J&M Manufacturing v. Kinze: Grain Cart Patent Voided for Indefiniteness
J&M Manufacturing asserted US9113598B2 — covering auger grain cart technology — against rival Kinze Manufacturing’s 1421 Grain Cart and single auger carts. After 937 days of litigation in the Northern District of Iowa, the court invalidated the entire patent on indefiniteness grounds, awarding summary judgment to Kinze.
A single ambiguous phrase sinks J&M’s grain cart patent entirely
J&M Manufacturing, Co, Inc filed suit against Kinze Manufacturing, Inc. on August 26, 2022, in the Northern District of Iowa, asserting infringement of US9113598B2 — a patent directed to grain cart auger technology. The accused products were Kinze’s 1421 Grain Cart and its broader line of single auger grain carts, putting two of Iowa’s major agricultural equipment manufacturers directly at odds over a core piece of harvest logistics technology.
The case resolved on March 20, 2025, when the court granted Kinze’s motion for summary judgment and denied J&M’s cross-motion. The court’s ruling turned on claim construction: the phrase ‘askewed angle,’ which appears in all three claims of the ‘598 Patent, was found to fail the definiteness requirement under 35 U.S.C. § 112. Because every claim depended on that phrase, the invalidity finding was total — leaving J&M with no surviving claims and Kinze free from liability.
The 937-day duration suggests contested claim construction proceedings and likely extensive expert discovery before the indefiniteness issue crystallised at summary judgment. The public record does not disclose whether licensing negotiations were attempted or why the prosecution history failed to clarify the disputed term. What is clear is that the patent’s entire enforceability rested on a phrase the court found incapable of informing skilled artisans of the invention’s scope with reasonable certainty — a drafting vulnerability that proved fatal.
Filing to Judgment on the merits for Defendant in 937 days
937 days — above-average for a district court patent case resolved on summary judgment
Summary judgment for Kinze: what the indefiniteness ruling means for both parties
Patent invalidated for indefiniteness under 35 U.S.C. § 112
Indefiniteness is a validity defence requiring a challenger to show that patent claims fail to inform a skilled artisan of the invention’s scope with reasonable certainty. Here, the court found the term ‘askewed angle’ — present in all three claims — failed that standard when read in light of the specification and prosecution history. Because all claims fell, the patent was entirely invalidated, not just narrowed.
Full invalidity — all claims voidedJ&M loses all enforceability; no surviving claims remain
J&M’s own summary judgment motion was denied simultaneously, confirming there was no viable path to infringement liability. With US9113598B2 invalidated in its entirety, J&M cannot assert this patent against Kinze or any other competitor. Any appeal would require demonstrating that the district court’s claim construction of ‘askewed angle’ was erroneous — a challenging standard given the prosecution history findings.
Patent unenforceableKinze wins on invalidity — 1421 Grain Cart cleared
Kinze secured a merits judgment that eliminates the ‘598 Patent as an ongoing legal threat. The ruling clears the Kinze 1421 Grain Cart and single auger cart line from any liability under this patent. Kinze’s defence team at McKee, Voorhees & Sease successfully converted a definiteness argument into a case-ending summary judgment without the cost and risk of a full trial.
Full dismissal — products clearedGrain cart IP landscape shifts as key J&M patent falls
The ruling signals that grain cart auger patents relying on imprecise angular terminology may be vulnerable to indefiniteness challenges. Competitors and licensees of J&M should audit related patents for similar claim language. For the agricultural equipment sector broadly, this case reinforces that vague directional or geometric terms in claims — without a clear specification anchor — represent a significant prosecution and litigation risk.
Competitor IP risk reducedFull party and counsel information
| Role | Name | Type | Detail |
|---|---|---|---|
| Plaintiff | J&M Manufacturing, Co, Inc | Company | Agricultural equipment manufacturer — holder of US9113598B2 (grain cart auger technology)Search in Eureka ↗ |
| Defendant | Kinze Manufacturing, Inc. | Company | Kinze Manufacturing, Inc. — Iowa-based agricultural equipment maker, producer of the 1421 Grain CartSearch in Eureka ↗ |
| Plaintiff counsel | Ace Factor | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Eric Bartlam | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Gopal Rao Gannamraj | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Jonathan Tehan Deters | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Justin A. Nelson | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Kevin Gerard Rooney | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Meng Xi | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Savannah Ezelle | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Shawn D. Blackburn | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Thomas D. Wolle | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff counsel | Wilbert B Markovits | Attorney | Counsel for J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff law firm | Brown Rudnick LLP | Law Firm | Representing J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff law firm | Markovits Stock & DeMarco LLC | Law Firm | Representing J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff law firm | Rooney IP LLC | Law Firm | Representing J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff law firm | Simmons Perrine Moyer Bergman PLC | Law Firm | Representing J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Plaintiff law firm | Susman Godfrey LLP | Law Firm | Representing J&M Manufacturing, Co, IncSearch in Eureka ↗ |
| Defendant counsel | Glenn L. Johnson | Attorney | Counsel for Kinze Manufacturing, Inc.Search in Eureka ↗ |
| Defendant counsel | Jonathan Lee Kennedy | Attorney | Counsel for Kinze Manufacturing, Inc.Search in Eureka ↗ |
| Defendant counsel | Sarah Marie Dickhut Luth | Attorney | Counsel for Kinze Manufacturing, Inc.Search in Eureka ↗ |
| Defendant law firm | McKee, Voorhees & Sease PLC | Law Firm | Representing Kinze Manufacturing, Inc.Search in Eureka ↗ |
| Presiding judge | Judge N/A | Judge | Iowa Northern District CourtSearch in Eureka ↗ |
Official order — verbatim text
The court’s verdict language is unambiguous in scope: all three claims of the ‘598 Patent were found invalid, and judgment entered entirely in Kinze’s favour. The ruling rests on claim construction — specifically that ‘askewed angle’ fails the definiteness standard of Nautilus, Inc. v. Biosig Instruments, Inc. — rather than on any infringement merits. The simultaneous denial of J&M’s cross-motion confirms the court found no genuine dispute of material fact favouring the plaintiff on the central validity question.
US9113598B2 — Grain cart auger conveyor positioning technology
US9113598B2 (application number US13/506009) covers grain cart auger conveyor technology — specifically the angular arrangement of auger components used to transfer harvested grain from a cart to a truck or storage facility. Auger positioning is a key engineering variable in grain cart design, affecting unloading speed, reach, and compatibility with different transport vehicles. The patent’s three claims all depend on the term ‘askewed angle’ to define the inventive configuration, which the court found fatally ambiguous.
For the agricultural equipment sector, grain cart patents occupy commercially significant territory: efficient unloading is a critical competitive differentiator during harvest season. J&M and Kinze are both established Iowa manufacturers competing directly in this space. The invalidation of US9113598B2 removes a potential barrier to Kinze’s current product line and may signal vulnerability in other J&M patents that employ similar geometric claim language — a risk warranting portfolio-level review by any competitor or licensee.
Should you run an FTO against US9113598B2?
US9113598B2 has been invalidated in its entirety by the Northern District of Iowa, meaning it no longer poses an infringement risk in its current form. However, R&D teams and product managers developing grain cart auger systems should still conduct freedom-to-operate analysis against related J&M patents — the ‘598 Patent may have family members or continuation applications that survive this ruling and cover similar angular positioning technology.
PatSnap Eureka’s FTO Search Agent can map the full J&M patent family around application US13/506009, identify related auger conveyance patents that remain enforceable, and flag claim language in active patents that may cover your grain cart product designs. For agricultural equipment teams operating in harvest logistics, this analysis is especially time-sensitive ahead of new product launches or licensing discussions.
Run a freedom-to-operate analysis on US9113598B2 to assess your product’s exposure
Run FTO in Eureka →Similar patent cases: grain cart and agricultural equipment invalidity disputes
Cases below involve patent invalidity challenges in agricultural equipment — including auger and conveyor technology — adjudicated in Midwestern district courts.
What this case signals for the agricultural equipment IP landscape
A single ambiguous claim term invalidated a three-claim patent. The implications extend well beyond grain carts.
Geometric claim terms need explicit specification anchors to survive challenge
The court’s invalidation of ‘askewed angle’ illustrates a recurring vulnerability: directional or angular terms that lack a clear numerical range, reference plane, or structural definition in the specification are prime indefiniteness targets. Patent owners in agricultural machinery should audit existing claim language against this standard before asserting or licensing.
All-claims invalidity from a single term is a disproportionate litigation risk
Because all three claims of the ‘598 Patent depended on the disputed phrase, J&M had no fallback position once the court ruled on construction. Drafting claims with independent definitional anchors for critical terms — and including dependent claims that could survive partial invalidity — is essential risk mitigation for portfolio owners in the agricultural equipment space.
J&M v Kinze — key questions answered
The court invalidated US9113598B2 because the claim term ‘askewed angle’ failed to inform those skilled in the art about the scope of the invention with reasonable certainty. All three claims of the patent depended on this phrase. Applying the definiteness standard under 35 U.S.C. § 112, and reviewing the specification and prosecution history, the court found the term fatally ambiguous and granted summary judgment for Kinze.
J&M Manufacturing accused Kinze’s 1421 Grain Cart and Kinze’s broader line of single auger grain carts of infringing US9113598B2. The patent relates to grain cart auger conveyor positioning technology. With the patent now invalidated, those products are cleared from liability under this specific patent.
Indefiniteness is a ground for patent invalidity under 35 U.S.C. § 112. A claim is indefinite if it fails to inform skilled artisans of the invention’s scope with reasonable certainty when read in light of the specification and prosecution history. An indefinite patent — or one with indefinite claims — is unenforceable: the patent holder cannot obtain damages or injunctions based on it.
The court granted Kinze’s motion for summary judgment on invalidity grounds, finding the ‘598 Patent indefinite in its entirety. Simultaneously, the court denied J&M’s cross-motion for summary judgment. The court also denied Kinze’s motion to strike. Judgment was entered in favour of Kinze, and the case was dismissed.
J&M could appeal to the United States Court of Appeals for the Federal Circuit, which has exclusive jurisdiction over patent appeals. To succeed, J&M would need to show that the district court erred in its claim construction of ‘askewed angle’ — either by misapplying the definiteness standard or by misreading the specification or prosecution history. Federal Circuit review of claim construction is de novo, which gives an appellant some leverage, but definiteness findings supported by prosecution history analysis are difficult to overcome.
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