DCT
2:25-cv-06983
BelAir Electronics Inc v. Totallee LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Totallee, LLC (dba TOTALLEE) (California)
- Plaintiff’s Counsel: Law Offices of Marc Libarle; Haller Law PLLC
- Case Identification: 2:25-cv-06983, C.D. Cal., 07/30/2025
- Venue Allegations: Venue is alleged to be proper in the Central District of California because the Defendant is a California corporation that resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s thin, protective mobile phone cases infringe two patents related to protective masks for mobile devices.
- Technical Context: The patents address protective coverings for mobile phones designed to prevent scratches and damage while allowing for aesthetic customization.
- Key Procedural History: The complaint alleges that both patents-in-suit expired prior to the filing of the lawsuit and that the infringing activity occurred before their expiration. Plaintiff alleges it provided Defendant with notice of the patents and the likelihood of infringement via email beginning on May 1, 2023, but received no response. The action seeks damages for a period beginning July 30, 2019.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | '195 and '676 Patent Priority Date |
| 2011-05-10 | '195 Patent Issue Date |
| 2018-10-09 | '676 Patent Issue Date |
| 2019-07-30 | Alleged start of damages period |
| 2021-10-23 | Alleged expiration of '676 Patent |
| 2022-11-16 | Alleged expiration of '195 Patent |
| 2023-05-01 | Alleged date of first notice letter to Defendant |
| 2025-07-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,941,195 - “Protective Mask of Mobile Phone,” issued May 10, 2011
The Invention Explained
- Problem Addressed: The patent's background section notes that mobile phones are often "smooth and delicate," making them susceptible to "ill-favored scars" from abrasion due to user carelessness, which deteriorates the phone's quality and value (’195 Patent, col. 1:29-35). It also notes the "waste of money" when users replace entire phones to keep up with fashion trends (’195 Patent, col. 1:36-41).
- The Patented Solution: The invention is a protective mask, comprising an upper and lower cover body, that can be joined with the front and rear housings of a mobile phone to sheathe it (’195 Patent, Abstract). This mask protects the phone from damage and allows for customization with "patterns, types, or nameplates" without replacing the device itself, thereby saving money and reducing economic burden (’195 Patent, col. 2:33-35, col. 1:53-60).
- Technical Importance: The invention provides a method for both protecting a mobile device and altering its appearance, addressing a consumer need for personalization and durability that became increasingly important as mobile phones evolved from simple communication tools to personal accessories.
Key Claims at a Glance
- The complaint asserts independent Claim 9.
- The essential elements of Claim 9 are:
- A protective mask adapted to be coupled to an exterior housing of a mobile phone.
- A first mask portion, molded to conform to the shape of a first portion of the exterior housing.
- The first mask portion having flanges to allow it to be coupled to the mobile phone and retain it.
- The complaint does not explicitly reserve the right to assert dependent claims of the ’195 Patent.
U.S. Patent No. 10,097,676 - “Protective Mask of Mobile Phone,” issued October 9, 2018
The Invention Explained
- Problem Addressed: Similar to its parent patent, the ’676 Patent addresses the problem of mobile phones being easily damaged by abrasion, leading to "ill-favored scars thereon, resulting in the deterioration of the quality of the mobile phone and the fall of its value" (’676 Patent, col. 1:35-39).
- The Patented Solution: The invention is a single, "integrally-formed mask body" that is "molded and contoured to conform and frictionally-fit tightly" against the phone's housing (’676 Patent, col. 4:41-44). The mask is held in place by "at least one retainer having an extension protruding laterally inward" which engages an edge of the phone's housing, providing secure retention (’676 Patent, col. 4:55-63).
- Technical Importance: This patent describes a form-fitting, single-piece protective case, a design that became dominant in the smartphone accessory market for offering protection with minimal added bulk.
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9.
- The essential elements of Claim 1 include:
- A protective mask molded for frictional retention to a mobile phone's exterior housing.
- An integrally-formed mask body molded to frictionally fit tightly against the housing.
- An inner surface in "substantially continuous surface-to-surface contact" with the housing's exterior.
- At least one opening for user access to interfaces.
- At least one retainer with a laterally inward-protruding extension that is retained to an exterior housing edge.
- The complaint states that the Accused Products also likely infringed dependent Claims 3, 4, 6, 7, 11, and 12 (Compl. ¶31, ¶34, ¶39).
III. The Accused Instrumentality
- Product Identification: The Accused Products are "protective masks for mobile devices" sold by Defendant Totallee, including various "Case Styles" such as "The Super Thin" and "The Clear Grip" for a wide range of Apple iPhone, Google Pixel, and Samsung Galaxy models (Compl. ¶13-15).
- Functionality and Market Context: The Accused Products are described as thin, minimalist cases that provide "non-permanent, temporary protection to the mobile device" (Compl. ¶17-18). The complaint includes marketing copy from Defendant's website advertising the cases as offering "Zero bulk" and "Full protection" (Compl. p. 6). The complaint alleges these cases use a "flange or retainer" to couple to the mobile device and prevent it from falling out (Compl. ¶17). The complaint provides an image of the interior of a "totallee Thin iPhone 14 Pro Max Case" with red markings highlighting a continuous lip alleged to be the infringing structure (Compl. p. 6).
IV. Analysis of Infringement Allegations
’195 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone | The Accused Products comprise a mask portion molded to conform to the shape of the exterior of a mobile phone. | ¶23.a | col. 2:36-42 |
| the first mask portion having flanges to allow the first mask portion to be coupled to the mobile phone to retain the first mask portion to the first portion of the exterior housing... | The Accused Products have flanges that allow the mask to be coupled to the mobile phone to retain it. | ¶23.b | col. 2:38-42 |
’676 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an integrally-formed mask body molded and contoured to conform and frictionally-fit tightly against the exterior shape of the exterior housing | The Accused Products are an integrally-formed mask body molded to conform and frictionally fit the housing. | ¶30.a | col. 4:41-44 |
| an inner surface of the integrally-formed mask body ... conforming to and in substantially continuous surface-to-surface contact with the exterior shape of the exterior housing, with no substantial space between the inner surface ... and the exterior shape of the exterior housing | The inner surface of the accused mask body conforms to and is in substantially continuous surface-to-surface contact with the phone's exterior, with no substantial space between them. | ¶30.b | col. 4:45-50 |
| at least one opening defined by the integrally-formed mask body permitting user access to at least the user input and output interfaces | The accused mask body has at least one opening for user access to input and output interfaces. | ¶30.c | col. 4:51-54 |
| at least one retainer having an extension protruding laterally inward...wherein the at least one retainer is retained to the exterior housing at an exterior housing edge...participating in retaining the integrally-formed mask body to the mobile communication device | The Accused Products have at least one retainer with a laterally inward extension that is retained at the phone's edge to hold the mask on the device. | ¶30.d | col. 4:55-63 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges that the continuous lip around the front of the Accused Products constitutes the "flanges" of the ’195 Patent and the "at least one retainer" of the ’676 Patent (Compl. ¶17, pp. 6-7). This raises the question of whether these terms, which are depicted in patent figures as potentially discrete structures, can be construed to read on a single, continuous, integrally-molded feature of the accused cases.
- Technical Questions: A factual question for the ’676 Patent is whether the Accused Products achieve "substantially continuous surface-to-surface contact with no substantial space" as claimed (’676 Patent, col. 4:47-50). The resolution may depend on expert analysis of the fit and tolerances between the cases and the phones they are designed for.
V. Key Claim Terms for Construction
For the ’195 Patent:
- The Term: "flanges"
- Context and Importance: The existence of "flanges" is a central limitation of asserted Claim 9. The infringement analysis will depend on whether the raised lip on the accused single-piece cases can be defined as "flanges."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires "flanges" in the plural but does not specify their number, shape, or that they must be discontinuous. One might argue that any structure performing the function of allowing the mask to be coupled and retained meets the definition.
- Evidence for a Narrower Interpretation: The specification describes and illustrates "a plurality of flanges 21" which appear as distinct, separate tabs on the rear side of the cover body (’195 Patent, col. 2:38-40; Fig. 3). A defendant may argue this disclosure limits the term to such discrete structures, not a continuous lip.
For the ’676 Patent:
- The Term: "at least one retainer"
- Context and Importance: This term is the primary retention mechanism described in the asserted independent claims of the ’676 Patent. Practitioners may focus on this term because the infringement case hinges on mapping this limitation to the continuous lip of the accused products. The complaint's visual aids, which circle sections of this lip, suggest this is the core of the infringement theory (Compl. pp. 6-7).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires "at least one" retainer, which does not preclude a single, continuous retainer that extends around the periphery of the device. The functional language—"participating in retaining the integrally-formed mask body"—could be argued to describe the function of the entire lip.
- Evidence for a Narrower Interpretation: The claim recites a retainer "having an extension protruding laterally inward," which could suggest a discrete part rather than the entire edge of the case. The specification does not provide a specific definition, leaving its interpretation open to arguments based on the overall context and drawings.
VI. Other Allegations
- Indirect Infringement: The complaint focuses on allegations of direct infringement through Defendant's acts of making, using, selling, and importing the Accused Products (Compl. ¶13, ¶21, ¶28). It does not contain specific factual allegations to support a claim for indirect infringement, such as inducement or contributory infringement.
- Willful Infringement: The complaint alleges that Defendant had pre-suit knowledge of both asserted patents and the likelihood of infringement "at least as early as May 1, 2023, pursuant to email correspondence from BelAir" (Compl. ¶25, ¶41). It further alleges that Defendant did not respond to this or subsequent communications, which may be used to support a claim of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue for both patents will be one of definitional scope: can the terms "flanges" (’195 Patent) and "at least one retainer" (’676 Patent), which are described in the specifications with reference to particular structural embodiments, be construed to read on the continuous, integrally-molded lip of the accused single-piece phone cases?
- A central legal and factual question will be one of notice and willfulness: did the series of unanswered emails alleged in the complaint constitute actual notice sufficient to support a claim for willful infringement, and what evidence will be presented to establish the objective recklessness of Defendant's alleged conduct post-notice?
- A key evidentiary question for the ’676 Patent will be one of functional contact: does the fit of the accused cases on their respective mobile devices meet the claim requirement of "substantially continuous surface-to-surface contact with no substantial space," a determination that will likely require detailed product testing and expert testimony.