The case

The case is Happy Products Inc. v. Ontel Products Corporation, No. 2:24-cv-09819 (D.N.J.). Happy Products' amended complaint (ECF No. 34) is titled as a complaint for patent infringement, trade dress infringement, false advertising, unfair competition, and tortious interference. The October 26, 2026 opinion and order (ECF No. 190) addresses claim construction of the asserted patent, U.S. Patent RE48,479, titled "Multiple Viewing Angle Media Support." The patent reissued on March 23, 2021 from U.S. Patent 9,642,454 and is directed to an apparatus that supports media such as electronic readers, tablet computers, magazines, and books for comfortable viewing. According to the amended complaint, the reissue recites the same claims as the '454 patent plus 19 additional claims. The court held a claim construction hearing on August 12, 2026, and neither side called expert witnesses.

Solid interior

Claim 1 recites an apparatus with three support sides, each with a back support and an edge support, in physical communication with two ends of a "solid interior," and it requires that the solid interior be a pillow covered in fabric. Happy Products proposed "an interior that is a contiguous piece of material (for example, foam) rather than a shredded or particulate material (for example, pillow feathers)." Ontel proposed "an interior that is one contiguous piece without any cavities or holes," pointing to the specification's description of the foam's firmness and to the reasons for allowance of the original '454 patent. The court construed the term as "an interior that is one whole contiguous piece of material (for example, foam)." It reasoned that the claim language supports a contiguous piece because the support sides are in physical communication with the ends of the solid interior, that a skilled artisan reading the claims and figures would not take the word "pillow" to mean an interior stuffed with feathers, and that "solid," read with the figures, has its plain meaning of "a material that is one whole unit, without holes."

Other constructions

The court gave "a body," which appears in claim 12, its plain and ordinary meaning of "the main piece of the apparatus," declining Ontel's proposal to give it the same meaning as "solid interior" because the claims use the two terms differently. It construed "virtual plane" as "an imaginary plane configured from (i) the top of the back support of one side and (ii) the outer edge of the edge support of the adjacent side when the apparatus rests on it," and "viewing angle" as "an angle that is orthogonal to the back support or support back for a user." It also adopted the parties' agreed construction of "plane angle" as "the angle between the plane of a back support and a virtual plane."

Indefiniteness deferred

Ontel contends that multiple terms are indefinite, and the court had earlier allowed the parties to defer indefiniteness and raise it at summary judgment or trial. For "support angle," Ontel argued only indefiniteness and proposed no alternative construction, and the court deferred the arguments on that term.

What to watch next

Watch for Ontel's indefiniteness arguments at summary judgment or trial, as the court allowed.