DCT
8:20-cv-00782
Targus Intl LLC v. Swissdigital USA Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Targus Intl LLC (Delaware)
- Defendant: Swissdigital USA Co., Ltd. (Delaware)
- Plaintiff’s Counsel: Armond Wilson LLP
- Case Identification: 8:20-cv-00782, C.D. Cal., 04/22/2020
- Venue Allegations: Plaintiff alleges venue is proper because Defendant resides in the Central District of California, maintains a regular and established place of business in the district, and has committed alleged acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "checkpoint-friendly" backpacks infringe a patent related to the design of portable computer cases that allow for convenient security screening without removing the computer.
- Technical Context: The technology addresses the airport security requirement to scan laptops separately by creating bi-fold bags that isolate the laptop for X-ray scanning when unfolded, avoiding the need for full removal.
- Key Procedural History: The complaint states that on April 9, 2020, Plaintiff sent a letter to Defendant identifying the patent-in-suit and specific accused products, putting Defendant on notice of the alleged infringement prior to the lawsuit's filing.
Case Timeline
| Date | Event |
|---|---|
| 2008-03-13 | U.S. Patent No. 8,567,578 Priority Date |
| 2013-10-29 | U.S. Patent No. 8,567,578 Issue Date |
| 2020-04-09 | Plaintiff sends notice letter to Defendant |
| 2020-04-22 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,567,578 - "Portable Computer Case"
- Issued: October 29, 2013
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience and risk of damage associated with the Transportation Security Administration (TSA) policy that requires travelers to remove portable computers from their cases for X-ray screening at security checkpoints (’578 Patent, col. 1:16-28).
- The Patented Solution: The invention is a bi-fold or multi-section computer case designed to be laid open and flat on a scanner belt. One section is specifically designed to hold only the computer and is constructed of materials that do not obstruct X-ray scanning. Other sections, which hold accessories that could interfere with the scan, are physically separated from the computer section when the case is unfolded. This configuration allows the computer to be scanned while remaining inside its dedicated, protected pouch (’578 Patent, col. 2:33-52, Fig. 1C).
- Technical Importance: This design sought to create a "checkpoint-friendly" standard for luggage, streamlining the airport security process for travelers carrying laptops by eliminating a time-consuming step (’578 Patent, col. 1:28-32).
Key Claims at a Glance
- The complaint asserts claims 1-4, 17, 18, 42, 44, 47, and 50-56, with a detailed infringement analysis provided for independent claim 1 (Compl. ¶¶ 11, 19).
- Independent Claim 1 requires, in essence:
- A bi-fold case with a first and second storage section joined by a hinge.
- The first storage section has a first pouch and may also have a separate third pouch for other items.
- The second storage section has a second pouch, configured without an additional pouch, to receive a computer.
- Both sections are configured to be scanned by a scanning device.
- When unfolded and laid flat, an object in the first storage section is "removed from interfering" with a scanner, enabling "uninhibited scanning" of the computer in the second pouch.
III. The Accused Instrumentality
Product Identification
- The complaint names a line of "checkpoint friendly" or "TSA-Friendly" bags, including the Circuit Business Travel Backpack (Item No. J14-BR), Terabyte Business Travel Backpack (Item No. J16BT-1), and others (Compl. ¶¶ 10-11). The Circuit Business Travel Backpack is used as a representative example (Compl. ¶11).
Functionality and Market Context
- The accused products are backpacks designed with a bi-fold structure that allows the bag to be unzipped and laid flat. This creates two separate halves connected by a hinge, with one half containing a dedicated, padded sleeve for a laptop and the other half containing pockets for accessories (Compl. ¶¶ 11[a]-[f]).
- This design is marketed to allow users to pass through airport security without removing their laptops from the bags (Compl. ¶11).
- The complaint alleges that Plaintiff and Defendant are direct competitors in this market (Compl. ¶¶ 7, 17).
- The complaint provides an annotated image showing the accused backpack in a folded configuration, ready for carrying. (Compl. p. 5, "FOLDED CONFIGURATION").
IV. Analysis of Infringement Allegations
'578 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first storage section comprising a first outer side, a first inner side ... defining a first pouch with a first pouch opening ... wherein the first storage section further comprises a third pouch including a third pouch opening, independent of the first pouch opening... | The accused backpack has a first storage section with multiple pouches for accessories, which are separate from the main computer pouch. The complaint includes an annotated image of the accused product identifying the "First Storage Section" and its various pouches. | ¶11[a] | col. 9:15-25 |
| a second storage section comprising a second outer side, a second inner side ... the second storage section comprising, a second pouch and the second storage section configured without an additional pouch, the second pouch configured to receive a computer... | The accused backpack's second storage section is alleged to contain only a single pouch designed to hold a computer. An annotated image in the complaint points to this section, stating "Computer Fits Here" and noting the absence of other pouches. | ¶11[b-2] | col. 9:31-40 |
| the second storage section foldably joined at the second proximal end to the first proximal end of the first storage section such that the second proximal end and the first proximal end are coupled adjacent one another to form a hinge... | The two storage sections of the accused backpack are joined by a fabric hinge that allows them to be folded together or laid flat. The complaint provides a visual pointing to the "Hinge" that joins the two sections. | ¶11[c] | col. 9:41-47 |
| wherein in the unfolded configuration with the outer sides of both the first and second storage sections laid flat upon a same planar surface, an object in the first storage section is removed from interfering with a scanner ... to enable uninhibited scanning of a computer... | When the accused backpack is unfolded and laid flat, the accessory-filled first section is physically separated from the computer-holding second section, allegedly preventing interference and allowing for uninhibited scanning of the computer. | ¶11[f] | col. 10:4-14 |
Identified Points of Contention
- Scope Questions: The complaint alleges the second inner side of the accused product has a surface area "approximately equal" to the first inner side, as required by the claim (Compl. ¶11[b-1]). The interpretation of "approximately equal" may become a point of factual dispute.
- Technical Questions: A key question is whether the accused backpack's design, even when unfolded, achieves the functional requirement of "uninhibited scanning" (’578 Patent, col. 10:12). The court may need to consider whether the materials of the hinge or other parts of the bag's structure still "interfere" with a scanner in a way that is inconsistent with the patent's claims. The complaint provides a diagram illustrating this alleged "Uninhibited Scanning in Unfolded Configuration" (Compl. p. 8).
V. Key Claim Terms for Construction
The Term: "uninhibited scanning"
- Context and Importance: This term appears in the final functional limitation of claim 1 and defines the required outcome of the invention's structural arrangement. The entire purpose of the patented design is to achieve this result. Practitioners may focus on this term because its definition will determine whether merely separating the laptop from accessories is sufficient, or if a more stringent standard of non-interference is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent’s background discusses removing "obstructions and/or interference" in general terms, which could support an interpretation where "uninhibited" means free from the specific interference caused by accessories, rather than free from all possible minor obstructions from the bag itself (’578 Patent, col. 1:20-22).
- Evidence for a Narrower Interpretation: The specification states that in the unfolded configuration, an object in the first section is "removed from interfering with a scanner," which could imply a complete removal from the scanning field (’578 Patent, col. 10:9-12). Figure 1C, showing two completely distinct sections when flat, may support a narrower reading that requires a high degree of physical and radiological separation.
The Term: "configured without an additional pouch"
- Context and Importance: This is a negative limitation defining the structure of the computer-holding section. Infringement requires that the second storage section lacks any pouches other than the one for the computer. This term is critical because if the accused product’s computer section contains any feature that could be construed as an "additional pouch" (e.g., a small mesh pocket for a cable), it may not infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not appear to explicitly define "pouch." A party might argue for a common-sense definition of a significant, closable storage compartment, which might exclude very minor pockets or sleeves.
- Evidence for a Narrower Interpretation: The claim language is absolute ("without an additional pouch"). An opposing party could argue this means the section must be entirely unitary and dedicated to the computer, with no other storage capability whatsoever, as depicted for the computer receiving area 104 in Figure 1C (’578 Patent, Fig. 1C).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant had actual knowledge of the patent and intentionally encouraged its distributors to sell the accused products in the U.S. (Compl. ¶20).
- Willful Infringement: The complaint alleges willfulness based on both pre-suit and post-filing conduct. It alleges Defendant knew or should have known of the patent due to former Targus employees now working for Defendant (Compl. ¶15). More concretely, it alleges Defendant had actual knowledge of the patent and its alleged infringement "at least by April 9, 2020," the date of a notice letter, and continued to sell the products thereafter (Compl. ¶¶ 16-17).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of functional performance: Does the accused backpack's unfolded configuration, which physically separates the laptop compartment from the accessory compartment, achieve the "uninhibited scanning" required by claim 1? The case may turn on evidence of whether the bag’s remaining structure, such as the hinge or padding, constitutes "interference" that would inhibit a security scan.
- A second key issue will be one of structural compliance with negative limitations: Does the accused product's computer-holding section meet the strict requirement of being "configured without an additional pouch"? The resolution of this question will depend on the court's construction of the term "pouch" and a factual analysis of the accused product's design.