DCT

2:18-cv-06048

Universal Transdata LLC v. Adesso Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:18-cv-06048, C.D. Cal., 03/27/2019
  • Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation with a registered office and an established place of business in the district, and has allegedly committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s 2.4 GHz wireless computer peripheral products, such as keyboard and mouse combinations, infringe three patents related to wireless Universal Serial Bus (USB) hubs.
  • Technical Context: The technology at issue concerns systems and methods for wirelessly connecting multiple computer peripherals (e.g., keyboards, mice) to a computer through a single USB-connected hub, thereby eliminating the need for direct cable connections from each peripheral.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement for the '114 Patent, and by extension, the related '901 and '888 Patents, which may form the basis for the willfulness allegations.

Case Timeline

Date Event
1999-08-11 Priority Date for '114, '901, and '888 Patents
2000-08-04 '114 Patent Application Filing Date
2006-04-11 '114 Patent Issue Date
2010-04-29 '888 Patent Application Filing Date
2011-12-28 '901 Patent Application Filing Date
2012-01-03 '888 Patent Issue Date
2013-02-19 '901 Patent Issue Date
2019-03-27 Complaint Filing Date

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,028,114 - "Universal Serial Bus Hub with Wireless Communication to Remote Peripheral Device"

  • Issued: April 11, 2006 (Compl. ¶¶6, 9)

The Invention Explained

  • Problem Addressed: The patent describes the state of the art where computer peripherals connect to USB hubs via physical cables, noting a desire to provide a USB hub with the capability to communicate with multiple remote wireless peripherals without requiring such a cable connection ('114 Patent, col. 1:45-52).
  • The Patented Solution: The invention proposes a wireless system where a remote peripheral device (e.g., a keyboard or mouse) transmits its data wirelessly to a dedicated USB hub. This hub contains an RF receiver and a hub controller that converts the incoming wireless signal into a standard USB data signal, which is then passed to the computer via an upstream USB port ('114 Patent, Abstract; Fig. 2). This architecture consolidates the wireless-to-wired connection for multiple peripherals into a single hub device ('114 Patent, col. 2:1-13).
  • Technical Importance: The technology aimed to declutter the user's workspace by creating a central wireless access point for common input peripherals that interfaces with the computer using the ubiquitous USB standard ('114 Patent, col. 1:53-65).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 3, and 9, and dependent claims 2, 4, 5, and 6 (Compl. ¶43).
  • Independent Claim 1 includes these essential elements:
    • A remote wireless peripheral device (keyboard, mouse, or joystick) with an integral RF transmitter as its sole means of communication, lacking any native USB capability.
    • The device's operations are not triggered by wireless telephony.
    • A USB hub with an upstream port and a hub controller.
    • The hub controller converts the received wireless signal to a USB data signal and passes it to the computer.
  • Independent Claim 3 is similar but more general, claiming:
    • A remote wireless peripheral device with an integral RF transmitter as its sole means of communication, lacking USB capability and not triggered by wireless telephony.
    • A USB hub with a hub controller that converts the wireless signal to a USB signal for the computer.
  • Independent Claim 9 covers a system with:
    • At least two remote wireless peripheral devices (including a keyboard and a mouse), each with an integral RF transmitter as its sole communication means, lacking USB capability.
    • A data reception circuit in the hub for receiving the wireless signals.
    • A hub controller that converts each wireless signal to a USB data signal for the computer.

U.S. Patent No. 8,380,901 - "Universal Serial Bus Hub with Wireless Communication to Remote Peripheral Device"

  • Issued: February 19, 2013 (Compl. ¶¶20, 23)

The Invention Explained

  • Problem Addressed: As a continuation in the same family, this patent addresses the same general problem of wirelessly connecting peripherals. It further refines the hub's functionality, focusing on how the hub intelligently processes incoming data from multiple sources.
  • The Patented Solution: The invention claims a wireless hub with distinct modules for handling data. A "wireless communication module" receives data that includes both "device information" (e.g., keystrokes) and "error detection information" (e.g., a checksum). A "signal discriminator module" then uses this information to first verify the data's validity and second to determine which peripheral sent it. Critically, the hub is configured to provide only the device information to the computer over the USB connection, stripping out the wireless-layer error detection information ('901 Patent, Claim 8).
  • Technical Importance: This patent describes a more robust wireless hub that not only connects devices but also actively manages data integrity and sourcing, and standardizes the data for the USB protocol by removing protocol-specific overhead.

Key Claims at a Glance

  • The complaint asserts independent claim 8 and dependent claims 9, 10, 11, and 12 (Compl. ¶55).
  • Independent Claim 8 recites:
    • A wireless hub comprising a wireless communication module, a signal discriminator module, and a first USB connection.
    • The wireless communication module receives data from multiple peripherals, with the data including both "error detection information" and "device information."
    • The signal discriminator module is configured to verify data validity using the error detection information and determine the source peripheral using the device information.
    • The apparatus provides the device information to a computer via the USB connection without including the error detection information.

Multi-Patent Capsule: U.S. Patent No. 8,090,888

  • Patent Identification: U.S. Patent No. 8,090,888, "Universal Serial Bus Hub with Wireless Communication to Remote Peripheral Device," issued January 3, 2012 (Compl. ¶¶32, 35).
  • Technology Synopsis: This patent enhances the reliability of the wireless connection. It describes a hub with a multichannel receiver capable of detecting interference on a communication channel and dynamically switching to a different, clearer channel to maintain a stable connection with the peripheral device ('888 Patent, Claim 1). This frequency-agile capability is combined with the core function of receiving, verifying, and converting peripheral data for a USB interface.
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶65).
  • Accused Features: The complaint alleges that Defendant's 2.4 GHz wireless products, which operate in a crowded frequency band where channel-switching is common, embody the invention of the '888 Patent (Compl. ¶¶65-67).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are identified as Defendant's "2.4 GHz Wireless Desktop and Optical Mouse and other as-yet-unknown products that similarly satisfy each element of each asserted claim" (Compl. ¶¶44, 56, 66).

Functionality and Market Context

  • The Accused Products are wireless keyboard and mouse combinations that operate in the 2.4 GHz radio-frequency spectrum (Compl. ¶44). They are sold with a USB dongle that plugs into a computer, allowing the wireless peripherals to communicate with the computer. The complaint alleges these products are sold throughout the United States via online retailers, including Amazon.com and Defendant's own website (Compl. ¶4). The core of the infringement allegation is that the combination of the wireless peripherals (e.g., keyboard, mouse) and the USB dongle together constitute the claimed "wireless system" or "wireless hub."

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits D, E, and F, which were not provided for this analysis. The infringement theory is therefore summarized from the body of the complaint.

The complaint's central theory is that Adesso's wireless keyboard and mouse sets, when paired with their included USB dongle, meet the limitations of the asserted claims (Compl. ¶¶45, 57, 67). The wireless peripherals are alleged to be the claimed "remote wireless peripheral device[s]," and the USB dongle is alleged to be the claimed "Universal Serial Bus (USB) hub" or "apparatus." The complaint asserts that this system works by the peripherals transmitting RF signals to the dongle, which then processes these signals and communicates the resulting data to the host computer via its USB interface (Compl. ¶¶44-45).

For the '901 and '888 Patents specifically, the complaint alleges that the dongle's internal electronics perform the claimed functions of error verification, source determination, and interference-avoiding channel switching before passing the data to the computer (Compl. ¶¶57, 67).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The Term: "a Universal Serial Bus (USB) hub" ('114 Patent, Claim 1)

  • Context and Importance: The viability of the infringement case against a compact USB dongle hinges on whether such a device can be legally construed as a "USB hub." Practitioners may focus on this term because Defendant could argue that a "hub" requires multiple downstream physical ports for connecting additional devices, a feature a typical dongle lacks. Plaintiff's position would need to be that the term's meaning in the patent's context is a device that manages communications from multiple peripherals for a single upstream USB connection, regardless of physical downstream ports.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes the invention's core function as receiving wireless signals and passing "appropriate peripheral device information to a USB upstream port" ('114 Patent, Abstract). Some embodiments, like that in Figure 8, are depicted abstractly with a single path to the hub controller, suggesting the number of physical output ports is not the dispositive feature.
    • Evidence for a Narrower Interpretation: The patent's "Background of the Invention" section repeatedly describes conventional USB hubs as providing "a plurality of downstream ports for connecting the peripheral devices" ('114 Patent, col. 1:42-44). Furthermore, dependent claim 8 of the '114 Patent explicitly adds "at least one conventional downstream USB port," which a defendant could argue implies the base claim's "hub" was intended to be the conventional, multi-port device.

The Term: "without including the error detection information" ('901 Patent, Claim 8)

  • Context and Importance: This negative limitation is a critical point of proof. Practitioners may focus on this term because infringement will require technical evidence that the accused dongle's chipset actively strips the error-checking data (e.g., CRC checksums) from the wireless data packet before formatting the payload for the USB bus. The dispute will be highly factual and dependent on technical analysis of the accused device's operation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (supporting infringement): The specification for the parent '114 patent, incorporated by reference, provides a clear basis for this function, stating that the "signal discriminator... strips the data packet to present only the peripheral device data bytes to the hub controller" ('114 Patent, col. 4:65-col. 5:1). This suggests a deliberate removal of wireless protocol overhead was a contemplated feature of the invention.
    • Evidence for a Narrower Interpretation (countering infringement): A defendant would likely focus on the specific type of "error detection information" at issue. They might argue that the term is limited to the specific checksums described in the embodiments and that if their device uses a different, inseparable form of data integrity check that is passed along, they do not meet this negative limitation.

VI. Other Allegations

  • Indirect Infringement: The complaint includes a count for induced infringement of the '114 Patent, alleging Defendant acted "actively and intentionally, with prior knowledge" to induce infringement by others (Compl. ¶53). The complaint does not, however, specify the actions taken to induce, such as providing user manuals or instructions that guide users to perform the infringing acts.
  • Willful Infringement: Willfulness is alleged for all three patents. The basis for this allegation is Defendant's alleged "actual knowledge" of the patents, stemming from pre-suit notice provided by the Plaintiff (Compl. ¶¶47, 59, 69). The complaint seeks enhanced damages as a result of the alleged willful and deliberate conduct (Compl. ¶H, p. 14).

VII. Analyst’s Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "Universal Serial Bus (USB) hub," which is described in the patent's background with reference to multi-port devices, be construed to read on the accused compact, single-purpose USB dongles that lack physical downstream ports?
  • A second central question will be evidentiary and technical: does the firmware or chipset in Adesso’s USB dongle perform the specific function of stripping the wireless protocol's "error detection information" before passing the user data to the computer, as required by the negative limitation in claim 8 of the '901 patent?
  • Finally, the allegation of willfulness will turn on the timing and content of the alleged pre-suit notice. The court will examine what actions, if any, Defendant took after being made aware of the patents-in-suit to determine if any continued infringement was "willful and deliberate."