DCT
8:17-cv-01254
Reversible Connections LLC v. Razer USA Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Reversible Connections LLC (Delaware)
- Defendant: Razer USA Ltd. (Delaware)
- Plaintiff’s Counsel: Friedman Suder & Cooke
- Case Identification: 8:17-cv-01254, C.D. Cal., 10/01/2021
- Venue Allegations: Venue is alleged to be proper in the Central District of California because Defendant Razer maintains its principal place of business in Irvine, California.
- Core Dispute: Plaintiff alleges that Defendant’s products containing USB Type-C ports infringe a patent related to reversible, double-sided electrical connectors with short-circuit prevention features.
- Technical Context: The technology addresses the common usability problem of single-orientation connectors (like USB-A) by creating a reversible connector, a concept now widely adopted in standards like USB-C.
- Key Procedural History: This First Amended Complaint was filed following an ex parte reexamination of the patent-in-suit, U.S. Patent No. 7,458,825. During reexamination, the originally issued claims 1-24 were canceled, and new claims 25-43 were added and found patentable by the USPTO. The original complaint, filed in 2017, asserted a now-canceled claim, while the current complaint asserts new claim 25. The litigation was previously stayed pending the outcome of the reexamination.
Case Timeline
| Date | Event |
|---|---|
| 2004-06-17 | ’825 Patent Priority Date |
| 2008-12-02 | ’825 Patent Issue Date |
| 2017-07-13 | Plaintiff sent letter to Razer alleging infringement |
| 2017-07-20 | Original Complaint filed |
| 2020-04-29 | Ex Parte Reexamination of ’825 Patent requested |
| 2021-07-07 | Reexamination Certificate for ’825 Patent issued, adding claims 25-43 |
| 2021-10-01 | First Amended Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 7,458,825, "DOUBLE-SIDED USB-COMPATIBLE PLUG CONNECTOR ADAPTED FOR INSERTION IN EITHER ORIENTATION INTO A USB-COMPATIBLE RECEPTACLE," issued December 2, 2008 (as amended by Ex Parte Reexamination Certificate issued July 7, 2021).
- The Invention Explained:
- Problem Addressed: The patent addresses the inconvenience of conventional USB connectors, which can only be inserted in a single orientation, making connection difficult, particularly when a port is not easily visible (’825 Patent, col. 2:21-28). It also identifies a specific risk with thin, card-like connectors: if inserted upside-down, the power (VBUS) contacts could touch the grounded metallic parts of the receptacle, causing a dangerous short circuit (’825 Patent, col. 2:44-53).
- The Patented Solution: The invention is a male plug connector with two sets of contacts, one on each of its opposing flat surfaces (’825 Patent, col. 5:41-50). The contacts are arranged in a "mutually opposed" or "anti-phase" relationship, such that regardless of which way the plug is inserted into a standard, single-sided female receptacle, the correct electrical connections are made (’825 Patent, col. 5:51-56). To solve the short-circuit problem, the invention includes a "short circuit prevention device," such as a diode or relay circuit, that prevents current from flowing if the VBUS contact is connected to ground (’825 Patent, Fig. 2d; col. 6:2-11).
- Technical Importance: The invention describes a foundational solution for making data and power connectors reversible, a significant usability improvement that anticipates features now standardized in modern connectors.
- Key Claims at a Glance:
- The complaint asserts infringement of at least independent claim 25 (’825 Patent, Compl. ¶7).
- Independent Claim 25 (added during reexamination) requires:
- A multi-contact connector with first and second sets of mutually opposed contacts on opposite surfaces.
- Corresponding contacts in each set are electrically interconnected and spatially aligned in a mutually opposed relationship.
- The connector can be connected in two opposed orientations to a standard USB-compatible receptacle that has only a single set of internal contacts.
- Identical functionality is obtained regardless of the connector's orientation.
- The connector includes an "electronic short circuit prevention device" to prevent a short between the VBUS and GND contacts of the receptacle upon insertion.
- The complaint’s prayer for relief seeks a finding of infringement on "one or more claims," suggesting dependent claims may be asserted later (Compl. ¶17(a)).
III. The Accused Instrumentality
- Product Identification: The complaint accuses desktop computers, laptops, and other electronics manufactured and sold by Razer that include USB Type-C ports (Compl. ¶7). A specific list of accused models is allegedly provided in Exhibit B to the complaint (Compl. ¶6).
- Functionality and Market Context: The complaint alleges that the USB Type-C ports in Razer's products adhere to the USB Type-C standard and, in doing so, embody the patented technology (Compl. ¶7). It is alleged that these ports function as reversible connectors with two sets of mutually opposed contacts, allowing connection in either orientation (Compl. ¶7). The complaint further alleges that the accused products contain circuitry that provides "electronic short circuit prevention" between the power (VBUS) and ground (GND) contacts when a connector is inserted (Compl. ¶7).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’825 Patent Infringement Allegations
| Claim Element (from Independent Claim 25) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A multi-contact connector supporting on opposite surfaces first and second sets of mutually opposed contacts... | The USB Type-C ports in the Accused Products include a connector having two sets of mutually opposed contacts. | ¶8 | col. 5:1-8 |
| ...wherein corresponding contacts in each set are electrically interconnected and are spatially aligned in a mutually opposed relationship... | The corresponding contacts in each set are electrically interconnected and are spatially aligned in a mutually opposed relationship. | ¶9-10 | col. 5:41-46 |
| ...allowing the multi-contact connector to be connected in two opposed orientations directly to a corresponding USB-compatible receptacle... | As a result, the USB connectors are capable of being connected in either orientation with a compatible receptacle... | ¶10-12 | col. 3:25-29 |
| ...such that identical functionality is obtained regardless of the orientation of the multi-contact connector within the USB-compatible receptacle... | By adhering to the USB Type C standards described above, the Accused Products include a multi-contact connector that meets each and every limitation of claim 25. | ¶17-19 | col. 3:8-13 |
| ...said multi-contact connector further comprising an electronic short circuit prevention device to prevent an electric short circuit between a VBUS contact... and a GND contact... | The Accused Products further include circuitry... that provides short circuit prevention for the port, including electronic short circuit prevention for preventing an electric short circuit... | ¶13-17 | col. 5:57-6:2 |
- Identified Points of Contention:
- Scope Questions: The complaint alleges that adherence to the USB Type-C standard results in infringement. A primary question for the court will be whether the functions mandated by the USB-C standard are coextensive with the limitations of claim 25. For example, the USB-C standard uses a sophisticated Configuration Channel (CC) pin and associated logic to detect orientation and negotiate power. The dispute may turn on whether this system constitutes an "electronic short circuit prevention device" as that term is used in the patent.
- Technical Questions: The complaint makes a conclusory allegation that Razer’s products contain an "electronic short circuit prevention" feature. A factual question will be what specific circuitry in Razer's products performs this function and how it operates. The analysis will compare the operation of Razer's USB-C port management circuitry to the patent's disclosed embodiments, which include diode- or relay-based circuits that directly block current on the power lines.
V. Key Claim Terms for Construction
- The Term: "electronic short circuit prevention device"
- Context and Importance: This term was added during reexamination and appears central to distinguishing the invention from the prior art. Its definition is critical, as the infringement analysis will likely depend on whether the accused USB Type-C controller logic falls within its scope. Practitioners may focus on this term because the technical mechanism of USB-C (using CC pin logic for orientation detection) differs from the specific power-blocking circuits (diodes/relays) disclosed in the patent's embodiments.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the term should be given its plain and ordinary meaning, covering any electronic component or circuit that performs the function of preventing a VBUS-to-GND short upon insertion. The claim uses the general term "device" and is not expressly limited to the specific embodiments shown in the patent figures (’825 Patent, col. 6:2-11; col. 7:1-8).
- Evidence for a Narrower Interpretation: Defendant may argue that the term should be interpreted in light of the specification, which discloses specific circuits like diodes or a relay that directly block current on the power lines to prevent a short (’825 Patent, Figs. 2d-2e). They may contend that this context limits the term to reactive, power-blocking circuits, as opposed to the proactive orientation-sensing logic of the USB-C standard.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement.
- Inducement: It is alleged that Razer knew of the patent and intended for its customers to infringe by providing products "especially designed for and marketed toward infringing use" and by supplying "user guides and other sales-related materials" that instruct on the normal (and allegedly infringing) operation of the USB-C ports (Compl. ¶12-13).
- Contributory: The complaint alleges that the accused USB-C connectors have "no substantial non-infringing uses" and that Razer knows they are "especially made" for an infringing use (Compl. ¶15).
- Willful Infringement: The complaint alleges that Razer has had knowledge of the ’825 patent since at least July 13, 2017, via a letter from the Plaintiff, and knowledge of the newly-added claims since at least the reexamination certificate's issuance on July 7, 2021 (Compl. ¶10). While the word "willful" is not used, these allegations of pre-suit and ongoing knowledge, coupled with a prayer for an exceptional case finding and attorney's fees, form the basis for a potential willfulness claim (Compl. ¶17(e)).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "electronic short circuit prevention device," which was added during reexamination and is described in the patent's specification via diode and relay embodiments, be properly construed to cover the complex Configuration Channel (CC) logic used in the industry-standard USB Type-C protocol?
- A key evidentiary question will be one of technical mapping: assuming the claim is construed broadly, does the specific implementation of the USB-C standard in Razer’s products meet every element of Claim 25? This will require a detailed comparison between the operation of the accused ports and the patent's claimed structure.
- The case will also examine the impact of the patent’s reexamination history. The arguments made to the USPTO to secure the allowance of new claim 25 over the prior art will be critical in defining the claim's scope and assessing any future validity challenges.