DCT
8:25-cv-00974
BelAir Electronics Inc v. SP United
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: SP United USA, Inc. (fka SP United USA, LLC) (California)
- Plaintiff’s Counsel: Law Offices of Marc Libarle; Haller Law PLLC
- Case Identification: 8:25-cv-00974, C.D. Cal., 05/08/2025
- Venue Allegations: Venue is alleged to be proper as Defendant is a California corporation that resides in the Central District of California.
- Core Dispute: Plaintiff alleges that Defendant’s line of protective mobile phone cases infringes two patents related to protective masks for mobile devices.
- Technical Context: The technology concerns external protective cases for mobile phones, designed to prevent physical damage from abrasion and to allow for stylistic customization.
- Key Procedural History: The complaint asserts that both patents-in-suit expired prior to the filing of the lawsuit. It alleges that Defendant was notified of the potential infringement via email to its CEO beginning in July 2024, approximately two years after the alleged expiration of the last-to-expire patent. The lawsuit seeks only past damages for a period beginning May 8, 2019.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Priority Date for ’195 and ’676 Patents |
| 2011-05-10 | ’195 Patent Issue Date |
| 2018-10-09 | ’676 Patent Issue Date |
| 2019-05-08 | Alleged Damages Period Begins |
| 2021-10-23 | ’676 Patent Alleged Expiration Date |
| 2022-11-16 | ’195 Patent Alleged Expiration Date |
| 2024-07-24 | Plaintiff First Notified Defendant of Alleged Infringement |
| 2025-05-08 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,941,195 - "Protective Mask of Mobile Phone," issued May 10, 2011
The Invention Explained
- Problem Addressed: The patent identifies that mobile phones of the era were "very smooth and delicate," making them susceptible to "ill-favored scars" from abrasion, which diminished their quality and value. It also notes the consumer desire to follow changing fashion trends, which could require costly phone replacements ('195 Patent, col. 1:31-43).
- The Patented Solution: The invention proposes a two-part protective "mask" consisting of an "upper cover body" and a "lower cover body" that sheathe the front and rear of a mobile phone, respectively ('195 Patent, col. 2:29-32). This mask is designed to be easily attached and removed. The upper cover body uses a "plurality of flanges" that are "retained at the edge of the front phone housing" to secure the mask to the device ('195 Patent, col. 2:38-41, Fig. 3).
- Technical Importance: This approach provided a low-cost method for both protecting a device and altering its appearance to match trends, without needing to replace the entire phone ('195 Patent, col. 1:52-58).
Key Claims at a Glance
- The complaint asserts independent Claim 9 (Compl. ¶21).
- Essential elements of Claim 9:
- A protective mask adapted to be coupled to an exterior housing of a mobile phone.
- A first mask portion, molded to conform to the shape of a first portion of the exterior housing.
- The first mask portion having "flanges" to allow the first mask portion to be coupled to the mobile phone to retain it.
U.S. Patent No. 10,097,676 - "Protective Mask of Mobile Phone," issued October 9, 2018
The Invention Explained
- Problem Addressed: As a continuation, the ’676 Patent addresses the same problems of device abrasion and the cost of keeping up with mobile phone fashion trends (’676 Patent, col. 1:33-45).
- The Patented Solution: This patent describes a single, "integrally-formed mask body" that protects the phone (’676 Patent, col. 4:32-33). Retention is achieved through a combination of two mechanisms: the body is "molded and contoured to conform and frictionally-fit tightly" against the phone, and it includes "at least one retainer having an extension protruding laterally inward" that engages with an edge of the phone's housing (’676 Patent, col. 4:36-41, 52-62).
- Technical Importance: The invention refines the protective cover concept into a single-piece design that uses both friction and a mechanical retainer for a secure fit (’676 Patent, Abstract).
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9 (Compl. ¶28). The complaint also reserves the right to assert dependent claims 2-4, 6-7, and 10-12 (Compl. ¶¶31, 34, 39).
- Essential elements of Claim 1:
- A protective mask molded for frictional retention.
- An "integrally-formed mask body" that "frictionally-fit tightly" against the phone's exterior.
- An "inner surface" in "substantially continuous surface-to-surface contact" with the phone's exterior, with "no substantial space between" them.
- At least one "opening" for user access to interfaces.
- "at least one retainer" with an "extension protruding laterally inward" that participates in retaining the mask.
III. The Accused Instrumentality
Product Identification
The accused products are Defendant's protective mobile device cases, including the "SPC Phone Case," "SPC+ Phone Case," and "Ducati Edition Phone Case" product lines, sold for a wide variety of Apple, Samsung, Google, and Huawei phones (Compl. ¶¶14-15; Ex. C).
Functionality and Market Context
The complaint describes the accused products as "protective masks" that are coupled to a mobile device to prevent it from falling out (Compl. ¶17). Their function is to provide "non-permanent, temporary protection" using a "flange or retainer" mechanism (Compl. ¶17). The complaint includes several photographs of the accused products, including close-ups of their interior, to illustrate the allegedly infringing features (Compl. pp. 6-8). One such visual shows the interior of a case for a Samsung S22, with red circles highlighting the raised lip around the perimeter and corners, which the plaintiff alleges constitute the claimed "flanges" or "retainers" (Compl. p. 7).
IV. Analysis of Infringement Allegations
’195 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone; | The Accused Products are molded cases that conform to the shape of the exterior of a mobile phone. | ¶23a | col. 4:36-38 |
| and the first mask portion having flanges to allow the first mask portion to be coupled to the mobile phone to retain the first mask portion to the first portion of the exterior housing... | The Accused Products have flanges that couple to the mobile phone to retain the case on the phone. The complaint presents images with highlighted areas as evidence of these flanges. | ¶23b | col. 2:38-41 |
Identified Points of Contention
- Scope Questions: A central question will be whether the term "flanges," depicted in the patent as multiple discrete tabs ('195 Patent, Fig. 3), can be construed to read on the continuous, unitary retaining lip that appears to be present on the accused single-piece phone cases.
- Technical Questions: Does the continuous inner lip of the accused products function as a "plurality of flanges" for retention, or does it provide retention through a different mechanism, such as a continuous friction or interference fit? The complaint's visual evidence highlights these continuous lips (Compl. pp. 7-8).
’676 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an integrally-formed mask body molded and contoured to conform and frictionally-fit tightly against the exterior shape of the exterior housing; | The Accused Products are integrally-formed (single-piece) cases molded to conform and fit tightly by friction to the phone. | ¶30a | col. 4:36-39 |
| an inner surface ... in substantially continuous surface-to-surface contact with the exterior shape of the exterior housing, with no substantial space between the inner surface ... and the exterior shape ...; | The inner surface of the case is alleged to conform to the phone's exterior in continuous contact, with no substantial space between them. | ¶30b | col. 4:45-51 |
| at least one opening defined by the integrally-formed mask body permitting user access to at least the user input and output interfaces; | The cases have openings for access to ports, buttons, and other interfaces. | ¶30c | col. 4:52-55 |
| and at least one retainer having an extension protruding laterally inward ... the at least one retainer participating in retaining the integrally-formed mask body to the mobile communication device. | The Accused Products allegedly have at least one retainer with an extension protruding inward to help hold the case on the device. | ¶30d | col. 4:56-62 |
Identified Points of Contention
- Scope Questions: Claim 1 requires both that the mask "frictionally-fit tightly" and that it has "at least one retainer" that participates in retention. A key dispute may be whether the single, continuous lip on the accused product can be considered a separate "retainer" element, or if it is an integral part of the structure that provides the "frictional fit."
- Technical Questions: What evidence demonstrates that the accused cases maintain "substantially continuous surface-to-surface contact" with "no substantial space"? Defense could argue that internal textures, linings, or air gaps negate this limitation. A photograph of the inside of an iPhone 13 case shows such a lining (Compl. p. 8).
V. Key Claim Terms for Construction
The Term: "flanges" (’195 Patent, Claim 9)
Context and Importance
The infringement case for the ’195 Patent depends on this term. The patent's figures depict discrete tabs on a two-piece case for a flip phone, while the accused product is a modern, single-piece case with what appears to be a continuous retaining lip. Practitioners may focus on whether "flanges" requires a plurality of separate structures.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The term is not explicitly defined, which may support an argument for its plain and ordinary meaning, potentially encompassing any flange-like structure that retains the mask.
- Evidence for a Narrower Interpretation: The specification explicitly states, "A rear side face of the upper cover body 20 has a plurality of flanges 21" (’195 Patent, col. 2:38-39, emphasis added). The consistent depiction of multiple, discrete tabs in Figure 3 could be used to argue that the term requires more than one structure and excludes a single, continuous rim.
The Term: "retainer" (’676 Patent, Claims 1, 5, 8, 9)
Context and Importance
The asserted claims of the ’676 Patent require the mask to both "frictionally-fit" and have a "retainer." The viability of the infringement claim may turn on whether the accused product's retaining lip is a distinct "retainer" or simply part of the structure that creates the frictional fit.
Intrinsic Evidence for Interpretation
- Evidence for a Broader Interpretation: The claim language describes the retainer functionally as "participating in retaining the...mask body" (’676 Patent, col. 4:60-62). Plaintiff may argue any structural feature that achieves this, like a lip over the screen edge, qualifies.
- Evidence for a Narrower Interpretation: Defendant may argue that by claiming both a frictional fit and a retainer, the patent requires two distinct retention mechanisms. If the retaining lip is what creates the frictional fit, it may not be a separate "retainer." The patent describes the retainer as having an "extension protruding laterally inward," a general description that will require careful analysis in the context of the entire claim.
VI. Other Allegations
Indirect Infringement
The complaint does not plead a separate count for indirect or induced infringement. The allegations focus on direct infringement by Defendant's acts of making, using, selling, and importing the Accused Products (Compl. ¶¶22, 29).
Willful Infringement
The complaint does not use the term "willful," but it alleges facts that could support such a claim. It states that Defendant had notice of both the ’195 and ’676 patents and their "likelihood of infringement" as early as July 24, 2024, via emails to its CEO, and that Defendant did not respond to multiple follow-up communications before the suit was filed (Compl. ¶¶25, 41).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the terms "flanges" and "retainer," which originate in patents describing two-piece covers for older flip-phone models, be construed to cover the features of modern, single-piece, snap-on smartphone cases? The significant evolution in phone design since the patents' priority date will make the interpretation of these terms central to the dispute.
- A second key question will be one of claim differentiation and function: for the ’676 Patent, does the accused product’s design feature two distinct retention mechanisms—a "frictional fit" and a "retainer"—as required by the claims? Or does the product's continuous retaining lip provide a single, integrated retention function that may not satisfy both limitations simultaneously?
- Finally, a threshold issue concerns damages and patent term: the complaint alleges that both patents expired before the lawsuit was filed and even before pre-suit notice was given. The case will likely focus on establishing the correct expiration dates and whether infringement can be proven during the asserted damages period, which is entirely in the past.