DCT
1:23-cv-00898
Platinum Tools LLC v. Klein Tools Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Platinum Tools, LLC (California)
- Defendant: Klein Tools, Inc. (Delaware)
- Plaintiff’s Counsel: McCarter & English, LLP
- Case Identification: 1:23-cv-00898, D. Del., 08/16/2023
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Klein Tools, Inc. is a Delaware corporation and therefore resides in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "Pass-Thru" line of electrical connectors infringes a patent related to pass-through RJ45-style connectors featuring a sacrificial external load bar for improved termination.
- Technical Context: The technology concerns modular electrical connectors (e.g., RJ45 for Ethernet cables) that allow wires to pass completely through the connector body for easier visual inspection and termination.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with actual notice of infringement via a letter dated May 9, 2023, approximately three months prior to filing the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2013-08-19 | Priority Date for U.S. Patent No. 10,573,990 |
| 2020-02-25 | U.S. Patent No. 10,573,990 Issued |
| 2023-05-09 | Plaintiff allegedly sent notice letter to Defendant |
| 2023-08-16 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,573,990 - Electrical Connector with External Load Bar, and Method of Use (issued Feb. 25, 2020)
The Invention Explained
- Problem Addressed: The patent’s background section describes problems with prior art pass-through connectors where the forces applied during the crimping and wire-shearing process could distort the plastic connector housing, a potential compromising the connection’s integrity and compliance with industry standards. Additionally, some prior art systems required technicians to manually cut some of the wires after the primary crimping operation (’990 Patent, col. 3:25-54).
- The Patented Solution: The invention introduces a connector with a "thickened front end wall," referred to as an "External Load Bar" or "Stiffener," which is formed as an integral part of the connector's forward face (’990 Patent, Abstract; col. 4:62-63). This stiffener provides mechanical support to the connector housing during the crimping process. In a single action, a specialized tool shears off both the excess wire ends and the entire stiffener, leaving a properly dimensioned connector with all wires cut flush (’990 Patent, col. 4:30-40). This design is intended to prevent housing distortion while simultaneously terminating all eight wires.
- Technical Importance: This approach was designed to improve the reliability of field terminations for high-speed data cables (e.g., CAT 6A), where precise wire positioning and connector dimensions are critical for maintaining signal integrity and performance (’990 Patent, col. 5:11-19).
Key Claims at a Glance
- The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶18).
- Essential elements of Claim 1 include:
- A housing with a channel for wires.
- An "extension portion" that extends from the housing's front wall.
- A plurality of holes for the wires arranged in rows through the front wall.
- The "extension portion" is specifically positioned "below the lowermost row" of holes.
- The "extension portion" is sized to accommodate "posts on a cutting tool."
- The extension portion and the tool's posts act together as a "cutting surface" for a blade that shears the wires.
III. The Accused Instrumentality
Product Identification
- The accused products are Klein Tools’ "Pass-Thru" brand of electrical connectors, including product numbers VDV826-764, VDV826-705, VDV826-702, and others (Compl. ¶15). The complaint also implicates the use of Klein Tools’ specialty crimping tool (VDV226-110) with these connectors (Compl. ¶16).
Functionality and Market Context
- The complaint alleges the Accused Products are pass-through RJ45 connectors that allow wires to be fed through the connector face for easier alignment (Compl. ¶14). It further alleges that once the wires are fed through, they are "simultaneously cut by specialty tools such as crimp tools" (Compl. ¶14). The complaint positions these products as direct competitors to the Plaintiff's own ezEX® line of connectors (Compl. ¶1, ¶15).
IV. Analysis of Infringement Allegations
The complaint references, but does not include, a claim chart (Exhibit E) detailing infringement of Claim 1 (Compl. ¶18). The following summary is based on the narrative allegations in the complaint.
’990 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing having a first end and a second end, with a channel extending from an opening in the second end towards a wall of the front end... | The Accused Products are described as RJ45-style electrical connectors with a housing into which wires are fed (Compl. ¶14). | ¶1, ¶14 | col. 7:34-37 |
| an extension portion extending from the wall of the front end, with the wall of the front end including a plurality of holes...that extend through the wall of the front end... | The Accused Products are alleged to be a "pass-through...design which allows for a user to feed wires through the connectors" (Compl. ¶14). | ¶14, ¶15 | col. 7:38-43 |
| with the extension portion being positioned below the lowermost row of the rows... | The complaint does not provide sufficient detail for analysis of the specific position of the alleged "extension portion" relative to the wire holes. | N/A | col. 7:43-45 |
| with the extension portion being sized to accommodate posts on a cutting tool...such that the extension portion and posts act as a cutting surface for a blade that shears each wire extending through each hole | The complaint alleges that protruding wire ends from the Accused Products are "simultaneously cut by specialty tools such as crimp tools" and that Klein Tools provides instructions for this specific use (Compl. ¶14, ¶16). | ¶14, ¶16 | col. 7:45-53 |
| wherein, the channel is sized to accommodate a cable including a plurality of wires with each wire engaging a corresponding hole in the wall of the front end. | The Accused Products are identified as connectors for telecommunications and data communications equipment, which use multi-wire cables (Compl. ¶1, ¶15). | ¶1, ¶15 | col. 7:54-58 |
Identified Points of Contention
- Structural Questions: A primary factual dispute may be whether the accused connectors have a structure that meets the definition of the claimed "extension portion." Specifically, the analysis will question whether the accused connectors possess a distinct, sacrificial structure that is "positioned below the lowermost row" of wire holes, as strictly required by the claim language.
- Functional Questions: Infringement appears to depend on the interaction between the accused connector and its associated crimping tool. A key question will be whether the Klein Tools crimper (VDV226-110) operates with "posts" that become "co-planer" with a part of the connector to form a "cutting surface" for the blade, as recited in Claim 1. The complaint’s allegation that wires are "simultaneously cut" suggests this possibility (Compl. ¶14).
V. Key Claim Terms for Construction
- 1. "extension portion"
- Context and Importance: This term is the central feature of the invention, synonymous with the "Stiffener" or "External Load Bar" described in the specification. The existence, structure, and location of this feature on the accused connectors will likely be the core of the infringement dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the feature as a "thickened front end wall" and a "Stiffener," which could support an argument that any integrally molded, sacrificial front piece designed to provide support during crimping falls within the term's scope (’990 Patent, col. 4:62-63).
- Evidence for a Narrower Interpretation: Claim 1 explicitly limits this portion as being "positioned below the lowermost row of the rows [of holes]" (’990 Patent, col. 7:43-45). The specific embodiments consistently show this feature as an integral lower part of the connector's front face, which may support a narrower construction limited to that specific geometry (’990 Patent, Fig. 5-6; col. 6:46-51).
- 2. "posts on a cutting tool" and "co-planer with a top surface of the extension portion"
- Context and Importance: These related terms define the required functional relationship between the connector and the tool used to terminate it. Practitioners may focus on these terms because they tie the apparatus claim to a specific method of use, making infringement dependent not just on the connector's structure but on the design of the tool it is used with.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "posts" could refer to any raised surfaces on the tool's anvil that support the connector, and "co-planer" could mean generally level, without requiring perfect mathematical planarity.
- Evidence for a Narrower Interpretation: The patent describes modifying a prior art tool to "provide two small posts that extend the ends of anvil 42" (’990 Patent, col. 7:11-13). Figure 8 schematically shows a specific interaction where the tool (via anvil 42/400) and the connector's bottom surface (104) create a defined cutting plane for the blade (60). This could support a narrower definition requiring a specific geometric alignment between discrete posts and the extension portion's top surface.
VI. Other Allegations
- Indirect Infringement: The complaint alleges active inducement of infringement under 35 U.S.C. § 271(b). The factual basis is Defendant's alleged provision of video instructions on its website that instruct consumers to use the Accused Products with a specialty crimping tool in a manner that allegedly performs the final, infringing step of simultaneously cutting the wires (Compl. ¶16). The complaint states a screenshot of this website is attached as Exhibit D (Compl. ¶16).
- Willful Infringement: The complaint alleges willful infringement based on two grounds: (1) constructive notice via Plaintiff’s marking of its own products with the ’990 Patent number, pursuant to 35 U.S.C. § 287(a) (Compl. ¶21); and (2) actual notice provided by a letter sent to Klein Tools on May 9, 2023, which allegedly informed Defendant of its infringement (Compl. ¶21, ¶27).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural correspondence: Do the accused "Pass-Thru" connectors possess a distinct, sacrificial "extension portion" that is located entirely "below the lowermost row" of wire holes, as strictly defined by Claim 1, or is their physical structure materially different from that claimed?
- A key evidentiary question will be one of relational functionality: Does the interaction between the accused Klein connector and its designated crimping tool meet the claim requirement that "posts on a cutting tool" become "co-planer" with the connector's extension portion to form a unified "cutting surface" for a shearing blade? The case may turn on whether the accused system operates in this specific manner.