DCT

5:23-cv-05892

Lenovo United States Inc v. ASUSTeK Computer Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:23-cv-05892, N.D. Cal., 11/15/2023
  • Venue Allegations: Venue is alleged to be proper for ASUSTeK Computer Inc. as a foreign corporation and for ASUS Computer International as a California corporation with its principal place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s laptop computers, including the Zenbook Pro and Zenbook Flip series, infringe four patents related to wireless communication protocols, power management, touchpad functionality, and hinge mechanisms.
  • Technical Context: The dispute spans multiple fundamental technologies in modern portable computing, including wireless data transmission efficiency, power management, user interface controls, and mechanical design for convertible devices.
  • Key Procedural History: No prior litigation, administrative proceedings, or licensing history is mentioned in the complaint.

Case Timeline

Date Event
2003-06-25 ’066 Patent Priority Date
2005-01-21 ’189 Patent Priority Date
2010-07-20 ’189 Patent Issue Date
2010-09-07 ’066 Patent Issue Date
2012-01-30 ’354 Patent Priority Date
2014-04-01 ’354 Patent Issue Date
2015-07-14 ’203 Patent Priority Date
2021-03-16 ’203 Patent Issue Date
2023-11-15 Complaint Filing Date

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

U.S. Patent No. 10,952,203, "Methods and Apparatus for Transmitting in Resource Blocks", Issued March 16, 2021

The Invention Explained

  • Problem Addressed: The patent describes latency in conventional wireless uplink transmissions, which arises from the multi-step negotiation a device must perform with a base station: (1) request a grant to transmit data, (2) wait for the grant, and then (3) transmit the data (Compl. ¶12; ’203 Patent, col. 3:58-4:12).
  • The Patented Solution: The invention proposes a more efficient contention-based uplink mechanism. A base station transmits a contention-based uplink grant, which allows a device with data ready for upload to transmit its data packet immediately, using the information in the grant, thereby bypassing the initial scheduling request step and reducing overall delay (Compl. ¶12; ’203 Patent, Fig. 3, col. 4:24-31).
  • Technical Importance: This approach is designed to reduce latency in LTE uplink transmissions, which is important for emerging applications such as augmented reality and vehicular communications that are sensitive to communication delays (’203 Patent, col. 3:51-57).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 9, and 17 (Compl. ¶26).
  • Essential elements of independent claim 1 (a method claim) include:
    • Receiving, at a device, a resource assignment indication, where the indication indicates a set of resource blocks for a data transmission.
    • Determining, based on the indication, whether the set of resource blocks includes both a first set of resource blocks and a second set of resource blocks, or only the first set.
    • Transmitting, based on the determination, the data transmission in only the first set of resource blocks if only the first set is included.
    • Transmitting, based on the determination, the data transmission in at least one selected from the first and second sets of resource blocks if both are included.
  • The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶26).

U.S. Patent No. 7,792,066, "Wireless Wake-On-LAN Power Management", Issued September 7, 2010

The Invention Explained

  • Problem Addressed: The patent identifies the high power consumption of wireless LAN adaptors as a significant hindrance to implementing a "Wake-on-LAN" (WOL) feature, which is common in wired networks. The need for a device to formally associate with an access point before entering a power-saving mode further complicates low-power wireless operation (Compl. ¶15; ’066 Patent, col. 2:4-35).
  • The Patented Solution: The invention discloses a system where a wireless receiver in a computer can, while the computer's main power is off, receive and monitor a broadcast or multicast frame for a specific "magic packet" without first performing a handshake or association procedure with the wireless access point. Upon recognizing the packet, the receiver outputs a signal to turn on the main system power supply (’066 Patent, Abstract; Compl. ¶15).
  • Technical Importance: This technology enables a practical, low-power version of WOL for wireless devices, a critical feature for remote system administration and energy efficiency in networked environments.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 10, and 16 (Compl. ¶36).
  • Essential elements of independent claim 1 (an apparatus claim) include:
    • A wireless receiver that receives a beacon frame from a wireless access point while the main system power is off.
    • The wireless receiver setting at least one parameter in response to the beacon frame.
    • The parameter setting enabling reception of a predetermined frame (e.g., broadcast or multicast) without the receiver transmitting a wireless frame to the access point to handshake.
    • The receiver, enabled by the parameter, receiving the predetermined frame and determining if a "magic packet" exists within it.
    • The receiver supplying a signal to turn on the main power supply if the magic packet is found.
  • The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶36).

Multi-Patent Capsule: U.S. Patent No. 7,760,189, "Touchpad Diagonal Scrolling", Issued July 20, 2010

  • Technology Synopsis: The complaint alleges that prior art touchpads restricted scrolling to purely horizontal or vertical directions (Compl. ¶18). The patented invention addresses this by providing a method and system that allows a user to initiate diagonal scrolling at any location on a touchpad by using two fingers, thereby offering greater flexibility in user interface navigation ('189 Patent, col. 1:43-45; Compl. ¶18).
  • Asserted Claims: Independent claims 1 and 9 (Compl. ¶46).
  • Accused Features: The touchpads incorporated into the ASUS Zenbook Pro are accused of infringement, particularly when used with software applications like Google Chrome and Adobe Acrobat that are allegedly "specially designed to allow the user to practice the invention" (Compl. ¶¶48-49).

Multi-Patent Capsule: U.S. Patent No. 8,687,354, "Dual Shaft Hinge with Angle Timing Shaft Mechanism", Issued April 1, 2014

  • Technology Synopsis: The complaint states that prior convertible laptops often required complex hinge mechanisms or complete detachment of the screen to convert into a tablet form factor (Compl. ¶21). The '354 patent discloses a hinge block with an "inhibitor stopper" mechanism that operatively couples a device's upper and lower housings, allowing the upper housing (screen) to rotate synchronously through 360 degrees relative to the lower housing to transition between laptop and tablet configurations ('354 Patent, Abstract; Compl. ¶21).
  • Asserted Claims: Independent claims 1 and 7 (Compl. ¶56).
  • Accused Features: The accused product is the ASUS Zenbook Flip 14, which allegedly incorporates a "flippable touchscreen with a 360° ErgoLift hinge" that practices the claimed invention (Compl. ¶¶ 56, 58).

III. The Accused Instrumentality

  • Product Identification: The complaint names the "exemplary ASUS Zenbook Pro" and "exemplary ASUS Zenbook Flip 14" as the accused instrumentalities (Compl. ¶¶ 26, 56).
  • Functionality and Market Context:
    • The complaint alleges the ASUS Zenbook Pro infringes the '203 patent by supporting the Wi-Fi 6 or 6E (802.11ax) wireless standard, which allegedly practices the claimed method for low-latency communication (Compl. ¶¶ 28-29). The complaint provides a URL to a product page that it alleges describes these capabilities (Compl. ¶28).
    • For the '066 patent, the accused functionality is the Zenbook Pro's ability to "wake based on a signal sent over a wireless network," which is alleged to be specially adapted to practice the claimed invention (Compl. ¶39).
    • For the '189 patent, the accused functionality resides in the Zenbook Pro's touchpad hardware and firmware, in conjunction with supported software applications like Google Chrome, which allegedly enable the claimed two-finger diagonal scrolling (Compl. ¶¶ 48-49).
    • For the '354 patent, the accused functionality is the "flippable touchscreen with a 360° ErgoLift hinge" of the ASUS Zenbook Flip 14, which allegedly allows the device to convert between laptop and tablet configurations in an infringing manner (Compl. ¶¶ 58-59). The complaint provides a URL to a product page allegedly demonstrating this feature (Compl. ¶58).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts attached as exhibits, but these exhibits were not filed with the complaint. The following is a summary of the narrative infringement theories.

’203 Patent Infringement Allegations
The complaint alleges that the ASUS Zenbook Pro infringes by making, using, and selling products that support Wi-Fi 6 or 6E (802.11ax) (Compl. ¶¶ 26, 28-29). The central theory appears to be that the 802.11ax standard itself implements the patented method of using contention-based resource allocation to reduce transmission latency. The infringement is therefore alleged to occur whenever the device operates according to that standard. The complaint provides a URL to a product page for the ASUS Zenbook Pro, which allegedly documents the product's support for Wi-Fi 6E (Compl. ¶28).

’066 Patent Infringement Allegations
The infringement theory for the ’066 patent centers on the ASUS Zenbook Pro's alleged support for a wireless "wake" functionality (Compl. ¶¶ 36, 39). The complaint alleges that the product includes software and hardware "specially adapted" to receive a "magic packet" over a wireless network to power on the computer from a low-power state (Compl. ¶¶ 38-39). The core of this allegation is that the product performs this function in the manner claimed by the patent, specifically without requiring a formal handshake procedure with an access point.

  • Identified Points of Contention:
    • Scope and Technical Questions ('203 Patent): A primary issue may be whether the specific resource allocation mechanisms defined in the 802.11ax standard and implemented by the accused product map to the claim limitations of the '203 patent, which are described in the context of LTE cellular networks. The analysis will likely focus on whether the Wi-Fi protocol's operation constitutes the "determining" steps and involves the "first set" and "second set" of "resource blocks" as defined and contemplated by the patent.
    • Technical Questions ('066 Patent): The dispute may hinge on the operational details of the accused product's wireless WOL feature. A key question is whether the product can receive a "magic packet" without first performing any "handshake" with the access point, as required by claim 1. Evidence of the precise communication protocol between the accused device and an access point when in a low-power state will be critical.

V. Key Claim Terms for Construction

For the ’203 Patent:

  • The Term: "a set of resource blocks"
  • Context and Importance: This term is foundational to claim 1. Infringement depends on whether the resource allocation units used in the accused product's Wi-Fi 6/6E implementation can be characterized as the "first set" and "second set" of "resource blocks" recited in the claim. Practitioners may focus on this term because the patent's specification is rooted in LTE terminology, and its application to a Wi-Fi standard is a potential point of dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers generally to "a set of frequency domain resource blocks for possible PUSCH transmission" (’203 Patent, col. 2:42-44), which could support an interpretation not strictly limited to a specific cellular standard.
    • Evidence for a Narrower Interpretation: The specification provides specific examples tied to LTE, such as "in every alternate subframe, RB0-RB6 can be available for possible PUSCH" (’203 Patent, col. 2:65-67). This language could be used to argue for a narrower construction tied to the specific structures and timings of cellular technology.

For the ’066 Patent:

  • The Term: "without the wireless receiver transmitting a wireless frame to the wireless access point to handshake"
  • Context and Importance: This negative limitation is a core inventive concept, distinguishing the claimed invention from prior art that required formal association. The infringement case rests on showing the accused product operates in this manner.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent summary states the invention enables reception of a broadcast frame "without performing handshaking with the predetermined wireless access point" (’066 Patent, col. 4:1-5), suggesting a broad preclusion of any formal, two-way association process.
    • Evidence for a Narrower Interpretation: The background section discusses the invention in the context of IEEE 802.11 standards (e.g., ’066 Patent, col. 1:50-54). A defendant might argue that "handshake" should be construed narrowly to mean the specific authentication and association message exchanges defined in those standards, and that any other form of preliminary communication is not precluded.

VI. Other Allegations

  • Indirect Infringement: For all four asserted patents, the complaint alleges both induced and contributory infringement. The inducement allegations are based on claims that Defendant provides marketing materials, product guides, and software that instruct and encourage customers to use the accused products in an infringing manner (e.g., Compl. ¶¶ 28, 38, 48, 58). The contributory infringement allegations are based on claims that the accused functionalities (e.g., Wi-Fi 6E support, 360° hinge) are specially made or adapted for the infringing use and are not staple articles of commerce suitable for substantial non-infringing use (e.g., Compl. ¶¶ 29, 39, 49, 59).
  • Willful Infringement: The complaint alleges that Defendants had "actual knowledge" of the asserted patents and their infringement "at least as early as the filing of this complaint" (e.g., Compl. ¶¶ 25, 35, 45, 55). This allegation appears to support a claim for post-filing willful infringement only, as no pre-suit knowledge is alleged.

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

  • A central issue for the '203 patent will be one of technical translation and scope: can the claims, drafted in the context of LTE cellular technology, be construed to read on the operational protocols of the standardized Wi-Fi 6/6E (802.11ax) technology as implemented in the accused products? The case may turn on whether the term "resource blocks" can bridge the gap between these two distinct technical standards.
  • For the '066 and '189 patents, a key evidentiary question will be one of operational equivalence: does the accused WOL feature operate "without...handshaking" as claimed, and does the accused touchpad's two-finger gesture perform the specific function of "diagonal scrolling" as claimed, or is there a fundamental mismatch in the technical operation of these user-facing features?
  • A primary question for the '354 patent will be one of mechanical construction: does the accused "360° ErgoLift hinge" contain the specific structures recited in the claims, such as an "inhibitor stopper" that functions in the manner described by the patent to enable synchronous rotation from a laptop to a tablet configuration?