DCT

1:17-cv-01104

Interface Linx LLC v. Voxx Intl Corp

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:17-cv-01104, D. Del., 08/07/2017
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because one or more of the Defendant entities is incorporated in Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s audio/visual products incorporating HDMI Type-A connectors infringe a patent directed to the specific physical geometry of an electrical connector assembly.
  • Technical Context: The technology concerns the physical design of electrical connectors, specifically the non-symmetrical shape of the plug and receptacle that defines the High-Definition Multimedia Interface (HDMI) standard.
  • Key Procedural History: The complaint alleges Defendant had knowledge of the patent-in-suit since at least April 27, 2017, the filing date of a prior action. Subsequent to the filing of this complaint, the patent-in-suit (U.S. Patent No. 6,508,678) was the subject of an Inter Partes Review (IPR2020-01463). On July 14, 2022, the U.S. Patent and Trademark Office issued a certificate cancelling all claims of the patent (Claims 1-5).

Case Timeline

Date Event
2000-08-31 '678 Patent Priority Date
2003-01-21 '678 Patent Issue Date
2017-04-27 Filing date of original action, establishing alleged knowledge
2017-08-07 Complaint Filing Date
2020-08-14 Inter Partes Review (IPR) Filed against '678 Patent
2022-07-14 U.S. Patent and Trademark Office cancels all claims of '678 Patent

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

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 problem with prior art connectors like USB, where a symmetrical plug design could lead to a user attempting to insert it into a receptacle incorrectly, thereby hindering data transmission (’678 Patent, col. 1:25-39).
  • The Patented Solution: The invention solves this problem by defining a unique, asymmetrical geometry for the mating plug and receptacle. The core of the solution is a multi-sided "confining wall" with a specific arrangement of five distinct sides having defined relationships in length and orientation, ensuring the plug can only be inserted in one way (’678 Patent, Abstract; col. 2:39-60; Fig. 9). This physical keying prevents incorrect insertion.
  • Technical Importance: The complaint alleges that the patented physical design offered such significant improvements over the prior art that it was utilized to create the HDMI Type-A plug and receptacle standard found on a vast majority of modern electronic devices (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 ('678 Patent).
  • The essential elements of independent claim 1 include:
    • An electrical connector assembly comprising a plug and a receptacle.
    • The plug and receptacle each have a mating portion defined by a multi-sided confining wall.
    • Each confining wall has: opposite first and second sides; a pair of opposite third sides connected to the first side; a pair of opposite fourth sides connected to the second side; and a pair of fifth sides connecting the third and fourth sides.
    • The geometry is further defined by specific relationships: the first side is longer than the second side; the width between the third sides is greater than the width between the fourth sides; and 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.
    • The fourth sides extend obliquely from the second side.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are a range of Defendant’s products referred to as the "Accused Systems" (Compl. ¶14). Specific examples include the "12.1" Digital Hi-Def Overhead Monitor System...ADVEXL12A," the "INVISION ConnectedHD 8” Headrest System HR8D," and the "Klipsch Reference RSB-14 Sound Bar" (Compl. ¶16).

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. ¶14). The complaint alleges these systems require both plugs and receptacles with a specific physical structure to transfer audio and video data (Compl. ¶17). The complaint provides images from Defendant's marketing materials showing the accused products and their HDMI ports (Compl. ¶¶19-22). The diagram from a user manual for the ADVEXL12A overhead monitor shows an HDMI/MHL input port for connecting external devices (Compl. ¶19, p. 6).

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 assembly and transfer data via an HDMI connection. ¶17 col. 2:39-50
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 HDMI Type A connectors have a confining wall with a plurality of specifically designed and oriented sides. A color-coded diagram of an HDMI receptacle is presented to illustrate the claimed first, second, third, fourth, and fifth sides. ¶23, ¶24 col. 4:1-8
said first side being longer than said second side, The first side (top) is alleged to be longer than the second side (bottom). ¶24 col. 4:8-9
the width between said third sides being greater than that between said fourth sides, The width between the two fourth sides is alleged to be less than the width between the two third sides. ¶24 col. 4:9-11
said fifth sides being angled away from each other while extending from said fourth sides to said third sides; The fifth sides are alleged to be angled away from each other, connecting the third and fourth sides. ¶24 col. 4:11-14
wherein said first and second sides are substantially parallel, The first and second sides are alleged to run substantially parallel to each other. ¶25 col. 4:14-15
and said third sides are substantially perpendicular to said first side; The third sides are alleged to be substantially perpendicular to the first side. ¶25 col.4:15-17
and wherein said fourth sides extend obliquely from said second side. The fourth sides are alleged to extend obliquely from each end of the second side. ¶26 col. 6:3-4

Identified Points of Contention

  • Scope Questions: The central allegation is that the patent's claims read directly onto the ubiquitous HDMI Type-A standard (Compl. ¶15). A threshold question is whether the industry standard's dimensions and geometry perfectly align with every limitation of claim 1. The use of terms of degree, such as "substantially parallel" and "obliquely," creates potential for disputes over whether the physical characteristics of the accused connectors fall within the scope of these terms.
  • Technical Questions: The infringement analysis hinges on a direct comparison of the physical structure of Defendant's HDMI ports against the claim language. The complaint provides a color-coded diagram to map the claim language onto an image of an HDMI port (Compl. ¶24). The key technical question is whether this mapping is accurate for the actual accused products and whether any deviation in geometry or angle is sufficient to place the products outside the claim scope.

V. Key Claim Terms for Construction

  • The Term: "substantially perpendicular"
  • Context and Importance: This term defines the geometric relationship between the top side ("first side") and the vertical sides ("third sides") of the connector's confining wall. The precise meaning of "substantially" is critical; a narrow construction might exclude connectors with even minor angular deviations from 90 degrees, while a broader one would cover a wider range of geometries. Practitioners may focus on this term to argue that the angles on the accused HDMI connectors do or do not meet the limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of the word "substantially" itself suggests that the patentee did not intend to limit the claim to a precise 90-degree angle and that some tolerance was contemplated ('678 Patent, col. 4:15-17).
    • Evidence for a Narrower Interpretation: The patent drawings, such as Figure 9, depict the third sides as appearing perfectly perpendicular to the first side. A party could argue that these embodiments define the intended meaning of the term, limiting it to angles that are geometrically perpendicular, accounting only for minor manufacturing tolerances.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant instructs customers on how to use the Accused Systems through user manuals and promotional materials (Compl. ¶30). It also alleges contributory infringement, asserting that the HDMI receptacle is a material component of the invention that is not a staple article of commerce and has no substantial non-infringing use (Compl. ¶31).
  • Willful Infringement: The willfulness allegation is based on Defendant's alleged knowledge of the '678 Patent since at least April 27, 2017, the filing date of a prior action. The complaint claims that continued infringement despite this knowledge is egregious and wanton (Compl. ¶¶32, 34).

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

  • A dispositive issue for the entire action is the legal effect of the post-complaint claim cancellation. Given that all asserted claims were cancelled by the USPTO in an Inter Partes Review, a threshold question is what, if any, damages are recoverable for alleged infringement that occurred prior to the July 14, 2022 cancellation date.
  • The primary factual question at the time of filing was one of direct correspondence: do the accused HDMI Type-A connectors, as manufactured and sold by the Defendant, embody every geometric and relational limitation recited in claim 1, or are there measurable differences in side lengths, parallelism, or angularity that would support a non-infringement finding?
  • The case would also have turned on a question of definitional boundaries: how should terms of degree, such as "substantially perpendicular" and "obliquely," be construed? The outcome of claim construction for these terms would have determined whether the widely adopted geometry of the HDMI standard falls within or outside the scope of the patent's claims.