DCT
5:19-cv-02649
Universal Transdata LLC v. Lexar Intl
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Universal Transdata, LLC (Georgia)
- Defendant: Lexar International (California); Longsys Electronics Limited (California)
- Plaintiff’s Counsel: Cotman IP Law Group, PLC; Kent & Risley LLC
- Case Identification: 5:19-cv-02649, N.D. Cal., 05/15/2019
- Venue Allegations: Venue is alleged to be proper as Defendants are claimed to reside in, maintain regular and established places of business in, and have sold or induced the sale of infringing products within the Northern District of California.
- Core Dispute: Plaintiff alleges that Defendants’ Lexar S75 JumpDrive line of USB flash drives infringes a patent related to a portable storage device with a retractable connector mechanism.
- Technical Context: The technology concerns the mechanical design of USB flash drives, a ubiquitous method for portable data storage, specifically focusing on mechanisms that protect the connector without a separate, losable cap.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendants with pre-suit notice of the patent and the alleged infringement, which may form the basis for its willfulness claim.
Case Timeline
| Date | Event |
|---|---|
| 2002-09-30 | '030 Patent Priority Date |
| 2004-06-01 | '030 Patent Issue Date |
| 2019-05-15 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,743,030 - “Portable Storage Device with Universal Serial Bus”
- Patent Identification: U.S. Patent No. 6,743,030, “Portable Storage Device with Universal Serial Bus,” issued June 1, 2004.
The Invention Explained
- Problem Addressed: The patent identifies a drawback with conventional portable storage devices (like early USB drives) that used a separate, detachable cover to protect the data connector. This cover was “completely separated from the case” when removed and could be easily lost, leaving the connector unprotected and prone to damage, failure, or uselessness (’030 Patent, col. 1:29-39).
- The Patented Solution: The invention proposes a portable storage device where the connector is retractable into the main case. It describes a main body, comprising the circuit board and connector, which slides within a hollow case. This movement is controlled by an external "push member" that is connected to the internal main body, allowing a user to extend the connector for use and retract it for protection, thus eliminating the need for a separate cap (’030 Patent, Abstract; col. 2:46-62). The exploded view in Figure 2 illustrates the distinct components: the case (1), the main body (2), and the push member (3) (’030 Patent, Fig. 2).
- Technical Importance: This integrated design offered a more convenient and reliable solution for protecting the USB connector, addressing a common point of failure and user frustration with prior designs that relied on separate caps (’030 Patent, col. 3:45-51).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 7 and 8 (Compl. ¶21).
- Independent Claim 1 recites the core elements of the invention:
- a case having a longitudinal length and a front opening;
- a main body comprising a circuit board and a connector located in front of said circuit board;
- said main body being positioned in said case with said connector being movable out of or retractable into said front opening of said case;
- a push member being connected to said main body in the manner of interference fit and exposed from said case; and
- whereby by pushing said push member forward or rearward, said connector of said main body is brought to project from or retract into said case, and said push member does not extend substantially beyond the longitudinal length of said case.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the "Lexar S75 JumpDrive products" as the Accused Products (Compl. ¶22).
Functionality and Market Context
- The complaint alleges the Accused Products are portable USB flash drives that feature a sliding mechanism to extend and retract the USB connector (Compl. Ex. B, p. 21). An image in the complaint's claim chart shows the Accused Product with its internal circuit board and connector visible, corresponding to the claimed "main body" (Compl. Ex. B, p. 20). The complaint’s allegations focus on the mechanical functionality of the device’s housing and slider, which allows the connector to be protected within the case when not in use and exposed for connection to a computer. Another image depicts the disassembled two-part case, which allegedly forms the claimed "hollow chamber" (Compl. Ex. B, p. 24).
IV. Analysis of Infringement Allegations
'030 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a case having a longitudinal length and a front opening | The Accused Product is alleged to have a case with a longitudinal length and a front opening for the connector to pass through, as shown in an annotated photograph (Compl. Ex. B, p. 20). | ¶23 | col. 4:5-6 |
| a main body comprising a circuit board and a connector located in front of said circuit board | The Accused Product allegedly contains an internal assembly of a circuit board and a USB connector, which is depicted in a photograph of the device's internals (Compl. Ex. B, p. 20). | ¶23 | col. 4:7-9 |
| said main body being positioned in said case with said connector being movable out of or retractable into said front opening of said case | The complaint alleges the internal main body is positioned inside the case and is movable, allowing the connector to slide out of and back into the case's front opening, as illustrated in images showing the connector in both retracted and extended positions (Compl. Ex. B, p. 21). | ¶23 | col. 4:10-12 |
| a push member being connected to said main body in the manner of interference fit and exposed from said case | The complaint alleges the device has an external thumb-slide ("push member") that is connected to the internal main body. The complaint asserts this connection is an "interference fit" and provides a photograph pointing to the connection point on the internal circuit board (Compl. Ex. B, p. 21). | ¶23 | col. 4:13-15 |
| whereby by pushing said push member forward or rearward, said connector...is brought to project from or retract into said case, and said push member does not extend substantially beyond the longitudinal length of said case | The complaint alleges that sliding the push member causes the connector to project or retract, and that the push member itself does not substantially extend beyond the case's length. This functionality is depicted in two annotated photographs showing the sliding action and result (Compl. Ex. B, p. 22). | ¶23 | col. 4:16-20 |
Identified Points of Contention
- Scope Questions: A central dispute may concern the scope of the term "interference fit." The complaint asserts this limitation is met but provides only a high-level photograph of the internal connection point. The question for the court will be whether the specific mechanism connecting the slider to the circuit board in the Accused Product falls within the meaning of "interference fit" as described and claimed in the patent.
- Technical Questions: The complaint does not provide detailed evidence of the how the push member is connected to the main body, beyond a photograph pointing to the general area of connection (Compl. Ex. B, p. 21). A technical question will be what evidence supports the assertion that this connection operates "in the manner of interference fit," as opposed to another form of mechanical linkage not contemplated by the patent.
V. Key Claim Terms for Construction
- The Term: "interference fit"
- Context and Importance: This term is critical as it defines the required method of connection between the user-operated "push member" and the internal "main body." The nature of this connection is a core technical aspect of the claim. Infringement will depend on whether the Accused Product's sliding mechanism uses a connection that can be properly characterized as an "interference fit."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is used in the summary of the invention without being strictly tied to a single structure, suggesting it describes a functional connection rather than a specific form ('030 Patent, col. 2:59-60). A party might argue it should be given its plain and ordinary meaning in mechanical engineering.
- Evidence for a Narrower Interpretation: The detailed description provides specific examples of how this fit is achieved, such as a "hole 311 fitly engaged with the raised electronic element 221 on the circuit board" or "lugs 312... engaged with the grooves 121" ('030 Patent, col. 2:56-62). A party could argue these embodiments limit the term to a direct, physical inter-locking engagement, potentially excluding other types of sliding connections.
VI. Other Allegations
Indirect Infringement
- The complaint alleges that Defendants actively and intentionally induced infringement by others with prior knowledge of the patent (Compl. ¶31). The complaint does not, however, specify the particular acts of inducement, such as citations to user manuals, advertisements, or other instructional materials.
Willful Infringement
- The complaint alleges that Defendants' infringement was and is willful and deliberate (Compl. ¶26). This allegation is based on the claim that Plaintiff provided "pre-suit notice of the '030 Patent and Defendants' infringement" (Compl. ¶19, ¶25).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute will likely depend on the answers to two central questions:
A core issue will be one of definitional scope: Can the term "interference fit," as used in Claim 1 and informed by the patent’s specification, be construed to read on the specific mechanical linkage between the external slider and the internal circuit board of the accused Lexar S75 JumpDrive?
A key evidentiary question will be one of technical proof: Beyond the high-level allegations and photographs in the complaint, what evidence can the Plaintiff provide during discovery to demonstrate that the internal mechanism of the Accused Product actually functions "in the manner of interference fit" as required by the patent claims, as opposed to a different, non-infringing mechanism?