DCT
1:17-cv-01238
Universal Transdata LLC v. Dexxxon Digital Storage Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Universal Transdata, LLC. (Georgia)
- Defendant: Dexxxon Digital Storage, Inc. (Delaware)
- Plaintiff’s Counsel: STAMOULIS & WEINBLATT LLC
- Case Identification: 1:17-cv-01238, D. Del., 08/30/2017
- Venue Allegations: Venue is asserted on the basis that the Defendant is a Delaware corporation and therefore resides in the judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s portable USB flash drives with retractable connectors infringe a patent directed to the mechanical design of such devices.
- Technical Context: The technology concerns retractable connectors for portable data storage devices, a design intended to protect the USB plug from damage without requiring a separate, losable cap.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the patent and its alleged infringement.
Case Timeline
| Date | Event |
|---|---|
| 2002-09-30 | '030 Patent Priority Date (Application Filing) |
| 2004-04-01 | '030 Patent Application Publication Date |
| 2004-06-01 | '030 Patent Issue Date |
| 2017-08-30 | Complaint Filing Date |
| 2022-09-30 | Alleged '030 Patent Term Expiration Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,743,030 - “Portable Storage Device with Universal Serial Bus”
The Invention Explained
- Problem Addressed: The patent’s background section identifies a drawback in conventional portable storage devices that use a separate, detachable cover to protect the USB connector. This cover can be easily lost, leaving the connector unprotected and prone to damage, distortion, or failure (’030 Patent, col. 1:21-38).
- The Patented Solution: The invention is a portable storage device with an integrated, retractable USB connector. It comprises a case, an internal "main body" (containing the circuit board and connector), and an external "push member" (’030 Patent, col. 2:27-29). By sliding the external push member, the user causes the internal main body and its attached connector to project from or retract into the protective case, eliminating the need for a separate cap (’030 Patent, col. 3:9-25). The push member is connected to the main body via an "interference fit," illustrated in an embodiment as a hole on the push member engaging a raised element on the circuit board (’030 Patent, col. 2:55-58, Fig. 2).
- Technical Importance: The design provides a "very convenient" solution that protects the connector without the risk of losing a separate cover, thereby improving the device's durability and usability (’030 Patent, col. 3:48-51).
Key Claims at a Glance
- The complaint asserts independent claim 1 and dependent claims 7 and 8 (’030 Patent, Compl. ¶20).
- The essential elements of independent claim 1 include:
- a case having a longitudinal length and a front opening;
- a main body comprising a circuit board and a connector located in front of said circuit board;
- said main body being positioned in said case with said connector being movable out of or retractable into said front opening of said case;
- a push member being connected to said main body in the manner of interference fit and exposed from said case; and
- a “whereby” clause stating that pushing the push member causes the connector to project or retract, and the push member does not extend substantially beyond the case's length.
- The complaint does not explicitly reserve the right to assert additional claims, but the prayer for relief requests an adjudication that "one or more claims" have been infringed (Compl. Prayer ¶A).
III. The Accused Instrumentality
Product Identification
- The complaint identifies "Emtec 8GB Flash Drive USB 2.0 'Wallpaper' products" as infringing instrumentalities, along with other "as-yet-unknown products that similarly satisfy each element of each asserted claim" (Compl. ¶21).
Functionality and Market Context
- The complaint alleges that the Accused Products are made, used, sold, or offered for sale in the United States by the Defendant (Compl. ¶20). It does not provide a technical description of the Accused Products' functionality, instead incorporating by reference a "preliminary claim chart attached hereto as Exhibit B" (Compl. ¶22). This exhibit was not included with the public filing. No allegations regarding the products' specific market position are made.
IV. Analysis of Infringement Allegations
The complaint’s substantive infringement allegations are contained in an unprovided exhibit (Compl. ¶22). The following table summarizes the infringement theory for claim 1 as can be inferred from the claim language and the general allegations.
No probative visual evidence provided in complaint.
'030 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a case having a longitudinal length and a front opening | The Accused Products are alleged to have an outer housing or shell with a front opening through which the USB connector extends. | ¶22 | col. 4:6-7 |
| a main body comprising a circuit board and a connector located in front of said circuit board | The Accused Products are alleged to contain an internal assembly consisting of a printed circuit board and a USB connector positioned at its front. | ¶22 | col. 4:8-10 |
| said main body being positioned in said case with said connector being movable out of or retractable into said front opening of said case | The internal assembly of the Accused Products is alleged to be slidable within the housing, allowing the USB connector to move from a retracted position inside the case to an extended position outside the case. | ¶22 | col. 4:11-14 |
| a push member being connected to said main body in the manner of interference fit and exposed from said case | The Accused Products are alleged to have an external slider or button (push member) that is connected to the internal slidable assembly via a mechanism that constitutes an "interference fit." | ¶22 | col. 4:15-17 |
| whereby by pushing said push member forward or rearward, said connector of said main body is brought to project from or retract into said case... | Pushing the external slider on the Accused Products is alleged to cause the internal USB connector to extend from or retract into the housing. | ¶22 | col. 4:18-21 |
- Identified Points of Contention:
- Scope Questions: A central dispute may concern the meaning of "in the manner of interference fit." The question for the court will be whether the specific mechanism connecting the slider to the internal circuit board in the Accused Products falls within the scope of this term as it is used and described in the patent.
- Technical Questions: The complaint lacks any specific factual allegations about the internal mechanics of the Accused Products. A key evidentiary question will be what physical structure connects the external slider to the internal main body in the "Wallpaper" drive and whether that structure functions as an "interference fit" as claimed.
V. Key Claim Terms for Construction
- The Term: "in the manner of interference fit"
- Context and Importance: This term defines the required connection between the external push member and the internal main body. Its construction is critical because it will likely determine whether the mechanism used in the Accused Products—and potentially many other commercially available sliding USB drives—meets this limitation. Practitioners may focus on this term because it is a specific technical requirement at the heart of the invention's claimed structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not define the term, and a party may argue for its plain and ordinary meaning in mechanical engineering, which could encompass a range of connections where friction between components prevents sliding. The summary of the invention also uses the term without tying it to a single structure (’030 Patent, col. 2:5-7).
- Evidence for a Narrower Interpretation: The specification describes a specific embodiment where the "interference fit" is formed by a "hole 311 fitly engaged with the raised electronic element 221 on the circuit board 22" (’030 Patent, col. 2:55-58). A party may argue that this detailed disclosure limits the claim term to this specific type of mechanical interlock, rather than a more general friction-based connection.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement with prior knowledge of the ’030 Patent, asserting Defendant induced infringement by selling products that embody the invention (Compl. ¶30). The complaint does not plead specific facts explaining how Defendant encouraged infringing acts by others (e.g., through user instructions or advertising).
- Willful Infringement: The complaint alleges willful infringement based on Defendant having "actual knowledge of the ’030 Patent...at least since receiving pre-suit notice" (Compl. ¶24). This allegation appears to be based on conduct occurring after Defendant was notified of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "in the manner of interference fit," which is exemplified in the patent as a specific physical interlock (a hole engaging a raised element), be construed broadly enough to read on the actual connection mechanism used in the accused "Wallpaper" flash drive?
- A key evidentiary question will be one of technical fact: what is the precise mechanical structure connecting the external slider to the internal components of the accused product? As the complaint provides no technical details, the outcome may depend heavily on evidence uncovered during discovery regarding the product's design and operation.