand, it is equally true that, like appellate courts, trial courts have 
limited resources, and this Court is no different. This Court has made a finding of non-
infringement in Tricam’s favor that fully resolves that key aspect of this dispute. As a 

result, resolving all the invalidity issues at this stage could be a waste of the Court’s 
resources as it would need to address a dense set of competing briefs on the issues of written 
description, lack of enablement, indefiniteness, anticipation, and obviousness. This is 
especially true where, as here, the issues of invalidity are numerous, far from clear, and 
Tricam hasn’t persuaded the Court that there is any additional benefit to obtaining a finding 
of invalidity based on a threat of future litigation concerning the patent at issue in this suit. 
See Eugene Baratto, Textures, LLC v. Brushstrokes Fine Art, Inc., 
701 F. Supp. 2d 1068, 1083
 (W.D. Wis. 2010) (“Because I am granting summary judgment for Brushstrokes on 
the  core  issue  of  non-infringement  on  clear  grounds  and  because  Brushstrokes’s 
counterclaim for invalidity is less certain, I am exercising my discretion and dismissing 
without prejudice Brushstrokes’s invalidity counterclaim.”) (emphasis added). 
    Accordingly, in the Court’s discretion, it declines to exercise jurisdiction over 

Tricam’s  invalidity  counterclaim  and  dismisses  that  counterclaim  without  prejudice. 
Further, as set forth below, the Court modifies its March 28th Summary Judgment Order 
and directs the Clerk of Court to enter judgment.                         

ORDER

    For the reasons set forth above, IT IS HEREBY ORDERED THAT           

    1.   The Court’s March 28, 2024 Order (Doc. 208) on the parties’ motions for 
         summary judgment and to exclude expert testimony is modified as set forth 
         below.                                                          
    2.   Plaintiff’s Motion for Summary Judgment (Doc. 164) is DENIED. The 
         Court denies Plaintiff’s motion on the merits to the extent Plaintiff argues 
         that it is entitled to judgment as a matter of law on the issues of whether the 
         Accused Ladders infringe the cavity limitation in the ’416 patent literally or 
         under the doctrine of equivalents. The Court does not address Plaintiff’s 
         arguments concerning invalidity issues based on its decision to decline to 
         exercise jurisdiction over Defendant’s invalidity counterclaim. 
    3.   Defendant’s  Motion  for  Summary  Judgment  (Doc.  167)  is  GRANTED 
         because no reasonable jury could conclude that the Accused Ladders literally 
         infringe  the  cavity  limitation  in  the  ’416  patent  and  amendment-based 
         estoppel precludes Plaintiff from relying on the doctrine of equivalents to 
         prove  infringement  of  this  limitation.  The  Court  does  not  address 
        Defendant’s arguments concerning invalidity issues based on its decision to 
        decline to exercise jurisdiction over Defendant’s invalidity counterclaim. 
   4.   Defendant’s Motion to Exclude Expert Testimony of Fred Smith (Doc. 171) 
        is  GRANTED  IN  PART.  The  Court  excludes  Mr.  Smith’s  opinions 
        concerning infringement of the cavity limitation because Mr. Smith failed to 
        apply the Court’s claim construction.                           
   5.   Defendant’s  counterclaim  seeking  a  declaratory  judgment  that  the  ’416 
        patent is invalid is DISMISSED WITHOUT PREJUDICE in the Court’s 
        discretion.                                                     

   Let Judgment be entered accordingly.                                 

Date: June 14, 2024             s/Katherine Menendez                     
                               Katherine Menendez                       
                               United States District Judge             

Trial Court Opinion

                UNITED STATES DISTRICT COURT                             
                    DISTRICT OF MINNESOTA                                


Little Giant Ladder Systems, LLC,        No. 20-cv-2497 (KMM/ECW)        

          Plaintiff,                                                     

v.                                                                       

ORDER

Tricam Industries, Inc.,                                                 

          Defendant.                                                     


    This matter is before the Court on the parties’ competing proposals concerning the 
appropriate disposition of Defendant Tricam Industries, Inc.’s counterclaim seeking a 
declaration of invalidity of United States Patent No. 10,767,416 (the ’416 patent). Plaintiff 
Little Giant Ladder Systems, LLC argues that the Court should dismiss Tricam’s invalidity 
counterclaim without prejudice so that a final judgment can be entered in this case without 
further delay. Pl.’s Letter (Doc. 216). Tricam asserts that the Court should address the 
merits of its invalidity counterclaim now based on Little Giant’s recent conduct concerning 
a newly issued patent within the same patent family. Def.’s Letter (Doc. 217). For the 
reasons  that  follow,  the  Court  dismisses  Tricam’s  invalidity  counterclaim  without 
prejudice.                                                                
    On March 28, 2024, the Court entered an Order denying Little Giant’s motion for 
summary judgment and granting Tricam’s motion for summary judgment. The Court found 
that no reasonable jury could conclude that Tricam’s accused ladders have the “cavity” 
limitation found in the ’416 patent’s sole independent claim. Based on that finding of non-
infringement, the Court stated that the issues of invalidity the parties had raised in their 
motions were rendered “moot.” Summ. J. Order 48–49 (Doc. 208). The Clerk of Court 
entered judgement consistent with the March 28th Order.                   

    The parties jointly notified the Court that the non-infringement ruling did not, in 
fact, moot Tricam’s invalidity counterclaim. Joint Letter (citing Cardinal Chemical Co. v. 
Morton International, Inc., 
508 U.S. 83, 98
 (1993); Fort James Corp. v. Solo Cup Co., 
412 F.3d 1340
, 1348–49 (Fed. Cir. 2005)) (Doc. 210). As a result, the Court issued an Order 
vacating the Judgment and set a status conference. (Doc. 213, 214). During the status 

conference, the Court and the parties discussed whether it would be appropriate for the 
Court to decline to exercise its jurisdiction and dismiss the invalidity counterclaim without 
prejudice. In particular, the Court directed the parties’ attention to the Federal Circuit’s 
decisions in SSI Technologies, LLC v. Dongguan Zhengyang Electronic Mechanical Ltd., 
59 F.4th 1328
 (Fed. Cir. 2023) and AstraZeneca LP v. Breath Ltd., 542 Fed. App’x 971 

(Fed. Cir. 2013). The Court instructed the parties to file letter briefs setting forth their 
respective positions on what should be done with the invalidity counterclaim if they were 
unable to reach an agreement. Minute Entry (Doc. 215).                    
    Tricam brings its invalidity counterclaim under the Federal Declaratory Judgment 
Act, 
28 U.S.C. §§ 2201
 and 2202.1 Generally, district courts have discretion to decline to 

exercise jurisdiction over claims brought under the Declaratory Judgment Act. WMC 
Mortg.,  LLC  v.  J.P.  Morgan  Mortg.  Acquisition  Tr.  2006-WMC4,  No.  12-cv-3146 


    1 Countercl. ¶ 5 (Doc. 17).                                          
(DWF/AJB), 
2013 WL 3808004
, at *3 (D. Minn. July 22, 2013) (“District courts ‘possess 
discretion in determining whether and when to entertain an action under the Declaratory 
Judgment  Act,  even  when  the  suit  otherwise  satisfies  subject  matter  jurisdictional 

prerequisites.’”) (quoting Wilton v. Seven Falls Co., 
515 U.S. 277, 282
 (1995)). This 
includes  discretionary  authority  to  decline  to  exercise  jurisdiction  over  an  accused 
infringer’s invalidity counterclaim in patent cases. SSI Techs., 59 F.4th at 1338–39. Indeed, 
the Federal Circuit has “repeatedly held that a district court ‘faced with an invalidity 
counterclaim challenging a patent that it concludes was not infringed may either hear the 

claim or dismiss it without prejudice.’” 
Id.
 (quoting Liquid Dynamics Corp. v. Vaughan 
Co., 
355 F.3d 1361, 1371
 (Fed. Cir. 2004), and citing Flexuspine, Inc. v. Globus Med. Inc., 
879 F.3d 1369, 1376
 (Fed. Cir. 2018); Phonometrics, Inc. v. N. Telecom Inc., 
133 F.3d 1459, 1468
 (Fed. Cir. 1998); Nystrom v. TREX Co., 
339 F.3d 1347
, 1351 & n.* (Fed. Cir. 
2003); Benitec Australia, Ltd. v. Nucleonics, Inc., 
495 F.3d 1340
, 1353 & n.4 (Fed. Cir. 

2007) (Dyk, J., dissenting); AstraZeneca LP, 542 Fed. App’x at 981–82).   
    District courts should exercise their discretion “consistent with the purposes of the 
Declaratory  Judgment  Act  and  considerations  of  wise  judicial  administration.” 
AstraZeneca, 542 Fed. App’x at 981 (quotation omitted). A court should provide “well-
founded reasons for declining to entertain a declaratory judgment action.” 
Id.
 (quoting 
Capo, Inc. v. Dioptics Med. Prods., Inc., 
387 F.3d 1352, 1355
 (Fed. Cir. 2004)).2 It is a 
“sufficient reason to decline jurisdiction” where the accused infringer fails to “show[] how 
a judgment of invalidity would provide any additional benefit” following a determination 

of non-infringement that “firmly and clearly resolves the case[.]” 
Id.
 (internal quotation 
marks).  The  Federal  Circuit  has  also  indicated  that  a  court’s  “discretion  to  dismiss 
invalidity counterclaims at later stages in the proceedings may be more limited” than it is 
when a district court “grants summary judgment of noninfringement.” Flexuspine, Inc., 
879 F.3d at 1376
.                                                         

    Tricam argues that adjudication of its invalidity counterclaim now will provide 
Tricam with additional benefit because Little Giant has obtained a new patent—United 
States Patent No. 11,788,351 (the “’351 patent”)—and informed Tricam that it believes 
Trimcam’s ladders are infringing that new patent. The ladders alleged to be infringing the 
new patent are the same Tricam ladders that are at issue in this case. Tricam points out that 

Little Giant drafted some claims in the ’351 patent specifically to get around certain 
arguments Tricam raised in this litigation regarding the ’416 patent—substituting the 
claimed “cavity” in the ’416 patent with a “recess” limitation in the ’351 patent. But the 
’351 patent still includes the same “at least one retaining mechanism” language that is 

    2 In practice, courts need not provide lengthy explanations of their reasoning. E.g., Thought, 
Inc. v. Oracle Corp., No. 12-cv-5601-WHO, 
2016 WL 3230696
, at *14 (N.D. Cal. June 13, 2016) 
(dismissing invalidity counterclaim sua sponte because “the non-infringement judgment resolves 
this case and appears to extinguish any threat of future enforcement of the claims or litigation 
against Oracle.”); SSI Techs., LLC v. Dongguan Zhengyang Elec. Mech. LTD, 
559 F. Supp. 3d 821
, 835 (W.D. Wis. 2021) (“Nothing in DZEM's complaint or any of the parties’ briefing suggests 
that DZEM faces any risk of future prosecution under either of the patents-in-suit, so there is no 
need for the court to determine whether the patents are invalid.”), aff’d in relevant part, 
59 F.4th 1328
 (Fed. Cir. 2023).                                                    
found in the ’416 patent, and that retaining-mechanism limitation is the subject of several 
of Tricam’s invalidity arguments in this case.3 Therefore, according to Tricam, a ruling in 
this case that the ’416 patent is invalid will preclude Little Giant from relitigating the issue 

of invalidity in its threatened infringement action under the ’351 patent. 
    Although the Court appreciates Tricam’s interest in obtaining a ruling on invalidity, 
the Court finds that considerations of wise judicial administration  weigh in favor of 
declining  to  exercise  jurisdiction  over  the  declaratory  invalidity  counterclaim.  As 
discussed, the Court has found that Tricam is entitled to judgment in its favor on the issue 

of infringement. Tricam has not identified any current threat of liability arising from the 
patent-in-suit in this case, aside from the possibility of an appeal of the Court’s non-
infringement ruling. Instead, Tricam has argued that the Court should rule on an invalidity 
claim that may have benefit to it in a future, hypothetical suit regarding a patent that is not 
at issue in this case. Tricam has not cited, and this Court’s own research has not located, a 

case in which a Court has exercised discretionary jurisdiction over a declaratory invalidity 
counterclaim based on that type of possible future benefit regarding a patent that is not a 
patent-in-suit. Moreover, the parties do not even agree on whether a determination of 
invalidity of the ’416 patent in this case would have preclusive effect on any future 



    3 In its summary judgment briefing, Tricam argues that a prior art reference—U.S. Patent 
No. 6,220,389 (“Krause”)—anticipates the ’416 patent because it discloses the “at least one 
retaining mechanism” limitation. Def.’s Summ. J. Mem. 23–26 (Doc. 169). In addition, Tricam 
raised arguments concerning lack of written description, lack of enablement, and indefiniteness 
defenses all relating to the retaining-mechanism limitation (including the “detent,” which is the 
structure that corresponds to that means-plus-function term) in its briefing. Def.’s Summ. J. Opp’n 
27–40 (Doc. 188).                                                         
litigation involving the ’351 patent. Compare Pl.’s Letter 3–4 n.2 (suggesting that a finding 
of invalidity would be “persuasive” or “advisory” with regard to future suits on a different 
patent) with Def.’s Letter 2 (arguing that collateral estoppel would bar relitigation of the 

invalidity issues in a future suit over the ’351 patent). Therefore, it is uncertain at best that 
any invalidity judgment in this case would give Tricam the additional benefit it argues 
would be obtained by addressing the counterclaim now, and the Court will not offer an 
advisory opinion on that issue.                                           
    Relying on Cardinal Chemical Co., Tricam also argues that the Court should decide 

the invalidity issues now because failing to do so will permit Little Giant to threaten 
improper monopoly rights based on a patent that Tricam believes is invalid. Def.’s Letter 
at 2–3 (citing Cardinal Chem. Co., 508 U.S. at 100–01). In Cardinal Chemical Co., the 
Supreme Court held that the Federal Circuit’s prior uniform practice of declaring any 
already-issued judgment of invalidity moot whenever it affirmed a district court judgment 

of non-infringement was erroneous because there still existed an actual case or controversy. 
508 U.S. 96–98. But  even the  Cardinal  Chemical Co. Court recognized that it was 
addressing a separate question from a district court’s discretion to decline to exercise 
discretion over claims for a declaratory judgment. 
Id.
 at 95 & n.17 (“As we have noted, the 
Declaratory Judgment Act affords the district court some discretion in determining whether 

or not to exercise that jurisdiction, even when it has been established.”). And in the three 
decades since Cardinal Chemical Co. was decided, district courts have routinely dismissed 
invalidity counterclaims without prejudice under circumstances like those present here. 
E.g., PayRange, Inc. v. KioSoft Techs., LLC, No. 1:20-cv-20970-LFL, 
2023 WL 6310230
, 
at *3 (S.D. Fla. June 27, 2023) (dismissing invalidity counterclaims without prejudice 
because “the anticipated benefit of exercising jurisdiction over the invalidity counterclaims 
[appeared] hypothetical”).                                                

    Ultimately,  the  Court  finds  that  declining  to  exercise  its  jurisdiction  over  the 
invalidity counterclaim serves the interests of judicial economy. True, if Little Giant 
appeals the finding of non-infringement and prevails, there is a possibility that this case 
could be remanded for further proceedings. That might result in additional litigation in this 
Court and, potentially, the Court might have to address invalidity at that time. However, it 

is neither certain that Little Giant will appeal; nor that it would prevail; nor that, in the 
event both of those things occur, the parties wouldn’t find a way to resolve their differences 
around the ’416 patent rather than continue this litigation. But in the event the case were to 
return to this Court after a successful appeal of the non-infringement ruling, the parties and 
the Court would not be forced to return to square one. Rather, we would have the benefit 

of the work the parties have already performed in this litigation regarding the invalidity 
issues.                                                                   
    On the other hand, it is equally true that, like appellate courts, trial courts have 
limited resources, and this Court is no different. This Court has made a finding of non-
infringement in Tricam’s favor that fully resolves that key aspect of this dispute. As a 

result, resolving all the invalidity issues at this stage could be a waste of the Court’s 
resources as it would need to address a dense set of competing briefs on the issues of written 
description, lack of enablement, indefiniteness, anticipation, and obviousness. This is 
especially true where, as here, the issues of invalidity are numerous, far from clear, and 
Tricam hasn’t persuaded the Court that there is any additional benefit to obtaining a finding 
of invalidity based on a threat of future litigation concerning the patent at issue in this suit. 
See Eugene Baratto, Textures, LLC v. Brushstrokes Fine Art, Inc., 
701 F. Supp. 2d 1068, 1083
 (W.D. Wis. 2010) (“Because I am granting summary judgment for Brushstrokes on 
the  core  issue  of  non-infringement  on  clear  grounds  and  because  Brushstrokes’s 
counterclaim for invalidity is less certain, I am exercising my discretion and dismissing 
without prejudice Brushstrokes’s invalidity counterclaim.”) (emphasis added). 
    Accordingly, in the Court’s discretion, it declines to exercise jurisdiction over 

Tricam’s  invalidity  counterclaim  and  dismisses  that  counterclaim  without  prejudice. 
Further, as set forth below, the Court modifies its March 28th Summary Judgment Order 
and directs the Clerk of Court to enter judgment.                         

ORDER

    For the reasons set forth above, IT IS HEREBY ORDERED THAT           

    1.   The Court’s March 28, 2024 Order (Doc. 208) on the parties’ motions for 
         summary judgment and to exclude expert testimony is modified as set forth 
         below.                                                          
    2.   Plaintiff’s Motion for Summary Judgment (Doc. 164) is DENIED. The 
         Court denies Plaintiff’s motion on the merits to the extent Plaintiff argues 
         that it is entitled to judgment as a matter of law on the issues of whether the 
         Accused Ladders infringe the cavity limitation in the ’416 patent literally or 
         under the doctrine of equivalents. The Court does not address Plaintiff’s 
         arguments concerning invalidity issues based on its decision to decline to 
         exercise jurisdiction over Defendant’s invalidity counterclaim. 
    3.   Defendant’s  Motion  for  Summary  Judgment  (Doc.  167)  is  GRANTED 
         because no reasonable jury could conclude that the Accused Ladders literally 
         infringe  the  cavity  limitation  in  the  ’416  patent  and  amendment-based 
         estoppel precludes Plaintiff from relying on the doctrine of equivalents to 
         prove  infringement  of  this  limitation.  The  Court  does  not  address 
        Defendant’s arguments concerning invalidity issues based on its decision to 
        decline to exercise jurisdiction over Defendant’s invalidity counterclaim. 
   4.   Defendant’s Motion to Exclude Expert Testimony of Fred Smith (Doc. 171) 
        is  GRANTED  IN  PART.  The  Court  excludes  Mr.  Smith’s  opinions 
        concerning infringement of the cavity limitation because Mr. Smith failed to 
        apply the Court’s claim construction.                           
   5.   Defendant’s  counterclaim  seeking  a  declaratory  judgment  that  the  ’416 
        patent is invalid is DISMISSED WITHOUT PREJUDICE in the Court’s 
        discretion.                                                     

   Let Judgment be entered accordingly.                                 

Date: June 14, 2024             s/Katherine Menendez                     
                               Katherine Menendez                       
                               United States District Judge             

Reference

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