DCT

1:17-cv-01098

Interface Linx LLC v. Haier America Co LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-01098, D. Del., 08/07/2017
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Haier America Company, LLC is a Delaware corporation.
  • Core Dispute: Plaintiff alleges that Defendants’ televisions containing HDMI Type A ports infringe a patent directed to the specific geometric structure of an electrical connector assembly.
  • Technical Context: The technology concerns the physical, multi-sided shape of a plug and receptacle combination, a design which the complaint asserts was foundational to the widely adopted HDMI Type A connector standard.
  • Key Procedural History: The complaint alleges that Defendants had knowledge of the patent since at least April 27, 2017, the filing date of a prior action. Subsequent to the filing of this complaint, a third party initiated an inter partes review (IPR) of the patent-in-suit. This IPR proceeding (IPR2020-01463) resulted in a certificate issued on July 14, 2022, cancelling all claims of the patent, including the asserted Claim 1. This post-filing development raises fundamental questions about the viability of the infringement action.

Case Timeline

Date Event
2000-08-31 '678 Patent Priority Date
2003-01-21 '678 Patent Issue Date
2017-04-27 Filing date of prior action, establishing alleged knowledge
2017-08-07 Complaint Filing Date
2020-08-14 Inter Partes Review (IPR2020-01463) filed against '678 Patent
2022-07-14 IPR Certificate issued cancelling claims 1-5 of the '678 Patent

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

U.S. Patent No. 6,508,678 - "Electrical Connector Assembly"

  • Patent Identification: U.S. Patent No. 6,508,678, titled "Electrical Connector Assembly," issued January 21, 2003 (the “’678 Patent”).

The Invention Explained

  • Problem Addressed: The patent’s background section describes conventional Universal Serial Bus (USB) connectors where a cable has identical plugs on both ends, creating a "tendency to plug a wrong one of the plugs" into a device, which could hinder data transmission (’678 Patent, col. 1:25-34).
  • The Patented Solution: The invention is an electrical connector assembly, comprising a matched plug and receptacle, defined by a unique and specific non-symmetrical geometry. The mating portions are defined by a "multi-sided...confining wall" with a specific arrangement of five distinct side types, where the relative lengths, widths, and angles are precisely defined to ensure a unique fit and prevent incorrect insertion (’678 Patent, Abstract; col. 1:43-col. 2:4).
  • Technical Importance: The complaint alleges that the physical design offered "significant improvements" over prior art connectors and that the HDMI standards organization "utilized this design to create the Type A plug and receptacle found on the vast majority of electronic devices today" (Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts infringement of "at least claim 1" of the ’678 Patent (Compl. ¶11). The general prayer for relief suggests the potential assertion of other claims as well (Compl. ¶23).
  • The essential elements of independent Claim 1 include:
    • An electrical connector assembly comprising a plug and a receptacle, each with a multi-sided confining wall.
    • The confining walls have a specific geometry: opposite first and second sides; a pair of third sides connected to the first side; a pair of fourth sides connected to the second side; and a pair of fifth sides connecting the third and fourth sides.
    • The walls have specific dimensional relationships: the first side is longer than the second; both first and second sides are longer than the third sides; and the width between the third sides is greater than the width between the fourth sides.
    • The walls have specific angular relationships: the fifth sides are "angled away from each other"; the first and second sides are "substantially parallel"; the third sides are "substantially perpendicular" to the first side; and the fourth sides "extend obliquely" from the second side (’678 Patent, col. 5:9-col. 6:4).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are referred to as "Accused Systems," which include electronic products that incorporate electrical connector assemblies "designed to the specifications of HDMI Type A" (Compl. ¶12). The complaint specifically identifies the "Haier Defendants’ televisions, such as the 50” Class LED HDTV 50E3500" (Compl. ¶14).

Functionality and Market Context

The accused functionality resides in the HDMI receptacles (ports) integrated into Defendants' televisions (Compl. ¶16). These ports are designed to receive a corresponding HDMI plug to transfer audio and video data between devices (Compl. ¶15). The complaint provides a screenshot from a product webpage for the accused television, showing a panel with multiple inputs. (Compl. p. 4, "Range of Inputs"). This visual identifies the presence of three HDMI ports on the accused product (Compl. p. 4).

IV. Analysis of Infringement Allegations

'678 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An electrical connector assembly, comprising: a plug...and a receptacle... The accused systems require both plugs and receptacles to form the HDMI connection for data transfer. The receptacle is part of the accused television. ¶15, ¶16 col. 5:9-19
each of said first and second confining walls having opposite first and second sides, a pair of opposite third sides..., a pair of fourth sides..., and a pair of fifth sides... The complaint alleges that HDMI Type A connectors have a specific shape with a first, second, third, fourth, and fifth side, as illustrated in a color-coded diagram mapping the claim terms to an HDMI port. ¶17, ¶18 col. 5:20-27
said first side being longer than said second side, The complaint asserts that in HDMI Type A connectors, "the first side is longer than the second side." ¶18 col. 5:28-29
the width between said third sides being greater than that between said fourth sides, The complaint asserts that in these connectors, "the width between the two fourth sides must be less than that between the two third sides." ¶18 col. 5:30-32
said fifth sides being angled away from each other while extending from said fourth sides to said third sides; The complaint alleges that the fifth sides of the HDMI Type A connector "must be angled away from each other while extending from the fourth sides to the third sides." The visual provided shows the angled nature of these sides. ¶18, p. 5 col. 5:32-35
wherein said first and second sides are substantially parallel, and said third sides are substantially perpendicular to said first side; It is alleged that in the accused HDMI Type A connectors, "the first and second sides run substantially parallel to each other" and "the third sides are substantially perpendicular to the first side." ¶19 col. 6:1-3
and wherein said fourth sides extend obliquely from said second side. The complaint alleges that the "fourth sides extend obliquely from each end of the second side." ¶20 col. 6:4

Identified Points of Contention

  • Scope Questions: The patent's specification repeatedly frames the invention in the context of a "USB type electrical connector assembly" (’678 Patent, col. 1:5-7). The infringement allegation, however, targets the geometry of an HDMI Type A connector. This raises the question of whether the claims, which do not explicitly mention "USB," are limited by the specification's narrower focus or can be construed to cover different connector standards like HDMI.
  • Technical Questions: The infringement case hinges on whether the physical shape of the accused HDMI ports precisely matches every geometric and dimensional limitation in Claim 1. The complaint provides a color-coded diagram mapping the claim terms to an image of an HDMI port (Compl. p. 5), but a central factual dispute will likely concern whether the measured angles and side-length ratios of the actual accused products satisfy limitations such as "substantially parallel," "substantially perpendicular," and "obliquely" as those terms would be construed by the court.

V. Key Claim Terms for Construction

  • The Term: "electrical connector assembly"

    • Context and Importance: The construction of this term is critical to determining the overall scope of the patent. The defense may argue that extensive discussion of "USB" in the specification limits the claims to that specific type of connector, which would be fatal to a case targeting HDMI ports.
    • Intrinsic Evidence for a Broader Interpretation: The term itself is generic. The claim language defines the assembly by its geometric properties, not by reference to a specific data transmission standard like USB (’678 Patent, col. 5:9-col. 6:4).
    • Intrinsic Evidence for a Narrower Interpretation: The "Field of the Invention" section states the invention relates "more particularly to a USB type electrical connector assembly" (’678 Patent, col. 1:6-7). The "Description of the Related Art" section also focuses exclusively on the problems with conventional USB connectors (’678 Patent, col. 1:8-34).

  • The Term: "substantially parallel" / "substantially perpendicular" / "obliquely"

    • Context and Importance: These relational terms define the connector's shape. The degree of variance permitted by "substantially" and the specific angular range covered by "obliquely" will be central to the infringement analysis.
    • Intrinsic Evidence for a Broader Interpretation: A party arguing for broader scope may contend these terms are intended to encompass minor variations inherent in manufacturing processes and should not be limited to the exact angles depicted in the drawings.
    • Intrinsic Evidence for a Narrower Interpretation: The patent's drawings, such as Figure 9 and Figure 10, illustrate a very distinct and precise geometry. A party arguing for a narrower scope may assert that these figures define the intended meaning of the terms, limiting them to a narrow range of angles close to those depicted. The specification does not provide numerical definitions, leaving the interpretation dependent on this intrinsic evidence.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement, asserting that Defendants encourage infringement by providing "user manuals, product support, and marketing materials" that instruct customers on how to use the accused HDMI ports (Compl. ¶24). It also pleads contributory infringement, alleging the HDMI receptacle is a non-staple component with no substantial non-infringing use (Compl. ¶25).
  • Willful Infringement: Willfulness is alleged based on Defendants' purported knowledge of the ’678 Patent "since at least the filing of the original action on April 27, 2017" (Compl. ¶26). The claim is that Defendants "disregarded, and continue to disregard, an objectively high likelihood that their actions infringe" (Compl. ¶28).

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

  • A dispositive issue is the post-filing invalidation of the patent. Given that all asserted claims were cancelled in an inter partes review after the complaint was filed, a primary question is what, if any, legal remedy remains for alleged infringement that occurred during the period when the patent was presumptively valid.
  • A core issue will be one of definitional scope: can the term "electrical connector assembly," which arises in a specification that explicitly describes the invention as a "USB type" connector, be construed broadly enough to read on the standardized geometry of an HDMI Type A port?
  • A key evidentiary question will be one of geometric conformance: assuming the claims are valid for the relevant time period and broad enough to cover HDMI, does the physical structure of the accused television's HDMI port meet every specific dimensional and angular limitation recited in Claim 1, particularly the relative side lengths and the "oblique" and "angled away" nature of its confining walls?