Certain Powered Rocker-Recliner and Glider-Recliner Mechanisms and Seating Units Containing Same; Inv. No. 337-TA-1524 (Violation)

This supplemental complaint, a redline incorporating a second supplement, restates the Section 337 complaint of Ultra-Mek, Inc., Leggett & Platt, Inc., and L&P Property Management Company against Living Style, the Henglin Respondents, and Carya Smart. It alleges infringement of the '348, '693, '165, and '168 Patents by powered rocker-recliner and glider-recliner mechanisms and seating units. The filing targets imported powered recliner mechanisms and finished seating units, including Barcalounger- and COLAMY-branded products built with Carya Smart mechanisms. Complainants seek permanent limited exclusion orders, cease-and-desist orders, and a bond during Presidential review. The second supplement appears to add or update respondents and infringement allegations, but the redline does not show what changed. Complainants: Ultra-Mek (owner of the '348 and '693 Patents) and Leggett & Platt and L&P Property Management Company (owner of the '165 and '168 Patents). Proposed respondents: Living Style entities, the Henglin entities (including Nanjing Hengning, Zhejiang Hengjian, Colamy, Aurora Maison, and Aerisnexus), and Jiangsu Carya Smart. Accused products: Carya Smart 5115 powered-rocker and 7115 powered-glider mechanisms and seating units incorporating them, such as Barcalounger and COLAMY recliners. Infringement is alleged literally and/or under the doctrine of equivalents, with direct infringement under 271(a), inducement under 271(b), and contributory infringement by Carya Smart. Domestic industry is alleged under Section 337(a)(3)(A), (B), and (C), based on Ultra-Mek's North Carolina manufacturing and L&P's U.S. facilities, with the 7800/7900-series and Delta, CZ, BEST, and EZ-Pro lines as domestic industry products. Relief requested: institution of an investigation, a violation finding, permanent limited exclusion orders, cease-and-desist orders, and a bond during the 60-day Presidential review period.