DCT
2:17-cv-05383
Reversible Connections LLC v. MSI Computer Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Reversible Connections LLC (Delaware / Canada)
- Defendant: MSI Computer Corp. (California)
- Plaintiff’s Counsel: Friedman, Suder & Cooke; S|H|K Legal, APC
- Case Identification: 2:17-cv-05383, C.D. Cal., 07/20/2017
- Venue Allegations: Venue is based on Defendant's principal place of business being located within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s products incorporating the USB Type-C standard infringe a patent related to reversible electrical connectors with short-circuit prevention.
- Technical Context: The technology at issue involves rotationally agnostic electrical connectors that can be inserted into a corresponding receptacle in either of two orientations (e.g., right-side up or upside-down).
- Key Procedural History: The complaint was filed in 2017, asserting a single patent. Subsequent to the filing, the patent was subject to post-grant proceedings. An Inter Partes Review (IPR) certificate issued in January 2021 found the asserted claim patentable. However, a subsequent ex parte reexamination certificate, issued in July 2021, cancelled original claims 1-24, including the sole claim asserted in this complaint (Claim 1), and added new, narrower claims. This procedural history raises a foundational question regarding the ongoing viability of the complaint as currently pleaded.
Case Timeline
| Date | Event |
|---|---|
| 2004-06-17 | '825 Patent Priority Date |
| 2008-12-02 | '825 Patent Issue Date |
| 2017-07-13 | Plaintiff allegedly sent notice letter to Defendant |
| 2017-07-20 | Complaint Filing Date |
| 2021-01-07 | Inter Partes Review Certificate Issued |
| 2021-07-07 | Ex Parte Reexamination Certificate Issued |
II. Technology and Patent(s)-in-Suit Analysis
- 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's background section describes the difficulty and inconvenience of inserting prior art USB connectors, which could only be connected in a single orientation ('825 Patent, col. 1:21-28). It also identifies a more critical problem: for thin, card-like plugs, incorrect insertion could cause a short circuit by connecting the power pin (VBUS) to the ground (GND) contacts in the receptacle ('825 Patent, col. 2:40-52).
- The Patented Solution: The invention proposes a double-sided male connector with two sets of contacts on opposite surfaces ('825 Patent, Abstract). These contact sets are arranged in a "mutually opposed relationship" so that regardless of the plug's orientation, the correct electrical connections are made with the single set of contacts in the female receptacle ('825 Patent, col. 5:3-12). To solve the short-circuit problem, the invention includes a "short circuit prevention device," such as a diode or relay circuit, which ensures that power cannot flow if the connection would result in a short ('825 Patent, col. 6:2-12; Figs. 2d-2e).
- Technical Importance: The technology aimed to provide a more user-friendly and electrically robust connector, a key consideration for the market's progression toward thinner and more portable electronic devices ('825 Patent, col. 2:27-31).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('825 Patent, col. 17:11-24) and reserves the right to assert other claims (Compl. ¶10).
- Essential elements of Claim 1 (as originally issued and asserted):
- A multi-contact connector supporting on opposite surfaces first and second sets of mutually opposed contacts
- wherein corresponding contacts in each set are electrically interconnected and are spatially aligned in a mutually opposed relationship allowing the connector to be connected in two opposed orientations to a corresponding FCCS-compatible receptacle
- said connector further comprising a short circuit prevention device to prevent an electric short circuit between contacts of the receptacle on inserting the connector therein.
III. The Accused Instrumentality
Product Identification
- The complaint accuses "products and systems with USB ports adhering to the USB 3.1 Type C standard," including laptops, gaming desktops, VR Backpack computers, All-in-One computers, and gaming motherboards (Compl. ¶11).
Functionality and Market Context
- The accused functionality is the products' inclusion of USB Type-C ports (Compl. ¶11). The complaint alleges that by implementing the USB Type-C standard, these ports necessarily include a reversible, multi-contact connector with two sets of mutually opposed contacts and circuitry for short circuit prevention (Compl. ¶11).
- The complaint does not provide specific details on the market context or commercial importance of the accused products beyond identifying general product categories.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
Claim Chart Summary
- The complaint alleges that adherence to the USB 3.1 Type C standard meets every limitation of claim 1 (Compl. ¶11).
| Claim Element (from Independent Claim 1) | 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 ports "include a connector having two sets of mutually opposed contacts." | ¶11 | col. 5:42-50 |
| ...wherein corresponding contacts in each set are electrically interconnected and are spatially aligned in a mutually opposed relationship allowing the connector to be connected in two opposed orientations to a corresponding FCCS-compatible receptacle... | The accused "USB ports are capable of being connected in either orientation with a compatible receptacle that is plugged into the port." | ¶11 | col. 5:3-12 |
| ...said connector further comprising a short circuit prevention device to prevent an electric short circuit between contacts of the receptacle on inserting the connector therein. | The "Accused Products further include circuitry connected to the USB ports that provides short circuit prevention for the port." | ¶11 | col. 6:2-12 |
Identified Points of Contention
- Procedural Question: The primary point of contention is procedural. Given that the sole asserted claim (Claim 1) was cancelled in a 2021 reexamination that occurred after the complaint was filed, a threshold question is whether the lawsuit can proceed on this claim or if Plaintiff must seek to amend its complaint to assert one of the newly issued, narrower claims.
- Scope Question: A key dispute may concern the construction of "short circuit prevention device." The complaint alleges that circuitry in products adhering to the USB Type-C standard performs this function. The defense may argue that this claim term should be limited to the specific diode and relay embodiments disclosed in the patent, raising the question of whether the complex power delivery and configuration logic of the USB Type-C standard falls within the scope of the term as claimed.
- Technical Question: The complaint's infringement theory rests on the allegation that "adhering to the USB 3.1 Type C standard" is sufficient to meet the claim limitations (Compl. ¶11). A central technical question will be what evidence Plaintiff provides to demonstrate that the specific implementation of the USB-C standard in Defendant's products performs the functions required by the claim, particularly the "short circuit prevention" limitation.
V. Key Claim Terms for Construction
The Term
- "short circuit prevention device"
Context and Importance
- This term is a critical limitation that distinguishes the invention from a simple reversible connector. The infringement analysis will depend heavily on whether the safety mechanisms inherent in the accused USB Type-C standard are determined to be the same as or equivalent to the claimed "device." Practitioners may focus on this term because the patent's disclosed embodiments (diodes, a relay) are arguably simpler than the sophisticated power negotiation and configuration channel (CC) logic used in modern USB-C ports.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language itself uses the broad, functionally-defined term "device" without structural limitations. The specification refers generally to "means to prevent an electric short circuit" ('825 Patent, col. 4:46-48), language that may support a construction covering any component that performs the stated function.
- Evidence for a Narrower Interpretation: The specification only discloses two specific embodiments for this function: a circuit using diodes (Fig. 2d) and a "relay unit" (Fig. 2e) ('825 Patent, col. 6:2-12, col. 7:1-7). A party could argue that the term should be construed more narrowly in light of these specific examples, potentially limiting its scope to these or structurally similar solutions.
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement, asserting that Defendant had specific intent to encourage infringement by providing "user guides and other sales-related materials... that instruct its customers and end users on the normal operation of the Accused Products" (Compl. ¶13). It also alleges contributory infringement, claiming the accused USB connectors have no substantial non-infringing uses and that MSI knows they are especially adapted for an infringing use (Compl. ¶15).
Willful Infringement
- The complaint does not use the term "willful," but it alleges that Defendant has had knowledge of the patent since at least July 13, 2017, the date of a notice letter sent by Plaintiff (Compl. ¶9). The prayer for relief requests that the court declare the case "exceptional" and award attorney's fees under 35 U.S.C. § 285, which is often associated with findings of willful infringement or other litigation misconduct (Compl. p.5, ¶e).
VII. Analyst’s Conclusion: Key Questions for the Case
- A dispositive threshold issue will be one of case viability: can the lawsuit proceed based on the asserted claim (Claim 1), which was cancelled by an ex parte reexamination after the complaint was filed, or must the Plaintiff amend its pleadings to assert one of the newly-issued, narrower claims?
- A core issue will be one of definitional scope: can the term "short circuit prevention device," which is disclosed in the patent as a diode or relay circuit, be construed broadly enough to read on the complex configuration and power delivery negotiation logic inherent in the accused USB Type-C standard?
- A key evidentiary question will be one of technical proof: can the Plaintiff move beyond its general allegation that "adhering to the USB 3.1 Type C standard" constitutes infringement and provide concrete evidence mapping the specific hardware and software operations of Defendant's accused products to each limitation of an asserted patent claim?