DCT

1:24-cv-00576

John Mezzalingua Associates LLC v. Amphenol Corp

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-00576, D. Del., 05/13/2024
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Amphenol Corporation is a Delaware corporation and therefore resides in the district for venue purposes, and Defendant Changzhou Amphenol Fuyang Communication Equipment Co., Ltd. is not a resident of the United States.
  • Core Dispute: Plaintiff alleges that Defendant’s radio frequency compression connectors infringe five U.S. patents related to coaxial cable connector technology designed to ensure reliable, field-installable connections.
  • Technical Context: The technology concerns specialized connectors for coaxial cables, which are critical components in wireless communications infrastructure such as cellular towers, where secure and electrically stable connections are essential for network performance.
  • Key Procedural History: The complaint alleges that Defendants have been aware of the patented technology since at least 2014, when a U.S. Patent and Trademark Office examiner rejected claims in one of Defendants’ own patent applications by citing the parent patent to the patents-in-suit. This event is asserted as a basis for willful infringement.

Case Timeline

Date Event
2010-04-02 Earliest Patent Priority Date for all Patents-in-Suit
2013-03-05 U.S. Patent No. 8,388,375 Issues
2013-11-26 U.S. Patent No. 8,591,253 Issues
2013-11-26 U.S. Patent No. 8,591,254 Issues
2013-12-10 U.S. Patent No. 8,602,818 Issues
2014-04-29 U.S. Patent No. 8,708,737 Issues
2014 Defendant allegedly becomes aware of parent patent to Patents-in-Suit during prosecution of its own patent
2024-05-13 Complaint Filed

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

U.S. Patent No. 8,591,253 - "Cable Compression Connectors"

The Invention Explained

  • Problem Addressed: The patent addresses difficulties with field-installable coaxial cable connectors used in applications like cellular towers (Compl. ¶22). Such connectors can suffer from inconsistent impedance matching and passive intermodulation (PIM), which degrades signal quality. Pre-fabricated "jumper" cables with factory-installed connectors offer better performance but are inconvenient and wasteful due to their fixed, standard lengths. (’253 Patent, col. 2:21-42; Compl. ¶23).
  • The Patented Solution: The invention is a field-installable compression connector designed to improve impedance matching and mechanical contact (’253 Patent, col. 2:48-56). The solution involves preparing the cable end by creating an "increased-diameter cylindrical section" of the outer conductor. The connector itself features an internal structure (e.g., a mandrel) and an external structure (e.g., a clamp) that define a gap to receive this widened section. During installation, moving the connector from an open to an engaged position causes the external structure to radially compress the widened cable section against the internal structure, creating a secure connection. (’253 Patent, Abstract; col. 3:1-8).
  • Technical Importance: This approach seeks to combine the high performance and reliability of factory-installed connectors with the flexibility of using custom-length cables in the field. (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts at least dependent Claim 44, which depends from independent Claim 21. (Compl. ¶35).
  • The essential elements of independent Claim 21 include:
    • a first connector structure;
    • a second connector structure that cooperates with the first to define a gap for receiving a portion of a cable's outer conductor;
    • a conductive pin for engaging the cable's inner conductor; and
    • wherein the second connector structure is configured to clamp and radially compress the outer conductor portion within the gap when the connector is moved from a first position to a second position, increasing the contact force between the pin and the inner conductor. (’253 Patent, col. 19:58-20:22).
  • The complaint notes this is an exemplary claim and does not limit its infringement contentions. (Compl. ¶35).

U.S. Patent No. 8,591,254 - "Compression Connector for Cables"

The Invention Explained

  • Problem Addressed: The patent identifies the same technical problems as the ’253 Patent: PIM and inconsistent impedance in field-installable coaxial cable connectors, and the inconvenience of pre-fabricated jumper cables. (’254 Patent, col. 2:1-54).
  • The Patented Solution: The patented solution is a compression connector comprised of cooperative components that compress a portion of a cable's outer conductor to ensure a reliable connection. The claims focus on a "first connector component" and a "second connector component" that define a space to receive the outer conductor, and which compress it upon moving the connector from a first to a second position. A key feature is that this movement also causes the conductive pin to radially expand to engage the inner conductor, increasing the contact force. (’254 Patent, Abstract; col. 3:5-4:4).
  • Technical Importance: The invention aims to provide a robust, field-installable connector that maintains signal integrity and mechanical stability, comparable to factory-terminated cables. (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts at least Claim 37, which is an independent claim. (Compl. ¶40).
  • The essential elements of independent Claim 37 include:
    • a first connector component comprising a first surface;
    • a second connector component comprising a second surface, which cooperates with the first to define a space to receive a portion of an outer conductor and compress it when the connector is moved from a first to a second position via a sliding movement; and
    • a conductive pin that engages the inner conductor, wherein the contact force increases and the pin is radially expanded to engage the inner conductor as the connector is moved to the second position. (’254 Patent, col. 22:4-39).
  • The complaint notes this is an exemplary claim and does not limit its infringement contentions. (Compl. ¶40).

U.S. Patent No. 8,602,818 - "Compression Connector for Cables"

  • Patent Identification: U.S. Patent No. 8,602,818, "Compression Connector for Cables," Issued December 10, 2013. (Compl. ¶17).
  • Technology Synopsis: The patent describes a compression connector for coaxial cables designed to mitigate PIM and impedance mismatch issues common in field installations. The technology centers on the mechanical interaction of connector members that compress a prepared portion of the cable's outer conductor to create a secure electrical and physical bond. (’818 Patent, Abstract).
  • Asserted Claims: At least Claim 46. (Compl. ¶45).
  • Accused Features: The complaint accuses the overall mechanical structure of the Accused Products, including the internal and external components that engage and compress the outer conductor of a coaxial cable. (Compl. ¶¶29-30).

U.S. Patent No. 8,388,375 - "Coaxial Cable Compression Connectors"

  • Patent Identification: U.S. Patent No. 8,388,375, "Coaxial Cable Compression Connectors," Issued March 5, 2013. (Compl. ¶18).
  • Technology Synopsis: The patent is directed to a connector for terminating a corrugated coaxial cable. The invention features a "mandrel" and a "clamp" that define a gap to receive a "widened section" of the corrugated outer conductor. As the connector is compressed, the clamp radially compresses this widened section against the mandrel. (’375 Patent, col. 3:10-30).
  • Asserted Claims: At least Claim 12. (Compl. ¶50).
  • Accused Features: The complaint targets the internal mandrel and clamp structure of the Accused Products, which are alleged to engage and radially compress the outer conductor of a coaxial cable. (Compl. ¶¶26, 30).

U.S. Patent No. 8,708,737 - "Cable Connectors Having a Jacket Seal"

  • Patent Identification: U.S. Patent No. 8,708,737, "Cable Connectors Having a Jacket Seal," Issued April 29, 2014. (Compl. ¶19).
  • Technology Synopsis: This patent focuses on a cable connector featuring a distinct jacket seal component. The invention describes moving the connector from a first to a second position, which causes the jacket seal to be compressed and to engage the outer jacket of the cable, providing a weather seal and cable retention. (’737 Patent, Abstract; Compl. ¶26).
  • Asserted Claims: At least Claim 1. (Compl. ¶55).
  • Accused Features: The complaint accuses the jacket seal component of the Accused Products and the overall connector mechanism that compresses this seal against the cable jacket during installation. (Compl. ¶¶26, 30).

III. The Accused Instrumentality

Product Identification

  • Radio frequency compression connectors bearing model numbers AFA297-1, AFDF07-1, and AFDF07-2. (Compl. ¶3).

Functionality and Market Context

  • The Accused Products are field-installable connectors for terminating coaxial cables used in wireless communication systems. (Compl. ¶¶3, 22). The complaint alleges that although the models may differ based on the type of cable they are used with, they are "identical in terms of how they operate." (Compl. ¶29). A table in the complaint provides cross-section photographs of all three models in both "Open Position" and "Closed Position," illustrating their internal mechanics before and after compression. (Compl. p. 8). A labeled diagram, using model AFDF07-1 as a representative example, identifies key components including a nut, body, mandrel, clamp, conductive pin, compression sleeve, and jacket seal. (Compl. p. 9). Plaintiff alleges these products are sold in the United States in direct competition with its own connector products. (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided; this analysis summarizes the infringement theory based on the complaint's narrative and visual allegations.

’253 Patent Infringement Allegations

Claim Element (from Independent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
a first connector structure The connector's internal components, such as the mandrel, which is inserted into the prepared end of the coaxial cable. ¶¶26, 30 col. 8:52-54
a second connector structure that cooperates with the...first connector structure to define a gap that is configured to receive a portion of an outer conductor The connector’s external components, such as the clamp and body, which surround the mandrel and define a space for the cable's outer conductor. ¶¶26, 30 col. 8:55-57
a conductive pin configured to engage an inner conductor of the cable A conductive pin component that receives the cable's center conductor upon insertion. ¶¶26, 30 col. 8:46-48
the second connector structure is configured to be clamped...and radially compress the portion of the outer conductor...when the connector is moved from a first position to a second position The compression sleeve moves axially, forcing the clamp and other components to press inward and compress the outer conductor against the mandrel, as depicted in the "Open" vs. "Closed" position images. ¶¶29, 30 col. 10:15-34

’254 Patent Infringement Allegations

Claim Element (from Independent Claim 37) Alleged Infringing Functionality Complaint Citation Patent Citation
a first connector component comprising a first surface Internal components of the connector, such as the mandrel. ¶¶26, 30 col. 22:5-6
a second connector component comprising a second surface... to compress the received portion of the outer conductor when the connector is moved from a first position to a second position External components of the connector, such as the clamp, that are moved during installation to compress the cable's outer conductor. ¶¶29, 30 col. 22:7-14
a conductive pin configured to engage an inner conductor...wherein a contact force between the conductive pin and the inner conductor increases... The conductive pin which makes electrical contact with the cable's center conductor. ¶¶26, 30 col. 22:15-20
and wherein the conductive pin is configured to be radially expanded as the connector moves from the first position to the second position to radially engage the inner conductor. The complaint alleges infringement of this claim element, but does not provide specific factual allegations or visual evidence detailing a mechanism for radial expansion of the conductive pin. ¶40 col. 10:48-56

Identified Points of Contention

  • Scope Questions: The patents’ specifications describe preparing a cable by creating a "widened section" of the outer conductor (’253 Patent, col. 7:10-14). The complaint alleges infringement through structural similarity but does not describe the installation process for the Accused Products. An issue may arise as to whether the Accused Products are used with, or instruct users to create, such a "widened section" as required to practice the claimed invention.
  • Technical Questions: What evidence does the complaint provide that the Accused Product’s conductive pin performs the specific function of being "radially expanded" as required by Claim 37 of the ’254 Patent? The complaint's visual evidence focuses on the compression of the outer conductor, not a specific expansion mechanism of the inner conductive pin.

V. Key Claim Terms for Construction

The Term: "first connector structure" / "second connector structure" (and similar "component" terms)

  • Context and Importance: These terms define the fundamental interacting parts of the claimed connectors. Their construction will be critical to determining if the components of the Accused Products map onto the claim elements. Practitioners may focus on these terms because their potential ambiguity could be a central point of non-infringement or invalidity arguments.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification provides examples, stating, "The mandrel 290 is an example of an internal connector structure... The clamp 300 is an example of an external connector structure." (’253 Patent, col. 8:52-57). This language may support a broad functional interpretation where any internal/external component pair that performs the claimed compression meets the limitation.
    • Evidence for a Narrower Interpretation: Defendants may argue the terms should be limited to the specific embodiments shown, such as the distinct, multi-part mandrel and clamp depicted in the patent figures. (’253 Patent, Fig. 2C). They could contend that a connector with a different or more integrated structure does not have the claimed "first" and "second" structures.

The Term: "radially compress"

  • Context and Importance: This term describes the core mechanical action of the invention. The dispute will likely focus on whether the force applied by the Accused Products is functionally and structurally the same as that claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the outcome as clamping the outer conductor "so as to radially compress" it between two surfaces. (’253 Patent, Abstract). This may support reading the term to cover any mechanism that results in squeezing the outer conductor from the outside inward.
    • Evidence for a Narrower Interpretation: The patent repeatedly discusses preparing a "cylindrical section" of the outer conductor to be compressed, and describes a force that is "primarily a radial component and having substantially no axial component." (’253 Patent, col. 10:29-32). This could support a narrower construction requiring a specific type of uniform, inward-directed force, as distinct from other connection methods like crimping or swaging that might involve different force vectors.

VI. Other Allegations

  • Willful Infringement: The complaint alleges willful infringement based on both pre-suit and post-suit knowledge. The basis for pre-suit knowledge is an allegation that Defendants became aware of the parent patent to the patents-in-suit (U.S. Patent No. 7,934,954) at least as early as 2014, when it was cited by a USPTO Examiner during the prosecution of one of Defendants’ own patent applications. (Compl. ¶32).

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

  • A core issue will be one of operational method: Does infringement require not only structural similarity but also use of the patented method of preparing the cable (i.e., creating a "widened section" of the outer conductor)? The case may turn on evidence of how the Accused Products are actually installed in the field or how Defendants instruct users to install them.
  • A key evidentiary question will be one of functional proof: For claims requiring specific mechanical actions, such as the "radial expansion" of the conductive pin in the ’254 Patent, what technical evidence will be presented to demonstrate that the accused connectors perform these precise functions, beyond the general structural similarities shown in the complaint's photographs?
  • A central question for willfulness will be one of imputed knowledge: Can Plaintiff establish that Defendants’ alleged knowledge of a parent patent during their own patent prosecution in 2014 gave them actual knowledge of the claims of five different patents that issued between 2013 and 2014, sufficient to meet the standard for pre-suit willful infringement?