Creekview IP LLC v. Corsair Gaming Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Creekview IP LLC (Texas)
  • Defendant: Corsair Gaming, Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm, P.A.
• Case Identification: 1:21-cv-01685, D. Del., 11/30/2021
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a corporation organized under the laws of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s wireless charging mouse pad infringes a patent related to methods for wirelessly transferring power to, and communicating with, electronic devices.
• Technical Context: The technology at issue concerns wireless power transfer systems, a field significant for consumer electronics seeking to eliminate charging cables for devices such as smartphones and computer peripherals.
• Key Procedural History: The patent-in-suit is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in its family. The complaint does not specify any other prior litigation or administrative proceedings.

Case Timeline

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

U.S. Patent No. 9,608,472 - METHOD AND APPARATUS FOR WIRELESSLY TRANSFERRING POWER AND COMMUNICATING WITH ONE OR MORE SLAVE DEVICES

• Patent Identification: U.S. Patent No. 9,608,472, issued March 28, 2017.

The Invention Explained

• Problem Addressed: The patent’s background section describes the limitations of then-existing wireless power technologies, noting that non-resonant induction requires very close proximity and that both resonant and non-resonant induction methods are non-directive, irradiating the surrounding space and using low frequencies unsuitable for high-speed communication (’472 Patent, col. 1:25-44).
• The Patented Solution: The invention proposes a system comprising a "master device" and a "slave device" that uses radio frequency (RF) signals, particularly at high frequencies such as 60 GHz, to both charge and communicate with slave devices (’472 Patent, col. 2:4-10). The system employs directional antennas to focus the RF energy, which purports to increase efficiency, enable simultaneous power and data transfer, and reduce unintended human exposure compared to inductive methods (’472 Patent, col. 2:11-28; Fig. 2).
• Technical Importance: This approach sought to unify wireless charging and high-speed data transfer into a single, efficient system, addressing a key challenge in the design of portable consumer electronics (’472 Patent, col. 1:62-64).

Key Claims at a Glance

• The complaint asserts independent method claim 19 and notes in its prayer for relief that Defendant has infringed "at least claim 19" (Compl. ¶14; Prayer for Relief ¶A).
• The essential elements of independent claim 19, a method performed by a slave device, are:
  • transmitting a slave device identification to the master device for determining authorization to wirelessly receive energy from the master device;
  • wirelessly receiving, in response to transmitting the slave device identification to the master device, energy from the master device; and
  • generating power from the wireless energy received from the master device for use by a set of electronic circuitry of the slave device.

III. The Accused Instrumentality

Product Identification

• The Corsair MM1000 Qi® Wireless Charging Mouse Pad (the "Accused Product") (Compl. ¶11).

Functionality and Market Context

• The complaint alleges the Accused Product is a mouse pad that incorporates Qi-standard wireless charging, allowing users to charge any Qi-compatible device on their desktop (Compl. ¶12). The complaint provides a screenshot from Defendant's website illustrating the product as a mouse pad with a dedicated circular charging zone (Compl. p. 3). The infringement theory is predicated on the operation of the Accused Product in conjunction with compatible Qi devices, where the Accused Product acts as a "power transmitter" (master device) and the Qi-compatible device acts as a "power receiver" (slave device) pursuant to the Qi standard (Compl. ¶13, ¶15).

IV. Analysis of Infringement Allegations

'472 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A primary question may be whether the patent's claims, read in light of a specification that heavily emphasizes high-frequency RF beamforming, can be construed to cover the low-frequency inductive charging used by the accused Qi-standard product. The complaint alleges infringement by a product operating under the Qi standard, which typically relies on technology distinct from the high-frequency RF systems detailed in the patent specification.
• Technical Questions: The complaint asserts direct infringement of method claim 19, which recites steps performed by a "slave device" (e.g., a Qi-compatible phone). The defendant, Corsair, manufactures the "master device" (the mouse pad). This raises the legal question of how Corsair directly infringes a method claim performed by a separate product. The complaint alleges Corsair performed the method "at least when the Accused Product was tested by Defendant," which suggests a theory of infringement based on Corsair's own internal testing activities (Compl. ¶14).

V. Key Claim Terms for Construction

The Term: "wirelessly receiving ... energy"

• Context and Importance: The definition of this term is central to the dispute. The case may turn on whether "energy" as claimed is limited to the high-frequency, directional RF beams described throughout the patent's specification or if it is broad enough to encompass the low-frequency, non-resonant inductive coupling employed by the accused Qi-standard product.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is facially broad. Furthermore, the detailed description mentions that the channel for power transfer "in some embodiments is RF or electro-magnetic induction" and that the invention may use "different methods (RF Beam and induction)," which may support an interpretation that covers both technologies (’472 Patent, col. 3:39-44).
  • Evidence for a Narrower Interpretation: The patent's background section explicitly frames the invention as a solution to the problems of induction-based charging, such as its non-directive nature and inability to support high-speed communication (’472 Patent, col. 1:25-44). A party might argue that the specification as a whole defines the invention by its improvements over induction, thereby limiting the scope of "energy" to the novel RF-based approach.

The Term: "slave device identification... for determining authorization"

• Context and Importance: The complaint alleges the Qi standard's handshake protocol satisfies this limitation (Compl. ¶15). Practitioners may focus on whether this protocol constitutes "determining authorization" as contemplated by the patent, or if it is merely a technical compatibility check.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent provides a non-exhaustive list for "identifying information" that includes "MAC ID, network Internet protocol (IP) address, name, serial number, product name and manufacturer, capabilities, etc.," which could suggest flexibility in what constitutes an "identification" (’472 Patent, col. 3:63-67).
  • Evidence for a Narrower Interpretation: The specification repeatedly discusses checking the slave's identification against an "authorized list" stored in a database, which suggests a security or access-control function beyond a simple handshake for technical compatibility (’472 Patent, col. 4:1-7, col. 12:7-27). A party could argue that the Qi protocol does not perform this type of "authorization."

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant encourages its customers to infringe claim 19 by providing the Accused Product along with "downloadable instructional guides on how to use" it with Qi-compatible devices (Compl. ¶17, ¶19).
• Willful Infringement: The complaint alleges Defendant has had knowledge of the ’472 Patent "since at least the filing of this complaint" and seeks enhanced damages for willful infringement based on continued alleged infringement post-filing (Compl. ¶18; Prayer for Relief ¶B).

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

• A core issue will be one of technological scope: can the claims, interpreted in light of a specification that extensively details a high-frequency RF beamforming system as an improvement over prior art, be construed to cover the low-frequency inductive coupling technology of the accused Qi-standard product?
• A key legal question will be one of direct infringement liability: can the plaintiff demonstrate that the defendant, as the manufacturer of the "master device," is directly liable for infringing a method claim whose steps are performed by a separate "slave device," and will the plaintiff's theory of infringement based on the defendant's internal product testing be sufficient to establish this liability?