DCT
1:17-cv-01099
Interface Linx LLC v. Onkyo USA Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Interface Linx, LLC (California)
- Defendant: Onkyo U.S.A. Corporation (Delaware) and Onkyo Corporation (Japan)
- Plaintiff’s Counsel: Devlin Law Firm LLC; One LLP
- Case Identification: 1:17-cv-01099, D. Del., 08/07/2017
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because at least one defendant, Onkyo U.S.A. Corporation, is incorporated in Delaware.
- Core Dispute: Plaintiff alleges that Defendants’ audio/visual products incorporating standard HDMI Type A connectors infringe a patent directed to the specific geometry of an electrical connector assembly.
- Technical Context: The technology relates to the physical design of high-speed data connectors, a fundamental component in the consumer electronics market for interconnecting devices like televisions, receivers, and media players.
- Key Procedural History: The complaint alleges Defendants had knowledge of the patent since at least the filing of an original action on April 27, 2017. Subsequent to the filing of this complaint, a third party initiated an Inter Partes Review (IPR) proceeding (IPR2020-01463) against the patent-in-suit. This proceeding concluded on July 14, 2022, with a certificate from the U.S. Patent and Trademark Office cancelling all claims of the patent, including the asserted Claim 1. This post-filing event renders the patent unenforceable.
Case Timeline
| Date | Event |
|---|---|
| 2000-08-31 | '678 Patent Priority Date |
| 2003-01-21 | '678 Patent Issue Date |
| 2017-04-27 | Filing of a prior, related action alleged in complaint |
| 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 all claims of '678 Patent |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 6,508,678, "Electrical Connector Assembly," issued January 21, 2003.
The Invention Explained
- Problem Addressed: The patent’s background section identifies a drawback with conventional connectors like USB, where a user might attempt to connect the wrong end of a cable to a device, "thereby hindering data transmission" ('678 Patent, col. 1:23-28).
- The Patented Solution: The invention is an electrical connector assembly, comprising a plug and a receptacle, characterized by a specific, non-symmetrical, multi-sided "confining wall." This wall's unique geometry, detailed through a series of relational requirements for its five distinct side types, ensures that the plug can only mate with the receptacle in a single, correct orientation ('678 Patent, Abstract; col. 2:40-60). The design aims to prevent improper connection.
- Technical Importance: The complaint alleges that the patented design offered such significant improvements that it was adopted for the HDMI Type A standard, which became a ubiquitous connector in the consumer electronics industry (Compl. ¶13).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶11).
- Essential elements of Claim 1 include:
- An electrical connector assembly with a plug and a receptacle, each defined by a multi-sided confining wall.
- Each confining wall has 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.
- A series of specific dimensional and relational constraints: the first side is longer than the second; the first and second sides are longer than the third sides; the width between the third sides is greater than the width between the fourth sides.
- A series of specific orientational constraints: 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.
III. The Accused Instrumentality
- Product Identification: The accused products are a range of Onkyo-branded electronics, including A/V Receivers (e.g., TX-RZ810), Home Theater Systems, Blu-ray Players, Soundbars, and Preamplifiers, which are collectively referred to as the "Accused Systems" (Compl. ¶14).
- Functionality and Market Context: The accused functionality is the inclusion and use of electrical connector assemblies designed to the "specifications of HDMI Type A" (Compl. ¶12). The complaint alleges these HDMI ports embody the patented connector assembly (Compl. ¶13). The complaint provides a "Connection example" diagram from an Onkyo product manual, showing HDMI cables being used to connect external devices to the accused receiver, thereby illustrating the plug-and-receptacle system in its intended environment (Compl. p. 4, ¶15). A photograph of the rear panel of an Onkyo receiver is also provided to show the array of accused HDMI receptacles (Compl. p. 5, ¶17).
IV. Analysis of Infringement Allegations
U.S. Patent No. 6,508,678 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a plug that includes a plug housing having a first mating portion...and a receptacle that includes a receptacle housing having a second mating portion...said second mating portion being defined by a multi-sided second confining wall | The Accused Systems require both plugs and receptacles (i.e., HDMI cables and ports) to form the connector assembly. The plug and receptacle both feature a mating portion defined by a multi-sided confining wall. | ¶15, ¶16 | col. 5:9-20 |
| 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 each extending between and interconnecting one of said third sides and one of said fourth sides | The geometry of the accused HDMI Type A connectors is alleged to have the claimed first, second, third, fourth, and fifth sides. The complaint provides a color-coded diagram of an HDMI port to illustrate this mapping. This diagram labels each side of the port in accordance with the claim language. | ¶18, ¶19 | col. 5:21-29 |
| said first side being longer than said second side, said first and second sides being longer than each of said third sides, the width between said third sides being greater than that between said fourth sides, said fifth sides being angled away from each other... | The complaint alleges that the dimensions and relative angles of the sides of the accused HDMI Type A connectors meet these specific geometric and relational limitations recited in the claim. | ¶19 | col. 5:27-32 |
| wherein said first and second sides are substantially parallel, and said third sides are substantially perpendicular to said first side | In the accused HDMI Type A connectors, the top and bottom sides ("first and second sides") allegedly run substantially parallel, and the vertical sides ("third sides") are allegedly substantially perpendicular to the top side. | ¶20 | col. 6:1-3 |
| wherein said fourth sides extend obliquely from said second side | In the accused HDMI Type A connectors, the angled lower corners ("fourth sides") allegedly extend obliquely from the bottom side ("second side"). | ¶21 | col. 6:4-5 |
- Identified Points of Contention:
- Factual/Technical Question: The infringement theory rests on a direct assertion that the standard geometry of an HDMI Type A connector maps precisely onto the elements of Claim 1. The complaint presents this as a direct factual correspondence, supported by a color-coded diagram labeling the parts of an HDMI port with the patent's terminology (Compl. p. 6, ¶19). A potential dispute would focus on whether the physical measurements and angles of an actual HDMI Type A connector fall within the scope of the claim limitations, particularly the qualitative terms.
- Scope Questions: The case would raise questions about the proper construction of relative and qualitative terms. For example, a court would need to determine the permissible degree of deviation from perfect angles for terms like "substantially parallel," "substantially perpendicular," and "obliquely." The infringement analysis would depend entirely on how broadly or narrowly these terms are construed in light of the patent's specification and drawings.
V. Key Claim Terms for Construction
The Term: "substantially perpendicular"
- Context and Importance: This term defines the orientation of the "third sides" relative to the "first side." Its construction is critical because if the angle of the corresponding sides of an HDMI connector falls outside the construed scope of "substantially perpendicular," a finding of non-infringement could result for that element. Practitioners may focus on this term because standardized connectors have precise geometric specifications, and any deviation from a true 90-degree angle could be a focal point for a non-infringement argument.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that the use of the modifier "substantially" was a deliberate choice by the patentee to capture minor variations and manufacturing tolerances, and thus should not be limited to a perfect 90-degree angle.
- Evidence for a Narrower Interpretation: The patent drawings, such as Figure 9, depict the third sides (483) as appearing perfectly perpendicular to the first side (481) ('678 Patent, Fig. 9). A party could argue these embodiments limit the scope of "substantially" to only de minimis deviations from 90 degrees.
The Term: "obliquely"
- Context and Importance: This term describes the orientation of the "fourth sides." As a non-specific angular term (i.e., not parallel and not perpendicular), its scope is inherently ambiguous and central to determining if the angled corners of an HDMI connector infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain and ordinary meaning of "oblique" is broad, covering any angle that is not 0 or 90 degrees. A party could argue the term should be given this wide scope in the absence of a narrowing definition in the specification.
- Evidence for a Narrower Interpretation: A defendant could argue that the term "obliquely" should be limited to the specific angle and configuration shown in the patent's preferred embodiment in Figure 9 ('678 Patent, Fig. 9). The complaint itself illustrates a specific angle for the fourth side in its diagram, suggesting a particular geometry is contemplated (Compl. p. 6, ¶19).
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement based on Defendants' affirmative acts of encouraging infringement, including by "distributing instructions for using the Accused Systems" in product manuals and through advertising (Compl. ¶25). Contributory infringement is also alleged, on the basis that the HDMI receptacle is a material part of the invention, is not a staple article of commerce, and has no substantial non-infringing use (Compl. ¶26).
- Willful Infringement: The willfulness claim is based on alleged knowledge of the '678 Patent "since at least the filing of the original action on April 27, 2017" (Compl. ¶27). The complaint alleges that Defendants have continued to infringe in an "egregious and wanton manner" despite this knowledge (Compl. ¶29).
VII. Analyst’s Conclusion: Key Questions for the Case
- The foundational question for this litigation is the viability of the asserted patent itself. Subsequent to the complaint's filing, an Inter Partes Review proceeding resulted in a final determination and certificate canceling all claims of the '678 patent, including the asserted Claim 1. This development raises the dispositive question of whether a live controversy remains for the court to adjudicate, as an invalid patent cannot be infringed.
- Assuming the patent were still valid, a central issue would be one of definitional scope: do the qualitative terms in Claim 1, such as "substantially perpendicular" and "obliquely," read on the precise, standardized geometry of the accused HDMI Type A connectors when interpreted in light of the patent's specification and drawings? The case would likely depend on whether the patentee's chosen language was broad enough to capture the industry standard or was implicitly limited to the specific embodiments shown.