DCT

1:25-cv-00904

Gametronics LLC v. Voyetra Turtle Beach Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00904, D. Del., 07/18/2025
  • Venue Allegations: Venue is alleged to be proper as Defendant maintains an established place of business in the District of Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s products infringe three patents related to ergonomic data input devices, such as keyboards and controllers, designed to reduce physical strain.
  • Technical Context: The technology domain is human-computer interface devices, which are critical for user interaction with computers, gaming consoles, and handheld electronics.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2000-11-14 Earliest Priority Date for '762, '872, and '667 Patents
2005-11-18 Application Filing Date for '872 Patent
2006-06-27 Application Filing Date for '667 Patent
2007-08-28 Issue Date for '762 Patent
2013-07-16 Issue Date for '872 Patent
2013-12-24 Issue Date for '667 Patent
2025-07-18 Complaint Filing Date

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

U.S. Patent No. 7,262,762 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS”

  • Patent Identification: U.S. Patent No. 7,262,762, “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” issued August 28, 2007.

The Invention Explained

  • Problem Addressed: The patent’s background section describes neuromuscular injuries, such as carpal tunnel syndrome, that result from the repetitive and fatiguing hand, wrist, and finger motions required by conventional typewriter-like keyboards (ʼ762 Patent, col. 1:38-51).
  • The Patented Solution: The invention is an ergonomic apparatus featuring one or two domes upon which a user rests their palms. Instead of pressing individual keys, the user generates data signals by sliding the domes in various directions from a central "home" position. This design aims to eliminate finger-specific movements and maintain the hands and wrists in a more relaxed state ('762 Patent, Abstract; col. 3:14-25).
  • Technical Importance: The technology sought to provide a data entry method that reduces overuse injuries by focusing on the "entire aggregate of hand, wrist, and finger motions" and requiring only slight arm or hand movement rather than finger-tip actuation ('762 Patent, col. 3:14-19; col. 4:52-56).

Key Claims at a Glance

  • The complaint does not identify the specific claims asserted from the ’762 Patent, referring only to “Exemplary ’762 Patent Claims” identified in an unprovided claim chart exhibit (Compl. ¶13).

U.S. Patent No. 8,487,872 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS”

  • Patent Identification: U.S. Patent No. 8,487,872, “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” issued July 16, 2013.

The Invention Explained

  • Problem Addressed: Similar to its parent patent, the ʼ872 Patent addresses the physical problems and muscular syndromes associated with conventional keyboard use ('872 Patent, col. 1:21-48).
  • The Patented Solution: This patent describes a handheld embodiment of the ergonomic input device, featuring a pair of "thumb controllers." A user holds the device and manipulates the controllers with their thumbs to generate electrical signals, which are then resolved by a processing module to determine an alphanumeric character ('872 Patent, Abstract; claim 1). Figure 9A illustrates such a handheld device with two thumb controllers (204, 206) on its surface ('872 Patent, Fig. 9A).
  • Technical Importance: This approach adapts the ergonomic input concept for miniaturized, handheld devices, such as gaming controllers or personal digital assistants, allowing for data entry without a traditional keypad ('872 Patent, col. 2:45-56).

Key Claims at a Glance

  • The complaint does not identify the specific claims asserted from the ’872 Patent, referring only to “Exemplary ’872 Patent Claims” identified in an unprovided claim chart exhibit (Compl. ¶22, 24).

U.S. Patent No. 8,614,667 - “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS”

  • Patent Identification: U.S. Patent No. 8,614,667, “APPARATUS AND METHOD FOR GENERATING DATA SIGNALS,” issued December 24, 2013.
  • Technology Synopsis: This patent, from the same family as the '762 and '872 Patents, also discloses an ergonomic data input apparatus. It describes associating the radial movements of its domes with the character layout of a conventional QWERTY keyboard. This design leverages a user's pre-existing kinesthetic knowledge of a standard keyboard to facilitate learning and use of the ergonomic device ('667 Patent, Abstract; col. 22:10-33).
  • Asserted Claims: The complaint refers to the “Exemplary ’667 Patent Claims” identified in an unprovided claim chart exhibit (Compl. ¶28, 33).
  • Accused Features: The complaint alleges infringement by Defendant's "Exemplary Defendant Products" but does not describe the specific products or features in the body of the complaint, referring instead to unprovided exhibits (Compl. ¶28, 31).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers throughout to “Exemplary Defendant Products” that are purportedly identified in external exhibits not attached to the complaint (Compl. ¶13, 22, 28).

Functionality and Market Context

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

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement for all three patents-in-suit. For each patent, the complaint incorporates by reference an external claim chart exhibit, which is not provided, and makes the conclusory statement that the exhibit demonstrates that the accused products satisfy all elements of the asserted claims (Compl. ¶18, 24, 33). The complaint does not provide a narrative description of the specific infringing functionality for any of the accused products. As such, a claim chart summary and identification of specific points of contention is not possible based on the provided documents.

V. Key Claim Terms for Construction

The complaint does not identify specific asserted claims or provide the referenced claim charts, precluding an analysis of key claim terms for construction.

VI. Other Allegations

  • Indirect Infringement: For the ’762 and ’667 Patents, the complaint alleges induced infringement. The allegations are based on Defendant's distribution of "product literature and website materials," which allegedly instruct or direct end users on how to use the accused products in an infringing manner (Compl. ¶16-17, 31-32). No specific facts are alleged to support indirect infringement of the ’872 Patent.
  • Willful Infringement: For the ’762 and ’667 Patents, the complaint alleges knowledge of infringement based on the service of the complaint itself, which may support claims for post-suit inducement and potential enhanced damages for post-suit conduct (Compl. ¶15, 17, 30, 32). The complaint does not allege pre-suit knowledge for any of the patents-in-suit. The prayer for relief seeks a declaration that the case is “exceptional” under 35 U.S.C. § 285 (Compl. p. 8, ¶J.i.).

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

Based on the initial pleading, the case appears to present immediate procedural questions before reaching the technical merits. The central issues for the court to decide will likely include:

  • A threshold issue may be one of pleading sufficiency: does the complaint, which relies entirely on incorporating unprovided external exhibits to identify the accused products, asserted claims, and infringement theories, provide sufficient notice of infringement to the defendant under the federal pleading standards?
  • A fundamental evidentiary question will be one of infringement mapping: assuming the pleading is deemed sufficient, what specific features of the accused products are alleged to perform the functions of the claimed ergonomic input mechanisms, and does the evidence support a finding that they operate in the manner required by the patent claims?