DCT

2:19-cv-09937

Neutrik AG v. ADJ Products LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:19-cv-09937, C.D. Cal., 11/20/2019
  • Venue Allegations: Venue is alleged to be proper as to ADJ Products because it is a California corporation with its principal place of business in the district. Venue is alleged to be proper as to Seetronic because it is a foreign corporation and because a substantial part of the events giving rise to the claim, including supplying accused goods to ADJ in California, allegedly occurred in the district.
  • Core Dispute: Plaintiff alleges that Defendants’ ruggedized data and power connectors, and cable assemblies incorporating them, infringe a patent related to a durable protective assembly for RJ-45 style connectors.
  • Technical Context: The technology concerns protective housings for standard electronic data connectors, designed to increase durability and reliability for use in demanding professional environments like live event production, where equipment is subject to physical stress.
  • Key Procedural History: The complaint alleges that Plaintiff provided pre-suit notice of infringement to both Defendants. Specifically, it alleges that Defendant Seetronic was notified of infringement of a European counterpart patent in March 2019 and subsequently entered into cease-and-desist undertakings covering sales in Europe and the U.S. It further alleges Defendant ADJ was notified of infringement of the U.S. patent-in-suit in June 2019 and was provided with a detailed infringement claim chart in August 2019.

Case Timeline

Date Event
2001-11-29 ’248 Patent Priority Date
2003-06-24 ’248 Patent Issue Date
2019-03-28 Neutrik allegedly notifies Seetronic of European counterpart patent
2019-04-22 Seetronic allegedly reaches settlement agreement with Neutrik in Europe
2019-05-11 Seetronic allegedly enters "Cease and desist undertaking" with Neutrik for EU/UK sales
2019-06-20 Neutrik allegedly notifies ADJ of infringement of the ’248 Patent
2019-08-12 Neutrik allegedly provides claim chart to ADJ
2019-08-13 Seetronic allegedly enters "Cease and desist undertaking" covering U.S. sales
2019-11-20 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 6,582,248, “DURABLE RJ-45 DATA CONNECTOR ASSEMBLY,” issued June 24, 2003.

The Invention Explained

  • Problem Addressed: The patent’s background section states that standard RJ-45 connectors used for data transmission are vulnerable to damage. Specifically, the plastic locking tab can break off, the electrical contacts can be bent through misinsertion, and the cable itself can be damaged by sharp flexing or longitudinal stress (pulling) at the point where it enters the connector (’248 Patent, col. 1:22-38).
  • The Patented Solution: The invention is a protective assembly that encases a standard RJ-45 plug to make it more robust. It consists of a multi-part system including a rugged, cylindrical housing (often die-cast metal), a "radially-compressible chuck" that grips the cable to relieve strain, a "tapered boot" to prevent sharp cable bends, and a "threaded bushing" that tightens onto the housing, compressing the internal components to secure the cable and connector (’248 Patent, Abstract; col. 2:52-col. 3:9). This design transfers physical stresses from the fragile RJ-45 plug to the durable outer housing.
  • Technical Importance: This approach allows for the use of inexpensive, standardized data connectors in physically demanding applications where they would otherwise be prone to frequent failure (’248 Patent, col. 1:39-49).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 and dependent claims 2, 4, 5, 6, 7, and 8 (Compl. ¶29, 32, 33).
  • Independent Claim 1 recites a data connector assembly comprising four key components:
    • a) a housing with positioning means (e.g., a septum) and threads
    • b) a radially-compressible chuck for gripping the cable
    • c) a tapered boot for radially compressing the chuck
    • d) a threaded bushing that mates with the housing threads to compress the assembly together

III. The Accused Instrumentality

  • Product Identification: The complaint identifies two categories of accused instrumentalities: connectors manufactured by Seetronic (e.g., SE8MC-1, SAC3MX, SC3FX) and cable products sold by ADJ that allegedly incorporate these Seetronic connectors. Accused ADJ products include Data Link (Data/Ethernet/RJ45) cables and IP65 power cables (Compl. ¶30, 31).
  • Functionality and Market Context: The complaint alleges these products are ruggedized connector systems for data and power transmission sold for professional audio and lighting applications (Compl. ¶5, 14, 27). The complaint includes several images of the accused products, including a photograph of accused ADJ cables with Seetronic connectors for sale on a third-party retail website (Compl. ¶27, p. 10). The core functionality, as alleged, involves a multi-part assembly that houses and protects a cable end plug, providing strain relief and a secure, lockable connection (Compl. ¶32, 33).

IV. Analysis of Infringement Allegations

  • Claim Chart Summary: The complaint provides pictorial claim charts mapping elements of the accused products to the limitations of the ’248 Patent’s claims. The following table summarizes the allegations for claim 1 with respect to the Seetronic SE8MC-1 connector.
Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a) a housing having positioning means for positioning said multi-channel end plug at a predetermined location within said housing and having thread means formed on a surface thereof... The accused connectors include a housing with external threads and an internal transverse septum to position the end plug. A photo shows the housing's interior septum (Compl. p. 13). ¶32 col. 3:21-24
b) a radially-compressible chuck for urging said multi-channel end plug to said predetermined location and for gripping said cable; The accused products include a blue, slotted plastic chuck that is allegedly radially compressible to grip the cable. A photo shows the chuck component (Compl. p. 14). ¶32 col. 2:57-65
c) a tapered boot for radially compressing said chuck; and The accused products have a black boot with a tapered interior portion that allegedly compresses the chuck when assembled. A photo shows the boot's tapered interior (Compl. p. 14). ¶32 col. 3:1-4
d) a threaded bushing for arresting said tapered boot and for mating to said threads on said housing in a threaded joint for compressing said bushing, boot, chuck, housing, and multi-channel end plug together to form said assembly. The accused products include a threaded bushing that screws onto the housing, allegedly compressing the internal components (boot, chuck) to complete the assembly. A photo shows the bushing and boot assembly (Compl. p. 15). ¶32 col. 3:9-18
  • Identified Points of Contention:
    • Scope Questions: Claim 1 requires "a tapered boot for radially compressing said chuck" and, separately, "a threaded bushing for arresting said tapered boot." The complaint’s second claim chart, for the SC3FX/SC3MX connectors, alleges that a single "combined tapered bushing/boot" meets both limitations (Compl. ¶33, p. 19). This raises the question of whether a single integrated component can satisfy two claim limitations recited as distinct elements.
    • Technical Questions: What evidence does the complaint provide that the accused "chuck" performs the dual functions of both "urging said multi-channel end plug to said predetermined location" and "gripping said cable," as required by claim 1(b)? A defense may argue the chuck only performs the gripping function, while other components perform the urging function.

V. Key Claim Terms for Construction

  • The Term: "a tapered boot...; and d) a threaded bushing..."
  • Context and Importance: Practitioners may focus on this phrasing because the complaint accuses products that allegedly integrate these two components into a single "combined bushing/boot" (Compl. ¶33, p. 19). The question of whether the claim requires two structurally separate pieces or if a single piece can satisfy both limitations could be dispositive for a portion of the accused products. This implicates the "separate-element rule" in claim construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (Function-Based): The patent's summary focuses on the function of the components working in concert to compress the chuck and secure the assembly, which could support an argument that the specific number of physical parts is less important than achieving the recited functions (’248 Patent, col. 1:62-col. 2:2).
    • Evidence for a Narrower Interpretation (Structure-Based): The plain language of claim 1 lists "a tapered boot" and "a threaded bushing" as separate limitations, connected by "and" and lettered as (c) and (d). The preferred embodiment shown in the patent figures depicts the boot (26) and bushing (34) as distinct physical components, which may support a construction requiring two separate structures (’248 Patent, Fig. 5).

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges facts that could potentially support such a claim, stating that Seetronic manufactures and sells the accused connectors to ADJ, which then "incorporates such connector products into ADJ cable products" that are sold to customers (Compl. ¶5, 27).
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge by both defendants (Compl. ¶46). For Seetronic, it alleges notice via a March 28, 2019 letter regarding a European counterpart patent, followed by cease-and-desist undertakings covering U.S. sales (Compl. ¶36, 40). For ADJ, it alleges notice via a June 20, 2019 letter and the provision of a detailed infringement claim chart on August 12, 2019 (Compl. ¶34, 35). The complaint alleges that infringement continued despite this notice.

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

  • A core issue will be one of claim construction: must the claimed "tapered boot" and "threaded bushing" be two structurally separate components as depicted in the patent's embodiment, or can a single integrated part, as allegedly used in some accused products, satisfy both limitations under the doctrine of claim differentiation and the separate-element rule?
  • A key evidentiary question will concern willfulness: given the complaint’s detailed allegations of pre-suit notice—including letters, a claim chart, and prior cease-and-desist undertakings by one defendant related to a foreign counterpart patent—the central question will be whether the defendants' alleged continued infringement rises to the level of "egregious" conduct required to justify enhanced damages.