DCT

3:20-cv-06785

Amphenol Corp v. Luxs

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Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:20-cv-06785, N.D. Cal., 12/17/2020
  • Venue Allegations: Plaintiff alleges venue is 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 because both defendants have allegedly committed acts of infringement and maintain a regular and established place of business there. Venue over Luxshare Precision, a Chinese corporation, is asserted based on its amenability to personal jurisdiction in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s high-speed input/output (HSIO) electrical connectors infringe five patents related to technologies for improving signal integrity and performance in high-density connectors.
  • Technical Context: The technology concerns high-speed, high-density interconnect devices, which are fundamental components for data centers, servers, switches, and other telecommunications hardware that underpin modern data infrastructure.
  • Key Procedural History: The complaint alleges that Defendant Luxshare had pre-suit knowledge of the application that matured into the ’767 Patent via a prior license agreement executed between the parties on May 18, 2016, a fact that may be central to allegations of willful infringement.

Case Timeline

Date Event
2004-09-30 Earliest Priority Date for ’117 and ’875 Patents
2006-06-29 Earliest Priority Date for ’521 and ’255 Patents
2008-05-13 ’117 Patent Issued
2010-05-07 Earliest Priority Date for ’767 Patent
2013-02-12 ’875 Patent Issued
2014-10-21 ’521 Patent Issued
2016-05-18 Luxshare allegedly gains knowledge of application for ’767 Patent
2017-07-11 ’255 Patent Issued
2019-08-13 ’767 Patent Issued
2020-01-28 Luxshare allegedly marketed Accused Products at DesignCon trade show
2020-12-17 Complaint Filed

Technology and Patent(s)-in-Suit Analysis

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

The Invention Explained

  • Problem Addressed: The patent addresses the problem of electrical resonances that can occur in the shielding systems of high-speed electrical connectors, particularly at frequencies of 1 GHz or greater. These resonances can create signal interference (crosstalk) and degrade the connector’s performance (U.S. Patent 7371117, col. 1:12-19).
  • The Patented Solution: The invention proposes incorporating an "electrically lossy material" to bridge the discrete conductive elements (e.g., ground members or shields) within the connector. This material dampens the unwanted resonances in the ground system without making electrical contact with the signal conductors, thereby improving signal integrity (U.S. Patent 7371117, Abstract; col. 2:36-42).
  • Technical Importance: This approach provided a method to manage signal integrity issues that become more pronounced as data transfer speeds and connector densities increase in advanced electronics (U.S. Patent 7371117, col. 1:20-25).

Key Claims at a Glance

  • The complaint asserts independent claim 9 (Compl. ¶43).
  • Essential elements of Claim 9 include:
    • An electrical connector comprising a plurality of regions, each having:
    • insulative material;
    • a plurality of signal conductors secured in the insulative material;
    • a plurality of conductive elements not in contact with the signal conductors; and
    • electrically lossy material extending between and in contact with the intermediate portion of the conductive elements, where the signal conductors are not electrically connected with the lossy material.
  • The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶42).

U.S. Patent No. 8,371,875 - "High Speed, High Density Electrical Connector"

The Invention Explained

  • Problem Addressed: Like the ’117 Patent, this patent targets the degradation of connector performance at high frequencies due to electrical resonances in the shielding system (U.S. Patent 8371875, col. 1:16-24).
  • The Patented Solution: The invention describes a connector constructed with a multi-layer approach. A first insulative layer contains both the signal conductors and adjacent shield strips. A second, distinct layer made of an "electrically lossy material" is placed adjacent to the first layer to create an "electrical bridging" connection between the shield strips, thereby damping resonances (U.S. Patent 8371875, Abstract; col. 2:40-52).
  • Technical Importance: This layered design offers a specific manufacturing method for integrating resonance-damping materials into high-performance connectors to support increasing data rates (U.S. Patent 8371875, col. 1:20-24).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶51).
  • Essential elements of Claim 1 include:
    • An electrical connector comprising:
    • a first layer formed from an insulative material;
    • a plurality of signal conductors having an intermediate portion disposed in the first layer;
    • a plurality of shield strips having an intermediate portion disposed in the first layer adjacent to the signal conductors; and
    • a second layer, adjacent to the first, formed from an electrically lossy material that provides electrical bridging between the shield strips.
    • The signal conductors are electrically isolated from the shield strips.
  • The complaint alleges infringement of "one or more claims," reserving the right to assert others (Compl. ¶50).

U.S. Patent No. 8,864,521 - "High Frequency Electrical Connector"

  • Technology Synopsis: The patent describes an electrical connector architecture using multiple subassemblies of conductive elements. To control electromagnetic radiation and improve signal integrity, separately manufactured "inserts" are positioned between these adjacent subassemblies, with the inserts comprising a material that attenuates radiation (U.S. Patent 8864521, Abstract; col. 28:33-43).
  • Asserted Claims: Claim 33 (Compl. ¶59).
  • Accused Features: The complaint accuses Luxshare's HSIO connectors generally of infringing the ’521 Patent (Compl. ¶58).

U.S. Patent No. 9,705,255 - "High Frequency Electrical Connector"

  • Technology Synopsis: This invention discloses a connector component with an insulative housing and a separately manufactured "lossy insert." The insert is specifically positioned adjacent to a "transition region" between the intermediate portion and the mating contact portion of a conductive element, a location chosen to manage signal integrity (U.S. Patent 9705255, Abstract; col. 23:45-56).
  • Asserted Claims: Claim 1 (Compl. ¶67).
  • Accused Features: The complaint accuses Luxshare's HSIO connectors generally of infringing the ’255 Patent (Compl. ¶66).

U.S. Patent No. 10,381,767 - "High Performance Cable Connector"

  • Technology Synopsis: This patent details the mechanical structure of a receptacle connector for mounting to a printed circuit board. It claims a housing containing first and second "lead assemblies," each of which includes its own "monolithic housing member" and a plurality of conductive elements. This specific two-assembly structure is designed to manage the arrangement of contacts within the connector's cavity (U.S. Patent 10381767, Abstract; col. 31:1-35).
  • Asserted Claims: Claim 1 (Compl. ¶74).
  • Accused Features: The complaint accuses Luxshare's HSIO connectors, which are receptacles, generally of infringing the ’767 Patent (Compl. ¶75).

The Accused Instrumentality

Product Identification

  • The Accused Products are Luxshare's HSIO connectors, including its QSFP, QSFP-DD, Super QSFP, and Ultra QSFP connector product lines (Compl. ¶9, 17).

Functionality and Market Context

  • The Accused Products are high-speed I/O connectors designed for use in data center equipment such as servers, switches, and routers (Compl. ¶4, 40). They are offered in various port configurations (e.g., 1xN, 2xN) and are marketed for data speeds up to 200G (Compl. ¶10). A product brochure describes the "Super QSFP(100G) and Ultra QSFP(200G) High Speed I/O Connector & Cage" as widely adopted for interconnections in data centers (Compl. p. 6, Ex. 9).
  • A central allegation is that Luxshare copied Amphenol's patented technology and designs, specifically by replicating Amphenol's connector footprint for mounting to a printed circuit board (Compl. ¶8). The complaint provides a side-by-side visual comparison of footprint drawings from Luxshare and Amphenol, alleging they are identical to within a fraction of a millimeter (Compl. p. 5, Ex. 8). The complaint also includes a world map from Luxshare's website to illustrate its sales presence in the United States (Compl. p. 11, Ex. 7).

Analysis of Infringement Allegations

The complaint alleges that the Accused Products satisfy every limitation of the asserted claims but does not provide a detailed, element-by-element mapping for infringement (Compl. ¶44, ¶52). The following charts summarize the infringement theory based on the general allegations against the Accused Products.

’117 Patent Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
insulative material The plastic or non-conductive housing material of the Accused Products. ¶44 col. 5:1-3
a plurality of signal conductors...secured in the insulative material The electrical signal contacts held within the connector housing. ¶44 col. 5:2-3
a plurality of conductive elements not in contact with any one of the plurality of signal conductors... The ground or shield contacts within the connector, separate from the signal contacts. ¶44 col. 5:15-17
electrically lossy material extending between and in contact with the intermediate portion of each of the plurality of conductive elements... A resonance-damping material within the Accused Products that allegedly bridges the ground/shield contacts. ¶44 col. 6:50-65

’875 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a first layer formed from an insulative material An insulative layer or component forming part of the internal structure of the Accused Products. ¶52 col. 2:41-42
a plurality of signal conductors...disposed in the first layer Signal contacts held within the aforementioned insulative layer. ¶52 col. 2:43-45
a plurality of shield strips...disposed in the first layer Shielding contacts held within the same insulative layer, adjacent to the signal contacts. ¶52 col. 2:45-48
a second layer adjacent the first layer that is formed from an electrically lossy material, the second layer providing electrical bridging between the plurality of shield strips A distinct adjacent layer of resonance-damping material within the Accused Products that contacts the shield strips. ¶52 col. 2:48-51
  • Identified Points of Contention:
    • Evidentiary Question: The complaint’s primary evidence of infringement appears to be the alleged copying of the external connector footprint. A central question will be whether the Accused Products actually contain the internal structures required by the claims, such as the "electrically lossy material" ('117 and '875 Patents) or the specific layered construction ('875 Patent). The complaint does not provide direct evidence (e.g., from a product teardown) of these internal features.
    • Scope Questions: The analysis may raise questions of definitional scope, such as whether the internal materials and components of the Accused Products, once identified through discovery, meet the specific claim definitions of "electrically lossy material," "conductive elements," "shield strips," and the layered structure of the '875 Patent.

Key Claim Terms for Construction

  • The Term: "electrically lossy material" (present in asserted claims of the ’117 and ’875 Patents)
  • Context and Importance: This term is central to the patented solution in the lead patents. The outcome of the infringement analysis for these patents will depend heavily on whether the materials used inside the Accused Products fall within the scope of this term's definition. Practitioners may focus on this term because it defines the core technological feature alleged to be copied.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the ’117 Patent defines the term broadly to include materials that "conduct, but with some loss, over the frequency range of interest," and states they can be formed from "lossy dielectric and/or lossy conductive materials" (’117 Patent, col. 5:18-23). It also provides a wide range of potential surface resistivity values, from 1 to 10^6 Ω/square (’117 Patent, col. 6:48-52).
    • Evidence for a Narrower Interpretation: The specification provides specific examples, such as a thermoplastic binder filled with conductive particles like carbon or graphite, and specific preferred resistivity ranges, such as "between about 20 Ω/square and 40 Ω/square" (’117 Patent, col. 6:55-67). A defendant might argue these embodiments and preferred ranges limit the term to materials specifically engineered for resonance damping, rather than any material that incidentally possesses some electrical loss.

Other Allegations

  • Indirect Infringement: The complaint alleges that Luxshare actively induces infringement by selling the Accused Products to third parties with the knowledge and intent that they will be imported and used in the United States in an infringing manner (Compl. ¶46, 54). The provision of "connector footprint drawings that serve as instructions to customers" may be presented as evidence of an affirmative act of inducement (Compl. ¶10).
  • Willful Infringement: Willfulness is alleged for all five patents-in-suit. For the ’117, ’875, ’521, and ’255 patents, the allegation is based on knowledge "at least as of the date this action was filed" (Compl. ¶48, 56, 64, 72). For the ’767 Patent, the complaint alleges pre-suit knowledge dating back to its issuance on August 13, 2019, based on a May 18, 2016 license agreement in which the underlying patent application was allegedly identified (Compl. ¶37, 81).

Analyst’s Conclusion: Key Questions for the Case

  • A central evidentiary question will be one of internal construction: Does discovery reveal that the accused Luxshare connectors contain the specific internal features recited in the asserted claims, namely the "electrically lossy material" configured to bridge ground elements? The complaint's theory of "exact[] cop[y]" (Compl. ¶8) based on external footprints will be tested against the actual internal makeup of the products.
  • A key legal issue will be one of willful conduct, particularly for the ’767 Patent: Does a party's identification of a patent application in a prior commercial agreement create an affirmative duty to monitor that application and, upon its issuance as a patent, to avoid infringement? The court's answer will determine whether Luxshare's alleged infringement could be deemed egregious.
  • The case may also turn on a question of claim scope: Can the term "electrically lossy material," which is central to the asserted technology, be construed broadly to cover a range of materials, or will it be limited by the specification's preferred embodiments to materials specifically designed for resonance damping?