DCT

1:25-cv-00870

Belden Canada ULC v. CommScope LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00870, D. Del., 07/14/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant entities are organized in Delaware, or because non-Delaware entities are alter-egos of Delaware entities and have committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Propel™ line of modular fiber connectivity products infringes patents related to high-density, configurable fiber optic management tray systems.
  • Technical Context: The technology concerns high-density fiber optic management systems used in data centers and enterprise networks, where maximizing connection density and maintaining flexibility in a standardized rack space is critical.
  • Key Procedural History: The complaint alleges that the parties have previously litigated related patents, which may be relevant to the issue of willful infringement. The patents-in-suit are part of a family that has been subject to Inter Partes Review (IPR) proceedings at the U.S. Patent and Trademark Office, though the complaint does not specify the outcomes or their direct relevance to the asserted patents.

Case Timeline

Date Event
2017-10-03 Priority Date for ’896 and ’491 Patents
2023-06-02 ’896 Patent’s underlying application filed
2023-08-10 ’491 Patent’s underlying application filed
2025-05-27 U.S. Patent No. 12,313,896 Issued
2025-06-17 U.S. Patent No. 12,332,491 Issued
2025-07-14 Complaint Filed

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

U.S. Patent No. 12,313,896 - "Tray Means For Providing A Plurality Of Different Modular Cassette Configurations In A Fiber Optic Management System," Issued May 27, 2025

The Invention Explained

  • Problem Addressed: The patent describes a drawback in prior art fiber optic management systems where trays are typically preconfigured for a single, predetermined number of optic fibers or a single size of cassette. This approach is described as inflexible and inefficient in its use of tray space when network administrators need to mix cassettes of different sizes to accommodate varying termination needs (’896 Patent, col. 1:36-49).
  • The Patented Solution: The invention is a tray system designed to accept and secure modular fiber optic cassettes of various widths (e.g., 2-width, 3-width, 4-width, and 6-width units) side-by-side on a single standardized tray (’896 Patent, Abstract). This is achieved by designing the tray and cassettes around a fundamental "standard one width (1W) unit," which allows for a mix-and-match approach to optimize the use of space within a standard rack (’896 Patent, col. 2:51-60). Figure 3 of the patent visually demonstrates how cassettes of different widths (e.g., 2W, 3W, 4W) can be combined to populate the full width of the tray (’896 Patent, Fig. 3).
  • Technical Importance: This modular approach provides greater flexibility and density in data center and enterprise network environments, allowing for more efficient use of valuable rack space (’896 Patent, col. 1:29-35).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 112 (Compl. ¶37).
  • Essential elements of independent claim 112 include:
    • A tray for providing a plurality of different modular fiber optic cassette configurations in a standard U-space.
    • The tray comprises a "tray means for supporting" these configurations.
    • The configurations include "different sizes of modular fiber optic cassettes."
    • The cassettes are based on integer multiples of a "standard one width (1W) unit" (e.g., 2W, 3W, 4W, 6W).
    • The 2W cassette consists of only eight fiber optic plug receiving receptacle portions, the 3W of twelve, the 4W of sixteen, and the 6W of twenty-four.
    • The tray means is configured to conform to the standard one width (1W) to support the various cassette sizes.
  • The complaint does not explicitly reserve the right to assert dependent claims, but infringement is alleged for "one or more claims" (Compl. ¶37).

U.S. Patent No. 12,332,491 - "Tray System For Providing Modular Cassette Configurations In A Fiber Optic Management System," Issued June 17, 2025

The Invention Explained

  • Problem Addressed: Similar to its related patent, the ’491 Patent addresses the lack of compatibility and inefficient space utilization in prior art systems that cannot easily accommodate fiber optic cassettes of different fiber counts and physical sizes on a single tray (’491 Patent, col. 1:40-50).
  • The Patented Solution: The patent discloses a tray system featuring a "tray member" specifically configured to fit various combinations of modular cassettes. The system is based on a standard width unit (1W), and cassettes are provided in multiple-width sizes (2W, 3W, etc.) that can be arranged in different configurations to fill the tray, thereby optimizing density (’491 Patent, Abstract; col. 2:53-62).
  • Technical Importance: This invention allows network infrastructure to be more adaptable and scalable, as administrators can customize connectivity density within a single piece of hardware rather than using multiple, specialized trays (’491 Patent, col. 1:33-39).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 79 (Compl. ¶44).
  • Essential elements of independent claim 79 include:
    • A tray for providing a plurality of different modular fiber optic cassette configurations.
    • The tray comprises a "tray member configured to support" these configurations.
    • The configurations include "different sizes of modular fiber optic cassettes."
    • The cassettes are based on a "standard width unit (1W)" and include 2W, 3W, and 4W sizes.
    • The tray member is configured to support different combinations of these cassettes arranged side-by-side.
    • The 2W cassette is configured to consist of only eight fiber optic plug receiving receptacle portions, the 3W of twelve, and the 4W of sixteen.
  • The complaint alleges infringement of "one or more claims," suggesting dependent claims may also be at issue (Compl. ¶44).

III. The Accused Instrumentality

  • Product Identification: The accused products are CommScope's "Propel™ system," which includes "Propel™ high-density panels, such as those with product numbers PPL-1U, PPL-2U, and PPL-4U, and Propel™ fiber modules and adapters," with a lengthy list of specific product numbers also provided (Compl. ¶3).
  • Functionality and Market Context: The complaint describes the Accused Products as "modular fiber connectivity products" (Compl. ¶3). It points to a CommScope marketing webpage, "https://www.commscope.com/propel/", for further information (Compl. ¶12). The complaint does not provide a detailed technical description of the products' operation, but alleges that they perform the functions claimed in the patents-in-suit, namely providing a modular system for managing fiber optic connections.

IV. Analysis of Infringement Allegations

The complaint states that claim charts demonstrating infringement are attached as Exhibits C and D but these exhibits were not included with the publicly filed document (Compl. ¶¶40, 47). The complaint text itself does not provide a narrative infringement theory, other than to state that the Accused Products "include each of the elements of at least Claim 112 of the ’896 Patent" and "Claim 79 of the ’491 Patent" (Compl. ¶¶40, 47).

  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether the modular system of the accused Propel™ products maps onto the specific dimensional schema claimed in the patents. The claims of both the '896 and '491 patents are highly specific about cassettes being multiples of a "standard one width (1W) unit" and having a specific number of receptacle portions for each width (e.g., 2W has eight, 3W has twelve). The infringement analysis will likely turn on whether the accused modules and panels meet these precise structural and quantitative limitations.
    • Technical Questions: For the ’896 Patent, a key technical and legal question relates to the "tray means for supporting" limitation in claim 112. The use of "means" language raises the possibility of construction under 35 U.S.C. § 112(f) (means-plus-function). If construed as such, infringement would require the accused Propel™ panels to have structures identical or equivalent to the specific "slideable tray 12" with "slots 38," a "raised shoulder 46," and other features disclosed in the specification (’896 Patent, col. 14:31-60). The court will need to determine if the Propel™ system's method for securing modules is structurally equivalent to the patented method.

V. Key Claim Terms for Construction

  • The Term: "standard one width (1W) unit" (in claims of both patents)

    • Context and Importance: This term is the fundamental building block of the claimed modular system. Its definition is critical because infringement will depend on whether the dimensions of the accused Propel™ modules correspond to the "1W" unit and its claimed integer multiples. Practitioners may focus on this term to determine if the patent covers only specific, disclosed industry standards or a more conceptual modular unit.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states the 1W unit "may be based on a standard LC Quad width unit" or "a standard SC Duplex width unit" (’896 Patent, col. 3:15-24). The use of "may be" could support an interpretation that the 1W unit is not strictly limited to these examples but is a more general concept of a base unit of width.
      • Evidence for a Narrower Interpretation: The specification's primary embodiments and examples are tied to specific connector footprints like LC Quad and SC Duplex (’896 Patent, col. 15:38-46). A defendant could argue that the term should be limited to the scope of these disclosed examples, particularly since they are the only concrete definitions provided for the 1W unit.

  • The Term: "tray means for supporting" (in Claim 112 of the ’896 Patent)

    • Context and Importance: This term appears to be drafted in means-plus-function format. Its construction will determine the structural scope of the claim. The outcome of the infringement analysis for the ’896 Patent may hinge on whether the mechanism used to hold modules in the accused Propel™ panel is structurally equivalent to the mechanism disclosed in the patent. This contrasts with the ’491 Patent, which uses the phrase "tray member configured to support," making a means-plus-function interpretation less likely for that patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Means-Plus-Function Interpretation (Narrower Scope): The use of the word "means" followed by a function ("for supporting...") creates a presumption that 35 U.S.C. § 112(f) applies. If it applies, the scope is limited to the corresponding structures disclosed in the specification and their equivalents.
      • Corresponding Structure in Specification: The specification discloses the corresponding structure as a "slideable tray 12" that uses "a fastener comprising tabs 36" that "engage with respective slots 38" and a "raised shoulder 46 which is received within a channel 48" on the cassette's underside to secure the cassettes (’896 Patent, col. 14:46-60). An alternative embodiment uses a magnet as the fastener (’896 Patent, col. 16:38-45). The scope of the claim would be limited to these specific structures and their equivalents.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that CommScope instructs customers on the use of the Accused Products through user manuals and other materials, with knowledge of the patents (Compl. ¶¶38, 45). Contributory infringement is based on allegations that the Accused Products are a material part of the patented invention, are not staple articles of commerce, and are especially adapted for use in an infringing manner (Compl. ¶¶39, 46).
  • Willful Infringement: Willfulness is alleged based on CommScope's status as a "sophisticated corporate enterprise" that should be aware of patents in its field, and more specifically on the allegation that the parties have litigated "related patents," suggesting CommScope had pre-suit knowledge of Belden's patent portfolio and the patents-in-suit (Compl. ¶¶42, 49).

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

  • A core issue will be one of technical and dimensional scope: Can the specific, quantitative limitations of the claims—such as the "standard one width (1W) unit" and the exact number of receptacle portions per cassette width—be shown to read on the physical design and modularity of CommScope's Propel™ system? The case may turn on a detailed comparison of the products' dimensions against the patents' definitions.
  • A key legal question will be one of claim construction and structural equivalence, particularly for the ’896 Patent. The resolution of whether "tray means for supporting" is a means-plus-function limitation, and if so, whether the accused products contain an equivalent of the disclosed tray-and-fastener structure, will be critical to the infringement finding for that patent.
  • A central evidentiary question for damages will be one of knowledge and intent. The plaintiff's ability to substantiate its claim that CommScope knew of these specific patents before the lawsuit, potentially through evidence from prior litigation between the parties, will be dispositive for the willfulness allegation and any potential for enhanced damages.