DCT

5:24-cv-00353

CMI USA Inc v. Shenzhen Apaltek Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:24-cv-00353, C.D. Cal., 02/13/2024
  • Venue Allegations: Plaintiff alleges venue is proper because two of the defendants, Silverstone Technology Inc and Enermax USA, are California corporations with regular and established places of business within the district. For the foreign defendants, the complaint invokes the alien venue rule, which permits suit in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ liquid cooling systems and associated controllers infringe two utility patents related to a cooling apparatus architecture and one design patent for an LED controller.
  • Technical Context: The technology concerns all-in-one liquid cooling systems used to manage heat in high-performance computer components, a critical market segment for PC gaming, content creation, and data center applications.
  • Key Procedural History: The complaint notes that U.S. Patent No. 11,061,450 is a continuation of the application that resulted in U.S. Patent No. 10,509,446, indicating a shared specification and a strategy to protect related aspects of the same core technology. No other procedural history is mentioned.

Case Timeline

Date Event
2015-12-30 Priority Date for ’446 and ’450 Patents
2017-11-15 Filing (Priority) Date for ’941 Patent
2019-08-20 ’941 Patent Issue Date
2019-12-17 ’446 Patent Issue Date
2021-07-13 ’450 Patent Issue Date
2024-02-13 Complaint Filing Date

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

U.S. Patent No. 10,509,446, “Cooling Apparatus for Electronic Components,” issued Dec. 17, 2019

The Invention Explained

  • Problem Addressed: The patent seeks to solve the problem of reduced heat transfer efficiency in existing liquid cooling systems, which it attributes to their "complicated structures" (’446 Patent, col. 1:42-44).
  • The Patented Solution: The invention proposes a multi-part cooling apparatus featuring a specific, layered construction. It comprises a base plate with a heat exchange unit (e.g., fins), a cover member enclosing the fins to form a chamber, a "flow guidance plate" disposed on the cover, and a "housing" disposed on the flow guidance plate (’446 Patent, Abstract). The cover member’s inlet and outlet openings are designed as elongated slots of different lengths, a configuration intended to increase the fluid’s dwell time and flow velocity within the heat exchange chamber, thereby improving thermal performance (’446 Patent, col. 4:52-66).
  • Technical Importance: This architecture aims to create a more efficient fluid dynamic path within the compact form factor of a CPU water block, addressing the increasing thermal-design power of modern processors (’446 Patent, col. 1:26-32).

Key Claims at a Glance

  • The complaint asserts infringement of unspecified "exemplary claims" (Compl. ¶11). Independent claim 1 is central to the patent.
  • Independent Claim 1 requires:
    • A base plate with a heat exchange unit.
    • A cover member coupled to the base plate, forming a heat exchange chamber and defining a first and second opening above the heat exchange unit.
    • A flow guidance plate disposed on the cover member’s top surface, which defines a first cavity and a separate second cavity on its bottom surface.
    • A housing disposed on the flow guidance plate.
  • The complaint implicitly reserves the right to assert additional claims.

U.S. Patent No. 11,061,450, “Cooling Apparatus for Electronic Components,” issued Jul. 13, 2021

The Invention Explained

  • Problem Addressed: As a continuation of the ’446 Patent, this patent addresses the same problem of improving heat transfer efficiency in liquid coolers (’450 Patent, col. 1:48-51).
  • The Patented Solution: The invention claims variations and more specific embodiments of the layered cooling apparatus described in the parent ’446 Patent. The claims add further components to the core structure, such as an "outer casing" to enclose the entire assembly, a "partitioning plate" made of thermally resistive material to be placed between the cover member and flow guidance plate, or specific "fixing members" to couple the components (’450 Patent, claim 1; claim 19).
  • Technical Importance: This continuation patent appears designed to protect specific commercial implementations and refinements of the core cooling architecture disclosed in the original application, potentially creating a broader and more defensible patent portfolio (’450 Patent, col. 1:5-14).

Key Claims at a Glance

  • The complaint asserts infringement of unspecified "exemplary claims" (Compl. ¶20). The patent contains multiple independent claims.
  • Independent Claim 1 requires a similar structure to claim 1 of the ’446 Patent, with the addition of:
    • An outer casing secured to the base plate that at least partially encloses the cover member, the flow guidance plate, and the housing.
  • Other independent claims (e.g., 13, 14, 18, 19) add different limitations, such as a partitioning plate or specific fluid pathways. The complaint reserves the right to assert these.

Multi-Patent Capsule: U.S. Design Patent No. D856,941, “LED Controller,” issued Aug. 20, 2019

  • Technology Synopsis: This is a design patent that protects the specific, non-functional ornamental appearance of an LED controller. The claimed design consists of a rectangular remote-control-style body featuring three buttons arranged vertically, with the button outlines connected by a continuous, serpentine line (’941 Patent, Figs. 1-5).
  • Asserted Claims: The patent contains a single claim for the ornamental design as shown and described (’941 Patent, Claim).
  • Accused Features: The complaint alleges that the "RGB Controller" products sold by both SilverStone and Enermax Corp embody an ornamental design that an ordinary observer would find to be substantially the same as the one claimed in the ’941 patent (Compl. ¶14, ¶30, ¶34).

III. The Accused Instrumentality

  • Product Identification: The accused products are All-in-One (AIO) liquid cooling systems and associated controllers, including the SilverStone ICEMYST, PF, ICEGEM, and VIDA series, and the Enermax Corp Aquafusion, Liqmax, and Liqtech series, as well as separately identified "RGB Controller" products from both brands (Compl. ¶14).
  • Functionality and Market Context: The accused products are AIO liquid coolers for computer processors. These systems circulate a liquid coolant between a water block mounted on the CPU and a separate radiator to dissipate heat (Compl. ¶14). The water block assembly contains a cold plate for heat transfer and an integrated pump to circulate the fluid. The accused "RGB Controllers" are accessories used to manage the customizable aesthetic lighting on these cooling products (Compl. ¶14). The complaint does not provide specific detail for analysis of the products' market context.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference external claim chart exhibits which were not filed with the complaint; therefore, the analysis is based on the narrative infringement allegations. No probative visual evidence provided in complaint.

  • ’446 Patent and ’450 Patent Infringement Allegations
    • The complaint alleges that the accused SilverStone and Enermax Corp liquid coolers directly infringe the utility patents by incorporating the claimed cooling apparatus (Compl. ¶16, ¶23). The core of the allegation is that the internal structure of the defendants' water block/pump assemblies contains a base plate, a cover member, a flow guidance plate, and a housing, arranged in the specific hierarchical manner required by the claims (Compl. ¶20, ¶27). The allegations for the ’450 Patent further suggest these products may include additional claimed features such as an outer casing or a partitioning plate (Compl. ¶27).
  • Identified Points of Contention:
    • Scope Questions: A primary question may be whether the term "flow guidance plate," as used in the patents, reads on the internal components of the defendants' products. The court will have to determine if the accused coolers contain a structure that is separate from but "disposed on" the cover member, as the claims require.
    • Technical Questions: The infringement case may turn on whether the accused products actually contain the distinct, layered assembly of a "cover member," a "flow guidance plate," and a "housing." Defendants may argue their products use a more integrated two-piece or unibody pump block housing that lacks the specific, separable components and interfaces central to the asserted claims.

V. Key Claim Terms for Construction

  • The Term: "flow guidance plate"

    • Context and Importance: This term appears to be unique to the patentee and is not a standard term of art. Its construction will be critical because the claims require it to be a distinct element "disposed on a top surface of the cover member" and to itself have a bottom surface that defines separate fluid cavities. Practitioners may focus on this term because the entire infringement theory for the utility patents rests on finding this specific structure within the accused products.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue the term simply refers to any internal plate that directs fluid, as the name implies, without being limited to the exact depicted embodiment. The specification does not appear to offer an explicit definition that would limit its scope.
      • Evidence for a Narrower Interpretation: The specification consistently depicts the "flow guidance plate" (3) as a structurally distinct component from the "cover member" (1) and "housing" (4) (’446 Patent, Fig. 9, Fig. 15D). The detailed description attributes specific structural features to it, including sidewalls (351, 352) and columns (36), which may support an interpretation limiting the term to a plate with these characteristics (’446 Patent, col. 5:10-42).

  • The Term: "housing disposed on the flow guidance plate"

    • Context and Importance: The infringement analysis depends on this precise spatial and structural relationship. The validity of the infringement allegation requires finding not just a "housing" and a "flow guidance plate," but a housing that is specifically located on the plate. This hierarchical language may be a key point of dispute.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party seeking a broad definition might argue that "disposed on" merely requires general placement above, without needing direct physical contact or a specific assembly method.
      • Evidence for a Narrower Interpretation: The patent figures, particularly exploded views like Fig. 15D, clearly show the housing (4) as a separate component that sits on top of the flow guidance plate (3) in a layered assembly (’446 Patent, Fig. 15D). This visual evidence could support a narrower construction requiring separate, stackable components.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents. The factual basis cited is that Defendants provide "product literature and website materials" that instruct customers on how to use the accused products in a manner that allegedly infringes the patents (Compl. ¶18, ¶22, ¶26, ¶32).
  • Willful Infringement: The complaint establishes a basis for post-suit willful infringement by stating that, "At a minimum, the service of this Complaint" provides Defendants with actual knowledge of their alleged infringement (Compl. ¶17, ¶24, ¶31). No facts are alleged to support pre-suit knowledge.

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

  1. A core issue will be one of structural correspondence: Do the integrated pump-and-block units in the accused AIO coolers contain the specific, discrete, and hierarchically arranged "cover member," "flow guidance plate," and "housing" components as claimed in the utility patents, or do they utilize a different, more integrated architecture that may fall outside the claim scope?
  2. The case will likely hinge on claim construction: The definition of the term "flow guidance plate," which appears to be a neologism, will be dispositive. Whether it is construed broadly as any fluid-directing internal surface or narrowly as the distinct, multi-featured component shown in the patent's figures will likely determine the outcome of the utility patent infringement analysis.
  3. For the design patent, the central question will be one of ornamental similarity: Would an ordinary observer, taking into account the prior art, be deceived into thinking the accused RGB controllers’ design is substantially the same as the ornamental design claimed in the ’941 Patent?