DCT
2:24-cv-08769
1LSS Inc v. Apple Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: 1LSS Inc. (California)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Jeffer Mangels Butler & Mitchell LLP
- Case Identification: 2:24-cv-08769, C.D. Cal., 01/10/2025
- Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant has a regular and established place of business in the district (the Apple Store at 10250 Santa Monica Blvd) and has allegedly committed acts of infringement within the district.
- Core Dispute: Plaintiff alleges that Defendant’s MagSafe line of wallets infringes a patent related to magnetically coupled accessories for mobile devices.
- Technical Context: The technology concerns magnetic systems for attaching accessories, such as wallets, to mobile electronic devices, a significant market segment for smartphone peripherals.
- Key Procedural History: The complaint states that Plaintiff notified Defendant of potential infringement of the patent-in-suit by letter on February 9, 2024, and subsequently provided a claim chart on February 28, 2024, establishing alleged pre-suit knowledge for willfulness claims.
Case Timeline
| Date | Event |
|---|---|
| 2018-09-25 | ’641 Patent - Earliest Priority Date (Provisional App. 62/736,379) |
| 2024-01-09 | ’641 Patent - Issue Date |
| 2024-02-09 | Plaintiff sends notification letter to Defendant |
| 2024-02-28 | Plaintiff provides infringement claim chart to Defendant |
| 2025-01-10 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,864,641 - "Magnetically Coupled Wallet Accessory for Mobile Device," issued January 9, 2024
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience of carrying a separate cell phone and wallet, which can be easily misplaced, particularly when driving or needing quick access to navigation or payment cards ('641 Patent, col. 1:26-47).
- The Patented Solution: The invention is a wallet accessory that uses two distinct arrangements of magnetic material, each with adjacent regions of opposite polarity. This dual-arrangement system is designed to magnetically couple the wallet to a mobile device, or a case, in a specific, stable, and self-aligning orientation ('641 Patent, Abstract; col. 2:1-13).
- Technical Importance: This approach provides a method for securely attaching accessories to a phone that is not only strong but also ensures a consistent and correct orientation upon attachment ('641 Patent, col. 13:7-15).
Key Claims at a Glance
- The complaint specifically asserts independent claim 11 (Compl. ¶¶23, 24, 27).
- The essential elements of independent claim 11 are:
- A body defining a compartment and having a device side surface;
- A first arrangement of magnetic material having a first region exposing a first polarity magnetic field at the device side surface and a second adjacent region exposing an opposite polarity magnetic field at the device side surface;
- A second arrangement of magnetic material having a first region exposing a first polarity magnetic field at the device side surface and a second adjacent region exposing an opposite polarity magnetic field at the device side surface;
- Wherein the first magnetic arrangement has at least one of a different orientation or a different geometric pattern than the second arrangement; and
- Wherein the first and second arrangements, in use, concurrently magnetically couple the wallet to a mobile device and cause the wallet to adopt a specific orientation on the mobile device.
- The complaint notes that infringement is not limited to the example of claim 11 and reserves the right to assert other claims (Compl. ¶23, ¶33).
III. The Accused Instrumentality
Product Identification
The accused instrumentality is Defendant’s "MagSafe line of wallets for attachment to mobile devices," also referred to as the "Infringing Product" (Compl. ¶13). A specific example identified is the "iPhone Finewoven Wallet with MagSafe" (Compl. p. 4, fn. 1).
Functionality and Market Context
The accused wallets are designed to attach to mobile devices like the Apple iPhone (Compl. ¶25). The complaint alleges the wallets feature "strong built-in magnets that allow it to effortlessly snap into place on the back of your iPhone" (Compl. ¶25). Plaintiff alleges it disassembled an accused wallet and used a magnetic pole indicator to determine that the arrangement and polarity of the internal magnets infringe the ’641 Patent (Compl. ¶¶15-16). An image from the complaint shows the disassembled wallet revealing a circular magnet array and a separate, vertically oriented magnet (Compl. ¶27-28). The complaint alleges that Defendant competes directly with Plaintiff's "MagBak" line of magnetic wallets in the same marketing channels (Compl. ¶14, ¶21).
IV. Analysis of Infringement Allegations
’641 Patent Infringement Allegations
| Claim Element (from Independent Claim 11) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a body defining a compartment and having a device side surface | The accused wallet has a body that defines a compartment for holding items and a "device side surface" for attaching to a phone. An annotated photo depicts these features (Compl. ¶26). | ¶26 | col. 20:53-54 |
| a first arrangement of magnetic material having a first region exposing a first polarity magnetic field at the device side surface and a second adjacent region exposing an opposite polarity magnetic field... | The accused wallet allegedly has a first, circular arrangement of magnets. Plaintiff's analysis with a magnetic film viewer purports to show an outer ring region with a first polarity (north) and an adjacent inner ring region with an opposite polarity (south) (Compl. ¶27). | ¶27 | col. 20:56-62 |
| a second arrangement of magnetic material having a first region exposing a first polarity magnetic field at the device side surface and a second adjacent region exposing an opposite polarity magnetic field... | The accused wallet allegedly has a second, rectangular arrangement of magnets. Plaintiff's analysis purports to show a left-side rectangular region with a first polarity (north) and an adjacent middle rectangular region with an opposite polarity (south) (Compl. ¶28). | ¶28 | col. 20:63-col. 21:3 |
| wherein the first magnetic arrangement has at least one of a different orientation or a different geometric pattern than the second arrangement | The complaint alleges the first (circular) magnetic arrangement has a different geometric pattern than the second (rectangular) magnetic arrangement (Compl. ¶29). | ¶29 | col. 21:4-7 |
| wherein the first and second arrangements, in use, concurrently magnetically couple the wallet to a mobile device and wherein the first and second arrangements cause the wallet to adopt a specific orientation... | The complaint alleges that the wallet’s magnets "snap into place on the back of your iPhone," and that the combination of the two arrangements causes the wallet's compartment opening to be oriented toward the top of the iPhone, thereby adopting a specific orientation (Compl. ¶¶25, 30). | ¶30 | col. 21:8-13 |
Identified Points of Contention
- Scope Questions: A central question may be whether the term "arrangement of magnetic material," as used in the patent, reads on both the circular ring of magnets and the separate, single rectangular magnet in the accused wallet. The defense may argue that the single rectangular magnet does not constitute an "arrangement" in the same way the multi-part ring does, or that it does not contain "adjacent" regions of opposite polarity as claimed.
- Technical Questions: The plaintiff’s infringement theory relies on its analysis using a magnetic pole indicator and viewing film (Compl. ¶¶16, 27-28). The factual accuracy of this analysis—specifically, the assertion that the accused magnets expose distinct, adjacent regions of opposite polarity on the device-side surface as required by the claim—will be a key evidentiary battleground.
V. Key Claim Terms for Construction
The Term: "arrangement of magnetic material"
- Context and Importance: Claim 11 requires two distinct "arrangements." The definition of this term is critical because the accused product contains what appear to be two geometrically and physically separate magnetic structures (a ring and a bar). Practitioners may focus on this term because its construction will determine whether the two discrete magnetic components in the accused wallet can meet two separate limitations of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes various configurations, including multiple "plurality of magnets" and "linear rows" ('641 Patent, col. 14:38-48), which may support a broad interpretation that an "arrangement" can be any purposeful grouping of one or more magnetic regions.
- Evidence for a Narrower Interpretation: The claim language itself requires each "arrangement" to have at least two "adjacent region[s]" with opposite polarities. The defense could argue this requires a more complex structure than a single magnet, potentially limiting the interpretation of what qualifies as an "arrangement."
The Term: "adjacent region"
- Context and Importance: Both the "first arrangement" and "second arrangement" limitations require a "first region" and a "second adjacent region" with opposite polarities. The physical and magnetic relationship needed to satisfy "adjacent" will be dispositive. The plaintiff's images purport to show this adjacency both within the circular ring and along the rectangular magnet (Compl. ¶¶27-28).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition of "adjacent," which may support giving the term its plain and ordinary meaning of "next to" or "adjoining."
- Evidence for a Narrower Interpretation: Figures 43A-43L depict various patterns of North ("N") and South ("S") poles immediately next to each other ('641 Patent, col. 18:5-16). The defense may argue these specific embodiments imply that "adjacent" requires direct physical contact or a specific magnetic field interaction pattern not present in the accused device.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that Apple knowingly encourages infringement by marketing the accused wallets and providing instructions on its website and in promotional videos that guide customers to use the product in an infringing manner (Compl. ¶33).
- Willful Infringement: The complaint alleges willful infringement based on Apple's continued infringement after receiving notice of the ’641 Patent. This notice was allegedly provided in a letter dated February 9, 2024, and a subsequent claim chart on February 28, 2024 (Compl. ¶¶17, 22, 35).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: how broadly will the court define an "arrangement of magnetic material" and its required "adjacent regions" of opposite polarity? The viability of the plaintiff's case depends on whether both the circular magnet ring and the separate rectangular bar magnet of the accused wallet can independently satisfy this structured limitation.
- A key evidentiary question will be one of factual proof: can the plaintiff demonstrate that the magnetic fields of the accused wallet, as they exist on its surface, are organized into the specific adjacent, oppositely-polarized regions required by claim 11? The dispute may hinge on the evidence presented to prove the internal magnetic structure and its external expression.