IP Law Daily, PATENT—E.D.N.Y.: Compact wallet manufacturer proceeds with infringement claims against generic competitor, (Dec 10, 2025)

By Steven D. Cole, J.D.

The manufacturer’s complaint alleging patent and trade-dress infringement withstood the alleged infringing competitor’s motion to dismiss.

The Ridge Wallet, LLC (Ridge Wallet) adequately alleged that Bemmo Inc. (Bemmo)—maker of “knock-off” hard, compact wallets—infringed upon Ridge Wallet’s patent and protected trade dress, according to a federal district court in New York. The case primarily involved Bemmo’s alleged unlawful copying of Ridge Wallet’s money clip and the product’s styling features. Bemmo unsuccessfully moved to dismiss the action on a number of grounds, but its arguments were either unconvincing or asserted prematurely (The Ridge Wallet, LLC v. Bemmo Inc., No. 1:23-cv-02091-EK-TAM (E.D.N.Y. Dec. 9, 2025)).

The wallets. Ridge Wallet manufactures and sells hard, compact wallets, with more than two million products sold as of the filing of its complaint in March 2023. Its design has become synonymous with the brand itself, with consumers referring to knock-offs as “generic ridge wallets.” Bemmo began selling its competing “Slim Wallet” in 2021 on sites such as Amazon.com, which Bemmo markets as a “lightweight” wallet designed to tuck “away in your pocket with no bulge” while still holding “up to 10 cards and … 1–10 bills comfortably.”

The alleged patent infringement. Ridge Wallet owns U.S. Patent No. 10,791,808 (’808 Patent), protecting its wallet’s design. Claims 1 and 14 of the patent, which are at issue here, both detail a “compact wallet” with “at least two rigid plates,” an “encircling elastic band,” a “channeling means” that “allow[s] freedom for the dynamic extension and contraction of the band,” and “an auxiliary feature removably attached to at least one of the … rigid plates.”

Ridge Wallet sufficiently alleged that Bemmo directly infringed upon these patent claims by incorporating a similar auxiliary feature—a recessed “money clip”—in the design of its Slim Wallet. Bemmo contended that its use of screws, instead of a hook, to attach the clip defeated Ridge Wallet’s claim. But Bemmo’s argument was premature at the motion-to-dismiss stage of the litigation, since assessing the merits of its description of the Slim Wallet would require the court to undertake detailed claim construction without the aid of a Markman hearing, expert testimony, or discovery.

Ridge Wallet also adequately stated claims against Bemmo for induced and contributory infringement. Despite Bemmo’s assertion to the contrary, Ridge Wallet’s pleadings alleged scienter. According to the complaint, Bemmo was on notice that its conduct was infringing when Bemmo responded to Ridge Wallet’s Amazon takedown requests in early 2023, which Ridge Wallet had filed based on its allegation of Bemmo’s infringement of the ’808 Patent. Bemmo countered by arguing that this exchange demonstrated that it has always maintained that its Slim Wallet did not infringe the ’808 Patent. Nevertheless, Bemmo’s “good-faith belief” presented a question of fact that would be best resolved at a later stage of the proceedings.

The alleged trade dress infringement. Ridge Wallet’s description of its Forged Ember trade dress met the standard of precision required at the motion-to-dismiss stage to describe some specific combination of components so as to permit the court to adequately evaluate the claim. The complaint defined the trade dress of the “compact wallet” as having “an irregularly-shaped geometric red speckling pattern … on a carbon fiber surface, consisting of various shades of gray and black … positioned to cover one or more of the wallet’s exterior plates.” Bemmo pointed out that Ridge Wallet used its Forged Ember trade dress on other products. But this was immaterial, since the complaint focused on the protection of Ridge Wallet’s compact wallet styling.

Ridge Wallet also adequately pled secondary meaning, alleging that it has spent millions of dollars on marketing its Forged Ember compact wallets, and that its trade dress has received significant unsolicited coverage, with many reviewers simply referring to the wallet as “The Ridge Forged Ember Wallet.”

The complaint’s allegations of non-functionality were sufficient, highlighting the fact that Ridge Wallet’s compact wallets did not have to be decorated with “Forged Ember” to perform their function. This was evident by Ridge Wallet’s own product offerings, which include a host of other compact wallets that do not incorporate the Forged Ember trade dress.

Finally, a likelihood of confusion was clear by simply comparing Ridge Wallet’s product and Bemmo’s Slim Wallet side by side, both of which were sold on Amazon.com.

Punitive and pre-litigation damages. Bemmo’s motion also challenged Ridge Wallet’s ability to recover punitive damages based on willful infringement, as well as its ability to recover pre-litigation damages. The court reserved judgment on both issues, finding that it would be premature to assess claims for damages at this early stage of this litigation.

The Case is No. 1:23-cv-02091-EK-TAM.

Judge: Komitee, E.

Attorneys: Benjamin Weed (The Ridge Wallet LLC) for The Ridge Wallet, LLC. Sandra Adele Hudak (Tarter Krinsky & Drogin LLP) for Bemmo Inc.

Companies: The Ridge Wallet, LLC; Bemmo Inc.

Cases: Patent Trademark TechnologyInternet