DCT
2:23-cv-07471
Lian Li Industrial Co Ltd v. Phanteks Europe
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Lian Li Industrial Co., Ltd. (Taiwan) and Chen, Chien-Hao (Taiwan)
- Defendant: Phanteks Europe (d.b.a. Axpertec International B.V.) (Netherlands); Axpertec Inc. (a.k.a. Phanteks USA) (California); Phanteks Taiwan Inc. (Taiwan); and Phanteks China (China)
- Plaintiff’s Counsel: Greenberg Traurig, LLP
- Case Identification: 2:23-cv-07471, C.D. Cal., 11/21/2023
- Venue Allegations: Venue is alleged to be proper based on Defendant Axpertec Inc.’s residence in the district and because the other foreign-domiciled defendants may be sued in any judicial district.
- Core Dispute: Plaintiffs allege that Defendants’ D30 line of computer cooling fans infringes a patent related to a modular, connectable illumination fan system.
- Technical Context: The technology addresses the market for high-performance, aesthetically customizable computer components, where users often install multiple illuminated fans that require simplified power and data connectivity.
- Key Procedural History: The complaint alleges that Plaintiffs sent a letter to Defendants in May 2023 identifying the patent-in-suit and providing infringement allegations, which forms the basis for the willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2018-12-26 | U.S. Patent No. 10,690,336 Priority Date |
| 2020-06-23 | U.S. Patent No. 10,690,336 Issue Date |
| 2023-05-01 | Approximate date of pre-suit notice letter sent to Defendant |
| 2023-11-21 | 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"
The Invention Explained
- Problem Addressed: The patent background describes the challenge of installing multiple cooling fans in a computer case, where each fan typically requires an independent power cable. This limits the number of installable fans based on available power supply connections and creates "cumbersome" cable routing and management issues (’336 Patent, col. 1:32-41).
- The Patented Solution: The invention is a modular fan designed to physically and electrically connect directly to other, identical fans. A single fan in a chain connects to the computer’s power supply, and that power and illumination signal is passed to the other connected fans through integrated connectors, eliminating the need for individual cables for each fan (’336 Patent, Abstract; col. 2:51-68). This design simplifies installation and improves internal computer aesthetics and airflow by reducing cable clutter.
- Technical Importance: This daisy-chain approach for both power and lighting signals offers a practical solution for PC builders who value clean cable management and coordinated aesthetics in systems with multiple fans.
Key Claims at a Glance
- The complaint asserts independent Claim 1 (’336 Patent, col. 4:2-21; Compl. ¶16).
- The essential elements of Claim 1 are:
- A body, provided with a fan in the center of the body.
- An illumination area on at least two sides of the fan at the top of the body.
- A power socket and a first connector on one side of the body.
- A second connector on another side of the body.
- The power socket is electrically connected with the first connector, the second connector, the fan, and the illumination area.
- When the power socket is supplied with power, the fan and illumination area are driven.
- When the first connector is connected to a second connector of another fan, the other fan's fan and illumination area are driven.
- The complaint does not explicitly reserve the right to assert dependent claims but references infringement of "at least claim 1" (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
- The accused product is the Phanteks D30 Fan (Compl. ¶20).
Functionality and Market Context
- The complaint alleges the D30 Fan is an illuminated computer fan designed to be connectable with other D30 fans (Compl. ¶17). The product features connectors that allow multiple fans to be linked together, sharing power and illumination signals from a single cable connection (Compl. ¶¶ 17, 22). An annotated image from the product manual included in the complaint shows a connector clip physically and electrically joining two fans. (Compl. ¶22). This modular functionality is a key feature for PC enthusiasts seeking to build clean, multi-fan cooling and lighting systems.
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The complaint provides a narrative infringement theory supported by annotated photographs. The following table synthesizes these allegations against Claim 1. The complaint includes an annotated photograph of the D30 Fan showing its main components, which serves as visual evidence for the body, fan, and illumination areas (Compl. ¶21).
’336 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 accused D30 Fan has a body, a central fan, and illumination areas on its sides. | ¶17 | 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 D30 Fan has a power socket and connectors on its body that facilitate linking to other fans. | ¶17 | col. 2:65-68 |
| 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 D30 Fan's power socket and connectors are electrically connected to its fan and lighting elements. | ¶17 | 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, | When power is supplied to a D30 Fan, its fan spins and its lights turn on. | ¶17 | col. 3:4-6 |
| 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. | When one D30 Fan is connected to another, the second fan and its illumination area are also powered, as depicted in the product manual. | ¶17, ¶22 | col. 3:12-20 |
Identified Points of Contention
- Scope Questions: The construction of "on at least two sides of the fan at top of the body" may become a point of dispute. The parties may contest whether this requires illumination on opposing sides or merely two distinct illuminated surfaces, and how "top of the body" is defined in three-dimensional space.
- Technical Questions: While the complaint provides visual evidence of physical connectors, a key evidentiary question for the court will be whether the electrical pathway in the accused D30 Fan functions precisely as claimed—specifically, that the "first connector" of one fan connecting to the "second connector" of another is what causes the second fan to be "driven into rotation and illumination."
V. Key Claim Terms for Construction
"illumination area on at least two sides of the fan at top of the body"
- Context and Importance: This term defines the location and distribution of the lighting, a key aesthetic feature of the invention. The scope of "at least two sides" and "top of the body" will be critical for determining infringement, as fan lighting can be implemented in many configurations (e.g., on the blades, in the corners, along the frame).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "at least two" suggests the claim is not limited to a specific number or arrangement of illuminated sides, potentially covering any configuration with two or more illuminated areas on the fan's top surface. The detailed description refers generally to "an illumination area 3 disposed on at least two sides of the fan" without further restriction (’336 Patent, col. 2:63-65).
- Evidence for a Narrower Interpretation: The patent figures consistently depict the illumination areas (3) as strips along the frame on opposing sides of the central fan (’336 Patent, Figs. 1-5). A defendant might argue these consistent depictions limit the claim's scope to this specific arrangement.
"electrically connected"
- Context and Importance: This term is the functional heart of the patent, enabling the daisy-chaining of power and signals. Its construction will determine what type of electrical pathway satisfies the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is used functionally in Claim 1 to describe the outcome: power flows from the socket to all components and between fans. Plaintiff may argue this covers any internal wiring or circuitry that achieves this result.
- Evidence for a Narrower Interpretation: Dependent Claim 2 recites a more specific structure: "an electrically conductive terminal" in the first connector and "an electrically conductive contact surface" in the second (’336 Patent, col. 4:22-30). A defendant could argue this more specific language informs a narrower construction of "electrically connected" in the independent claim, potentially limiting it to direct physical contacts rather than other forms of electrical coupling.
VI. Other Allegations
Indirect Infringement
- The complaint's prayer for relief seeks to enjoin inducement of infringement (Compl. ¶21.b). The complaint provides factual support for this by referencing and providing a URL to the accused product's manual, which allegedly instructs customers on how to connect the fans in an infringing, daisy-chained manner (Compl. ¶22).
Willful Infringement
- The complaint alleges that Defendants had pre-suit knowledge of the ’336 patent and their alleged infringement since "at least May 2023," when they received a letter from Plaintiffs. The complaint claims that Defendants' continued infringement after this notice has been and continues to be willful (Compl. ¶19).
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents a dispute over seemingly similar technologies in the PC component market. The primary questions for the court appear to be:
- A central question of claim construction: How broadly will the court define the structural limitation "illumination area on at least two sides of the fan at top of the body"? The answer may determine whether the specific aesthetic design of the accused D30 Fan falls within the patent's scope.
- A key evidentiary question of functionality: While the complaint provides strong visual evidence of connectable fans, Plaintiffs will need to prove that the accused product's electrical system operates exactly as described in the functional "wherein" and "such that" clauses of Claim 1, establishing a direct link between the claimed structure and the infringing operation.
- A question of intent for willfulness: Did the May 2023 notice letter provide knowledge of infringement that was so clear that Defendants’ subsequent conduct was objectively reckless, potentially justifying enhanced damages?