DCT

1:24-cv-01126

Lenovo United States Inc v. Universal Connectivity Tech Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01126, D. Del., 10/10/2024
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant UCT is a Delaware corporation and therefore resides in the district.
  • Core Dispute: Plaintiff Lenovo seeks a declaratory judgment that its consumer electronics products do not infringe eight patents owned by Defendant UCT related to data communication protocols.
  • Technical Context: The patents-in-suit relate to methods for managing, encoding, and transmitting data over high-speed serial interfaces, such as those governed by the DisplayPort and USB standards.
  • Key Procedural History: This declaratory judgment action arises from a prior lawsuit filed by UCT against Lenovo Group Limited, a corporate affiliate of Lenovo US, in the Eastern District of Texas. In that Texas case, UCT has alleged that various Lenovo US products infringe the same eight patents-in-suit and that such infringement has been willful.

Case Timeline

Date Event
2000-11-22 Earliest Priority Date (’905, ’798 Patents)
2003-06-12 Earliest Priority Date (’307 Patent)
2006-12-26 U.S. Patent No. 7,154,905 Issues
2007-03-06 U.S. Patent No. 7,187,307 Issues
2007-05-14 Earliest Priority Date (’265 Patent)
2008-01-04 Earliest Priority Date (’520, ’231 Patents)
2008-12-11 Earliest Priority Date (’712 Patent)
2010-06-29 U.S. Patent No. 7,746,798 Issues
2010-12-21 U.S. Patent No. 7,856,520 Issues
2011-03-29 U.S. Patent No. 7,921,231 Issues
2014-03-25 U.S. Patent No. 8,680,712 Issues
2014-08-29 Earliest Priority Date (’103 Patent)
2016-01-05 U.S. Patent No. 9,232,265 Issues
2017-12-26 U.S. Patent No. 9,852,103 Issues
2024-10-01 E.D. Texas court orders production of Lenovo US documents in related litigation
2024-10-10 Complaint for Declaratory Judgment filed

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

U.S. Patent No. 7,154,905 - Method and system for nesting of communications packets

The Invention Explained

  • Problem Addressed: The patent describes a bottleneck in data communications where high-speed processors and storage devices are limited by the speed of the connection between them. It notes that existing serial communication protocols like Fibre Channel can be inefficient for large data transfers due to high overhead from small packet sizes and large headers, making it difficult to transmit urgent, low-latency control information during a large data transfer. (’905 Patent, col. 1:49-col. 2:44).
  • The Patented Solution: The invention proposes a serial communication architecture that allows for "packet nesting." This technique enables a transmitting device to interrupt (or "preempt") the transmission of a large, lower-priority data packet to send a smaller, higher-priority control packet. Once the control packet is sent, the transmission of the original data packet resumes. This is managed through special "preempt" and "continue" primitives, as illustrated in the patent's figures and flowcharts. (’905 Patent, Abstract; Fig. 13; col. 20:1-19).
  • Technical Importance: This preemption mechanism allows for the timely delivery of critical control messages without waiting for large data transfers to complete, which can improve the overall responsiveness and efficiency of a storage area network. (Compl. ¶13; ’905 Patent, col. 20:1-19).

Key Claims at a Glance

The complaint does not identify specific claims asserted by UCT, stating only that UCT has alleged infringement of "one or more claims" (Compl. ¶13). Independent claims 1 and 21 are representative method and system claims, respectively.

  • Independent Claim 1 (Method):
    • receiving a first packet;
    • transmitting a portion of the first packet;
    • receiving a second packet;
    • stopping the transmission of the first packet upon receiving the second packet;
    • transmitting a preempt indicator;
    • transmitting the second packet;
    • transmitting a continue indicator after the second packet; and
    • resuming transmission of the untransmitted portion of the first packet.
  • Independent Claim 21 (Device):
    • a transmission component that transmits a first packet; and
    • a preemption component that signals the transmission component to stop, transmits a preempt indicator, transmits a second packet, and signals the transmission component to continue transmitting the first packet.

U.S. Patent No. 7,187,307 - Method and system for encapsulation of multiple levels of communication protocol functionality within line codes

The Invention Explained

  • Problem Addressed: The patent observes that traditional layered communication protocols (such as the seven-layer OSI model) can be inefficient because higher layers are firewalled from lower layers, preventing hardware at the physical level from acting on higher-level information contained within a data stream. (’307 Patent, col. 9:14-20).
  • The Patented Solution: The invention proposes a method to "collapse" functionality from multiple protocol layers into the line code itself. This is achieved by defining a data structure called a "cell" that contains not only application data but also various control bits representing different protocol layers (e.g., priority level, flow control, addressing). This cell is then encoded into a sequence of code words for physical transmission, allowing the link-layer hardware to parse and act on higher-level information without needing to pass the data up the protocol stack. (’307 Patent, Abstract; Fig. 2; col. 5:1-14).
  • Technical Importance: By embedding multi-layer protocol information directly into the physical transmission code, the invention aims to reduce latency and overhead, allowing for more efficient hardware-level processing of data streams in high-speed serial links. (’307 Patent, col. 7:26-34).

Key Claims at a Glance

The complaint does not identify specific claims asserted by UCT (Compl. ¶23). Independent claim 1 is a representative method claim.

  • Independent Claim 1 (Method):
    • coupling a first device to a second device, including a single-line, bi-directional control bus;
    • conducting arbitration for control of the control bus;
    • if the first device obtains control, it becomes an "initiator";
    • converting one or more control signals for a standard protocol into one or more data packets; and
    • transmitting the generated data packets from the initiator to the follower via the control bus.

U.S. Patent No. 7,746,798 - Method and system for integrating packet type information with synchronization symbols

  • Technology Synopsis: This patent describes a system where special synchronization symbols, used to maintain signal timing on a serial link, are also encoded with information about the type of data packet that follows (e.g., control packet vs. data packet). This allows a receiving device's link layer to immediately identify the packet type without having to first parse the packet's header, potentially reducing processing latency.
  • Asserted Claims: "one or more claims of the '798 Patent." (Compl. ¶33).
  • Accused Features: Lenovo products that support USB 3.0 and later. (Compl. ¶33).

U.S. Patent No. 9,232,265 - Method, apparatus and system for transitioning an audio/video device between a source mode and a sink mode

  • Technology Synopsis: This patent discloses techniques for an audio/video device to determine its role in a connection (e.g., as a source sending content or a sink receiving it). The invention describes a default "sink" mode and a process for detecting connectivity characteristics to determine whether it is safe and appropriate to transition into a "source" mode, thereby preventing electrical conflicts between two devices that both attempt to act as a source.
  • Asserted Claims: "one or more claims of the '265 Patent." (Compl. ¶43).
  • Accused Features: Lenovo products that support USB-C Revision 1.0 or later. (Compl. ¶43).

U.S. Patent No. 8,680,712 - Power delivery over digital interaction interface for video and audio (DiiVA)

  • Technology Synopsis: The patent relates to a system for delivering power over a serial data connection. It describes a power delivery circuit that includes components for detecting connected devices, identifying their power needs based on load current, and managing power delivery through a relay switch, intended for use in daisy-chained consumer electronics.
  • Asserted Claims: "one or more claims of the '712 Patent." (Compl. ¶53).
  • Accused Features: Lenovo products that support USB-C Version 1.0 and later. (Compl. ¶53).

U.S. Patent No. 7,856,520 - Control bus for connection of electronic devices

  • Technology Synopsis: This invention describes a method for consolidating multiple control signals onto a single, bi-directional control bus for connecting electronic devices. The system involves arbitration for bus control, after which an "initiator" device converts standard protocol control signals into data packets for transmission over the single-line bus to a "follower" device.
  • Asserted Claims: "one or more claims of the '520 Patent." (Compl. ¶63).
  • Accused Features: Lenovo products that support DisplayPort Alt Mode or HDMI Alt Mode on USB Type-C Version 1.0 and later. (Compl. ¶63).

U.S. Patent No. 7,921,231 - Discovery of electronic devices utilizing a control bus

  • Technology Synopsis: The patent outlines a method for a device to discover the type of device it is connected to via a control bus. It describes a state-based process where a receiving device transitions between states (e.g., "disconnect," "standard connect," "mobile connect") based on detecting voltage signals or pulses on the control and power lines, allowing it to distinguish between different types of transmitting devices.
  • Asserted Claims: "one or more claims of the '231 Patent." (Compl. ¶73).
  • Accused Features: Lenovo products that support DisplayPort Alt Mode on USB Type-C Version 1.0 and later. (Compl. ¶73).

U.S. Patent No. 9,852,103 - Bidirectional transmission of USB data using audio/video data channel

  • Technology Synopsis: This patent describes a system for transmitting USB data in both directions over a high-speed audio/video link (like MHL or HDMI) using Time Division Multiplexing (TDM). The source device sends forward USB data during a first time slot, and the sink device sends backward USB data during a second, non-overlapping time slot, enabling half-duplex USB communication over a channel primarily designed for one-way A/V transmission.
  • Asserted Claims: "one or more claims of the '103 Patent." (Compl. ¶83).
  • Accused Features: Lenovo products that support USB 4 Version 1.0 and later. (Compl. ¶83).

III. The Accused Instrumentality

Product Identification

The complaint identifies broad categories of "Lenovo-branded consumer electronics devices including laptops, desktop computers, monitors, docking stations, and adaptors" (Compl. ¶1). Specific exemplary products are named in connection with each asserted patent, such as the "Legion 7 Gen 6 & 7 Gaming Laptop," "ThinkPad USB-C Dock Gen 2 Docking Station," and "ThinkVision M14t USB-C Mobile Monitor." (Compl. ¶¶13, 33, 43).

Functionality and Market Context

The infringement allegations focus on the products' implementation of standardized data communication protocols, including DisplayPort (versions 1.0, 1.2, and Alt Mode), USB (3.0, 4, USB-C), and HDMI (Alt Mode) (Compl. ¶¶13, 23, 33, 43, 53, 63, 73, 83). The accused functionality is the method by which these devices transmit and receive data, control signals, and power when connected to other electronics, a core feature of modern computing and peripheral devices.

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed infringement theory or claim chart for any of the asserted patents. Instead, it quotes UCT's general allegations from a parallel litigation in the Eastern District of Texas, which state that Lenovo products supporting certain industry standards "directly infringe, literally and/or under the doctrine of equivalents, one or more claims" of the patents-in-suit (Compl. ¶13). The implied theory is that the protocols defined by standards such as DisplayPort and USB inherently practice the methods and systems claimed in the asserted patents.

No probative visual evidence provided in complaint.

The complaint does not provide sufficient detail for analysis of infringement on a claim-element-by-claim-element basis.

  • Identified Points of Contention:
    • '905 Patent: A potential point of contention is whether the method for handling different data streams in the DisplayPort 1.2 standard meets the specific claim limitations for packet "preemption." This raises the question of whether the standard's protocol involves "stopping" a first packet transmission to send a second, and whether it uses signals that function as the claimed "preempt indicator" and "continue indicator." The dispute may focus on whether the standard's multiplexing or channel-switching mechanisms are technically equivalent to the patent's specific preemption process.
    • '307 Patent: The dispute may center on whether the data structures defined in the DisplayPort 1.0 standard constitute an "encapsulation of multiple levels of communication protocol functionality within line codes" as claimed. This raises a technical question about how the DisplayPort standard organizes control and application data within its transmission stream and a legal question of whether that organization maps onto the patent's claimed "cell" structure containing distinct control and data bits for different protocol layers.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for a definitive analysis of claim construction disputes. However, based on the technology and the nature of the allegations, certain terms are likely to be critical.

  • Term: "preempt indicator" ('905 Patent, Claim 1)

  • Context and Importance: The infringement analysis for the '905 Patent may depend on whether the accused DisplayPort protocols transmit a signal that meets the definition of a "preempt indicator." Practitioners may focus on this term because its construction could determine whether a standard protocol feature, such as a command to switch data channels, falls within the scope of the claims.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes a "primitive" generally as a mechanism "used to exchange control information... between link layers." (’905 Patent, col. 11:59-62). This language could support an argument that any signal conveying control information to interrupt a data stream is a "preempt indicator."
    • Evidence for a Narrower Interpretation: The patent provides specific examples of control primitives, including a "preempt" primitive, with specific 9-bit symbol structures in a table. (’905 Patent, Table 1). This could support an argument that the term is limited to the specific out-of-band symbol structures disclosed, and not general-purpose commands within a data stream.

  • Term: "control bus" ('520 Patent, Claim 1)

  • Context and Importance: Infringement of the '520 Patent, which is asserted against products supporting DisplayPort Alt Mode on USB-C, may turn on whether the combination of pins and protocols used for control functions in a USB-C connection constitutes a "control bus." Its definition is critical because USB-C uses multiple lines for different functions (e.g., CC pins, SBU pins), and the patent's claims are directed to a "single-line" bus.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent's summary describes the invention in general terms as a "control bus for connection of electronic devices," which might be argued to encompass any set of conductors used for control. (’520 Patent, Abstract).
    • Evidence for a Narrower Interpretation: The claims and detailed description repeatedly characterize the invention as a "bi-directional, single-line bus." (’520 Patent, col. 1:62-64). This explicit language could support a narrower construction that excludes multi-line communication systems like those used in USB-C.

VI. Other Allegations

  • Indirect Infringement: The complaint is a request for a declaratory judgment of non-infringement and thus contains denials of all forms of infringement. It states that "Lenovo US has not contributed to infringement" and "has not induced others to infringe" any of the patents-in-suit (Compl. ¶¶16, 17, 26, 27, etc.).
  • Willful Infringement: Lenovo's complaint denies willful infringement (Compl. ¶18, 28, etc.). It acknowledges that UCT has alleged in the parallel Texas litigation that the "purported infringement is and has been willful" (Compl. ¶14, 24, etc.), which establishes part of the controversy justifying this declaratory judgment action.

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

This dispute appears to center on whether the implementation of public, industry-wide standards subjects a manufacturer to liability for patent infringement. The outcome will likely depend on the resolution of two central questions:

  • A core issue will be one of technical mapping: Do the specific data structures, signaling protocols, and state transitions defined in the DisplayPort and USB standards perform the same functions in the same way as the methods and systems claimed in the patents-in-suit? Resolution will require a detailed comparison between the standardized protocols and the patent claims.
  • A key legal question will be one of definitional scope: Can claim terms rooted in the patents' proprietary architectures (e.g., "preempt indicator," "cell," "single-line control bus") be construed broadly enough to read on the distinct and often more complex architectures found in modern, multi-vendor standards like USB-C and DisplayPort? The case may turn on whether the patent's teachings are narrow and specific to the disclosed embodiments or broad enough to cover subsequent, independently developed technologies.