DCT
2:20-cv-04059
Platinum Tools LLC v. Simply45 LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Platinum Tools, LLC (California)
- Defendant: Simply45, LLC (Florida); Structured Cable Products, Inc. (Florida)
- Plaintiff’s Counsel: Wu & Reddy, A Prof. Corp.
- Case Identification: 2:20-cv-04059, C.D. Cal., 05/01/2020
- Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendants conduct business, commit infringing acts, and transact business within the district, with the effects of these actions being felt in the jurisdiction.
- Core Dispute: Plaintiff alleges that Defendants’ pass-through style electrical connectors infringe patents related to RJ45 connectors featuring a removable, integrated front "load bar" designed to improve the cable termination process.
- Technical Context: The technology concerns modular electrical connectors (e.g., RJ45 plugs) used to terminate high-speed data communications cables, a ubiquitous component in the telecommunications and IT infrastructure industries.
- Key Procedural History: The complaint alleges that at least two of the named individual defendants are former senior employees of the Plaintiff who possessed "intimate knowledge" of Plaintiff's patented electrical connector products, intellectual property, and marketing strategy. Plaintiff acquired the patents-in-suit from Sullstar Technologies, Inc. in late 2019.
Case Timeline
| Date | Event |
|---|---|
| 2013-08-19 | Priority Date for ’729, ’082, and ’990 Patents |
| 2017-01-10 | U.S. Patent No. 9,543,729 Issues |
| 2018-10-30 | U.S. Patent No. 10,116,082 Issues |
| Late 2019 | Plaintiff acquires Sullstar's intellectual property |
| 2020-02-25 | U.S. Patent No. 10,573,990 Issues |
| 2020-05-01 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,543,729 - "ELECTRICAL CONNECTOR WITH REMOVABLE EXTERNAL LOAD BAR, AND METHOD OF ITS USE"
The Invention Explained
- Problem Addressed: The patent family addresses performance issues with prior art pass-through RJ45 connectors, where the forces of crimping could distort the plastic connector housing, leading to unreliable electrical connections. The patent also notes the inefficiency of prior methods that required some wires to be trimmed by hand after the primary crimping operation (’729 Patent, col. 3:20-43, col. 3:1-4).
- The Patented Solution: The invention is an electrical connector with an "integrally thickened" front portion, referred to as an "External Load Bar" or "Stiffener." This load bar provides mechanical support to the connector body during the crimping and wire-seating process, preventing distortion. Wires are passed through holes in this load bar, allowing a technician to pull them tight for a better connection. In a single action, a specialized crimping tool then simultaneously severs the load bar and the excess wire ends, leaving a clean, dimensionally stable connector front that conforms to industry standards (’729 Patent, Abstract; col. 4:26-38).
- Technical Importance: This design sought to improve the reliability and repeatability of terminating modern, high-performance network cables (e.g., CAT6, CAT6A), which use thicker wires and have stricter performance requirements than previous generations (’729 Patent, col. 5:9-15).
Key Claims at a Glance
- The complaint does not specify which claims it asserts, but alleges infringement of "one or more" claims (Compl. ¶45). Claim 3 is a representative independent product claim.
- Key elements of Claim 3 include:
- An elongated hollow housing with a continuous forward end wall.
- The lowermost surface area having an integrally thickened outer portion "which is adapted to be sheared off to make the connector operable."
- The thickened wall portion having a plurality of openings for wires to project through.
- The complaint does not explicitly reserve the right to assert dependent claims, but this is standard practice.
U.S. Patent No. 10,116,082 - "ELECTRICAL CONNECTOR WITH REMOVABLE EXTERNAL LOAD BAR, AND METHOD OF ITS USE"
The Invention Explained
- Problem Addressed: As a continuation of the ’729 Patent, this patent addresses the same challenges of ensuring a robust, reliable, and efficient termination for high-speed data cables, focusing on preventing housing distortion and simplifying the wire-trimming process (’082 Patent, col. 3:20-43).
- The Patented Solution: The ’082 Patent similarly describes a connector housing with a forward end wall whose lower portion is "integrally thickened to project forward." This thickened portion, or load bar, makes the connector initially "noncompliant with an applicable industry standard." It serves as a structural support and wire guide during termination. The load bar and protruding wires are then sheared off simultaneously, bringing the connector into its final, compliant dimensions (’082 Patent, Abstract; col. 4:38-54). Figure 6 of the patent illustrates the Stiffener (100) as an integral part of the forward end wall (128) of the housing (122) (’082 Patent, Fig. 6).
- Technical Importance: The invention provided a method to accommodate larger, higher-performance wires within a standards-compliant connector footprint by temporarily reinforcing the housing during the critical crimping and contact-setting stages (’082 Patent, col. 4:58-63).
Key Claims at a Glance
- The complaint does not identify specific asserted claims. Claim 1 is a representative independent product claim.
- Key elements of Claim 1 include:
- An electrical connector plastic housing with an open rearward end and an integral forward end wall.
- The lower portion of the forward end wall being "integrally thickened to project forward beyond the flat upper portion such that the housing is noncompliant with an applicable industry standard."
- The thickened lower portion having a plurality of wiring holes arranged in two parallel rows.
- The complaint does not explicitly reserve the right to assert dependent claims.
Multi-Patent Capsule: U.S. Patent No. 10,573,990
- Patent Identification: U.S. Patent No. 10,573,990, "ELECTRICAL CONNECTOR WITH EXTERNAL LOAD BAR, AND METHOD OF ITS USE", issued on February 25, 2020.
- Technology Synopsis: Continuing the same patent family, the ’990 Patent describes an electrical connector featuring an "extension portion" that is integral with the connector's front wall. This extension portion, positioned below the wire exit holes, is sized to engage with posts on a cutting tool, acting as a cutting surface to shear wires that pass through it. This design aims to ensure a clean and precise trim of all wires during the termination process (’990 Patent, Abstract; Claim 1).
- Asserted Claims: The complaint does not specify claims, but Claim 1 is a representative independent claim.
- Accused Features: The complaint accuses Defendants’ branded CAT5e, CAT6, and CAT6A-6UTP electrical connectors of infringement (Compl. ¶44).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendants Simply45 and SCP’s branded CAT5e, CAT6, and CAT6A-6UTP electrical connectors (Compl. ¶44).
Functionality and Market Context
- The complaint alleges these are electrical connectors used for terminating data cables, directly competing with Plaintiff's products (Compl. ¶47). The complaint provides visual evidence of the accused products. Figure 1 shows the Defendants' CAT6A/6 UTP Connector, which appears to be a pass-through style modular plug with a multi-part colored housing (Compl. ¶46, Fig. 1). Figure 2 shows the Defendants' CAT6 Connector, a similar device with a blue-tinted housing (Compl. ¶46, Fig. 2). Figure 3 depicts the Defendants' CAT5e Connector, which also appears to be a pass-through modular plug (Compl. ¶46, Fig. 3).
- The complaint alleges that Defendants are direct competitors who manufacture and sell many of the same types of products and accessories as Plaintiff (Compl. ¶47).
IV. Analysis of Infringement Allegations
The complaint makes general allegations of literal infringement without providing a detailed claim chart mapping patent limitations to accused product features (Compl. ¶¶45, 55, 68, 81). The analysis below outlines the infringement theory Plaintiff would need to prove for representative claims.
’729 Patent Infringement Allegations
| Claim Element (from Independent Claim 3) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an elongated hollow housing having a generally continuous forward end wall | The main body of the accused connectors, which are depicted as hollow, elongated modular plugs in the complaint's figures. | ¶46, Figs. 1-3 | col. 5:44-46 |
| the lowermost surface area having an integrally thickened outer portion which is adapted to be sheared off to make the connector operable | The complaint does not detail this structure, but alleges the accused products incorporate the invention. The provided images show connectors that may have a distinct or multi-part front section that Plaintiff will likely argue constitutes the claimed thickened portion. | ¶45, 46 | col. 4:46-51 |
| the thickened wall portion has a plurality of openings through which wires placed inside the housing may project outward | The accused products appear to be pass-through style connectors, designed for conductor wires to extend through openings in the front face for trimming. | ¶46, Figs. 1-3 | col. 5:47-51 |
’082 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An electrical connector plastic housing comprising an open rearward end and an integral forward end wall | The overall structure of the accused connectors as depicted in Figures 1-3. | ¶46, Figs. 1-3 | col. 6:33-35 |
| the lower portion of the forward end wall being integrally thickened to project forward...such that the housing is noncompliant with an applicable industry standard | Plaintiff would need to prove that a portion of the accused connectors' front end projects in a way that corresponds to this limitation and renders it initially non-compliant before use. | ¶45, 46 | col. 6:38-42 |
| the integrally thickened lower portion...having a plurality of wiring holes formed through the thickened lower portion arranged in two parallel rows | The pass-through wire openings visible on the front of the accused connectors, which Plaintiff would need to show are arranged in two parallel rows. | ¶46, Figs. 1-3 | col. 6:42-46 |
Identified Points of Contention
- Structural Questions: A primary point of contention may be whether the accused connectors possess an "integrally thickened outer portion" that is "adapted to be sheared off," as claimed. The defense could argue that their products have a fundamentally different front-end construction that does not meet this structural and functional limitation.
- Evidentiary Questions: The complaint does not provide evidence (such as user manuals or operational videos) demonstrating that any part of the accused connectors is actually sheared off during termination. The court will require factual evidence to substantiate the allegation that the accused products function in the manner required by the claims.
V. Key Claim Terms for Construction
The Term: "integrally thickened outer portion" / "integrally thickened to project forward" (’729 Patent, cl. 3; ’082 Patent, cl. 1)
Context and Importance: This term is central to the patented invention. Its construction will likely determine whether the accused connectors, which may use a different design for their front ends, fall within the scope of the claims.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the term should be interpreted functionally to cover any added material at the connector's front that provides the structural support described in the specification, regardless of its precise shape, pointing to the patent's stated goal of preventing housing distortion during crimping (’082 Patent, col. 4:35-38).
- Evidence for a Narrower Interpretation: A party could argue the term requires a specific structure that is molded as a single, integral piece with the housing and later severed, as depicted in the patent's embodiments (e.g., "Stiffener 100" in Fig. 6). They may point to language stating the "Stiffener or Load Bar is formed INTEGRAL WITH the forward end wall" (’082 Patent, col. 4:26-28).
The Term: "adapted to be sheared off" (’729 Patent, cl. 3)
Context and Importance: This functional limitation is critical. The dispute may turn on whether the accused product must be specifically designed for shearing or if it is sufficient that it is capable of being sheared during use.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any connector front designed to be used with a pass-through crimp tool (which shears wire ends) is inherently "adapted" for shearing, fulfilling the purpose of the invention.
- Evidence for a Narrower Interpretation: A party could argue that "adapted" implies a specific design feature intended to facilitate shearing, such as the "small groove 102" described in the specification as a guide for the cutting blade, rather than just the general possibility of being cut (’082 Patent, col. 5:15-19).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants contribute to and actively induce infringement by selling the accused connectors to end-users (e.g., cable installers) for use in an infringing manner (Compl. ¶¶56, 69, 82).
- Willful Infringement: The complaint alleges willful infringement, asserting that Defendants' acts were "deliberate and willful" (Compl. ¶52). The factual basis for this allegation includes the claim that several individual defendants are former senior employees of Plaintiff who had "intimate knowledge" of Plaintiff's patented products and intellectual property, suggesting pre-suit knowledge of the patents and infringement (Compl. ¶¶29, 30, 58).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural and functional identity: Do the accused connectors possess an "integrally thickened" front portion that is "adapted to be sheared off" as the claims require, or is their front-end construction and intended method of use fundamentally different from the patented technology?
- A key question will revolve around willfulness: Given the allegation that several defendants are former senior employees of Plaintiff with "intimate knowledge" of the patented products, a critical inquiry for the court will be whether Plaintiff can prove Defendants had pre-suit knowledge of the patents and acted with the specific intent required to support a finding of willful infringement.
- An evidentiary question will be one of infringement proof: Can Plaintiff produce sufficient evidence, beyond the conclusory allegations in its complaint, to demonstrate that the accused connectors meet every limitation of the asserted claims, particularly the functional requirements related to the shearing of a load-bearing portion of the connector itself?