DCT
2:23-cv-07470
Lian Li Industrial Co Ltd v. Thermaltake Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lian Li Industrial Co., Ltd. (Taiwan); Chen, Chien-Hao (Taiwan)
- Defendant: Thermaltake Technology Co., Ltd. (Taiwan); Thermaltake Inc. (a.k.a. Thermaltake USA) (California)
- Plaintiff’s Counsel: Greenberg Traurig, LLP
- Case Identification: 2:23-cv-07470, C.D. Cal., 09/08/2023
- Venue Allegations: Venue is alleged to be proper because Defendant Thermaltake Technology Co., Ltd. is a foreign corporation, and Defendant Thermaltake Inc. is a California corporation that resides within the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s modular computer cooling fans infringe a patent related to a system for physically and electrically connecting multiple fans to reduce cable clutter.
- Technical Context: The technology concerns interlocking computer case fans, a component segment in the PC enthusiast market where aesthetics, ease of installation, and cable management are significant features.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement via a letter in April 2023, which forms the basis for the willfulness allegation. No other prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2018-12-26 | '336 Patent Priority Date |
| 2020-06-23 | '336 Patent Issue Date |
| 2023-04-XX | Alleged pre-suit notice letter sent to Defendant |
| 2023-09-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,690,336 - "Illumination Fan Connectable With At Least One Illumination Fan For A Computer"
- Patent Identification: U.S. Patent No. 10,690,336, "Illumination Fan Connectable With At Least One Illumination Fan For A Computer," issued June 23, 2020.
The Invention Explained
- Problem Addressed: The patent identifies the problem of installing multiple cooling fans in a computer, where each fan requires an individual power cable connected to the power supply. This limits the number of installable fans and results in "cumbersome" cable routing and management inside the computer housing. ('336 Patent, col. 1:32-41).
- The Patented Solution: The invention is a modular fan designed to physically and electrically connect directly to other, similar fans. It features connectors on opposite sides of the fan body, allowing power and illumination signals to pass from one fan to the next in a "daisy-chain" fashion. This design aims to power a bank of fans using a single cable connection to the computer's power supply, simplifying installation. ('336 Patent, col. 2:57-col. 3:3; Fig. 2).
- Technical Importance: This approach addresses a practical challenge in the PC building community by reducing cable clutter, which can improve airflow and aesthetics inside the computer case. ('336 Patent, col. 3:34-40).
Key Claims at a Glance
- The complaint asserts independent claim 1. (Compl. ¶14).
- The essential elements of claim 1 are:
- a body, provided with a fan in center of the body,
- an illumination area on at least two sides of the fan at top of the body,
- a power socket and a first connector on one side of the body,
- and a second connector on another side of the body,
- wherein the power socket is electrically connected with the first connector, the second connector, the fan and the illumination area,
- such that when the power socket is supplied with power, the fan and illumination area are driven,
- and when the first connector is connected to a second connector of another fan, the fan and illumination area of the other fan are driven.
- The complaint’s prayer for relief seeks remedies for infringement of "any claim of the '336 patent," suggesting a reservation of rights to assert additional claims. (Compl. ¶19.b).
III. The Accused Instrumentality
Product Identification
- The accused product is Thermaltake's Swafan EX 12 RGB PC Cooling Fan ("Swafan"). (Compl. ¶14).
Functionality and Market Context
- The complaint alleges the Swafan is an "illumination fan connectable with at least one other illumination fan for a computer." (Compl. ¶15). The complaint includes an annotated photograph depicting two Swafan units physically connected to each other side-by-side. (Compl. p. 5, Image).
- The allegations state the Swafan includes a body, a central fan, an illumination area, a power socket, and connectors that allow it to be electrically connected to other fans to pass power for rotation and illumination. (Compl. ¶¶ 15-16). A second annotated image shows a Swafan with its fan blades removed to display what the complaint asserts are the claimed electrical connection points. (Compl. p. 6, Image).
- The complaint does not provide sufficient detail for analysis of the product's specific market positioning beyond its identification as a PC cooling fan.
IV. Analysis of Infringement Allegations
'336 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An illumination fan connectable with at least one illumination fan for a computer, comprising: a body, provided with a fan in center of the body, an illumination area on at least two sides of the fan at top of the body... | The Swafan is described as a connectable illumination fan comprising a body with a central fan and illumination areas. The complaint provides an annotated image labeling these features. (Compl. p. 5). | ¶15 | col. 2:61-65 |
| ...a power socket and a first connector on one side of the body, and a second connector on another side of the body... | The Swafan is alleged to have a power socket and connectors. The complaint provides an annotated image showing the fan with blades removed to reveal connection points. (Compl. p. 6). | ¶¶15-16 | col. 2:65-col.3:1 |
| ...wherein the power socket is electrically connected with the first connector, the second connector, the fan and the illumination area... | The complaint alleges that the Swafan's power socket and connectors are electrically connected to provide power to the fan and illumination area. | ¶15 | col. 3:1-3 |
| ...such that when the power socket on the one side of the body is supplied with power, the fan and the illumination area of the body are respectively driven into rotation and illumination... | The Swafan is alleged to operate such that when power is supplied to the power socket, its own fan and lights are activated. | ¶15 | col. 4:11-14 |
| ...and when the first connector of the body is connected with a second connector of a body of another illumination fan, a fan and an illumination area of the body of another illumination fan are respectively driven into rotation and illumination. | The Swafan is alleged to function such that connecting a first fan to a second fan drives the rotation and illumination of the second fan. | ¶15 | col. 4:14-22 |
- Identified Points of Contention:
- Scope Questions: A primary question may be whether the accused product's connector design meets the limitation "a power socket and a first connector on one side of the body." The patent figures depict the power socket (4) and first connector (5) as physically distinct components. The infringement analysis may turn on whether the Swafan's connector architecture, which could be a single integrated unit, can be mapped to these two distinct claimed elements.
- Technical Questions: What evidence does the complaint provide that the internal electrical pathways of the Swafan operate as claimed? The complaint asserts the required connectivity but does not detail the specific wiring that accomplishes the function of making the power socket electrically common to both the outbound connectors and the fan's own internal components (fan motor and illumination circuits).
V. Key Claim Terms for Construction
- The Term: "a power socket and a first connector on one side of the body"
- Context and Importance: This term appears in independent claim 1 and defines the input/output connection structure. The patent's drawings show the "power socket" (4) and "first connector" (5) as separate structures. The construction of this phrase—specifically whether "and" requires two physically separate components or allows for a single, functionally differentiated unit—will be critical to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party may argue that the claim requires functional distinction, not necessarily physical separation. The key claimed function is that the "power socket is electrically connected with the first connector," a requirement that could be met within a single integrated housing. ('336 Patent, col. 3:1-3).
- Evidence for a Narrower Interpretation: A party may argue that the plain language ("a power socket and a first connector") and the consistent depiction in the patent's figures (Figs. 1, 2) of two separate, numbered components (4 and 5) require two structurally distinct elements. The detailed description also lists them as separate items in a list of components. ('336 Patent, col. 2:65-67).
VI. Other Allegations
- Indirect Infringement: The complaint does not plead a separate count for indirect infringement, and the factual allegations do not specify acts of inducement or contribution, such as citing user manuals or instructions. However, the prayer for relief requests an injunction against inducement of infringement. (Compl. ¶19.b).
- Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge. It claims that Defendant was put on notice of the '336 patent and the alleged infringement by a letter sent in April 2023. (Compl. ¶17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: does the claim limitation "a power socket and a first connector," which the patent specification and figures depict as two separate physical structures, read on the accused product's potentially integrated magnetic connector design? The resolution of whether the term requires two physically distinct components or merely two distinct functions will be central to the infringement dispute.
- A key evidentiary question will be one of technical proof: can the plaintiff demonstrate with sufficient evidence that the accused fan's internal circuitry performs the specific electrical daisy-chaining function recited in the claim, where power from a single socket is distributed to both the host fan's components and the pass-through connectors for an adjacent fan?