DCT
2:17-cv-05382
Reversible Connections LLC v. GBT Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Reversible Connections LLC (Delaware)
- Defendant: GBT. Inc. (California)
- Plaintiff’s Counsel: Stradling Yocca Carlson & Rauth, P.C.; Friedman, Suder & Cooke
- Case Identification: 2:17-cv-05382, C.D. Cal., 10/01/2021
- Venue Allegations: Venue is alleged to be proper based on Defendant’s principal place of business being located in the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s computer products incorporating USB Type-C ports infringe a patent related to a reversible, double-sided USB-compatible connector with electronic short-circuit protection.
- Technical Context: The technology addresses the orientation-specific limitations of early USB standards by enabling a connector to function regardless of which way it is inserted into a receptacle.
- Key Procedural History: The original complaint in this matter was filed in 2017. The patent-in-suit subsequently underwent an ex parte reexamination, initiated by the patent owner in 2020, during which the originally issued claims 1-24 were canceled and new claims 25-43 were added and confirmed as patentable by the USPTO in 2021. This First Amended Complaint asserts one of these newly-added claims.
Case Timeline
| Date | Event |
|---|---|
| 2004-06-17 | ’825 Patent Earliest Priority Date |
| 2008-12-02 | ’825 Patent Issue Date |
| 2017-07-20 | Original Complaint Filing Date |
| 2020-04-29 | Ex Parte Reexamination Requested |
| 2021-07-07 | ’825 Patent Reexamination Certificate Issued |
| 2021-10-01 | First Amended Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,458,825 - "DOUBLE-SIDED USB-COMPATIBLE PLUG CONNECTOR ADAPTED FOR INSERTION IN EITHER ORIENTATION INTO A USB-COMPATIBLE RECEPTACLE"
- Patent Identification: U.S. Patent No. 7,458,825, "DOUBLE-SIDED USB-COMPATIBLE PLUG CONNECTOR ADAPTED FOR INSERTION IN EITHER ORIENTATION INTO A USB-COMPATIBLE RECEPTACLE," issued December 2, 2008.
The Invention Explained
- Problem Addressed: The patent describes how prior art USB connectors could only be inserted in one orientation. For thin, card-like devices, inserting the connector upside-down created a danger that the power contacts (VBUS) on the plug would touch the grounded metallic housing of the receptacle, causing a short circuit (’825 Patent, col. 2:40-52).
- The Patented Solution: The invention is a multi-contact plug connector with contacts on both its top and bottom surfaces. These two sets of contacts are arranged in a "mutually opposed" or anti-phase relationship, allowing the plug to connect to a standard, single-sided USB receptacle regardless of insertion orientation (’825 Patent, Fig. 2c; col. 5:1-8). To prevent short circuits, the connector incorporates an "electronic short circuit prevention device," such as diodes, that ensures current flows correctly from the VBUS pin and blocks current flow if the VBUS pin is incorrectly connected to ground (’825 Patent, col. 5:42-61).
- Technical Importance: This technology offered a way to create a user-friendly, reversible connector that was compatible with the vast ecosystem of existing, non-reversible USB receptacles, addressing a significant usability complaint of the era (’825 Patent, col. 1:47-52, col. 2:20-27).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 25, which was added during reexamination (Compl. ¶¶ 7, 11).
- Independent Claim 25 requires:
- A multi-contact connector with first and second sets of "mutually opposed contacts" on opposite surfaces.
- The contacts are "electrically interconnected" and "spatially aligned in a mutually opposed relationship."
- The connector can be connected in two orientations to a "USB-compatible receptacle" that has metallic leaves and a single set of internal contacts.
- "Identical functionality" is obtained regardless of the connector's orientation.
- The connector includes an "electronic short circuit prevention device" to prevent a short circuit between the receptacle's VBUS and GND contacts.
- The complaint alleges infringement of "one or more claims" (Compl. ¶13).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are computer motherboards, desktop computers, laptops, and other electronics manufactured and sold by G.B.T. that include USB Type-C ports (Compl. ¶7).
Functionality and Market Context
- The complaint alleges that the accused products "adhere to the USB Type C or USB Type C compatible standard" (Compl. ¶7).
- The relevant functionality includes a connector with "two sets of mutually opposed contacts" that are "electrically interconnected and are spatially aligned in a mutually opposed relationship," enabling connection in either orientation (Compl. ¶7).
- The products are also alleged to contain "circuitry connected to the USB ports that provides short circuit prevention," specifically for preventing a short between a VBUS contact and a GND contact (Compl. ¶7).
- No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
’825 Patent Infringement Allegations
| Claim Element (from Independent Claim 25) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A multi-contact connector supporting on opposite surfaces first and second sets of mutually opposed contacts | The accused USB Type-C ports include a connector that has "two sets of mutually opposed contacts." | ¶7 | col. 5:42-50 |
| wherein corresponding contacts in each set are electrically interconnected and are spatially aligned in a mutually opposed relationship | The corresponding contacts in each set in the accused ports "are electrically interconnected and are spatially aligned in a mutually opposed relationship." | ¶7 | col. 5:1-8 |
| allowing the multi-contact connector to be connected in two opposed orientations directly to a corresponding USB-compatible receptacle... | The accused USB connectors "are capable of being connected in either orientation with a compatible receptacle." | ¶7 | col. 5:50-61 |
| said multi-contact connector further comprising an electronic short circuit prevention device to prevent an electric short circuit between a VBUS contact... and a GND contact... | The accused products include "circuitry connected to the USB ports that provides short circuit prevention," including for VBUS and GND contacts. | ¶7 | col. 5:55-61 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the term "USB-compatible receptacle". The patent was filed years before the USB Type-C standard was developed, and its specification focuses on solving problems with the legacy USB-A/B standard. A question for the court will be whether this term, in the context of the '825 patent, can be construed to read on a modern USB Type-C port, which the complaint alleges is the infringing technology (Compl. ¶7).
- Technical Questions: The complaint alleges the accused products contain a generic "circuitry... that provides short circuit prevention" (Compl. ¶7). A key technical question will be whether the specific circuitry implemented in a standard USB Type-C port operates in a manner consistent with the claimed "electronic short circuit prevention device", as described and enabled by the '825 patent's specification (e.g., using diodes or a relay).
V. Key Claim Terms for Construction
The Term: "USB-compatible receptacle"
Context and Importance: The viability of the infringement claim depends on this term covering the USB Type-C standard, which did not exist when the patent was filed. Practitioners may focus on this term because its construction will determine whether the patent's scope can reach this next-generation technology.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification introduces the term "FCCS" (flexibly connectable computer systems) and states, "it is to be understood that the principles of the invention are equally applicable to other standards" beyond USB, suggesting the inventors contemplated future applicability (’825 Patent, col. 2:60-65).
- Evidence for a Narrower Interpretation: The patent’s background section and figures exclusively describe the problem and solution in the context of the then-prevalent USB-A receptacle, suggesting the term was understood to mean the standard of that era (’825 Patent, Fig. 1; col. 2:3-20).
The Term: "electronic short circuit prevention device"
Context and Importance: This term's scope is critical for determining infringement. The analysis will compare the operation of the accused USB Type-C circuitry against the definition of this functional limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses broad, functional language, not limiting the device to a specific component. This may support a construction that covers any electronic circuit performing the stated function of preventing a VBUS-to-GND short.
- Evidence for a Narrower Interpretation: The specification only discloses two embodiments for this device: a circuit using diodes (Fig. 2d) and a relay unit (Fig. 2e). A party could argue that the claim scope should be construed as limited to these disclosed structures and their equivalents (’825 Patent, col. 5:42-61; col. 7:1-7).
VI. Other Allegations
- Indirect Infringement: The complaint alleges G.B.T. induces infringement by providing user guides and instruction materials that teach customers how to use the reversible and short-circuit-protected features of the accused USB Type-C ports (Compl. ¶13). It further alleges contributory infringement, stating the connectors have no substantial non-infringing uses and are especially adapted for infringement (Compl. ¶15).
- Willful Infringement: While not explicitly using the word "willful," the complaint requests that the court declare the case "exceptional" and award attorneys' fees pursuant to 35 U.S.C. § 285 (Compl. ¶17e). The basis for this allegation is G.B.T.'s purported knowledge of the patent since at least July 2017 and its awareness of the new, reexamined claims since their issuance in July 2021 (Compl. ¶10).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of temporal scope: Can the term "USB-compatible receptacle", rooted in the specification's description of legacy USB-A connectors from the mid-2000s, be construed to cover the standardized USB Type-C technology that was developed years after the patent was filed?
- A key evidentiary question will be one of functional correspondence: Does the standardized circuitry within the accused USB Type-C ports perform the specific function of the claimed "electronic short circuit prevention device" in a manner that is technically equivalent to the solutions disclosed in the '825 patent, or does the modern standard operate in a fundamentally different way?
- A central legal question will be the effect of reexamination: How will the court interpret claims that were added and allowed by the USPTO in 2021, well after the accused USB Type-C technology became ubiquitous, and what weight will that procedural history carry in determining claim scope and validity?