DCT

2:25-cv-09759

Superior Communications Inc v. Belkin Intl Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-09759, C.D. Cal., 10/10/2025
  • Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant Belkin is located, resides, and conducts business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s screen protector applicator products, including its "Easy Align Tray" systems, infringe eight U.S. patents related to apparatuses and methods for applying screen protectors to mobile electronic devices.
  • Technical Context: The technology at issue involves physical alignment trays and systems designed to simplify the process of applying protective films to smartphone screens, making the application precise and bubble-free for consumers and retailers.
  • Key Procedural History: The complaint alleges that one of the named inventors on all asserted patents, Ms. Shraddha Patel, was a manager at Plaintiff Superior Communications during the patents' conception and subsequently joined Defendant Belkin in a product management role. Plaintiff alleges it sent multiple letters to Belkin regarding the asserted patents between August 2019 and September 2022 without receiving a substantive response. The complaint also notes that Belkin cited one of the asserted patents in an Information Disclosure Statement (IDS) during the prosecution of its own separate patent applications. Based on these events, the complaint raises the doctrine of assignor estoppel to potentially bar Belkin from challenging the patents' validity.

Case Timeline

Date Event
2011-02-18 Earliest Priority Date for all Asserted Patents
2012-09-01 Inventor Shraddha Patel leaves Plaintiff and joins Defendant
2012-09-01 Alleged first sales of Accused Products begin after this date
2015-04-21 U.S. Patent No. 9,010,396 Issues
2015-07-21 U.S. Patent No. 9,089,085 Issues
2016-11-09 Defendant cites the ’085 Patent in an Information Disclosure Statement
2018-04-03 U.S. Patent No. 9,931,823 Issues
2018-07-10 U.S. Patent No. 10,021,818 Issues
2019-08-30 Plaintiff sends first letter to Defendant regarding alleged infringement
2019-09-03 U.S. Patent No. 10,399,315 Issues
2019-10-30 Plaintiff sends second letter to Defendant
2020-02-04 U.S. Patent No. 10,555,445 Issues
2021-06-28 Plaintiff sends third letter to Defendant
2021-10-26 U.S. Patent No. 11,155,067 Issues
2022-06-07 U.S. Patent No. 11,357,143 Issues
2022-09-27 Plaintiff sends fourth letter to Defendant
2022-10-05 Defendant’s counsel responds to Plaintiff's letters
2025-10-10 Complaint Filed

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

U.S. Patent No. 9,010,396 - "Protective Material Applicator Device"

The Invention Explained

  • Problem Addressed: The patent family addresses challenges with applying screen protectors, particularly "wet fluid solution" methods that can be messy, require users to "squeegee" out excess liquid, and can leave air bubbles that take 24-48 hours to disappear (’818 Patent, col. 1:53-62). These issues detract from the consumer experience of acquiring a new electronic device.
  • The Patented Solution: The invention provides a physical apparatus—an alignment tray—to simplify the application of a protective film without a wet solution (’818 Patent, col. 2:11-15). The apparatus includes a "body defining a cavity" to hold the mobile device securely, and a "tab" that couples the screen protector to the body of the apparatus, ensuring the film is precisely aligned over the screen before application (Compl. ¶17; ’396 Patent, Abstract). This design aims to make screen protector installation straightforward, perfectly aligned, and bubble-free (Compl. ¶14).
  • Technical Importance: This technology sought to shift the market from difficult, wet-application films to user-friendly, dry-application systems that provide instant, perfect results, improving the consumer experience for a ubiquitous accessory (Compl. ¶¶14, 25-27).

Key Claims at a Glance

  • The complaint asserts dependent claim 3, which depends from independent claim 1 (Compl. ¶63).
  • Independent Claim 1 Elements:
    • An apparatus for applying a screen protector to a mobile communications device.
    • A body defining a cavity configured to receive the mobile device.
    • A screen protector having a first portion and a second portion.
    • A tab with a first end and a second end, where the first end is coupled to a surface of the body and the second end is coupled to the first portion of the screen protector.
  • Dependent Claim 3 adds: The tab is configured to couple to the surface of the body to align the screen protector over the screen of the mobile communications device when the device is in the cavity (’396 Patent, col. 16:11-15).

U.S. Patent No. 9,089,085 - "Protective Material Applicator Device"

The Invention Explained

  • Problem Addressed: As part of the same patent family as the '396 patent, this patent addresses the same difficulties associated with traditional screen protector application, such as misalignment and air bubbles (Compl. ¶18).
  • The Patented Solution: The ’085 patent describes both a system and a method for applying a screen protector. The system, like that in the ’396 Patent, uses a body with a cavity and a tab to facilitate alignment of the protector film onto a mobile device (Compl. ¶18). The method claim outlines the steps of using such a system, from inserting the device into the body to separating the film's backing and applying the film to the screen (’085 Patent, col. 19:48-20:6).
  • Technical Importance: By claiming both the apparatus (system) and the steps for its use (method), the patent seeks to provide comprehensive protection for the inventive application process.

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 7 (Compl. ¶74).
  • Independent Claim 1 (System) Elements:
    • A system comprising a body defining a cavity for receiving a mobile device.
    • A screen protector with a first portion, a second portion, a backing portion, and an application portion.
    • A tab with a first portion coupled to the body's surface and a second portion coupled to the screen protector to "sandwich" the application portion between the tab and the backing portion.
    • The tab is configured to remain coupled to the body while the backing portion is separated from the application portion.
  • Independent Claim 7 (Method) Elements:
    • Providing a body having an area for receiving a mobile device.
    • Inserting the mobile device into the area.
    • Providing a screen protector attached to a tab, where the protector has a backing portion and an application portion sandwiched between the backing and the tab.
    • Separating the backing portion from the application portion while the application portion remains attached to the tab.
    • Applying the application portion to the screen of the mobile device.

Multi-Patent Capsule Summaries

  • Patent Identification: U.S. Patent No. 9,931,823 ("the ’823 Patent"), "Protective Material Applicator Device," issued April 3, 2018.

  • Technology Synopsis: The ’823 Patent relates to improved systems for applying screen protectors that facilitate alignment of the protector with the mobile device through the use of a tab and a body defining a cavity (Compl. ¶19).

  • Asserted Claims: Independent Claim 1 (Compl. ¶¶33, 85).

  • Accused Features: The "Accused Belkin Face Up Tray Systems" and "Accused Belkin Face Down Tray Systems" are accused of infringing this patent (Compl. ¶¶33, 85).

  • Patent Identification: U.S. Patent No. 10,021,818 ("the ’818 Patent"), "Protective Material Applicator Device," issued July 10, 2018.

  • Technology Synopsis: The ’818 Patent relates to improved systems and methods for applying screen protectors that facilitate alignment through the use of a tab and a body defining a cavity (Compl. ¶20).

  • Asserted Claims: Independent Claim 1 (Compl. ¶¶33, 96).

  • Accused Features: The "Accused Belkin Face Up Tray Systems," "Accused Belkin Face Down Tray Systems," and "Accused Belkin Application Systems" are accused of infringing this patent (Compl. ¶¶33, 96).

  • Patent Identification: U.S. Patent No. 10,399,315 ("the ’315 Patent"), "Protective Material Applicator Device," issued September 3, 2019.

  • Technology Synopsis: The ’315 Patent relates to improved systems for applying screen protectors that facilitate alignment with a mobile device using a tab and an apparatus that includes a cavity (Compl. ¶21).

  • Asserted Claims: Independent Claim 1 (Compl. ¶¶33, 107).

  • Accused Features: The "Accused Belkin Face Up Tray Systems," "Accused Belkin Face Down Tray Systems," and "Accused Belkin Application Systems" are accused of infringing this patent (Compl. ¶¶33, 107).

  • Patent Identification: U.S. Patent No. 10,555,445 ("the ’445 Patent"), "Protective Material Applicator Device," issued February 4, 2020.

  • Technology Synopsis: The ’445 Patent relates to improved systems and methods for applying screen protectors that facilitate alignment with a mobile device using a tab and an apparatus that includes an area for the device (Compl. ¶22).

  • Asserted Claims: Independent Claim 1 (Compl. ¶¶33, 118).

  • Accused Features: The "Accused Belkin Face Up Tray Systems," "Accused Belkin Face Down Tray Systems," and "Accused Belkin Application Systems" are accused of infringing this patent (Compl. ¶¶33, 118).

  • Patent Identification: U.S. Patent No. 11,155,067 ("the ’067 Patent"), "Protective Material Applicator Device," issued October 26, 2021.

  • Technology Synopsis: The ’067 Patent relates to improved systems for applying screen protectors that facilitate alignment with a mobile device using a tab and a body defining a cavity (Compl. ¶23).

  • Asserted Claims: Independent Claim 1 (Compl. ¶¶33, 129).

  • Accused Features: The "Accused Belkin Face Up Tray Systems," "Accused Belkin Face Down Tray Systems," and "Accused Belkin Application Systems" are accused of infringing this patent (Compl. ¶¶33, 129).

  • Patent Identification: U.S. Patent No. 11,357,143 ("the ’143 Patent"), "Protective Material Applicator Device," issued June 7, 2022.

  • Technology Synopsis: The ’143 Patent relates to improved methods for applying screen protectors that facilitate alignment with a mobile device using a tab and a body defining an area for the device (Compl. ¶24).

  • Asserted Claims: Independent Claims 1 and 11 (Compl. ¶¶33, 140).

  • Accused Features: The "Accused Belkin Face Up Tray Systems," "Accused Belkin Face Down Tray Systems," and "Accused Belkin Application Systems" are accused of infringing this patent (Compl. ¶¶33, 140).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies several categories of accused products: "Accused Belkin Tray Systems," which include "Accused Belkin Face Up Tray Systems" and "Accused Belkin Face Down Tray Systems," as well as "Accused Belkin Application Systems" (Compl. ¶¶28, 30). Specific product lines named include Belkin's "Easy Align Tray" and "ScreenForce" products (Compl. ¶¶28, p. 9).
  • Functionality and Market Context: The accused products are described as tray systems designed for installing screen protectors onto mobile devices, including Apple iPhones, Samsung Galaxy phones, Apple Watches, and Apple iPads (Compl. ¶28). The complaint alleges these products are widely available through major retail channels, including Belkin's website, Best Buy, Office Depot, Staples, Target, and Walmart (Compl. ¶32). The "Application Systems" appear to be systems used in retail stores to apply the screen protectors for customers (Compl. ¶¶29, 33, p. 23).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of eight patents but does not provide element-by-element infringement contentions in the body of the complaint. Instead, it states that the accused products "satisfy all claim limitations" and refers to infringement claim charts attached as exhibits (e.g., Compl. ¶¶63, 74, Exs. 21, 22). These exhibits were not publicly filed with the complaint.

The narrative theory of infringement for all asserted patents is that Defendant’s "Easy Align Tray" and related application systems are apparatuses and/or methods for applying screen protectors that operate using the patented technology (Compl. ¶28). Specifically, the complaint alleges that Defendant’s trays function as a "body defining a cavity" to hold a mobile device and use a "tab" to facilitate the precise alignment and application of a screen protector, thereby infringing the asserted claims (Compl. ¶¶17-24). The complaint alleges infringement by Defendant's making, using, offering for sale, selling, and/or importing of these products in the United States (Compl. ¶¶63-64, 74-75).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central question for infringement will be whether the physical components of Defendant's "Easy Align Tray" systems fall within the scope of the claim terms "body defining a cavity" and "tab," as those terms are construed by the court. The dispute may focus on whether the term "tab," for example, requires a specific mechanical structure for coupling to the tray body, or if a broader definition covering different alignment mechanisms is appropriate.
    • Technical Questions: For the asserted method claims (e.g., ’085 Patent, claim 7), a key question will be whether the instructions and user manuals for the accused products direct users to perform all of the claimed steps. The complaint’s allegations of induced infringement suggest this will be a point of focus (Compl. ¶¶76-77).

V. Key Claim Terms for Construction

  • The Term: "tab" (from claims of the ’396 and ’085 Patents)

  • Context and Importance: The "tab" is the primary structural element responsible for the claimed alignment function. Its definition is critical because the infringement analysis will depend on whether the specific alignment feature on Belkin's accused products constitutes a "tab" as claimed.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the tab in functional terms, stating it is "configured to couple" to both the apparatus body and the screen protector (’085 Patent, col. 18:60-65). Language such as "film tab 695 may be applied (and may adhere) to the film 650" suggests the coupling could be as simple as an adhesive strip (’818 Patent, col. 10:30-31).
    • Evidence for a Narrower Interpretation: Many figures and embodiments show a more complex structure. For example, the specification describes a tab with "a pair of cylinders 1397 for engaging side engagement members" of the guiding apparatus, suggesting a mechanical, interlocking connection rather than simple adherence (’315 Patent, col. 22:5-8). Practitioners may argue that the term should be limited to such structural embodiments depicted in the patent.

  • The Term: "a body defining a cavity" (from claims of the ’396 and ’085 Patents)

  • Context and Importance: This term defines the main structure that holds the mobile device. The infringement case may turn on whether Belkin's tray, which may have a different shape or form factor, meets this definition.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims use general language, reciting "a body defining a cavity configured to receive the mobile device" (’396 Patent, col. 16:2-3). This broad functional language may support an interpretation that covers any tray-like structure that holds a phone for application.
    • Evidence for a Narrower Interpretation: The specification describes the body as a "substantially rectangular block having three or more portions including an inner wall defining a cavity" (’818 Patent, col. 13:37-40). Defendant may argue that this more specific description limits the scope of the "body" to a structure with these particular features, potentially excluding tray designs that deviate from this description.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement allegations are based on Defendant’s alleged active encouragement of infringement through user manuals, training videos on its website and YouTube, and other promotional literature that instructs consumers and retailers on how to use the accused products in an infringing manner (Compl. ¶¶65-67, 76-78). Contributory infringement is alleged on the basis that the accused tray systems are a material part of the patented invention, are not staple articles of commerce, and have no substantial non-infringing use (Compl. ¶¶69-70, 80-81).
  • Willful Infringement: The complaint alleges willful infringement based on extensive pre-suit knowledge. The allegations cite a series of four letters sent by Plaintiff to Defendant between August 2019 and September 2022, which allegedly identified the infringing products and asserted patents (Compl. ¶¶35-54). Willfulness is further supported by allegations that Defendant hired one of the patents' named inventors away from Plaintiff (Compl. ¶¶26-27, 59) and had independent knowledge of at least the ’085 patent from citing it in an IDS during its own patent prosecution in 2016 and 2017 (Compl. ¶59).

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

  • A core issue will be one of definitional scope: can terms like "tab" and "body defining a cavity," which are described with specific structural details in some embodiments, be construed broadly enough to read on the design of Defendant’s "Easy Align Tray" products? The outcome of claim construction will be pivotal to the infringement analysis.
  • A second central issue will be willfulness and estoppel, stemming from the unique factual allegations. A key question for the court will be whether the alleged pre-suit notice letters, combined with the hiring of a key inventor and Defendant's own citation of a patent-in-suit during prosecution, constitute the "egregious" conduct necessary to support a finding of willfulness and enhanced damages. A related question is whether the doctrine of assignor estoppel will bar Defendant from challenging the validity of the patents.
  • An evidentiary question of infringement mapping will be central. As the complaint relies on references to non-public exhibits for its infringement contentions, a key development will be how Plaintiff substantiates its claims by mapping each limitation of the asserted claims to the specific components and user instructions of the accused products.