Universal Transdata LLC v. Razer USA Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Universal Transdata, LLC (Georgia)
  • Defendant: Razer USA Ltd. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC; Kent & Risley LLC
• Case Identification: 1:18-cv-00344, D. Del., 03/02/2018
• Venue Allegations: Venue is alleged to be proper in the District of Delaware on the grounds that Defendant is a Delaware corporation and therefore resides in the judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s wireless computer mice and keyboard/mouse combination products infringe a patent related to a Universal Serial Bus (USB) hub that communicates wirelessly with remote peripheral devices.
• Technical Context: The technology concerns the architecture for connecting wireless computer peripherals (like keyboards and mice) to a computer, replacing physical cables with a radio-frequency link managed by a specialized USB hub.
• Key Procedural History: The complaint alleges that Plaintiff provided Defendant with notice of the patent-in-suit and its alleged infringement prior to filing the lawsuit.

Case Timeline

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

U.S. Patent No. 7,028,114 - "Universal Serial Bus Hub with Wireless Communication to Remote Peripheral Device," issued April 11, 2006

The Invention Explained

• Problem Addressed: The patent describes a market where computer peripherals like keyboards and mice connect to a computer through a USB hub, but this connection requires physical cables. The patent identifies a need for a USB hub that can communicate with multiple remote wireless peripheral devices without requiring a physical cable connection to each peripheral (’114 Patent, col. 1:44-49).
• The Patented Solution: The invention is a system comprising one or more wireless peripheral devices (e.g., a keyboard, mouse) and a special USB hub. The peripherals wirelessly transmit data to a reception circuit in the hub. A "hub controller" within the hub then processes these wireless signals, converts them into a standard USB data format, and passes them to the computer via a single upstream USB connection (’114 Patent, Abstract; col. 2:56-65). Figure 2 illustrates this architecture, showing separate wireless peripherals (52, 54, 56) communicating with a hub (40) that contains RF receivers and a hub controller.
• Technical Importance: This approach aimed to simplify the user experience by eliminating the clutter of peripheral cables while consolidating multiple wireless connections into a single USB hub device (’114 Patent, col. 1:35-37).

Key Claims at a Glance

• The complaint asserts independent claims 1, 3, and 9 (Compl. ¶23).
• Independent Claim 1 requires a system with:
  • A remote wireless peripheral device (keyboard, mouse, or joystick) with an integral RF transmitter as its sole means of communication, and which lacks any USB communication capability.
  • A USB hub with an upstream port to connect to a computer.
  • A hub controller that connects a data reception circuit to the upstream port.
  • The hub controller "converts" the received wireless signal to a USB data signal and passes it to the computer.
• Independent Claim 3 is similar to Claim 1 but recites the peripheral device more broadly (not limited to keyboard/mouse/joystick) and does not specify that the RF transmitter is the "sole means" of communication.
• Independent Claim 9 claims a system with:
  • At least two remote wireless peripheral devices (including a keyboard and mouse) that lack USB communication capability.
  • A data reception circuit in a hub for receiving wireless signals from the peripherals.
  • A hub controller that "converts each of said wireless signals to a USB data signal."
• The complaint also asserts dependent claims 2, 4, 5, and 6, and reserves the right to assert others (Compl. ¶23).

III. The Accused Instrumentality

Product Identification

• The complaint names the "Razer Atheris Mobile Productivity/Performance Mouse" and the "Razer Turret keyboard and mouse product" as the "Accused Products" (Compl. ¶24).

Functionality and Market Context

• The complaint describes the accused products as wireless mouse products and wireless keyboard/mouse products that are made, used, sold, or imported by the Defendant (Compl. ¶23, ¶24).
• The functionality relevant to the dispute is the products' ability to wirelessly communicate user inputs (e.g., mouse movements, keystrokes) to a host computer, which the complaint alleges embodies the patented invention (Compl. ¶23, ¶25).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits B and C, but these exhibits were not attached to the publicly filed document (Compl. ¶25). The complaint makes a general allegation that the Accused Products satisfy every element of the asserted claims (Compl. ¶25). The following table summarizes the infringement theory for a representative independent claim, with citations pointing to the complaint's general allegations due to the lack of specific element-by-element mapping.

’114 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the accused USB dongle/receiver constitutes a "Universal Serial Bus (USB) hub" with a "hub controller" as those terms are used in the patent. The defense may argue the dongle is a simple transceiver, while the patent describes a more complex hub architecture (e.g., ’114 Patent, Fig. 2).
  • Technical Questions: The analysis may focus on the negative limitation that the peripheral device "not having any USB communication capability" (Claim 1). If the accused Razer mouse or keyboard can be connected via a USB cable for charging or wired operation, it could raise a significant non-infringement question. Further, the claim requires the "hub controller" to perform a "convert[ing]" function, which raises an evidentiary question of whether the accused hardware performs this specific conversion, or if the conversion is primarily handled by a software driver on the host computer.

V. Key Claim Terms for Construction

• The Term: "hub controller"

• Context and Importance: This term appears in all asserted independent claims and is the central processing component of the claimed invention. Its construction will be critical to determining whether the circuitry within the accused Razer USB dongle falls within the scope of the claims. Practitioners may focus on this term because the patent discloses specific, multi-component architectures for the controller (’114 Patent, Fig. 5), which may be distinguished from the potentially simpler architecture of a modern dongle.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims define the term functionally, requiring it to be "connected between said data reception circuit and said upstream USB port" and to "convert[] said wireless signal to a USB data signal" (e.g., ’114 Patent, col. 8:3-9). This functional language may support a construction covering any component that performs this role.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where the hub controller is a "CY7C65113 hub controller chip" and includes a distinct "serial interface engine 72" (’114 Patent, col. 4:5-7; col. 5:22-26; Fig. 5). This disclosure of a specific commercial part and internal architecture could be used to argue for a narrower definition tied to that structure.

• The Term: "not having any USB communication capability"

• Context and Importance: This negative limitation appears in Claims 1 and 9 and is a potentially dispositive issue for infringement. Many modern wireless peripherals include a USB port for charging, and whether this constitutes "USB communication capability" will be a key dispute.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: An interpretation favorable to the patentee might argue this term means the peripheral is incapable of transmitting its primary operational data (e.g., keystrokes, mouse movements) over a USB-protocol data link, distinguishing it from devices that can function in a wired USB mode.
  • Evidence for a Narrower Interpretation: An interpretation favorable to the accused infringer might argue that any ability to communicate over a USB connection, including for charging or firmware updates, constitutes "USB communication capability," thereby placing the accused products outside the claim scope if they possess such a feature. The patent does not appear to explicitly define or limit the term.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induced infringement by "making, importing, using, selling, or offering for sale" the accused products, which embody the invention (Compl. ¶33). The complaint does not plead specific facts showing active steps taken to encourage or instruct direct infringement by end-users, such as by citing to user manuals or marketing materials.
• Willful Infringement: The complaint alleges that Defendant's infringement has been willful and deliberate based on its alleged actual knowledge of the ’114 patent from a pre-suit notice letter sent by Plaintiff (Compl. ¶27, ¶28).

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

This case appears to present two central questions for the court:

1. A core issue will be one of definitional scope: can the negative limitation "not having any USB communication capability", as used in the patent, be interpreted to read on modern wireless peripherals that may include a USB port for charging or firmware updates? The resolution of this question could be dispositive for several asserted claims.

2. A key evidentiary question will be one of technical architecture: do the accused Razer products, specifically their USB dongles, embody the claimed "USB hub" containing a "hub controller" that actively "converts" a wireless signal to a "USB data signal"? Or, will evidence show the dongle is a simpler transceiver that largely passes raw data to the host computer, with the principal conversion and processing handled by software drivers, potentially placing its architecture outside the scope of the claims as understood from the patent's specification.