DCT

1:18-cv-02053

Universal Transdata LLC v. Lenovo United States Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Universal Transdata, LLC v. Lenovo (United States), Inc., 1:18-cv-02053, D. Del., 12/27/2018
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware on the basis that Defendant is incorporated in the State of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless keyboard and mouse combination products infringe a patent related to a wireless Universal Serial Bus (USB) hub system for communicating with remote peripheral devices.
  • Technical Context: The technology concerns the architecture for connecting multiple wireless computer peripherals, such as keyboards and mice, to a computer through a single USB-connected receiver, eliminating the need for direct cable connections.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with pre-suit notice of the asserted patent and its alleged infringement, which may form the basis for the willfulness allegation.

Case Timeline

Date Event
1999-08-11 ’114 Patent Priority Date (Provisional App.)
2006-04-11 ’114 Patent Issue Date
2018-12-27 Complaint Filing Date

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

  • Patent Identification: 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 addresses the limitation of prior art USB hubs which required peripheral devices to be physically connected to the hub via cables ('114 Patent, col. 1:49-54). The stated goal was to create a USB hub capable of communicating with multiple remote wireless peripherals without physical cable connections ('114 Patent, col. 1:55-59).
  • The Patented Solution: The invention describes a system comprising one or more remote wireless peripherals (e.g., keyboard, mouse) and a wireless USB hub. The peripherals transmit device information via RF signals to the hub, which contains a receiver and a "hub controller." This controller converts the received wireless signal into a standard USB data signal and passes it to the computer via an upstream USB port ('114 Patent, Abstract; col. 3:1-14). Figure 2 illustrates an embodiment where separate receiver channels (47a, 47b, 47c) handle signals from different peripherals, which are then processed and sent to the hub controller (42).
  • Technical Importance: The described technology provided a blueprint for unifying the connection of multiple, distinct wireless input devices to a single point on a computer, simplifying the hardware architecture compared to needing a separate receiver for each device.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 3, and 9, as well as dependent claims 2, 4, 5, and 6 (Compl. ¶23).
  • Independent Claim 1: A system comprising:
    • A single remote wireless peripheral device (one of a keyboard, mouse, or joystick) with an integral RF transmitter as its "sole means for communicating."
    • The peripheral device does not have "any USB communication capability."
    • A "Universal Serial Bus (USB) hub" with an upstream port and a "hub controller."
    • The hub controller "converts said wireless signal to a USB data signal."
  • Independent Claim 3: A system comprising:
    • A single remote wireless peripheral device with an integral RF transmitter as its "sole means for communicating."
    • The peripheral device does not have "any USB communication capability."
    • A "Universal Serial Bus (USB) hub" with an upstream port and a "hub controller."
    • The hub controller "converts said wireless signal to a USB data signal."
  • Independent Claim 9: A system comprising:
    • "at least two remote wireless peripheral devices" including a keyboard and a mouse, each with an integral RF transmitter.
    • A "data reception circuit for receiving said wireless signals from said RF transmitters."
    • An "upstream USB port."
    • A "hub controller" that "converts each of said wireless signals to a USB data signal."

III. The Accused Instrumentality

  • Product Identification: The accused products are Defendant's "Ultraslim Plus Wireless Keyboard & Mouse" and products identified by part numbers 4X30H56796, 0A34032, GX30N81775, GX30N71805, 4X30M39458, and 4X30M3947,1 (Compl. ¶24).
  • Functionality and Market Context: The complaint describes the accused products as embodying the patented invention, which implies they consist of a wireless keyboard and mouse that communicate with a computer via a single USB receiver/dongle (Compl. ¶¶ 24-25). The complaint alleges these products are sold through various online and physical retailers, including Defendant's own website and Amazon.com (Compl. ¶4). The complaint does not provide further technical details on the operation or architecture of the accused products' internal circuitry.

IV. Analysis of Infringement Allegations

The complaint references an "exemplary preliminary claim chart attached hereto as Exhibit B" to detail its infringement allegations but does not include the exhibit itself (Compl. ¶25). The narrative infringement theory is that the accused wireless keyboard and mouse systems "satisfy each and every element of each asserted claim" of the ’114 Patent (Compl. ¶25). The core of this allegation is that the accused keyboard and mouse function as the claimed "remote wireless peripheral devices" and that the accompanying USB dongle functions as the claimed "Universal Serial Bus (USB) hub" that receives and converts the wireless signals (Compl. ¶¶ 12, 24-25).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A principal issue may be whether the accused USB dongle, which is typically a small, single-purpose receiver, meets the definition of a "Universal Serial Bus (USB) hub" as used in the patent. The specification describes the hub as including "a plurality of optional conventional downstream USB ports" (e.g., element 45 in Fig. 2), a feature a typical dongle lacks ('114 Patent, col. 3:12-14). The interpretation of "hub" could therefore be a central point of dispute.
    • Technical Questions: The claims require a "hub controller" that is connected between a "data reception circuit" and the "upstream USB port" ('114 Patent, col. 9:11-14). It is a question of fact whether the integrated system-on-a-chip (SoC) architecture common in modern USB dongles contains the specific, discrete functional blocks as claimed, or if its integrated nature creates a technical mismatch with the claimed structure.

V. Key Claim Terms for Construction

  • The Term: "Universal Serial Bus (USB) hub" (from independent claims 1, 3, 9)
  • Context and Importance: The infringement case hinges on whether the USB dongle supplied with the accused keyboard and mouse is properly classified as a "USB hub." If it is not, the claims would not read on the accused system. Practitioners may focus on this term because its definition—whether it requires features like downstream ports—is likely dispositive.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims define the hub primarily by its function: having an upstream port and a controller that converts wireless signals to USB data signals ('114 Patent, col. 8:36-44). A plaintiff could argue that any device performing this core function is a "hub" for the purposes of the invention, regardless of other features.
    • Evidence for a Narrower Interpretation: The specification's detailed description repeatedly refers to an embodiment that "includes a plurality of optional conventional downstream USB ports 45" ('114 Patent, col. 3:12-14). Furthermore, Figure 1, labeled "PRIOR ART," depicts a hub (10) with four downstream ports. A defendant could argue this context limits the term "hub" to devices that provide such downstream connectivity.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant, with "prior knowledge" of the ’114 Patent, induced infringement by others (presumably end-users) who use the Accused Products (Compl. ¶33). The specific acts of inducement, such as providing instructions or user manuals, are not detailed.
  • Willful Infringement: The complaint alleges that Defendant's infringement has been and continues to be "willful and deliberate" (Compl. ¶28). The factual basis for this allegation is Defendant's alleged "actual knowledge" of the ’114 Patent, which it gained "at least since receiving pre-suit notice" from the Plaintiff (Compl. ¶27).

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

The resolution of this case will likely depend on the answers to two central questions rooted in claim construction and factual evidence.

  1. A core issue will be one of definitional scope: Can the term "Universal Serial Bus (USB) hub", as used in the ’114 patent, be construed to cover a compact, single-purpose USB receiver dongle? The outcome will depend on whether the court determines that the term, in the context of the patent, requires features like the downstream ports shown in the specification's embodiments.

  2. A key evidentiary question will be one of architectural mapping: Does the integrated circuitry of the accused Lenovo USB dongle embody the specific structural arrangement of a "data reception circuit" and a "hub controller" as distinct functional elements required by the claims, or does its modern, highly integrated design differ materially from the architecture described in the patent?