DCT

2:20-cv-06055

Platinum Tools LLC v. Simply45 LLC

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:20-cv-06055, C.D. Cal., 07/07/2020
  • Venue Allegations: Plaintiffs allege venue is proper in the Central District of California because Defendants conduct business in the district, are subject to personal jurisdiction, and the alleged acts of infringement were carried out, made effective, and had an effect within the district.
  • Core Dispute: Plaintiffs allege that Defendants’ electrical connectors infringe three U.S. patents related to RJ45-type "pass-through" connectors that feature a removable external load bar to aid in cable termination.
  • Technical Context: The technology concerns high-performance electrical connectors, such as those used for Ethernet and data communications, where precise wire alignment and connection integrity are critical for maintaining signal quality at high speeds.
  • Key Procedural History: The complaint alleges that Plaintiff Platinum acquired Plaintiff Sullstar and its patent portfolio in late 2019. It further alleges that two individual defendants are former senior employees of Plaintiff Platinum who had "intimate knowledge" of the patented products and intellectual property, a fact that may be material to the allegations of willful infringement.

Case Timeline

Date Event
2013-08-19 Earliest Priority Date for all Patents-in-Suit
2017-01-10 U.S. Patent No. 9,543,729 Issues
2018-10-30 U.S. Patent No. 10,116,082 Issues
2019-01-01 Plaintiff Platinum acquires Plaintiff Sullstar (approx. "late 2019")
2020-02-25 U.S. Patent No. 10,573,990 Issues
2020-07-07 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"

  • Patent Identification: U.S. Patent No. 9,543,729, issued January 10, 2017 (Compl. ¶37).

The Invention Explained

  • Problem Addressed: The patent's background section describes the operational difficulties and potential for connection failure when terminating modern, high-speed data cables (e.g., CAT 5, CAT 6) with traditional RJ45 connectors. These issues include distortion of the connector housing during crimping and the difficulty of ensuring correct wire alignment and a clean cut, all of which can degrade electrical performance (’971 Patent, col. 3:20-49).
  • The Patented Solution: The invention is an electrical connector with an "integrally thickened" front portion, referred to as an "External Load Bar" or "Stiffener" (’971 Patent, col. 4:26-34). The individual wires of a cable are passed completely through holes in this load bar, allowing a technician to visually verify the correct wire order before termination. A specialized tool then performs three actions in one step: it crimps the connector housing, drives the electrical contacts into the wires, and shears off the entire load bar along with the excess wire, leaving a clean, flush front face on the connector (’971 Patent, col. 4:40-54; Abstract).
  • Technical Importance: This design improves the reliability and speed of terminating high-performance data cables by providing mechanical support during the crimping process and simplifying the verification of wire order (’971 Patent, col. 4:5-12).

Key Claims at a Glance

  • The complaint alleges infringement of one or more unspecified claims (Compl. ¶48). Independent claim 3 is a representative apparatus claim.
  • Essential elements of Independent Claim 3 include:
    • An elongated hollow housing with a generally continuous forward end wall.
    • The lowermost surface area of the wall having an "integrally thickened outer portion which is adapted to be sheared off to make the connector operable."
    • The thickened portion having a "plurality of openings" through which wires can project outward.
  • The complaint reserves the right to assert additional claims.

U.S. Patent No. 10,116,082 - "ELECTRICAL CONNECTOR WITH REMOVABLE EXTERNAL LOAD BAR, AND METHOD OF ITS USE"

  • Patent Identification: U.S. Patent No. 10,116,082, issued October 30, 2018 (Compl. ¶39).

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’971 Patent, this patent addresses a similar problem: forces generated during the crimping process can "push, twist, and deform the connector housing in an undesired manner," potentially resulting in a connection that fails to meet industry standards (’082 Patent, col. 3:42-49).
  • The Patented Solution: The patent describes a connector housing with an integral, thickened "External Load Bar" on its front wall that makes the connector initially too long to meet industry standards. This load bar has pass-through holes for wires and provides "stabilizing support" for the front of the housing during crimping. The key inventive step is that the cutting action of the crimp tool removes this excess thickened portion, thereby reducing the connector to a compliant length while ensuring the internal components remain precisely aligned (’082 Patent, col. 4:26-34, 4:45-54).
  • Technical Importance: The described structure allows for the use of thicker gauge wires required for higher data transmission rates while ensuring the final terminated connector conforms to the precise physical dimensions mandated by FCC and other industry standards (’082 Patent, col. 3:53-59).

Key Claims at a Glance

  • The complaint alleges infringement of one or more unspecified claims (Compl. ¶48). Independent claim 1 is a representative apparatus claim.
  • Essential elements of Independent Claim 1 include:
    • An electrical connector plastic housing with an open rearward end and an integral forward end wall.
    • A lower portion of the forward end wall being "integrally thickened to project forward... 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 reserves the right to assert additional claims.

U.S. Patent No. 10,573,990 - "ELECTRICAL CONNECTOR WITH EXTERNAL LOAD BAR, AND METHOD OF ITS USE"

  • Patent Identification: U.S. Patent No. 10,573,990, issued February 25, 2020 (Compl. ¶41).
  • Technology Synopsis: Continuing the technology of the parent patents, the ’990 Patent describes an electrical connector with a removable "extension portion" (or load bar) that is integral to the connector's front wall. This extension contains pass-through holes that allow wires to extend beyond the connector body for inspection. A cutting tool with specialized posts is used to support and then shear off the extension portion, along with the protruding wires, during the termination process, resulting in a standards-compliant connector. (’990 Patent, Abstract; Claim 1).
  • Asserted Claims: The complaint does not specify claims but alleges infringement of "one or more claims" (Compl. ¶48). Independent claims of the ’990 Patent include 1, 9, and 16.
  • Accused Features: The complaint accuses Defendants' branded CAT5e, CAT6, and CAT6A-6UTP electrical connectors of infringing the ’990 Patent (Compl. ¶¶ 47, 84).

III. The Accused Instrumentality

Product Identification

The "Accused Products" are identified as Defendant Simply45 and Defendant SCP's branded CAT5e, CAT6, and CAT6A-6UTP electrical connectors (Compl. ¶47).

Functionality and Market Context

The complaint alleges these are electrical connectors used in the telecommunications industry, specifically for terminating Category 5, 6, and 6A data cables with RJ45-style plugs (Compl. ¶22). The complaint provides visual evidence suggesting these products employ a "pass-through" design, where the internal wires of a cable are fed completely through the front face of the connector plug. Figure 1 presents two views of an accused CAT6A/6 UTP connector, showing wires passing through openings at the front face (Compl. p. 10, FIG. 1). The complaint positions Defendants as "direct competitors" who sell and manufacture many of the same products as Plaintiff Platinum (Compl. ¶50).

IV. Analysis of Infringement Allegations

’971 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 with upper and lower surface areas The main body of the Accused Products, which are depicted as hollow plastic connector plugs. Figure 2 depicts an accused CAT6 connector, illustrating a similar pass-through wire design (Compl. p. 10, FIG. 2). ¶47, FIG. 2 col. 4:45-54
the lowermost surface area having an integrally thickened outer portion which is adapted to be sheared off to make the connector operable The front portion of the Accused Products, through which the wires protrude. The complaint alleges these connectors infringe the patent, which requires this portion to be removable to make the connector functional and compliant. ¶58 col. 4:40-44
and wherein the thickened wall portion has a plurality of openings through which wires placed inside the housing may project outward beyond its forward end wall The pass-through holes visible on the front face of the Accused Products, which allow the individual cable wires to extend beyond the connector body. Figure 3 displays two images of an accused CAT5e connector, again showing the front face with protruding wires (Compl. p. 10, FIG. 3). ¶49, FIG. 3 col. 4:40-44

’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 having a flat upper portion and a lower portion The overall structure of the Accused Products, which are shown to be plastic RJ45-style connector housings (Compl. p. 10, FIG. 1-3). ¶71, FIG. 1 col. 5:8-9
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 front "load bar" section of the Accused Products. Infringement is alleged on the theory that this section makes the connector too long to meet industry standards until it is sheared off, mirroring the function described in the patent. ¶71 col. 6:46-54
and 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 holes in the front of the Accused Products. The images provided suggest these holes are arranged in two staggered, parallel rows to accommodate the pairs of wires. ¶49, FIG. 1 col. 5:48-52

Identified Points of Contention

  • Scope Questions: The patents repeatedly describe the removable load bar as "integral" with the connector housing. A central point of contention may be the proper construction of "integral." The dispute could turn on whether this term requires the load bar to be molded as a single, monolithic piece with the housing, or if a securely affixed but separately manufactured component could be considered "integral" for the purposes of the claims.
  • Technical Questions: The patents claim not just a structure, but a structure "adapted to be sheared off." The complaint shows images of the Accused Products but does not provide direct evidence (such as user manuals or instructional videos) demonstrating that they are designed or instructed to be used in an infringing manner—i.e., by shearing off the front portion during termination. The question will be what evidence Plaintiffs can produce to show the Accused Products are used in this way.

V. Key Claim Terms for Construction

  • The Term: "integrally thickened" (’082 Patent, Claim 1)

  • Context and Importance: This term is at the core of the patented structure. Its construction will determine whether the claims read on connectors where the front load bar is a separate piece that is permanently attached, or if it is limited to connectors where the housing and load bar are formed from a single, unitary piece of material. Practitioners may focus on this term because it defines a fundamental structural characteristic of the invention.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Narrower Interpretation: The specification repeatedly states that the "Stiffener 100 is formed integral with front end wall 128 of housing 122" (’082 Patent, col. 5:10-12). The summary of the invention also notes the "Stiffener or Load Bar is formed INTEGRAL WITH the forward end wall of the housing" (’082 Patent, col. 4:26-28). This language suggests a single, monolithic construction.
    • Evidence for a Broader Interpretation: A party arguing for a broader scope might contend that "integral" should be interpreted functionally, meaning the part is essential to the whole, rather than requiring a specific manufacturing process. However, the specification's explicit language provides strong support for a narrower, structural definition.

  • The Term: "noncompliant with an applicable industry standard" (’082 Patent, Claim 1)

  • Context and Importance: This limitation defines the purpose of the removable load bar: it intentionally makes the connector too large until it is removed. The infringement analysis will depend on whether the Accused Products, with their front portions attached, actually fail to meet a relevant FCC or other "applicable industry standard" for connector dimensions.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Narrower Interpretation: The specification links this feature directly to achieving compliance: "Removal of the Stiffener brings the size and shape of the housing 122 back to the industry and FCC standard, so as to correctly mate with a female RJ45 connector" (’082 Patent, col. 5:51-55). This suggests the non-compliance must be with respect to the specific standards for mating with a standard jack.
    • Evidence for a Broader Interpretation: The term itself is broad. A plaintiff might argue that any deviation from any part of a relevant standard would render the connector "noncompliant," while a defendant might argue for a more restrictive interpretation tied only to the ability to physically mate with a corresponding jack.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants contribute to and actively induce infringement by others (Compl. ¶¶ 59, 72, 85). The factual basis for inducement may rely on evidence not present in the complaint, such as Defendants’ product instructions, marketing materials, or training videos that allegedly instruct end-users on how to terminate the Accused Products in a manner that performs the patented method.
  • Willful Infringement: The complaint alleges that Defendants' infringement has been and continues to be "willful, deliberate and intentional, and in reckless disregard of Plaintiffs' patent rights" (Compl. ¶¶ 61, 74, 87). This allegation is supported by the specific assertion that two individual defendants are former senior sales employees of Plaintiff Platinum who allegedly possessed "intimate knowledge of Plaintiff Platinum and Plaintiff Sullstar's subject electrical connector and crimp tool products, and intellectual property, including without limitation the patents which are at issue in this action" (Compl. ¶¶ 30-31). These allegations appear to form the basis for a claim of pre-suit knowledge.

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

  • A core issue will be one of definitional scope: can the term "integral," as used in the asserted patents, be construed to cover the accused connectors if their front "load bar" portions are manufactured as separate components and later affixed to the main housing, or do the claims require a single, monolithic structure?
  • A key evidentiary question will be one of infringing use: beyond showing structural similarity, what evidence can Plaintiffs produce to demonstrate that the Accused Products are actually used according to the patented method—specifically, that the front "load bar" is sheared off as a required step of the termination process?
  • A central question for damages will be willfulness: do the allegations that former employees with "intimate knowledge" of the patents-in-suit now work for the Defendants establish pre-suit knowledge sufficient to support a finding of willful infringement, potentially leading to treble damages?