Amphenol Corp v. Luxs

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Amphenol Corporation (Delaware)
  • Defendant: Luxshare-ICT and Luxshare Precision Industry Co. Ltd. (California / China)
  • Plaintiff’s Counsel: Procopio, Cory, Hargreaves & Savitch LLP; Wolf, Greenfield & Sacks, P.C.
• Case Identification: 3:20-cv-06785, N.D. Cal., 09/29/2020
• Venue Allegations: Venue is alleged to be proper in the Northern District of California because Defendant Luxshare-ICT is a California corporation with its principal place of business in the district, and both defendants are alleged to have committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s high-speed input/output (HSIO) connectors infringe patents related to electrical connector structures designed to improve signal integrity at high frequencies.
• Technical Context: The technology at issue involves high-density electrical connectors, such as those conforming to QSFP standards, which are critical components for data centers, servers, and modern telecommunications infrastructure.
• Key Procedural History: The complaint alleges that Defendant Luxshare had pre-suit knowledge of the patent application that issued as the ’767 Patent, as the application was listed in a prior license agreement between the parties executed in 2016 concerning unrelated products.

Case Timeline

Date	Event
2004-09-30	U.S. Patent No. 7,371,117 Priority Date
2008-05-13	U.S. Patent No. 7,371,117 Issues
2010-05-07	U.S. Patent No. 10,381,767 Priority Date
2016-05-18	Luxshare executes license agreement allegedly listing ’767 Patent application
2019-08-13	U.S. Patent No. 10,381,767 Issues
2020-01-28	Luxshare allegedly markets Accused Products at DesignCon trade show
2020-09-29	Complaint Filed

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

U.S. Patent No. 7,371,117 - "High Speed, High Density Electrical Connector," Issued May 13, 2008

The Invention Explained

• Problem Addressed: At high signal frequencies (above 1 GHz), electrical resonances can develop within the shielding or ground structures of a connector, leading to performance degradation from noise and cross-talk between signal paths (’117 Patent, col. 1:12-25).
• The Patented Solution: The invention introduces an "electrically lossy material" that physically and electrically bridges discrete ground or shield members within the connector. This material dampens the unwanted resonances in the ground system without directly contacting the signal conductors, thereby improving signal integrity (’117 Patent, col. 2:35-43, Abstract).
• Technical Importance: This approach provided a method for managing high-frequency noise in dense connectors that went beyond simply adding more metallic shielding, which could create its own resonance problems.

Key Claims at a Glance

• The complaint asserts independent claim 9 (Compl. ¶34).
• Claim 9 recites an electrical connector comprising regions, each having:
  • insulative material;
  • a plurality of signal conductors secured in the insulative material;
  • a plurality of conductive elements (e.g., grounds/shields) not in contact with the signal conductors; and
  • an electrically lossy material that extends between and is in contact with the conductive elements, but is not electrically connected with the signal conductors.

U.S. Patent No. 10,381,767 - "High Performance Cable Connector," Issued August 13, 2019

The Invention Explained

• Problem Addressed: The patent describes challenges in interconnecting cables to circuit assemblies, particularly for high-speed, high-density standards like SFP and QSFP, where managing signal integrity and preventing incorrect mating is crucial (’767 Patent, col. 1:41-54, col. 18:36-44).
• The Patented Solution: The invention discloses a receptacle connector constructed from distinct sub-assemblies, referred to as lead assemblies. Each lead assembly includes a "monolithic housing member" holding conductive elements. The lead assemblies are arranged to create a receptacle with staggered ports, which can reduce crosstalk and, in some embodiments, form an L-shaped profile to ensure proper plug orientation (’767 Patent, Abstract, col. 14:30-67).
• Technical Importance: This modular design using monolithic lead assemblies offers a method for manufacturing complex, high-performance, high-density connectors with improved electrical characteristics.

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶41).
• Claim 1 recites a receptacle for mounting to a printed circuit board, comprising:
  • a housing with a cavity;
  • a first lead assembly, which includes a "first monolithic housing member" holding a first plurality of conductive elements and comprising "exterior projections"; and
  • a second lead assembly, which includes a "second monolithic housing member" holding a second plurality of conductive elements and also comprising "exterior projections."

III. The Accused Instrumentality

Product Identification

• The Accused Products are Luxshare's HSIO connectors, including its QSFP and QSFP-DD connectors, such as the "Super QSFP" and "Ultra QSFP" product lines (Compl. ¶9).

Functionality and Market Context

• The Accused Products are high-speed input/output connectors used in data centers and supercomputing systems to connect switches, servers, and other hardware (Compl. ¶¶9-10). A product brochure included in the complaint describes the Accused Products as supporting data speeds of 100G and 200G (Compl. p. 6, Ex. 5). The complaint alleges these products are available in various configurations, such as single-port (1x1), multi-port (1xN), and stacked-port (2x1, 2xN) arrangements (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed, element-by-element infringement analysis or claim chart. It makes general allegations that the Accused Products satisfy every limitation of the asserted claims (Compl. ¶¶35, 43).

’117 Patent Infringement Allegations

Narrative Theory

• The complaint’s infringement theory for the ’117 Patent is that the accused Luxshare connectors incorporate a design with signal conductors, separate conductive ground elements, and an electrically lossy material that bridges the ground elements to manage signal integrity, thereby meeting the limitations of at least claim 9 (Compl. ¶34). The complaint includes a side-by-side comparison of Luxshare's and Amphenol's connector footprint drawings, which it alleges shows Luxshare's copying of Amphenol's designs "with a precision of a fraction of a millimeter" (Compl. p. 5).

Identified Points of Contention

• Technical Question: A central factual question will be whether the accused Luxshare connectors contain a material that meets the definition of "electrically lossy material" as recited in the claim. Discovery will likely focus on the material composition, placement, and electrical properties of components within the accused connectors.
• Scope Question: Does the specific structure of the accused connectors, particularly the arrangement and interaction of its signal conductors, ground elements, and any lossy components, fall within the scope of claim 9?

’767 Patent Infringement Allegations

Narrative Theory

• The infringement theory for the ’767 Patent is that the accused Luxshare connector receptacles are constructed using a first lead assembly and a separate second lead assembly, where each assembly includes a "monolithic housing member" holding conductive elements, consistent with the structure required by at least claim 1 (Compl. ¶41).

Identified Points of Contention

• Technical Question: What is the actual physical construction of the accused Luxshare receptacles? Specifically, are they built from two distinct lead assemblies, and can the housing portion of each assembly be characterized as "monolithic"?
• Scope Question: Does the term "monolithic housing member," as defined by the patent, read on the specific manufacturing process and resulting structure of the housing components in the accused connectors? The meaning of "exterior projections" will also require construction and factual analysis.

V. Key Claim Terms for Construction

Term 1 (’117 Patent): "electrically lossy material"

Context and Importance

• This term is the central inventive concept of the ’117 Patent. The outcome of the infringement analysis for this patent will depend heavily on whether the material used in Luxshare's connectors is found to fall within the scope of this term.

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The specification provides a broad definition, stating that the material can be either "lossy dielectric and/or lossy conductive" (’117 Patent, col. 5:20-23). It also provides wide ranges for electrical properties, such as a surface resistivity between 1 Ω/square and 10⁶ Ω/square (’117 Patent, col. 5:48-51).
• Evidence for a Narrower Interpretation: A party might argue that the term should be limited by the specific examples disclosed, such as thermoplastics filled with conductive particles like carbon or graphite, or materials with properties in the "preferred" or "specific example" ranges provided in the specification (’117 Patent, col. 5:60-67; col. 6:1-3).

Term 2 (’767 Patent): "monolithic housing member"

Context and Importance

• This structural term is a key limitation in claim 1 of the ’767 Patent. Infringement will depend on whether the housing components of the accused connectors' lead assemblies are "monolithic."

Intrinsic Evidence for Interpretation

• Evidence for a Broader Interpretation: The ordinary meaning of "monolithic" suggests a single, solid, undifferentiated piece. The specification describes a process where an "insulative housing is molded over the lead frame," which could support an interpretation that the resulting single piece of molded material is monolithic (’767 Patent, col. 15:55-58).
• Evidence for a Narrower Interpretation: A party could argue the term is limited by the specific illustrated embodiments, such as the geometry of housing member 612A in Figure 6 (’767 Patent, Fig. 6). The context of being "molded over" a lead frame might also be argued as a limiting process step.

VI. Other Allegations

Indirect Infringement

• The complaint alleges both induced and contributory infringement for both patents. It asserts that Luxshare sells the Accused Products to third parties with knowledge and intent that they will be imported into and used in the U.S. in an infringing manner (Compl. ¶¶36, 37, 44, 45). The complaint also points to connector footprint drawings available on Luxshare's website as "instructions to customers on how to attach Luxshare’s connectors to a printed circuit board" (Compl. ¶8).

Willful Infringement

• ’117 Patent: Willfulness is alleged based on, at a minimum, post-suit knowledge from the filing of the complaint (Compl. ¶39).
• ’767 Patent: Willfulness is alleged based on pre-suit knowledge. The complaint asserts that Luxshare knew of the patent application underlying the ’767 Patent as early as May 18, 2016, because it was listed in an attachment to a license agreement Luxshare executed with Amphenol for other products (Compl. ¶28, ¶48).

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

• A core issue will be one of evidentiary proof: What is the actual material composition and physical construction of the accused Luxshare connectors? The case will likely depend on detailed technical evidence from discovery and expert testimony to determine if those products contain an "electrically lossy material" (’117 Patent) and are built with "monolithic housing members" (’767 Patent) as claimed.
• A second central question is one of pre-suit knowledge and willfulness: Will the 2016 license agreement, which allegedly identified the application for the ’767 Patent, be sufficient to establish that Luxshare knew of the patented technology before the lawsuit, thereby exposing it to a finding of willful infringement and potential enhanced damages?
• Finally, the dispute raises a question of definitional scope: How broadly will the court construe the key claim terms? The resolution will likely turn on whether the court adopts a broader, more functional definition of terms like "electrically lossy material" or a narrower one tied more closely to the specific embodiments and numerical ranges disclosed in the patents.