Universal Transdata LLC v. Inland Products Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Universal Transdata, LLC (Georgia)
  • Defendant: Inland Products, Inc. (California)
  • Plaintiff’s Counsel: Cotman IP Law Group, PLC
• Case Identification: 8:18-cv-01232, C.D. Cal., 07/12/2018
• Venue Allegations: Venue is alleged to be proper because Defendant is a California corporation with a registered office and an established place of business within the judicial district, and has allegedly committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s wireless keyboard and mouse combination products infringe a patent related to a system for wireless communication between computer peripherals and a Universal Serial Bus (USB) hub.
• Technical Context: The technology addresses the replacement of physical cables between computer peripherals (e.g., keyboards, mice) and a computer, utilizing a wireless link to a central USB hub receiver.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the asserted patent and its alleged infringement. The complaint also notes that the patent's term, including a patent term adjustment, extends through May 24, 2021.

Case Timeline

Date	Event
1999-08-11	U.S. Patent No. 7,028,114 Priority Date
2006-04-11	U.S. Patent No. 7,028,114 Issue Date
2018-07-12	Complaint Filing Date

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

U.S. Patent No. 7,028,114 - Universal Serial Bus Hub with Wireless Communication to Remote Peripheral Device

• Issued: April 11, 2006

The Invention Explained

• Problem Addressed: The patent describes the state of the art as requiring peripheral devices to be physically connected to USB hubs with cable connectors ('114 Patent, col. 1:44-47). The patent identifies a desire to eliminate these physical cable connections for a plurality of remote wireless peripherals ('114 Patent, col. 1:47-51).
• The Patented Solution: The invention is a system comprising one or more wireless peripheral devices (e.g., a keyboard, mouse) and a wireless USB hub. The peripherals wirelessly transmit data to a receiver in the hub, which includes a "hub controller" that processes the signal and converts it into a standard USB data format to be passed to the computer via an upstream USB port ('114 Patent, Abstract; col. 2:59-68). Figure 2 illustrates this architecture, showing multiple wireless peripherals (52, 54, 56) communicating with a central hub unit (40) that contains RF receivers and a hub controller.
• Technical Importance: The invention purports to provide the advantage of a "simple hardware design" by enabling communication with multiple remote peripherals through a single radio-frequency receiver system, thereby removing the need for individual cables connecting each device to the computer or hub (Compl. ¶13).

Key Claims at a Glance

• The complaint asserts independent claims 1, 3, and 9.
• Independent Claim 1 recites a wireless system comprising:
  • A remote wireless peripheral device, specified as "one of a keyboard, a mouse and a joystick," with a circuit for generating device information and an integral RF transmitter.
  • The RF transmitter is the "sole means for communicating" said information.
  • The peripheral device does "not hav[e] any USB communication capability."
  • A USB hub with a data reception circuit and a hub controller that converts the received wireless signal into a USB data signal for the computer.
• Independent Claim 3 recites a wireless system with similar elements to claim 1, comprising:
  • A remote wireless peripheral device (not limited to a specific type) with a circuit and an integral RF transmitter.
  • The RF transmitter is the "sole means for communicating" said information.
  • The peripheral device does "not hav[e] any USB communication capability."
  • A USB hub with a data reception circuit and a hub controller that converts the received wireless signal into a USB data signal for the computer.
• Independent Claim 9 recites a wireless hub and peripheral system comprising:
  • "at least two remote wireless peripheral devices," including a keyboard and a mouse, each with a circuit and an integral RF transmitter.
  • The RF transmitters are the "sole means for communicating."
  • The peripheral devices do "not hav[e] any USB communication capability."
  • A data reception circuit for receiving the wireless signals.
  • A hub controller that converts "each of said wireless signals to a USB data signal."
• The complaint asserts dependent claims 2, 4, 5, and 6 and reserves the right to assert additional claims (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

The complaint identifies Defendant’s "Pro wireless 2.4 GHz optical mouse and keyboard combo" as an exemplary accused product, along with other "as-yet-unknown products that similarly satisfy each element of each asserted claim" (Compl. ¶24).

Functionality and Market Context

The complaint alleges that these products are sold through online retailers including Amazon.com and the Defendant's own website (Compl. ¶4). The complaint does not provide specific technical details about the operation of the accused products beyond the general allegation that they are wireless keyboard and mouse combos that "embody the patented invention" (Compl. ¶24). The complaint further alleges that the products "satisfy each and every element of each asserted claim" (Compl. ¶25).

IV. Analysis of Infringement Allegations

The complaint references a preliminary claim chart (Exhibit B) which was not provided with the filed document (Compl. ¶25). As such, the infringement allegations are analyzed based on the narrative assertions in the complaint.

The core of the infringement theory appears to be that the "Pro wireless 2.4 GHz optical mouse and keyboard combo" constitutes the claimed system. Under this theory, the wireless keyboard and mouse function as the "remote wireless peripheral devices" of claims 1, 3, and 9 (Compl. ¶¶14, 16, 20). The USB receiver dongle, included with the combo product, is alleged to function as the claimed "Universal Serial Bus (USB) hub," which receives the RF signals from the peripherals and converts them into USB data signals for the host computer (Compl. ¶24). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may arise over the proper construction of "Universal Serial Bus (USB) hub." The defense may argue that the accused product's small USB receiver dongle is not a "hub" in the sense described by the patent, which depicts a hub as a potentially more complex device with a distinct "hub controller" and optional downstream physical ports ('114 Patent, Fig. 2; col. 1:40-42). The question is whether a simple receiver that communicates with a matched set of peripherals and lacks downstream ports falls within the scope of the term.
• Technical Questions: The infringement case may depend on factual evidence related to the negative limitations in the claims. A key question will be whether the accused peripherals truly have "no USB communication capability" and if their RF transmitters are the "sole means for communicating" ('114 Patent, col. 7:55-60). If the accused keyboard or mouse can be connected via a USB cable for functions like charging or firmware updates that also involve data transfer, the defense may argue these limitations are not met.

V. Key Claim Terms for Construction

"Universal Serial Bus (USB) hub" (from claims 1, 3, 9)

Context and Importance

The defendant's product is a keyboard/mouse combo that likely uses a single, small USB dongle as a receiver. Whether this component qualifies as a "hub" will be critical to the infringement analysis. Practitioners may focus on this term because its construction could be dispositive.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The patent summary states the invention "relates to a wireless USB hub" that includes a "receiver for receiving wireless data transmissions," a "signal discriminator," and a "hub controller" that communicates to an upstream port ('114 Patent, col. 2:59-68). Plaintiff may argue that any device performing these core functions of receiving, processing, and converting wireless peripheral data to a USB signal meets the definition, regardless of its physical size or the absence of downstream ports.
• Evidence for a Narrower Interpretation: The patent's background section discusses a conventional "USB hub" as having a "plurality of downstream ports for connecting the peripheral devices" ('114 Patent, col. 1:40-42). Defendant may argue that the term, as understood in the art and contextualized by the patent, requires the capability of connecting multiple devices via physical downstream ports, a feature a typical receiver dongle lacks.

"sole means for communicating" (from claims 1, 3, 9)

Context and Importance

This negative limitation requires that the RF transmitter be the only way for the peripheral to communicate device information. If the accused devices have any other communication pathway, such as a USB port used for charging that can also transmit data, this limitation may not be met.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: A plaintiff might argue that "communicating" in this context refers to the primary operational function of transmitting user input (e.g., keystrokes, mouse movements) and that other data pathways for ancillary functions like charging do not negate the "sole means" limitation for the device's main purpose.
• Evidence for a Narrower Interpretation: The term "sole" is absolute. Defendant will likely argue for a plain meaning interpretation: if the peripheral device possesses any other hardware or software that allows it to communicate information of any kind (e.g., battery status via a charging cable), then the RF transmitter is not the "sole means." The specification does not appear to explicitly qualify this term, lending weight to a literal interpretation.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant "actively and intentionally, with prior knowledge," induced infringement by "making, importing, using, selling, or offering for sale" the accused products (Compl. ¶33). The complaint does not plead specific facts detailing the affirmative acts of inducement, such as referencing user manuals or advertising that instruct customers on how to use the products in an infringing manner.

Willful Infringement

Willfulness is alleged based on pre-suit knowledge. The complaint asserts Defendant had "actual knowledge of the '114 Patent...at least since receiving pre-suit notice" and that its infringement has been "willful and deliberate" (Compl. ¶¶27-28).

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

• A core issue will be one of definitional scope: can the term "Universal Serial Bus (USB) hub," which the patent describes in the context of hub controllers and optional downstream ports, be construed to cover the integrated, single-purpose wireless receiver dongle supplied with the accused keyboard and mouse combo?
• A key evidentiary question will be one of factual compliance with negative limitations: does the evidence show that the accused wireless peripherals have "no USB communication capability" and that their RF transmitters are the "sole means for communicating", as strictly required by the asserted claims? The existence of any data-capable physical ports on the peripherals, even if for charging, will likely be a central point of contention.