Jefferson Street Holdings LLC v. Mous Products Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Jefferson Street Holdings, LLC d/b/a cradl. ltd. (Colorado)
  • Defendant: Mous Products Ltd. (United Kingdom)
  • Plaintiff’s Counsel: Antonelli, Harrington & Thompson LLP; Kutak Rock LLP
• Case Identification: 1:23-cv-01520, D. Colo., 06/15/2023
• Venue Allegations: Venue is alleged to be proper in the district because the Defendant is organized under the laws of a foreign jurisdiction and may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s protective phone cases infringe four patents related to structural designs that vary the height of the case's edges to balance device protection with screen accessibility.
• Technical Context: The technology addresses the design trade-off in the smartphone accessories market between providing a raised bezel for screen protection and allowing user access to the edges of modern touchscreens.
• Key Procedural History: The four asserted patents claim a shared priority date and represent a family of inventions refined over several years. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history concerning these patents.

Case Timeline

Date	Event
2015-01-06	Plaintiff's company "cradl." officially launched
2015-02-26	Earliest Priority Date for all Asserted Patents
2016-11-01	U.S. Patent No. 9,480,319 Issued
2019-06-25	U.S. Patent No. 10,327,524 Issued
2020-11-03	U.S. Patent No. 10,820,675 Issued
2022-08-02	U.S. Patent No. 11,399,606 Issued
2023-06-15	Complaint Filed

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

U.S. Patent No. 11,399,606 - "Protective Case for Portable Electronic Device," issued August 2, 2022

The Invention Explained

• Problem Addressed: The patent family, incorporated by reference, notes that conventional protective cases for electronic devices are often "bulky, unsightly, and can limit access to the device screen or control buttons" (’606 Patent, col. 1:21-24, incorporating '524 Patent).
• The Patented Solution: The invention proposes a specific case structure to resolve this tension. It describes a case where the side ("lateral") edges have a dual-height profile: the corners ("terminal ends") are raised to a first, higher height for drop protection, while the section between the corners has a second, lower continuous height to improve access to the sides of the device's screen (’606 Patent, col. 8:40-49). The top and bottom edges are maintained at a height equal to or greater than the raised corners, ensuring the screen does not touch a flat surface when laid face down (’606 Patent, col. 8:52-55).
• Technical Importance: This design provides a structural solution to the competing demands of robust corner protection and accessibility for edge-to-edge displays, a key challenge in modern smartphone case design (’606 Patent, col. 5:51-56, incorporating '524 Patent).

Key Claims at a Glance

• The complaint asserts independent claim 11 (Compl. ¶15).
• Essential elements of Claim 11 include:
  • A case with a first panel and at least four edges, including a pair of lateral edges and a second pair of edges.
  • The lateral edges have portions of a "first height" at their terminal ends and a "second height" between the ends, with the second height being less than the first.
  • The second height of the lateral edges is "continuous."
  • The second pair of edges has a height that is the same or greater than the first height of the lateral edges.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,820,675 - "Protective Case for Portable Electronic Device," issued November 3, 2020

The Invention Explained

• Problem Addressed: Similar to its family members, the patent seeks to improve upon existing protective cases that compromise between protection and user access (’675 Patent, col. 1:15-20).
• The Patented Solution: This patent describes the invention in terms of "edge panels" rather than just "edges." It claims an outer casing with four edge panels: upper and lower edge panels having a "first height," and first and second side edge panels having a "second height" that is less than the first (’675 Patent, Abstract). The patent also requires the height profile of the two side edge panels to be symmetrical and for the second height to be a single, continuous height (’675 Patent, col. 9:54-58).
• Technical Importance: The claimed structure offers a specific geometric configuration for a protective case that prioritizes elevated protection on the shorter top and bottom ends while lowering the longer side walls for improved ergonomics and screen interaction (’675 Patent, col. 5:46-63).

Key Claims at a Glance

• The complaint asserts independent claim 27 (Compl. ¶24).
• Essential elements of Claim 27 include:
  • An outer casing with a planar back panel and four edge panels (upper, lower, first side, second side).
  • The upper and lower edge panels comprise a "first height."
  • The first and second side edge panels comprise a "second height" less than the first height.
  • The first side edge panel has a "symmetrical height profile" to the second side edge panel.
  • The second height is a "single, continuous height."
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 10,327,524 - "Protective Case for Portable Electronic Device," issued June 25, 2019

• Patent Identification: U.S. Patent No. 10,327,524, "Protective Case for Portable Electronic Device," issued June 25, 2019 (Compl. ¶30).
• Technology Synopsis: This patent addresses the problem of bulky cases by claiming a specific structure of "turned edges" (’524 Patent, col. 1:15-24). The solution is a case where upper and lower edges have a "first, continuous height," while the side edges have a "second, continuous height" that is less than the first, with the height change occurring at the corners via a "first transition" and "second transition" that can be a taper or a step (’524 Patent, col. 9:1-28).
• Asserted Claims: Independent claim 28 (Compl. ¶33).
• Accused Features: The complaint alleges the accused case's varying edge heights and the "taper or a step" transitions at its corners infringe the patent (Compl. ¶35, p.12). The complaint's Figure 5 provides an annotated photograph showing the accused case's corners, edges, and panels (Compl. p. 12).

U.S. Patent No. 9,480,319 - "Protective Case for Portable Electronic Device," issued November 1, 2016

• Patent Identification: U.S. Patent No. 9,480,319, "Protective Case for Portable Electronic Device," issued November 1, 2016 (Compl. ¶39).
• Technology Synopsis: This patent, the earliest issued in the asserted family, describes the inventive concept as a case with varied edge panel heights to balance protection and access (’319 Patent, col. 1:13-21). It claims a case where two edge panels have a "first height," the four corners have a "second height" substantially equivalent to the first, and portions of the other two edge panels have a "third height" that is less than the other two heights (’319 Patent, col. 8:28-39).
• Asserted Claims: Independent claim 14 (Compl. ¶42).
• Accused Features: The complaint alleges the accused case's top/bottom edges, corners, and side edges correspond to the claimed first, second, and third heights, respectively (Compl. ¶44, p.15).

III. The Accused Instrumentality

Product Identification

• The "exemplary accused product" is the Mous Limitless 5.0 phone case for use with the Google Pixel 7 Pro, with the allegations extending more broadly to "Mous branded phone cases" (Compl. ¶14, ¶16).

Functionality and Market Context

• The complaint focuses on the physical structure of the accused case, alleging it incorporates the patented designs of varied edge heights (Compl. ¶17, ¶26). Figure 1 of the complaint shows an annotated interior view of the accused case, identifying the "First panel," "Lateral edges," and "Second pair of edges" (Compl. p. 7). Figure 2 presents a side-profile view of the accused case, highlighting the raised "First height" at the ends and the recessed "Second height" along the main side rail (Compl. p. 7). The complaint alleges Defendant has made, used, sold, and imported these products but provides no specific details on market share or commercial success (Compl. ¶14).

IV. Analysis of Infringement Allegations

'606 Patent Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A case adapted to receive an electronic device, the case comprising: a first panel comprising at least four edges, the edges comprising: a pair of lateral edges...and a second pair of edges	The accused case includes a first panel and four edges, which are identified as two lateral edges and a second pair of edges.	¶17	col. 8:33-39
the pair of lateral edges having portions of a first height at its terminal ends that are greater than the height of the electronic device and portions having a second height positioned between the portions of a first height, the second height being less than the first height	The terminal ends of the accused case's lateral edges are a "first height," while the section between them is a "second height" that is lower than the first height.	p. 7	col. 8:40-46
the second height of the pair of lateral edges is continuous and spans the entirety of the second portions	The recessed section of the lateral edges is alleged to be a "continuous, second height."	p. 7	col. 8:47-49
the second pair of edges comprises a height that is the same or greater than the first height of the pair of lateral edges	The top and bottom edges of the accused case are alleged to have a height "greater than or equal to the first height."	p. 7	col. 8:52-55

'675 Patent Infringement Allegations

Claim Element (from Independent Claim 27)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
an outer casing having a planar back panel and four edge panels; the four edge panels comprising different heights, wherein each of an upper and lower edge panels are positioned on opposite ends of the case and comprise a first height	The accused case is alleged to have an outer casing with a back panel and four edge panels (upper, lower, and two side panels). The upper and lower panels have a "first height." Figure 3 of the complaint provides a visual map of these alleged components (Compl. p. 9).	¶26	col. 9:43-49
and a first and second side edge panels are positioned on opposite ends of the case and comprise a second height less than the first height	The side edge panels of the accused case are alleged to have a "second height" that is less than the first height of the top and bottom panels.	p. 9	col. 9:50-53
and wherein the first side edge panel has a symmetrical height profile to the second side edge panel, and wherein the second height is a single, continuous height	The side edge panels are alleged to be "symmetrical" and feature a "second, continuous height."	p. 9	col. 9:54-58

Identified Points of Contention

• Scope Questions: The infringement allegations in the complaint closely mirror the language of the claims. This suggests a primary point of contention may be the proper construction of key terms. For example, whether the term "symmetrical height profile" (’675 Patent) can read on a case with different button cutouts on each side raises a question of claim scope.
• Technical Questions: A key factual question is whether the indentations for buttons on the side of the accused case (visible in Figure 2, Compl. p. 7) interrupt the "continuous" height required by the claims. The defense may argue that these features break the continuity, while the plaintiff may argue "continuous" refers to the overall design profile, not accounting for minor functional cutouts.

V. Key Claim Terms for Construction

The Term: "continuous" (referring to height)

• Context and Importance: This term appears in the independent claims of both the ’606 and ’675 patents. Its definition is critical because the accused product, like most phone cases, has indentations or cutouts for physical buttons on its side edges. Practitioners may focus on this term because if "continuous" is construed to mean perfectly uninterrupted, the infringement case could fail on this element alone.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes the overall goal as lowering the side edges to improve screen access while keeping the corners high for protection (’524 Patent, col. 5:51-63). A party could argue that "continuous" should be interpreted in light of this functional goal, referring to the general height profile along the side rail, not a mathematically perfect line.
  • Evidence for a Narrower Interpretation: The patent figures, such as Fig. 1E and 1F of the ’524 Patent, depict the side edges (138) as having a smooth, unbroken surface profile. A party could point to these embodiments as defining the scope of "continuous" to mean a surface without physical interruptions like button indentations.

The Term: "symmetrical" (referring to height profile)

• Context and Importance: This limitation is present in claim 27 of the ’675 Patent. Its construction is important because many phones have different button layouts on their left and right sides, requiring asymmetrical cutouts in a case. A finding of infringement requires the accused case's side panels to be "symmetrical."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly define "symmetrical." A party could argue it refers to the overall height profile being mirrored (i.e., high corners tapering to a low center), not that every feature must be identical.
  • Evidence for a Narrower Interpretation: The drawings in the patent (e.g., ’675 Patent, Figs. 1E and 1F) depict side profiles that appear to be geometrically identical mirror images. A party could argue these exemplary figures limit the term "symmetrical" to a strict, mirror-image standard.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Mous provides instructions, advertising, and tutorials that direct customers to use the products in an infringing manner (Compl. ¶51). Contributory infringement is based on allegations that the accused products have special features specifically designed for infringement and are not staple articles of commerce with substantial non-infringing uses (Compl. ¶60).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the Asserted Patents "at least since the filing of the Complaint," establishing a basis for potential post-filing willfulness (Compl. ¶66). The complaint also makes a general allegation that Defendant’s actions were "objectively reckless" (Compl. ¶67).

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

• A central issue will be one of claim construction and factual application: can terms like "continuous height" and "symmetrical height profile" be interpreted to read on a commercially standard phone case that includes functional, non-symmetrical indentations for buttons, or does a strict interpretation of these terms place the accused products outside the scope of the claims?
• A second key question will concern patent validity: given the crowded field of protective electronic device cases, the case will likely involve a significant dispute over whether the claimed combination of varied edge heights would have been obvious to a person of ordinary skill in the art at the time of the invention.
• An underlying evidentiary question will be one of demonstrative proof: while the complaint's annotated images present a compelling narrative, the ultimate infringement analysis will require detailed measurements and comparison of the accused products against the specific dimensional limitations recited in the claims (e.g., "second height is less than the first height").