DCT

2:20-cv-09728

Terrestrial Comms LLC v. Logitech Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:20-cv-09728, C.D. Cal., 10/22/2020
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the Central District of California.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless computer peripherals, including keyboard-and-mouse combination sets and standalone mice, infringe five patents related to integrated wireless interfaces and grounded antenna designs.
  • Technical Context: The technology at issue addresses methods for wirelessly connecting multiple computer peripherals to a host device and specific antenna structures for use in compact wireless devices.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2000-03-10 Earliest Priority Date for ’133 and ’290 Patents
2000-07-18 Earliest Priority Date for ’850, ’563, and ’552 Patents
2003-02-11 ’290 Patent Issued
2005-12-06 ’133 Patent Issued
2006-08-29 ’850 Patent Issued
2007-03-20 ’563 Patent Issued
2008-08-12 ’552 Patent Issued
2020-10-22 Complaint Filed

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

U.S. Patent No. 6,973,133 - "INTEGRATED RADIO FREQUENCY INTERFACE"

  • The Invention Explained:
    • Problem Addressed: The patent’s background section describes conventional wireless systems for computer peripherals as potentially expensive and prone to radio interference, as they often required a separate wireless device for each peripheral, with each device generating its own frequency hopping sequence and forming a separate "piconet" (’133 Patent, col. 1:50-67).
    • The Patented Solution: The invention proposes a single apparatus that integrates a Universal Serial Bus (USB) hub with a wireless network device (’133 Patent, col. 2:45-48). This integrated circuit uses a single frequency hopping radio signal to support one or more wireless peripheral devices, thereby aiming to reduce the number of required components and minimize radio interference that could arise from multiple, overlapping piconets (’133 Patent, col. 2:8-24; Fig. 2).
    • Technical Importance: This approach sought to reduce the cost and complexity of connecting multiple wireless peripherals to a host computer by consolidating the hub and wireless communication functions into a single device (’133 Patent, col. 2:15-24).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1.
    • Claim 1 requires:
      • An apparatus comprising: a circuit configured to
      • (i) communicate one or more Universal Serial Bus (USB) data signals via a wireless radio signal comprising a single frequency hopping sequence configured to support one or more USB devices and
      • (ii) enumerate said one or more USB devices.

U.S. Patent No. 6,519,290 - "INTEGRATED RADIO FREQUENCY INTERFACE"

  • The Invention Explained:
    • Problem Addressed: Like its continuation ('133 Patent), the ’290 Patent addresses the cost and potential for radio interference associated with conventional wireless systems that use separate wireless devices for each peripheral device (’290 Patent, col. 1:40-68).
    • The Patented Solution: The patent describes an apparatus that can both generate a wireless radio signal in response to USB data signals from a host and, conversely, generate USB data signals in response to a received wireless radio signal from a peripheral (’290 Patent, col. 2:5-12). This bidirectional conversion is managed using a single frequency hopping sequence designed to support multiple peripheral devices within a single piconet, with the apparatus acting as a master device (’290 Patent, col. 4:62-65; Fig. 2). A Certificate of Correction amends claim 1 to clarify the circuit's functions, including enumeration.
    • Technical Importance: The invention aimed to allow multiple wireless devices to connect transparently to a host through a single wireless controller, simplifying the hardware and potentially improving performance by reducing radio interference (’290 Patent, col. 4:45-50).
  • Key Claims at a Glance:
    • The complaint asserts independent claim 1, as amended by a Certificate of Correction.
    • Corrected Claim 1 requires:
      • An apparatus comprising: a circuit configured to generate a wireless radio Signal in response to one or more first Universal Serial Bus (USB) data signals,
      • wherein said wireless radio signal comprises a Single frequency hopping Sequence configured to Support one or more USB peripheral wireless network devices,
      • and Said circuit is configured to (i) generate Said one or more first USB data signals in response to said wireless radio signal and
      • (ii) enumberate [sic] Said one or more USB devices.

U.S. Patent No. 7,098,850 - "GROUNDED ANTENNA FOR A WIRELESS COMMUNICATION DEVICE AND METHOD"

  • Technology Synopsis: The ’850 Patent addresses the need for wireless devices to operate at multiple frequencies, such as 915 MHz commonly used in the United States and 2.45 GHz used elsewhere (’850 Patent, col. 1:46-62). The patented solution is a device with a first antenna coupled to a wireless chip and a "coupling element" that is itself "arranged to act as a second antenna at a second operating frequency" (’850 Patent, col. 2:47-56).
  • Asserted Claims: The complaint asserts independent claim 1.
  • Accused Features: The complaint accuses the Logitech MX Master 3 mouse, alleging it infringes by communicating on both a "wireless USB radio frequency and a wireless Bluetooth frequency," thereby utilizing a dual-frequency antenna structure (Compl. ¶¶ 62, 64).

U.S. Patent No. 7,193,563 - "GROUNDED ANTENNA FOR A WIRELESS COMMUNICATION DEVICE AND METHOD"

  • Technology Synopsis: The ’563 Patent describes an antenna structure for a wireless device comprising a substrate, a wireless chip, a ground plane, and an antenna. A key feature is that the antenna is "electrically shorted at one end to said ground plane" to achieve desired impedance matching characteristics for efficient energy transfer (’563 Patent, col. 2:5-16, 33-35).
  • Asserted Claims: The complaint asserts independent claim 1.
  • Accused Features: The complaint accuses the Logitech MX Master 3 mouse, providing teardown photographs to allege the presence of a substrate, wireless communication chip, ground plane, and an antenna that is electrically shorted to the ground plane (Compl. ¶¶ 83-91).

U.S. Patent No. 7,411,552 - "GROUNDED ANTENNA FOR A WIRELESS COMMUNICATION DEVICE AND METHOD"

  • Technology Synopsis: The ’552 Patent discloses a wireless communication device where a wireless chip is electrically connected to a ground plane. The device includes an antenna with a first end also connected to the ground plane and a second end that is an "open circuit" (’552 Patent, Claim 1). This configuration is intended to provide specific impedance matching characteristics.
  • Asserted Claims: The complaint asserts independent claim 1.
  • Accused Features: The complaint accuses the Logitech MX Master 3 mouse, alleging its internal chipset contains a substrate, a wireless chip connected to a ground plane, and an antenna with one end connected to the ground plane and the other end comprising an open circuit (Compl. ¶¶ 98, 103-105).

III. The Accused Instrumentality

Product Identification

  • The complaint names two sets of accused products:
    1. The Logitech Wireless Keyboard and Mouse (MK270) combo and similar products are accused of infringing the ’133 and ’290 Patents (Compl. ¶¶ 21, 36).
    2. The Logitech MX Master 3 mouse and similar products are accused of infringing the ’850, ’563, and ’552 Patents (Compl. ¶¶ 62, 80, 95).

Functionality and Market Context

  • The MK270 is a peripheral set that uses a single USB transceiver, or "dongle," to wirelessly connect both a keyboard and a mouse to a host computer (Compl. ¶¶ 23, 25, 27). The complaint alleges this system communicates using a 2.4GHz wireless radio frequency (Compl. ¶26).
  • The MX Master 3 is a wireless mouse alleged to be capable of communicating via two different wireless modes: a "wireless USB radio frequency and a wireless Bluetooth frequency" (Compl. ¶64). The complaint includes teardown photographs purporting to show the internal circuit board, communication chip, and antenna structure of the mouse (Compl. ¶¶ 67-69). The complaint's image of the product packaging highlights its "Advanced Wireless" capabilities (Compl. p. 25).

IV. Analysis of Infringement Allegations

'133 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus comprising: a circuit configured to (i) communicate one or more Universal Serial Bus (USB) data signals via a wireless radio signal... The accused MK270 products include a USB Transceiver unit containing a circuit with an RF chip that communicates data signals between a host computer and the wireless keyboard and mouse. ¶23, ¶25, ¶28 col. 3:3-10
...comprising a single frequency hopping sequence configured to support one or more USB devices... The circuit allegedly operates on a frequency hopping sequence (GFSK modulation) between 2405MHz and 2474MHz to support both the mouse and keyboard via the single transceiver. ¶30, ¶31 col. 3:3-6
...and (ii) enumerate said one or more USB devices. The accused products are allegedly operable to enumerate the USB devices, as shown by Windows Device Manager screenshots identifying the "HID-compliant mouse" and "HID Keyboard Device" via a hardware ID. ¶32 col. 4:39-42

'290 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An apparatus comprising: a circuit configured to generate a wireless radio Signal in response to one or more first Universal Serial Bus (USB) data signals... The accused MK270's USB transceiver registers with the host computer and, in response to data transactions, begins transmitting a wireless signal to connect to the peripheral devices. ¶39, ¶43 col. 2:5-7
...wherein said wireless radio signal comprises a Single frequency hopping Sequence configured to Support one or more USB peripheral wireless network devices... The generated radio signal allegedly comprises a frequency hopping sequence (GFSK) that operates between 2405MHz and 2474MHz to support both the mouse and keyboard. ¶45, ¶48, ¶51 col. 5:1-3
...and Said circuit is configured to (i) generate Said one or more first USB data signals in response to said wireless radio signal... The transmitter in the wireless keyboard allegedly sends a radio signal to the USB device, which receives the signal and converts it into a USB data signal that is communicated to the host. ¶52, ¶56 col. 2:9-12
...and (ii) enumberate [sic] Said one or more USB devices. The accused products are allegedly operable to enumerate the USB devices, evidenced by screenshots from Windows Device Manager identifying the mouse and keyboard hardware. The provided screenshot shows the operating system event log for the device being configured (Compl. p. 23). ¶58 Cert. of Corr.
  • Identified Points of Contention:
    • Scope Questions: A central question for the '133 and '290 patents may be whether the accused circuit itself performs the claimed function of "enumerating" the USB devices. The complaint relies on screenshots of the Windows operating system recognizing the hardware (Compl. p. 10). The analysis may turn on whether the circuit's role in merely enabling the host OS to perform enumeration meets the claim limitation, or if the claim requires the circuit to actively manage the enumeration process.
    • Technical Questions: For the '850 patent, a key question will be whether the physical construction of the antenna and circuitry inside the MX Master 3 mouse, as depicted in teardown photos (Compl. p. 29, 32), meets the claim requirement of a "coupling element being arranged to act as a second antenna at a second operating frequency." The analysis will require a technical comparison between the accused structure and the specific antenna configurations described in the patent.

V. Key Claim Terms for Construction

  • The Term: "enumerate said one or more USB devices" (from Claim 1 of ’133 and ’290 Patents)

    • Context and Importance: This term is critical because the act of enumeration is a foundational step in the USB protocol, making a device functional to a host system. Practitioners may focus on this term because the complaint's evidence consists of operating system screenshots, raising the question of whether the accused circuit performs the action or merely facilitates the host computer's performance of the action.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that mapping proximity connections "allows each of said wireless peripheral network devices that come into range to join said piconet and enumerate as a Universal Serial Bus device" (’290 Patent, col. 4:38-42). This language could suggest that the circuit's function of enabling the device to "join" and "enumerate" is sufficient to meet the limitation.
      • Evidence for a Narrower Interpretation: The specification also describes a process where the "host controller may then perform an enumeration sequence" after being notified of a connection by the accused apparatus's integrated hub (’290 Patent, col. 4:15-17). This could support an argument that "enumeration" is a distinct step performed by the host, not the accused circuit, requiring a narrower construction where the circuit itself must perform the protocol steps of enumeration.

  • The Term: "a circuit configured to" (from Claim 1 of ’133 and ’290 Patents)

    • Context and Importance: As these are apparatus claims, the meaning of "configured to" will be central to determining whether the accused Logitech transceiver has the requisite structure. The dispute will likely focus on whether the term implies specific hardware or firmware logic for performing the functions, or if it is met by a general-purpose RF chip that enables the functions in conjunction with host software.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patents describe the invention as an "integrated" device that combines a USB hub and wireless network device (’133 Patent, col. 2:45-48). This suggests the overall structural arrangement is the configuration, and if that structure is designed to achieve the claimed functions as part of a system, it is "configured to" perform them.
      • Evidence for a Narrower Interpretation: The claims require the circuit to be configured to both "communicate" and "enumerate." A defendant might argue that while the RF chip is configured to communicate, the enumeration is primarily a function of the host OS drivers. The specification's distinction between the "host controller" and the "wireless network device" could be used to argue that being "configured to" requires the circuit to possess the specific logic for enumeration, not just for passing data that is later enumerated by another component (’133 Patent, col. 4:11-15).

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

  • A core issue will be one of functional attribution: for the ’133 and ’290 patents, does the accused circuit within the Logitech USB dongle itself perform the claimed step of "enumerating" devices, or does it merely provide a data pathway that enables the host computer’s operating system to perform that function? The resolution will depend on how the court construes the claim term "enumerate" in the context of the patent's specification.
  • A second key issue will be one of structural correspondence: for the antenna patents (’850, ’563, ’552), does the physical layout of the circuit board, communication chip, ground plane, and antenna traces within the Logitech MX Master 3 mouse embody the specific grounded and/or dual-frequency antenna structures required by the asserted claims? This will likely be a technical, fact-intensive inquiry heavily reliant on expert testimony comparing the accused hardware to the patent claims.
  • Finally, the case may turn on the scope of "a circuit configured to": does this term require the accused device to contain specialized hardware or firmware for executing the claimed functions, or is it sufficient that the device is an indispensable component designed to work within a larger system (including host software) that, as a whole, performs those functions?