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Federal Circuit Affirms Non-Infringement in Ladder Patent Dispute

The Federal Circuit Court of Appeals affirmed a Minnesota district court's summary judgment of non-infringement in favor of Tricam Industries against Little Giant Ladder Systems in a patent dispute decided Feb. 5, 2026. The nonprecedential decision involves U.S. Patent No. 10,767,416 and marks the latest development in ongoing intellectual property litigation between the competing ladder manufacturers.

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Seal of the Federal Circuit Court of Appeals

Case Information

Case No.:
24-2115

Key Takeaways

  • Federal Circuit affirmed Minnesota district court's summary judgment of non-infringement in favor of Tricam Industries
  • Case involves U.S. Patent No. 10,767,416 and dispute between two major ladder manufacturers
  • Court found accused products don't literally infringe 'cavity' limitation and prosecution history estoppel bars doctrine of equivalents
  • Decision is nonprecedential, limiting its impact as legal precedent for future patent cases

The Federal Circuit Court of Appeals affirmed a district court's summary judgment of non-infringement in favor of Tricam Industries, Inc. against Little Giant Ladder Systems, LLC in a patent dispute decided Feb. 5, 2026.

The appeals court upheld the U.S. District Court for the District of Minnesota's ruling that Tricam's accused products do not infringe Little Giant's U.S. Patent No. 10,767,416. The case, *Little Giant Ladder Systems, LLC v. Tricam Industries, Inc.* (Fed. Cir. 2026), represents ongoing intellectual property litigation between two major ladder manufacturing companies.

Circuit Judges Kimberly A. Reyna and Pauline Newman, along with District Judge Freeman sitting by designation, heard the appeal. Judge Chen authored the nonprecedential opinion for the Federal Circuit panel.

The original lawsuit was filed in the District of Minnesota under case number 0:20-cv-02497-KMM-ECW before Judge Katherine Marie Menendez. The district court initially granted summary judgment in March 2024, which was later vacated in part in April 2024, then modified and superseded by a June 14, 2024 summary judgment order.

According to the Federal Circuit opinion, the district court determined that Tricam's accused products do not literally infringe the patent's "cavity" limitation. The lower court also found that prosecution history estoppel bars Little Giant from relying on the doctrine of equivalents to establish infringement.

Prosecution history estoppel is a legal doctrine that prevents patent holders from recapturing claim scope that was surrendered during patent prosecution through the doctrine of equivalents. This doctrine typically applies when a patent applicant narrows claims to avoid prior art or overcome rejections during the patent examination process.

The '416 patent at the center of the dispute relates to ladder technology, though the specific technical details of the patent claims and accused products were not fully detailed in the available portion of the court filing.

Little Giant was represented by Mark A. Miller of Dorsey & Whitney LLP in Salt Lake City, who argued the case before the Federal Circuit. The company's legal team also included Brett L. Foster, Elliot Hales, and Shannon L. Bjorklund from the firm's Minneapolis office.

Tricam's defense was handled by Eric Hugh Chadwick of DeWitt LLP in Minneapolis, with assistance from Zachary Paul Armstrong.

The Federal Circuit has exclusive jurisdiction over patent appeals from federal district courts, making it the final arbiter of most patent disputes unless the Supreme Court grants review. The court's decision is marked as nonprecedential, meaning it cannot be cited as binding authority in future cases, though it may be referenced for its persuasive value.

The ladder industry has seen increased patent litigation in recent years as manufacturers compete for market share in both consumer and commercial segments. Little Giant and Tricam are both established players in the ladder manufacturing space, with product lines that include extension ladders, step ladders, and specialty ladder systems.

Patent infringement cases in the ladder industry often focus on mechanical innovations related to safety features, adjustment mechanisms, and structural improvements. The technical nature of these disputes frequently involves detailed claim construction analysis and comparisons between patented inventions and accused products.

The affirmance of summary judgment represents a complete victory for Tricam at the appellate level. Summary judgment is granted when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law. In patent cases, this often occurs when claim construction definitively resolves the infringement question.

For Little Giant, the Federal Circuit's affirmance means the company cannot pursue damages or injunctive relief against Tricam based on the '416 patent. The decision also validates Tricam's freedom to operate with respect to the accused products without fear of infringement liability under this particular patent.

The case underscores the challenges patent holders face when prosecution history creates estoppel issues that limit their ability to enforce patents under the doctrine of equivalents. Patent prosecutors must carefully balance the need to overcome prior art with preserving broad claim scope for enforcement purposes.

While this decision resolves the immediate dispute over the '416 patent, it does not preclude future patent litigation between these companies based on other intellectual property. The competitive nature of the ladder industry and the ongoing innovation in safety and design features suggest that patent disputes may continue to arise between major manufacturers.

The nonprecedential nature of the ruling limits its broader impact on patent law, but the decision provides insight into how courts analyze literal infringement and prosecution history estoppel in mechanical patent cases.

Topics

patent lawintellectual propertyladder industrysummary judgmentdoctrine of equivalentsprosecution history estoppel

Original Source: courtlistener

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