Gametronics LLC v. Corsair Gaming Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Gametronics LLC (Delaware)
  • Defendant: Corsair Gaming, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00903, D. Del., 11/18/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant maintains an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe three patents related to ergonomic, movement-based data input devices designed as alternatives to traditional keyboards and controllers.
• Technical Context: The technology concerns human-computer interface devices that replace discrete key presses with holistic hand or thumb movements across a surface, aiming to reduce repetitive strain injuries.
• Key Procedural History: The complaint states that an Original Complaint was filed on July 18, 2025, which Plaintiff alleges constitutes Defendant's actual knowledge of infringement for its claims of ongoing and induced infringement.

Case Timeline

Date	Event
2000-11-14	Patent Priority Date ('762, '872, '667 Patents)
2004-06-18	'762 Patent Application Filed
2005-11-18	'872 Patent Application Filed
2006-06-27	'667 Patent Application Filed
2007-08-28	'762 Patent Issued
2013-07-16	'872 Patent Issued
2013-12-24	'667 Patent Issued
2025-07-18	Original Complaint Filed
2025-11-18	First Amended Complaint Filed

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

U.S. Patent No. 7,262,762 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” Issued Aug. 28, 2007 (’762 Patent)

The Invention Explained

• Problem Addressed: The patent background describes physical problems, such as neuromuscular injuries and carpal tunnel syndrome, associated with the repetitive and fatiguing hand, wrist, and finger motions required by conventional typewriter-like keyboards (ʼ762 Patent, col. 1:23-49).
• The Patented Solution: The invention proposes an ergonomic input apparatus comprising one or two domes contoured to fit a user’s hands in a relaxed state (ʼ762 Patent, Abstract). Instead of pressing individual keys, a user generates data signals by sliding a dome in one of several radial directions from a central home position (ʼ762 Patent, col. 3:20-28; Fig. 1). These movements, alone or "chorded" between two domes, are translated into alphanumeric characters, aiming to eliminate finger-specific motion and reduce strain (ʼ762 Patent, col. 4:18-28).
• Technical Importance: The technology represents a departure from traditional key-based data entry, focusing instead on larger, less repetitive arm and hand movements to address the root causes of keyboard-related injuries (ʼ762 Patent, col. 1:54-61).

Key Claims at a Glance

The complaint does not identify specific asserted claims, instead referencing "Exemplary '762 Patent Claims" in an unprovided exhibit (Compl. ¶13). Independent claim 14 is representative of the apparatus.

• Independent Claim 14: An apparatus for generating data signals, comprising:
  • a main body;
  • first means integral with the main body for enabling a user to tactilely generate a first signal;
  • second means integral with the main body for enabling a user to tactilely generate a second signal;
  • processing means for determining a first and second reference position indicated by the first and second signals;
  • processing means for associating at least one of the reference positions with an alphanumeric character and generating a corresponding data signal; and
  • first and second instructive patterns (templates) positioned proximate the first and second means.
• The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶13).

U.S. Patent No. 8,487,872 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” Issued July 16, 2013 (’872 Patent)

The Invention Explained

• Problem Addressed: The patent notes that miniaturizing conventional keyboards for handheld devices is difficult due to the need to accommodate human fingers, creating a barrier for efficient data entry on portable electronics (ʼ872 Patent, col. 1:45-51).
• The Patented Solution: The invention adapts the movement-based input concept for handheld devices by replacing the palm-sized domes with smaller "thumb controllers" or "thumb-operated elements" (ʼ872 Patent, col. 1:51-56). A user manipulates these controllers with their thumbs to generate data signals, making the ergonomic input method suitable for game controllers, PDAs, or other mobile devices (ʼ872 Patent, Abstract; Fig. 9A).
• Technical Importance: This innovation scaled down the ergonomic input system to a thumb-based form factor, extending its applicability to the expanding market for handheld and portable computing devices (ʼ872 Patent, col. 1:30-38).

Key Claims at a Glance

The complaint alleges infringement of "exemplary method claims" but does not identify them, instead referencing an unprovided exhibit (Compl. ¶22). Independent claim 1 is a representative apparatus claim.

• Independent Claim 1: A handheld device, comprising:
  • a main body;
  • at least one button;
  • a pair of thumb controllers positioned for thumb engagement;
  • a pair of position sensing means connected to the thumb controllers;
  • a processing module programmed to resolve signals from the sensing means to determine an alphanumeric character;
  • means for generating an electrical signal indicative of a video game state change; and
  • means for transmitting said signal for interaction with a video game.
• The complaint reserves the right to assert additional claims (Compl. ¶22).

U.S. Patent No. 8,614,667 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” Issued Dec. 24, 2013 (’667 Patent)

• Technology Synopsis: As part of the same patent family, this invention describes an ergonomic input device where data signals are generated by moving one or two domes from a home position ('667 Patent, Abstract). The specification provides significant detail on the underlying mechanical structures that enable this functionality, including a "flower-pedal shaped impression" on a kinematic map plate and a corresponding "spider mechanism" that guides the dome's movement and provides tactile feedback to the user ('667 Patent, col. 11:53-61, col. 12:1-11).
• Asserted Claims: The complaint does not specify asserted claims, referring to an unprovided exhibit (Compl. ¶¶ 28, 33). The patent includes independent apparatus claims 1 and 10.
• Accused Features: The complaint alleges infringement by the "Exemplary Defendant Products" but provides no details on the specific features accused of infringing this patent (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers generally to "Exemplary Defendant Products" that are identified in claim chart exhibits incorporated by reference (Compl. ¶¶ 13, 18, 24, 33). These exhibits were not provided.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges infringement of all three patents-in-suit but incorporates its specific infringement theories entirely by reference to Exhibits 4, 5, and 6, which were not provided with the pleading (Compl. ¶¶ 19, 25, 34). The complaint contains no narrative description of how any accused product operates or maps to the elements of any asserted patent claim. Accordingly, a detailed analysis of the infringement allegations is not possible based on the provided complaint.

• Identified Points of Contention:
  Based on the language of the representative claims analyzed in Section II, several areas of potential dispute may arise.
  • Scope Questions ('762 Patent): Claim 14 of the '762 Patent is written in means-plus-function format (e.g., 'processing means...for associating...a reference position with an alphanumeric character') ('762 Patent, col. 35:46-52). A central dispute will likely involve defining the corresponding structure disclosed in the specification for these "means" and determining whether the accused products contain identical or equivalent structures that perform the claimed function.
  • Technical Questions ('872 Patent): A key technical question for the '872 Patent will be whether the components of the accused products, which may be gaming peripherals, meet the definitions of the claimed elements. For example, does a standard analog stick on a gaming controller meet the limitations of the "thumb controller" as described in the patent ('872 Patent, col. 37:54-55)? Further, the claim recites functionality for both determining an "alphanumeric character" and generating a "video game state change," raising the question of whether the accused products perform this specific dual functionality as claimed ('872 Patent, col. 37:61-62, col. 38:1-3).

V. Key Claim Terms for Construction

'762 Patent

• The Term: "means...for enabling a user to tactilely generate a first signal" (from representative Claim 14)
• Context and Importance: This is a means-plus-function term governed by 35 U.S.C. § 112(f). Its scope is not its literal language but is limited to the specific structures disclosed in the patent specification that perform the stated function, and their equivalents. Practitioners may focus on this term because the outcome of the infringement analysis for this element will depend entirely on this construction.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses multiple embodiments that could correspond to this means, including large palm-operated domes ('762 Patent, Fig. 1) as well as smaller thumb-operated controllers ('762 Patent, Fig. 7), which could support an argument that the term covers a range of physical input structures.
  • Evidence for a Narrower Interpretation: A party may argue that the corresponding structure is limited to the primary embodiment detailed in the specification: the complete assembly of a sliding palm dome coupled to a kinematic map plate with flower-pedal impressions and an underlying spider mechanism ('762 Patent, Figs. 3, 5, col. 11:46-67).

'872 Patent

• The Term: "thumb controller" (from representative Claim 1)
• Context and Importance: The definition of this term will be critical to determining whether standard input components on modern gaming peripherals, such as analog joysticks or directional pads, fall within the scope of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent figures depict various designs for the "thumb controller," ranging from contoured surfaces with protuberances ('872 Patent, Fig. 21) to simple, smooth caps ('872 Patent, Fig. 23). This could support a broad construction covering any directional input designed for thumb actuation.
  • Evidence for a Narrower Interpretation: The abstract and background repeatedly emphasize the ergonomic nature of the invention, designed to conform to the user's body ('872 Patent, Abstract). A party may argue the term is limited to structures with specific ergonomic contours, as distinguished from generic, non-contoured analog sticks. The specification also describes specific guiding mechanisms (protuberances and recesses) as a key feature, which could be used to argue for a narrower scope that requires such features ('872 Patent, col. 25:47-67).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement of the '762 and '667 Patents. The allegations are based on Defendant’s distribution of "product literature and website materials" that allegedly instruct end users on how to use the accused products in an infringing manner (Compl. ¶¶ 16, 31).
• Willful Infringement: The complaint alleges that Defendant gained "actual knowledge" of the '762 and '667 Patents upon service of the Original Complaint on July 18, 2025, and that its continued infringement thereafter is willful (Compl. ¶¶ 15-16, 30-31). No allegation of pre-suit knowledge is made.

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

1. A core issue will be one of structural correspondence: for the means-plus-function claims of the '762 Patent, what specific structures described in the specification perform the claimed functions, and do the accused products contain hardware and software that are structurally equivalent?

2. A key dispute will be one of definitional scope: can the term "thumb controller," as used in the context of the '872 Patent's specific ergonomic and mechanical disclosures, be construed to cover the potentially generic analog sticks or other directional inputs found on modern gaming peripherals?

3. A foundational evidentiary question will be one of factual support: given the complaint's exclusive reliance on unprovided exhibits, a threshold issue will be whether Plaintiff can produce sufficient evidence to demonstrate how the accused products actually operate and meet the specific limitations of the asserted patent claims.