DCT
2:09-cv-01623
Molex Inc v. Lynn Products Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Molex Inc (Delaware)
- Defendant: Lynn Products Inc. (California); All Best technique Corp. (California)
- Plaintiff’s Counsel: Jones Day
- Case Identification: 2:09-cv-01623, C.D. Cal., 03/09/2009
- Venue Allegations: Venue is alleged in the Central District of California based on the Defendants being California corporations with their principal places of business within the district.
- Core Dispute: Plaintiff alleges that Defendants’ plug connector assemblies, which are compliant with industry standards for SAS-SATA connectors, infringe nine U.S. patents related to electrical connector design, construction, and alignment features.
- Technical Context: The technology concerns high-speed electrical connectors used to link devices like hard drives to computer systems, a critical component in the data storage and server markets.
- Key Procedural History: The complaint alleges that Plaintiff is the owner of patent rights necessary to implement the SAS-SATA standards. It further alleges that Plaintiff offered Defendants a license on a non-exclusive, nondiscriminatory basis, which Defendants refused to accept while continuing to sell standard-compliant products. For several patents, Plaintiff alleges it provided Defendants with actual notice of the pending patent applications, forming a basis for claims of willful infringement and pre-issuance damages.
Case Timeline
| Date | Event |
|---|---|
| 2004-07-07 | Priority Date for U.S. Patent Nos. 7,198,519 and 7,351,104 |
| 2004-12-17 | Priority Date for U.S. Patent Nos. 7,303,438, 7,448,897, and 7,413,461 |
| 2005-02-18 | Priority Date for U.S. Patent No. 7,281,937 |
| 2005-02-23 | Priority Date for U.S. Patent Nos. 7,175,444 and 7,344,409 |
| 2005-08-15 | Priority Date for U.S. Patent No. 7,442,089 |
| 2007-02-13 | U.S. Patent No. 7,175,444 Issues |
| 2007-04-03 | U.S. Patent No. 7,198,519 Issues |
| 2007-10-16 | U.S. Patent No. 7,281,937 Issues |
| 2007-12-04 | U.S. Patent No. 7,303,438 Issues |
| 2008-03-18 | U.S. Patent No. 7,344,409 Issues |
| 2008-04-01 | U.S. Patent No. 7,351,104 Issues |
| 2008-08-19 | U.S. Patent No. 7,413,461 Issues |
| 2008-10-28 | U.S. Patent No. 7,442,089 Issues |
| 2008-11-11 | U.S. Patent No. 7,448,897 Issues |
| 2009-03-09 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,175,444 - "Plug Connector and Construction Therefor"
- Issued: February 13, 2007
The Invention Explained
- Problem Addressed: The patent describes the problem of cable weight and movement loosening the connection point between a cable plug and a circuit board-mounted receptacle, which can break signal pathways and cause the circuit board to fail (’444 Patent, col. 1:16-24). Existing solutions, like large guide frames, were described as taking up valuable space on the circuit board (’444 Patent, col. 1:25-32).
- The Patented Solution: The invention is a plug connector system that uses a separate guide member, or shield, mounted to the circuit board forward of the receptacle connector (’444 Patent, col. 5:55-59). This guide member defines a channel that aligns the plug connector and includes a latching mechanism (a spring arm with a catch) that secures the plug connector, thereby absorbing strain that would otherwise be placed on the receptacle connector itself (’444 Patent, col. 7:27-34; Fig. 3). The plug connector also includes a flange that extends over its mating portion to protect it from damage (’444 Patent, col. 8:17-30).
- Technical Importance: This approach provides mechanical stability and alignment for pluggable connectors without requiring a large, integrated cage, conserving circuit board real estate.
Key Claims at a Glance
- The complaint asserts independent claim 1 (’444 Patent, col. 13:41).
- Essential elements of claim 1 include:
- A plug connector for connecting wires to a mating connector, comprising a connector housing with an insulative body portion and a forward face.
- A circuit card with a leading edge for mating and a trailing edge for wire termination, with the leading edge extending forward from the housing's forward face.
- A plurality of wires terminated to the trailing edge contacts.
- The housing includes a first flange extending a preselected distance from the forward face and spaced apart from the circuit card.
- The housing also includes a second flange extending a second preselected distance from the forward face and spaced apart from the circuit card, with the two flanges flanking the circuit card.
- The housing further includes a front wall and two side walls defining a hollow termination nest.
U.S. Patent No. 7,303,438 - "Plug Connector with Mating Protection and Alignment Means"
- Issued: December 4, 2007
The Invention Explained
- Problem Addressed: The patent addresses similar issues as the ’444 Patent, including the difficulty of orienting plug connectors for proper mating in confined spaces and the risk of contamination on exposed terminals (’438 Patent, col. 1:35-42).
- The Patented Solution: The invention is a plug connector that includes multiple alignment features. Primary alignment is provided by top and bottom flanges that flank a circuit card mating blade, protecting it and guiding it into a receptacle (’438 Patent, col. 3:47-61). A secondary alignment is provided by T-shaped lugs, or projections, on the outer side surfaces of the connector body. These lugs engage corresponding slots in a guide member to ensure precise orientation and to act as stop members that limit the insertion travel of the plug connector (’438 Patent, col. 4:14-27; Fig. 12).
- Technical Importance: This design provides a multi-stage alignment mechanism that enhances the reliability and durability of high-density connector mating, particularly in blind-mating applications common in servers and data storage hardware.
Key Claims at a Glance
- The complaint asserts independent claims 1, 14, and 22 (’438 Patent, col. 12:1-13:25).
- Essential elements of claim 1 include:
- A plug connector comprising a connector housing with a body portion and a forward face.
- A circuit card with a leading edge for mating, extending forward from the housing's forward face to define a mating blade.
- A first flange extending from the forward face and spaced from the circuit card.
- A second flange extending from the forward face and spaced from the circuit card, with the flanges having different widths.
- One of the flanges includes an angled lead-in configuration along its side edges.
U.S. Patent No. 7,448,897 - "Plug Connector with Mating Protection"
- Issued: November 11, 2008
- Technology Synopsis: This patent describes a plug connector with a protective flange extending from the connector body over the mating circuit card. The invention aims to protect the circuit card from "stubbing" (physical damage during insertion) and to provide a means for aligning the plug connector with the receptacle.
- Asserted Claims: Independent claims 1, 10, and 16 (Compl. ¶32, 38).
- Accused Features: The "Mini SAS series" from Defendant Lynn and the "I Best mini SAS series" from Defendant All Best are accused of infringement (Compl. ¶32, 38).
U.S. Patent No. 7,281,937 - "Low Profile Latching Connector"
- Issued: October 16, 2007
- Technology Synopsis: The patent discloses a low-profile plug connector with a latching mechanism designed for use with electronic devices. The latching mechanism uses a ramp and lobe system where horizontal movement of a pull-tab actuator is converted into vertical movement of a latching member to engage or disengage hooks from a guide frame.
- Asserted Claims: Independent claims 1, 15, and 28 (Compl. ¶45).
- Accused Features: The "I Best External mini SAS series" from Defendant All Best is accused of infringement (Compl. ¶45).
U.S. Patent No. 7,198,519 - "Edge Card Connector Assembly with Keying Means for Ensuring Proper Connection"
- Issued: April 3, 2007
- Technology Synopsis: This patent describes a surface-mount edge card connector for high-speed data applications. The invention includes a keying mechanism, in the form of a hollow recess on the connector's bottom, which receives a corresponding male portion from a mating connector to ensure proper orientation and prevent incorrect insertion.
- Asserted Claims: Independent claims 1 and 14 (Compl. ¶52).
- Accused Features: The "I Best SMT Connector series" from Defendant All Best is accused of infringement (Compl. ¶52).
U.S. Patent No. 7,442,089 - "Edge Card Connector Assembly with High-Speed Terminals"
- Issued: October 28, 2008
- Technology Synopsis: The patent discloses a high-speed edge card connector with terminals shaped to control electrical impedance. The terminals have a thin configuration to reduce capacitance and are supported on opposing sidewalls of the housing, with retention portions that engage the housing to hold the contact portions in a cantilevered position.
- Asserted Claims: Independent claims 1, 11, and 18 (Compl. ¶59).
- Accused Features: The "I Best SMT Connector series" from Defendant All Best is accused of infringement (Compl. ¶59).
U.S. Patent No. 7,351,104 - "Keyed Housing for Use with Small Size Plug Connectors"
- Issued: April 1, 2008
- Technology Synopsis: This patent describes a shielded housing for a circuit board connector (e.g., SFP-style). The housing includes guide members, or projections, that extend into the housing's interior to guide a mating plug connector and ensure correct orientation, particularly for blind mating.
- Asserted Claims: Independent claim 1 (Compl. ¶66).
- Accused Features: The "I Best Retention Fit and SMT Cage series" from Defendant All Best is accused of infringement (Compl. ¶66).
U.S. Patent No. 7,344,409 - "Connector Guide Member"
- Issued: March 18, 2008
- Technology Synopsis: The patent relates to a connector shroud or guide member that is mounted on a circuit board separately from the connector it serves. The shroud forms a guide channel and includes features like a press tab and notches to orient and secure a mating plug connector.
- Asserted Claims: Independent claims 1 and 12 (Compl. ¶73).
- Accused Features: The "I Best Retention Fit and SMT Cage series" from Defendant All Best is accused of infringement (Compl. ¶73).
U.S. Patent No. 7,413,461 - "Connector Guide with Latch and Connectors Therefor"
- Issued: August 19, 2008
- Technology Synopsis: This patent describes a connector guide mounted on a circuit board in front of a receptacle connector. The guide includes a latch that engages the mating plug connector, providing alignment and strain relief separately from the receptacle connector itself.
- Asserted Claims: Independent claim 9 (Compl. ¶81).
- Accused Features: The "I Best SMT Cage series" from Defendant All Best is accused of infringement (Compl. ¶81).
III. The Accused Instrumentality
Product Identification
- The accused products are "plug connector assemblies" sold by the Defendants (Compl. ¶12, 15). These include, but are not limited to, Defendant Lynn's "Mini SAS series" and Defendant All Best's "I Best mini SAS series," "I Best External mini SAS series," "I Best SMT Connector series," and "I Best Retention Fit and SMT Cage series" (Compl. ¶12, 15, 45, 52, 66, 73).
Functionality and Market Context
- The complaint alleges that the accused products are manufactured and sold for use in interconnect systems that implement the SAS-SATA (Serial Attached SCSI and Serial ATA) standards (Compl. ¶8-10). The functionality of these products is to provide high-speed data connections, and they are allegedly made "in accordance with the SAS-SATA standards" (Compl. ¶13).
No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not contain detailed infringement contentions or claim charts. The analysis below is based on the general allegations that the accused product lines practice the asserted claims.
7,175,444 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a connector housing, the connector housing including an insulative body portion, the connector housing body portion including a forward face; | The accused "Mini SAS series" and "I Best mini SAS series" products are alleged to include a connector housing with an insulative body portion and a forward face. | ¶12, 15 | col. 13:43-46 |
| a circuit card, the circuit card including a leading edge with contacts for mating with the mating connector and a trailing edge with contacts for termination... | The accused products are alleged to include a circuit card with mating and termination contacts. | ¶12, 15 | col. 13:47-51 |
| ...said circuit card being disposed in said connector housing such that the circuit card leading edge extends forwardly of the connector body portion forward face... | The accused products are alleged to have a circuit card that extends forward from the housing. | ¶12, 15 | col. 13:51-55 |
| said connector housing body portion including a first flange extending a first preselected distance from said connector housing body portion and spaced apart from said circuit card... | The accused products are alleged to have a first protective flange spaced apart from the circuit card. | ¶12, 15 | col. 13:58-62 |
| ...and a second flange extending a second preselected distance from said connector housing body portion and spaced apart from said circuit card; and, said first and second flanges flanking said circuit card. | The accused products are alleged to have a second protective flange, with the two flanges flanking the circuit card. | ¶12, 15 | col. 13:62-66 |
7,303,438 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...a connector housing, the body portion including a forward face; a circuit card, the circuit card including a leading edge with contacts for mating... | The accused "Mini SAS series" and "I Best mini SAS series" products are alleged to have a housing and a circuit card with mating contacts. | ¶19, 25 | col. 12:2-5 |
| said circuit card being disposed in said connector housing such that the circuit card leading edge extends forwardly of the connector body portion forward face...to define a mating blade of the connector... | The accused products are alleged to have a circuit card extending forward to form a mating blade. | ¶19, 25 | col. 12:6-9 |
| a first flange extending a first preselected distance from said connector housing body portion and spaced apart from said circuit card, and a second flange... | The accused products are alleged to have first and second protective flanges spaced from the circuit card. | ¶19, 25 | col. 12:10-15 |
| wherein said circuit card leading edge and first and second flanges all have respective widths, the width of said circuit card leading edge being less than the width of said first flange but greater than the width of said second flange... | The accused products are alleged to have flanges and a circuit card with the specific relative widths required by the claim. | ¶19, 25 | col. 12:16-20 |
| ...and one of said first and second flanges including an angled lead-in configuration along side edges thereof. | The accused products are alleged to have a flange with an angled lead-in feature. | ¶19, 25 | col. 12:20-22 |
Identified Points of Contention
- Scope Questions: The infringement allegations are directed at entire product series (e.g., "Mini SAS series"). A central question will be whether every product within each accused series practices every limitation of the asserted claims. The analysis may require a product-by-product examination.
- Technical Questions: The complaint does not provide specific evidence, such as diagrams or technical specifications, mapping the features of the accused products to the claim elements. A key question for the court will be what evidence demonstrates that the accused products meet the specific structural and dimensional requirements of the claims, such as the relative widths of the flanges and circuit card in claim 1 of the ’438 Patent.
V. Key Claim Terms for Construction
The complaint does not provide sufficient detail for analysis of specific claim construction disputes. However, based on the technology, certain terms may become central to the case.
- The Term: "T-shaped projection" (from asserted claim 7 of the ’438 Patent, which depends from claim 6).
- Context and Importance: This term describes the secondary alignment feature of the plug connector. Practitioners may focus on this term because its definition will determine the scope of protection for the patent's alignment and stop-member functionality. The dispute will likely center on whether the term is limited to the specific T-shape shown in the patent's figures or if it can encompass other shapes that perform a similar alignment and stop function.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of these lugs as "effecting a secondary alignment" and serving as "stop members that limit the forward travel" (’438 Patent, col. 4:14-27). A party could argue that any projection performing this dual function falls within the scope of the term.
- Evidence for a Narrower Interpretation: Figure 12 provides a detailed depiction of the "T-shape," showing a center leg (1227) and a base (1228) perpendicular to the center leg (’438 Patent, col. 11:10-15; Fig. 12). A party could argue the term should be limited to this specific geometric configuration, as it is the only embodiment disclosed.
VI. Other Allegations
Indirect Infringement
- The complaint alleges that both Defendants infringed "by knowingly and actively inducing others to infringe" (Compl. ¶12, 15, 19, 25, etc.). No specific facts supporting inducement, such as user manuals or marketing materials, are detailed.
Willful Infringement
- Willfulness is alleged for the '438 patent and all subsequent patents asserted in the complaint. The basis for this allegation is that Defendants were "provided with actual notice of the application underlying the... patent and that upon issuance... unlicensed activities would be an infringement" (Compl. ¶20, 26, 33, etc.). The complaint alleges this pre-suit knowledge makes the infringement "objectively reckless and willful" (Compl. ¶21, 27, 34, etc.).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute presents several core questions for the court that will likely define the litigation's trajectory.
- A central issue appears to be one of industry standards and licensing: The complaint alleges the patents are necessary to implement the SAS-SATA standards and that a license offer was refused. This raises the question of whether the patents are, in fact, standards-essential and what legal effect, if any, the alleged licensing negotiations have on the claims for infringement, willfulness, and damages.
- A key evidentiary question will be one of elemental proof: The complaint makes broad allegations against entire product lines without providing detailed evidence mapping product features to claim limitations. The case will likely turn on whether Plaintiff can produce sufficient technical evidence to prove that the accused products meet, limitation-by-limitation, the specific structural requirements of the asserted claims.
- The case may also involve a critical question of definitional scope: The patents claim specific mechanical structures, such as flanges with particular relative widths and "T-shaped projections." A core legal issue will be how these terms are construed and whether the court's construction will be broad enough to read on the designs of the accused standard-compliant connectors.