Wonderland Switzerland AG v. Evenflo Company, Inc.

Authored by: Jeremy J. Gustrowsky

A recent Federal Circuit decision offers important guidance on patent infringement, claim construction, and the standards for granting injunctions in patent cases. The dispute involved Wonderland Switzerland AG and Evenflo Company, Inc., both makers of child car seats. Wonderland accused Evenflo of infringing two patents—U.S. Patent No. 7,625,043 and U.S. Patent No. 8,141,951—covering various car seat features, including mechanisms for attaching seat backs and safety features.

The court examined whether Evenflo’s 4-in-1 car seats infringed claim 1 of the ’043 patent, which requires a seat back with a “locking mechanism for selectively detachably connecting” it to the seat assembly. The Federal Circuit found that Evenflo’s 4-in-1 seats did not meet this requirement, as the necessary locking components were located on the seat assembly, not the seat back. The court said that no reasonable jury could have found infringement under the doctrine of equivalents, and the therefore reversed the infringement finding for these products.

The decision also addressed claim construction disputes, such as the meaning of “pair of receptacles” and “attachment arms . . . for engagement.” The court upheld the district court’s constructions, finding them consistent with the patent language and supported by substantial evidence. On the ’951 patent, the court clarified that “connected to” does not always require physically separate components; it can include distinct portions of a single, integrally formed structure, as long as they serve different purposes.

The ruling also addressed standards for granting permanent injunctions. The Federal Circuit reversed the district court’s injunctions on both patents, finding that Wonderland had not provided non-speculative evidence of irreparable harm—such as lost sales or reputational damage directly tied to Evenflo’s actions. The court emphasized that injunctions are an extraordinary remedy and require clear, non-conclusory proof of harm that cannot be compensated by money damages.

Finally, the court addressed Wonderland’s cross-appeal regarding willful infringement. It found that the district court improperly excluded an email chain that was highly relevant to Evenflo’s awareness of potential infringement. The exclusion of this evidence was not harmless, so the court ordered a new trial on willful infringement for the relevant products.