DCT

8:20-cv-00735

Sanho Corp v. Intelliarmor

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:20-cv-00735, C.D. Cal., 05/18/2020
  • Venue Allegations: Venue is alleged based on Defendants conducting business, committing acts of infringement, and causing injury within the Central District of California.
  • Core Dispute: Plaintiff alleges that Defendant’s "LYNKHUB" line of USB-C hubs infringes one utility patent and four design patents related to port extension apparatus technology and ornamental designs.
  • Technical Context: The technology concerns external port extension hubs, or "dongles," which expand the limited connectivity options of modern laptops and mobile devices that often feature only a few versatile ports like USB-C.
  • Key Procedural History: The complaint states that Plaintiff provided Defendants with pre-suit written notice of the alleged infringement and a demand to cease and desist. Subsequent to the filing of this complaint, U.S. Patent No. 10,572,429 was the subject of an Inter Partes Review (IPR), IPR2021-00886, which resulted in the cancellation of claims 1-6 and 13-17.

Case Timeline

Date Event
2015-03-30 '290 Patent Priority Date
2016-11-24 '616 Patent Priority Date
2016-12-13 '875 Patent Priority Date
2017-04-27 '429 Patent Priority Date
2017-05-06 '618 Patent Priority Date
2018-01-09 '290 Patent Issue Date
2018-03-27 '875 Patent Issue Date
2019-04-02 '618 Patent Issue Date
Circa 2019 Alleged First Infringing Sales
2019-08-06 '616 Patent Issue Date
2020-02-25 '429 Patent Issue Date
2020-05-18 Complaint Filing Date
2021-04-30 IPR Filed against '429 Patent
2025-02-26 IPR Certificate Issued Cancelling Claims of '429 Patent

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

U.S. Patent No. 10,572,429 - "Port Extension Apparatus"

Issued February 25, 2020 (’429 Patent)

The Invention Explained

  • Problem Addressed: The patent identifies the problem of modern end-user devices, like laptops and tablets, having a limited number of ports that are often spaced too closely together, creating "low and/or inefficient port usage problems" (ʼ429 Patent, col. 1:13-28).
  • The Patented Solution: The invention is a "port extension apparatus" that connects to an end-user device and provides multiple additional ports for various functions (e.g., data, video). The core of the solution is a "data transmission control module" that manages the data flow between the host device and multiple peripherals connected to the apparatus, thereby increasing the "utilization efficiency of the end-user device port" (ʼ429 Patent, Abstract; Fig. 1; col. 2:19-22).
  • Technical Importance: This technology provides a solution to the market trend of computer manufacturers creating slimmer devices by reducing the number of built-in ports, leaving users in need of external adapters to connect legacy and multiple peripherals simultaneously (ʼ429 Patent, col. 1:8-16).

Key Claims at a Glance

  • The complaint does not specify which claims of the ’429 Patent are asserted (Compl. ¶¶14, 18). Independent claim 1 is the broadest claim.
  • Essential elements of Independent Claim 1 include:
    • A main port module for connecting to an end-user device, itself having first and second port units.
    • A first data port module connecting to the first port unit.
    • A data transmission control module connecting to the second port unit.
    • A second data port module and a video port module, both connecting to the data transmission control module.
    • The claim further recites specific functionalities: forming a direct transmission path for the first data port module, controlling data transmission for the second data port module, and receiving/displaying information for the video port module.
  • It is critical to note that an IPR proceeding subsequent to the complaint's filing resulted in the cancellation of this claim.

U.S. Design Patent No. D855,616 - "THUNDERBOLT 3.0 USB-C CONNECTOR"

Issued August 6, 2019 (’616 Patent)

The Invention Explained

  • Problem Addressed: Design patents do not solve technical problems; they protect the novel, non-functional, ornamental appearance of an article of manufacture.
  • The Patented Solution: The patent claims the specific ornamental design for a rectangular electronic hub. Key features of the claimed design include the overall shape of the housing and two male USB-C style connectors protruding from one end of the device, as depicted in the patent's figures (’616 Patent, Fig. 1; Description). The broken lines in the figures denote environmental structure that is not part of the claimed design (’616 Patent, Description).

Key Claims at a Glance

  • As is typical for a design patent, there is a single claim: "The ornamental design for a thunderbolt 3.0 USB-C connector, as shown and described" (’616 Patent, Claim).

U.S. Design Patent No. D813,875 - "MULTI-FUNCTION DOCKING STATION"

Issued March 27, 2018 (’875 Patent)

  • Technology Synopsis: The patent claims the ornamental design for a multi-function docking station, characterized by a generally rectangular body with a single male connector protruding from one end for connecting to a host device.
  • Asserted Claims: The single claim is for the ornamental design "as shown and described" (’875 Patent, Claim).
  • Accused Features: The complaint alleges that the overall appearance of the INTELLIARMOR LYNKHUB HD+, LYNKHUB PRO, and LYNKHUB MACBOOK PRO USB C HUB products infringes this design (Compl. ¶14).

U.S. Design Patent No. D844,618 - "MULTI-FUNCTION DOCKING STATION"

Issued April 2, 2019 (’618 Patent)

  • Technology Synopsis: The patent claims the ornamental design for a docking station featuring an integrated, short, flexible cable that terminates in a male connector.
  • Asserted Claims: The single claim is for the ornamental design "as shown and described" (’618 Patent, Claim).
  • Accused Features: The complaint alleges that the overall appearance of the INTELLIARMOR LYNKHUB HD+, LYNKHUB PRO, and LYNKHUB MACBOOK PRO USB C HUB products infringes this design (Compl. ¶14).

U.S. Design Patent No. D807,290 - "MULTI-FUNCTION CONNECTOR"

Issued January 9, 2018 (’290 Patent)

  • Technology Synopsis: The patent claims the ornamental design for a multi-function connector, also characterized by a main body connected to a male plug via an integrated cable.
  • Asserted Claims: The single claim is for the ornamental design "as shown and described" (’290 Patent, Claim).
  • Accused Features: The complaint alleges that the overall appearance of the INTELLIARMOR LYNKHUB MEDIA and LYNKHUB+ products infringes this design (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are various models of Defendants' USB-C hubs, sold under the "LYNKHUB" brand. Specific models named are the "LYNKHUB HD + 7 IN 1," "LYNKHUB PRO 3 IN 1," "LYNKHUB MACBOOK PRO USB C HUB," "LYNKHUB MEDIA - 4 IN 1," and "LYNKHUB+ 5 IN 1" (Compl. ¶¶14-15).

Functionality and Market Context

The complaint alleges these products are port extension devices that are designed, manufactured, and sold by the Defendants for use in the United States (Compl. ¶¶14-15). The complaint does not contain any images or technical descriptions of the accused products' specific features or operation. No probative visual evidence provided in complaint.

Commercial Importance

The complaint alleges that Defendants "designed, developed, manufacture, sell, [and] offer to sell" these products, but does not provide specific details on their market share or commercial success (Compl. ¶¶14-15).

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart exhibit or map specific product features to claim limitations for any asserted patent. The infringement allegations are made in a conclusory fashion.

  • ’429 Patent Infringement Allegations: The complaint alleges that the accused LYNKHUB products infringe the ’429 Patent but does not provide a detailed infringement theory (Compl. ¶14). An infringement theory for claim 1 would necessarily argue that the accused hubs possess each of the claimed modules (main port, data transmission control, etc.) and perform each of the claimed functions for routing data and video signals.
  • ’616 Patent Infringement Allegations: The complaint alleges that certain LYNKHUB models infringe the design claimed in the ’616 Patent (Compl. ¶14). The legal test for design patent infringement is whether an "ordinary observer," familiar with the prior art, would be deceived into purchasing the accused product believing it to be the patented design. The analysis will hinge on a visual comparison of the accused products' overall appearance with the design shown in the ’616 Patent's figures.
  • Identified Points of Contention:
    • Case-Dispositive Issue: A primary issue for the ’429 Patent claim is its viability, as all asserted independent and dependent claims were cancelled in an IPR proceeding after the complaint was filed. This development presents a substantial, and likely insurmountable, barrier to the infringement claim on this patent.
    • Design Patent Scope: For the four design patents, the dispute will center on the visual similarity between the accused LYNKHUB products and the specific ornamental features shown in the patent figures. The question will be whether the overall appearance of the accused products is "substantially the same" as the patented designs, which could be contested based on differences in shape, port layout, surface ornamentation, and proportions.

V. Key Claim Terms for Construction

Analysis is based on the now-cancelled Claim 1 of the ’429 Patent, as this would have been a focus of litigation at the time of filing.

  • The Term: "data transmission control module"

    • Context and Importance: This term represents the functional core of the claimed apparatus. The scope of this term is critical, as infringement requires the accused device to contain a corresponding component that performs all the functions attributed to this module in the claim.
    • Intrinsic Evidence for a Broader Interpretation: The abstract describes the module in purely functional terms as controlling data transmission, which may support an interpretation covering any controller that achieves the specified result (’429 Patent, Abstract).
    • Intrinsic Evidence for a Narrower Interpretation: Figure 2 and the accompanying text describe a specific embodiment where the "data transmission control module 30" is a complex system comprising five distinct sub-units: a USB control unit, a USB conversion unit, a memory card conversion unit, a mode control unit, and a mode conversion unit (’429 Patent, col. 4:16-20; Fig. 2). A party could argue the term should be limited to a structure containing these specific, enumerated components.

  • The Term: "main port module having first and second port units"

    • Context and Importance: This limitation defines the interface with the host computer. Whether an accused hub meets the specific "first and second port units" structure is a potential point of dispute.
    • Intrinsic Evidence for a Broader Interpretation: The claim preamble broadly describes the module as "for connecting to an end-user device," which might suggest the "port units" language describes functional aspects rather than distinct physical structures (’429 Patent, col. 5:47-49).
    • Intrinsic Evidence for a Narrower Interpretation: The detailed description of Figure 2 depicts "first port unit 11" and "second port unit 12" as distinct structural elements of the "main port module 10" (’429 Patent, col. 4:5-10). This could support an argument that the claim requires two physically separate connectors or pathways to the host device, which a single integrated USB-C connector may not satisfy.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants "have aided and abetted one another in doing so" and that Defendant Anderson "directed the infringement personally" (Compl. ¶18). The complaint does not allege specific facts, such as the content of user manuals or advertisements, that would show active steps taken to encourage or instruct others to infringe.
  • Willful Infringement: The complaint alleges willfulness on the basis that Plaintiff sent "written notice to Defendants regarding Defendants' infringement and demanded that Defendants immediately cease and desist," which Defendants allegedly refused (Compl. ¶¶16, 20). This allegation provides a factual basis for pre-suit knowledge of the asserted patents.

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

  • A dispositive threshold question is one of claim viability: given the post-filing cancellation of all relevant claims of the ’429 utility patent in an IPR, can the infringement count related to that patent proceed? This development suggests the case will likely be narrowed to the four asserted design patents.
  • The central issue for the remaining design patents will be one of visual comparison: are the ornamental designs of the accused IntelliArmor LYNKHUB products "substantially the same" as the designs claimed in the ’616, ’875, ’618, and ’290 patents in the eye of an ordinary observer? The outcome will depend on a feature-by-feature and holistic comparison between the accused products and the patent figures.
  • A key procedural question may be the sufficiency of the pleadings: does the complaint's recitation of only generalized and conclusory allegations of infringement, without mapping any accused product features to claim elements, meet the plausibility standard required to survive a motion to dismiss?