DCT
2:25-cv-10674
National Products Inc v. X Naut LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: National Products Inc. (Washington)
- Defendant: X-Naut LLC (California)
- Plaintiff’s Counsel: Fenwick & West LLP
- Case Identification: 2:25-cv-10674, C.D. Cal., 11/06/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains its headquarters and principal place of business within the Central District of California and has committed the alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s lines of powered docking systems and protective covers for portable electronic devices infringe five U.S. patents related to docking sleeves with integrated electrical adapters.
- Technical Context: The technology enables portable consumer electronics, such as tablets, to be used in protective cases that allow for seamless connection to docking stations for power and data transfer without removing the case.
- Key Procedural History: The complaint alleges that Defendant had actual knowledge of all five patents-in-suit as of at least October 23, 2025, based on a notification from Plaintiff, which forms the basis for the willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-24 | Priority Date for '984, '334, '275, '884, and '141 Patents |
| 2018-08-21 | '984 Patent Issued |
| 2020-04-21 | '334 Patent Issued |
| 2020-09-15 | '275 Patent Issued |
| 2022-10-18 | '884 Patent Issued |
| 2024-11-12 | '141 Patent Issued |
| 2025-10-23 | Alleged date of first notice of infringement |
| 2025-11-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,054,984 - Docking Sleeve With Electrical Adapter (issued August 21, 2018)
The Invention Explained
- Problem Addressed: The patent's background section observes that consumer portable electronic devices like smartphones and tablets lack the built-in docking connectors found on ruggedized laptops, and that existing protective "skins" do not facilitate easy docking into cradles for power and data transfer (ʼ984 Patent, col. 1:21-42).
- The Patented Solution: The invention is a flexible protective cover, or "skin," that incorporates a structurally integral electrical adapter. This adapter features a male plug that projects into the cover's interior to connect with the device's female I/O socket, and a corresponding contactor with exposed contacts on the exterior of the cover. This configuration allows a device housed within the skin to be docked directly into a cradle without removing the protective cover (ʼ984 Patent, Abstract; col. 2:7-19).
- Technical Importance: This design allows mass-market consumer devices to be integrated into professional or industrial environments that rely on rugged docking stations, thereby enhancing their utility and durability in such settings (ʼ984 Patent, col. 1:51-57).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶32).
- The essential elements of independent claim 1 include:
- A flexible protective cover configured to envelop an electronic device, extending around its side, front, and back faces.
- An adapter coupled to the cover, which itself includes:
- A male plug with connectors extending into the cover to mate with the device's female socket.
- A contactor with exposed contacts on the cover's exterior, electrically coupled to the male plug's connectors.
- A male positioning interface on the cover, defined by a rim that surrounds and is in contact with the perimeter of the contactor surface, intended to guide the mating of the contactor to an external connector.
- The complaint's phrasing suggests the right to assert other claims, including dependent claims, may be reserved.
U.S. Patent No. 10,630,334 - Docking Sleeve With Electrical Adapter (issued April 21, 2020)
The Invention Explained
- Problem Addressed: Similar to the ʼ984 Patent, this patent addresses the challenge of adapting consumer electronic devices, which lack native docking connectors, for use with docking cradles while inside a protective case (ʼ334 Patent, col. 1:35-47).
- The Patented Solution: The invention is a protective "arrangement" comprising a hard shell and an adapter. The adapter, which includes an external contactor and a positioning interface, is designed to be received within the hard shell alongside the electronic device. A key feature is that the adapter is configured to extend out of the hard shell for mating and is "detachable from the hard shell by a user," suggesting a modular approach (ʼ334 Patent, Abstract; col. 2:8-25).
- Technical Importance: This solution provides a more rigid and potentially modular protective system compared to a flexible skin, where the electrical adapter component can be separated from the main protective shell by the user (ʼ334 Patent, col. 36:23-24).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶43).
- The essential elements of independent claim 1 include:
- An adapter with a contactor (having an exposed contact surface) and a male positioning interface (defining a guiding rim).
- A hard shell configured to receive both the portable electronic device and the adapter.
- The hard shell is configured such that the adapter extends out of it for mating with an external connector.
- A specific limitation that the adapter is "detachable from the hard shell by a user."
- The phrasing of the allegation suggests the potential assertion of additional claims.
U.S. Patent No. 10,778,275 - Docking Sleeve With Electrical Adapter
- Patent Identification: U.S. Patent No. 10,778,275, "Docking Sleeve With Electrical Adapter," issued September 15, 2020 (Compl. ¶19).
- Technology Synopsis: This patent describes a protective arrangement where the cover has a panel and a surrounding skirt. The invention places the male plug inside the cover's cavity to connect to the device, while the external contactor is disposed on the exterior surface of the panel, with electrical conductors running within the cover to connect the two ('275 Patent, Abstract).
- Asserted Claims: At least claim 1 (Compl. ¶54).
- Accused Features: The complaint alleges that Defendant’s X30 line of products infringes by comprising a cover with an interior cavity, a male plug extending into that cavity, and a contactor disposed on the exterior surface (Compl. ¶¶ 56-58).
U.S. Patent No. 11,476,884 - Docking Sleeve With Electrical Adapter
- Patent Identification: U.S. Patent No. 11,476,884, "Docking Sleeve With Electrical Adapter," issued October 18, 2022 (Compl. ¶23).
- Technology Synopsis: This patent claims a protective arrangement with an adapter and hard shell, similar to the ʼ334 Patent. A distinguishing feature of claim 1 is the requirement that the adapter's contactor surface be "configured to be parallel to a nearest surface of the portable electronic device when the portable electronic device is coupled to the adapter" ('884 Patent, col. 34:5-9).
- Asserted Claims: At least claim 1 (Compl. ¶65).
- Accused Features: The X30, X90, and FlexGrip products are accused of infringing by allegedly having an adapter with a contactor surface parallel to the device, a male plug, and a positioning interface, and being used with a detachable hard shell (Compl. ¶¶ 67-69).
U.S. Patent No. 12,143,141 - Docking Sleeve With Electrical Adapter
- Patent Identification: U.S. Patent No. 12,143,141, "Docking Sleeve With Electrical Adapter," issued November 12, 2024 (Compl. ¶27).
- Technology Synopsis: This patent describes a protective case with a center panel and a side skirt. Its claims focus on the specific configuration of the contacts, requiring a male plug with "first contacts" inside the case and a "plurality of second contacts" on the exterior panel, where the second contacts comprise specific geometries such as "at least three circular contacts, at least three annular contacts, or at least three contacts spaced laterally" ('141 Patent, Abstract; col. 34:7-12).
- Asserted Claims: At least claim 1 (Compl. ¶76).
- Accused Features: The X30, X90, and FlexGrip products are accused of infringing by allegedly incorporating a protective case with an internal male plug and external contacts that have the specific circular, annular, or laterally-spaced configurations recited in the claim (Compl. ¶¶ 78-81).
III. The Accused Instrumentality
Product Identification
- Defendant’s "FlexGrip," "X90," and "X30" lines of "powered docking systems for and used with portable electronic devices" (Compl. ¶¶ 32, 43, 65).
Functionality and Market Context
- Based on the complaint, the FlexGrip and X90 products are flexible protective covers with an integrated electrical adapter that allows a housed device to be docked (Compl. ¶34). The complaint provides a photograph showing a tablet within a flexible, black, lattice-style X-Naut case (Compl. ¶34).
- The X30 products are described as comprising a hard shell and an adapter that is detachable from the shell (Compl. ¶¶ 46-47). The complaint includes an image showing a device in a hard-shell case with a U-shaped frame, where an adapter module extends from the back for connection (Compl. ¶46).
- Plaintiff alleges these products are marketed and sold by Defendant throughout the United States via its website (Compl. ¶¶ 4, 8).
IV. Analysis of Infringement Allegations
’984 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a flexible protective cover configured and arranged to receive an electronic device and extend around four side faces..., extend around a peripheral edge of a front face..., and extend around at least a peripheral edge of a back face... | The FlexGrip and X90 products comprise a "flexible protective cover" that is configured to receive a device and extend around its side, front, and back faces. A provided image shows a tablet computer enveloped by such a cover (Compl. ¶34). | ¶34 | col. 7:40-50 |
| an adapter coupled to the cover, the adapter comprising a male plug comprising a plurality of connectors extending into the cover in an arrangement for mating with a female socket of the electronic device... | The products are alleged to comprise an adapter coupled to the cover that includes a male plug with connectors extending into the cover to mate with the device's socket. | ¶35 | col. 2:12-16 |
| a contactor comprising a contactor surface and a plurality of contacts exposed and arranged on the contactor surface and electrically coupled to one or more of the connectors of the male plug | The adapter allegedly includes a contactor with an exposed contactor surface and contacts that are electrically coupled to the male plug connectors. | ¶35 | col. 2:16-19 |
| ...the cover further comprises a male positioning interface defining a rim surrounding, and in contact with, a perimeter of the contactor surface of the contactor of the adapter to guide proper mating... | The cover allegedly includes a male positioning interface that forms a rim around the contactor's perimeter to guide mating with an external connector. | ¶36 | col. 28:1-2 |
- Identified Points of Contention:
- Scope Questions: A potential issue is whether the term "flexible protective cover" as used in the patent, which is described as fitting like a "surgical glove" (ʼ984 Patent, col. 5:17-18), reads on the structure of the accused FlexGrip and X90 products.
- Technical Questions: The complaint alleges the accused product's cover includes a "male positioning interface" that functions "to guide proper mating" (Compl. ¶36). The analysis may raise the question of whether the accused product's rim-like structure performs this specific guiding function as required by the claim, or if its shape is merely incidental to housing the contactor.
’334 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an adapter coupleable to a portable electronic device for mating with an external connector, the adapter comprising a contactor and a male positioning interface... | The X30 line of products is alleged to comprise an adapter for mating with an external connector, which includes a contactor and a male positioning interface. | ¶45 | col. 36:8-11 |
| the contactor comprising a contactor surface and a plurality of contacts exposed and arranged on the contactor surface and electrically coupleable to the portable electronic device | The contactor is alleged to have an exposed surface with contacts that are electrically coupleable to the device. | ¶45 | col. 36:12-15 |
| the male positioning interface defining a rim surrounding, and in contact with, a perimeter of the contactor surface... to guide proper mating... | The male positioning interface allegedly defines a rim that surrounds and is in contact with the perimeter of the contactor surface to guide mating. | ¶45 | col. 36:16-19 |
| a hard shell configured to receive the portable electronic device and adapter, wherein the hard shell is configured so that the adapter extends out of the hard shell for mating with the external connector | The X30 products are alleged to include a hard shell configured to receive the device and adapter, from which the adapter extends for mating. An image shows this configuration (Compl. ¶46). | ¶46 | col. 36:20-22 |
| ...wherein the adapter is detachable from the hard shell by a user. | The adapter is alleged to be detachable from the hard shell by a user. The complaint includes a diagram from the patent illustrating this detachability (Compl. ¶47). | ¶47 | col. 36:23-24 |
- Identified Points of Contention:
- Scope Questions: A central question will be the construction of "detachable from the hard shell by a user." The litigation will likely explore whether this requires a tool-less or simple user action, versus a more involved disassembly, and whether the accused X30 products meet the construed definition.
- Technical Questions: The complaint alleges the hard shell is "configured to receive the portable electronic device and adapter" (Compl. ¶46). The infringement analysis raises the question of how the adapter and device are physically situated relative to the shell in the accused product, and whether this matches the configuration described and claimed in the patent.
V. Key Claim Terms for Construction
For the ’984 Patent
- The Term: "male positioning interface"
- Context and Importance: This term is critical because it defines the physical feature responsible for aligning the device for docking. The construction will determine whether any raised perimeter around the contacts infringes, or if a more specialized structure with specific guiding properties is required by the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself—"defining a rim surrounding ... to guide proper mating"—is functional and may support a construction where any rim structure that achieves the guiding function would satisfy the limitation (ʼ984 Patent, col. 28:1-2).
- Evidence for a Narrower Interpretation: The specification describes the "positioning interface dam" (132) as cooperating with a "socket receiver" in the docking cradle (ʼ984 Patent, col. 13:30-44). A party may argue that the term should be limited to structures that enable this specific dam-and-socket interaction, rather than any generic guiding rim.
For the ’334 Patent
- The Term: "detachable from the hard shell by a user"
- Context and Importance: This limitation is a key feature of claim 1, distinguishing it from a permanently integrated system. The case may turn on the meaning of "detachable," specifically the ease and method of separation intended for a "user."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language does not specify the method or ease of detachment, which may support a broad reading that covers any non-destructive separation a user could perform, even with tools. The specification does not appear to explicitly limit the term.
- Evidence for a Narrower Interpretation: The context of providing user flexibility may suggest an interpretation requiring a tool-less or simple, quick-release mechanism. A party might argue that a feature requiring significant disassembly would not be considered "detachable by a user" in the context of the invention, which aims to overcome the limitations of prior art devices (ʼ334 Patent, col. 1:43-47). The diagram provided in the complaint appears to show screws, which may complicate a purely tool-less interpretation and highlights the ambiguity of the term (Compl. ¶47).
VI. Other Allegations
- Indirect Infringement: For all five patents, the complaint alleges both induced and contributory infringement. Inducement allegations are based on Defendant providing the accused products with the intent that customers use them in an infringing manner, supported by advertising and instructional materials (Compl. ¶¶ 37, 48, 59, 70, 82). Contributory infringement is alleged on the basis that Defendant supplies components (e.g., protective covers) that are material parts of the patented inventions, are especially made for infringing use, and have no substantial non-infringing uses (Compl. ¶¶ 38, 49, 60, 71, 83).
- Willful Infringement: The complaint alleges willful infringement of all five patents. The basis for willfulness is alleged pre-suit knowledge stemming from a notification of infringement that Plaintiff provided to Defendant on or before October 23, 2025 (Compl. ¶¶ 41, 52, 63, 74, 86).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can terms like "male positioning interface" and "detachable from the hard shell by a user" be construed broadly enough to read on the physical structures and mechanisms of the accused X-Naut products? The resolution of these terms may determine the outcome for multiple asserted patents.
- A key evidentiary question will be one of technical specificity: does each accused product line (FlexGrip, X90, X30) contain the precise combination of elements required by each distinct patent claim asserted against it? The case will likely require a detailed factual comparison of how each product is constructed and operates versus the specific limitations of claims directed to, for example, a "flexible cover" ('984 Patent), a "hard shell" ('334 Patent), an "exterior contactor" ('275 Patent), a "parallel" contactor surface ('884 Patent), and specific contact geometries ('141 Patent).