DCT
1:25-cv-00949
Maybell Quantum Industries Inc v. Oxford Instruments PLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Maybell Quantum Industries, Inc. (Delaware)
- Defendant: Oxford Instruments PLC (England); Oxford Instruments Nanotechnology Tools Ltd. (England)
- Plaintiff’s Counsel: Shaw Keller LLP
- Case Identification: 1:25-cv-00949, D. Del., 07/29/2025
- Venue Allegations: Venue is asserted on the basis that Defendants are not residents of the United States and therefore may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s ProteoxQX line of dilution refrigerators infringes a patent related to integrated and scalable cryogenic systems.
- Technical Context: The technology at issue involves dilution refrigerators, which are critical for providing the extremely low temperatures required for quantum computing and advanced condensed matter physics research.
- Key Procedural History: The complaint alleges that Defendant Oxford Instruments associates the design of its accused products with a different patent, U.S. Patent No. 12,320,557, which may suggest a potential area of dispute regarding the design's origins and non-obviousness.
Case Timeline
| Date | Event |
|---|---|
| 2021-07-08 | U.S. Patent No. 12,313,320 Priority Date |
| 2025-04-23 | Date of article describing installation of Accused Products in U.S. |
| 2025-05-27 | U.S. Patent No. 12,313,320 Issue Date |
| 2025-07-29 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,313,320 - Integrated Dilution Refrigerators, issued May 27, 2025
The Invention Explained
- Problem Addressed: The patent describes conventional dilution refrigerators as having several drawbacks, including a large physical footprint, reliance on costly and hard-to-maintain liquid cryogens, and susceptibility to performance-degrading mechanical vibrations from cooling systems (Compl. ¶12; ’320 Patent, col. 4:6-22). These factors inhibit the scalability required for widespread adoption in fields like quantum computing.
- The Patented Solution: The invention proposes a more compact and user-friendly dilution refrigerator design that can be integrated with standard commercial infrastructure, such as 19-inch server racks (Compl. ¶13; ’320 Patent, col. 4:27-31). A key feature is an outer vacuum chamber with at least one "substantially planar surface" and an "opening" that provides direct access to the internal experimental volume, aiming to simplify maintenance and improve scalability (Compl. ¶14; ’320 Patent, col. 1:30-34).
- Technical Importance: This design approach seeks to shift dilution refrigerators from large, standalone laboratory instruments to modular, rack-mountable components, a step described as necessary for quantum technologies to become "easily scalable" (Compl. ¶13; ’320 Patent, col. 4:23-27).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶30).
- Independent Claim 1 requires:
- A dilution refrigerator comprising:
- an outer vacuum chamber comprising an outer housing having at least one substantially planar surface; and
- an opening in the at least one substantially planar surface of the outer housing configured to provide access to an experimental volume disposed within an interior of the outer vacuum chamber.
- The complaint reserves the right to assert additional claims during litigation (Compl. ¶26).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant’s ProteoxQX systems (Compl. ¶17).
Functionality and Market Context
- The ProteoxQX systems are dilution refrigerators used to create the cryogenic environments necessary for quantum computing and other advanced research (Compl. ¶10). The complaint alleges that Defendant markets these products based on features such as "modular architecture," "scalability," and a "fully accessible workspace," which allows users to access the internal mixing chamber sample space via "doors and easily removable radiation shields" (Compl. ¶17, ¶25). The complaint references a publicly available augmented reality application that purports to provide an accurate, life-size depiction of the Accused Products and their components (Compl. ¶17).
IV. Analysis of Infringement Allegations
'320 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a dilution refrigerator comprising: | The Accused Products are identified as ProteoxQX dilution refrigerators. | ¶17, ¶19 | col. 4:38-41 |
| an outer vacuum chamber comprising an outer housing having at least one substantially planar surface; | The Accused Products are alleged to have an outer vacuum chamber with surfaces arranged as a "rectangular prism," including first surfaces perpendicular to the floor and second surfaces parallel to the floor, thereby constituting substantially planar surfaces (Compl. ¶21, ¶23). | ¶19, ¶21, ¶23 | col. 20:2-4 |
| and an opening in the at least one substantially planar surface of the outer housing configured to provide access to an experimental volume disposed within an interior of the outer vacuum chamber. | The Accused Products are alleged to have an opening that provides access to the interior of the outer vacuum chamber and the experimental volume within (Compl. ¶19-20). This opening is described as part of a "fully accessible sample space" with "doors and easily removable radiation shields" (Compl. ¶17) and is also alleged to be a "hermetic opening" (Compl. ¶22) with a "hinged door" (Compl. ¶24). | ¶17, ¶19, ¶20, ¶24 | col. 20:5-10 |
Identified Points of Contention
- Scope Questions: The case may turn on the construction of "substantially planar surface." A central question will be whether the surfaces of the Accused Products, alleged to form a "rectangular prism" (Compl. ¶21), meet this limitation as it is understood in the context of the patent, which emphasizes integration into commercial server racks ('320 Patent, col. 2:20-29).
- Technical Questions: A factual question will concern the nature of the "opening" in the Accused Products. The complaint alleges features like a "hinged door" (Compl. ¶24) and "full access to the mixing chamber sample space" (Compl. ¶17), but the court will need to determine if the product's actual configuration performs the access function in the manner required by the claim. The complaint's reliance on an augmented reality app as evidence for the product's structure is notable and may raise evidentiary questions (Compl. ¶17).
V. Key Claim Terms for Construction
The Term: "substantially planar surface"
Context and Importance: This term is central because the infringement theory hinges on the shape of the accused refrigerator's housing. The defendant may argue its product does not possess the specific planarity contemplated by the patent, while the plaintiff will likely argue the term covers the generally flat-sided, rectangular prism shape alleged in the complaint (Compl. ¶21).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general. The specification does not appear to provide an explicit definition, which may support giving the term its plain and ordinary meaning of "mostly flat."
- Evidence for a Narrower Interpretation: The specification repeatedly links the design to integration with "commercial server rack infrastructure" and "19-inch server racks" ('320 Patent, col. 2:20-29, col. 4:29-31). A party could argue this context implies a specific degree of planarity and dimensional constraints necessary to fit within standardized rack systems, potentially narrowing the term's scope.
The Term: "opening"
Context and Importance: Practitioners may focus on this term because its meaning determines what kind of access point satisfies the claim. The dispute could center on whether any access panel infringes, or if the term is limited to a specific type of user-facing, tool-free access point for the experimental volume.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Independent Claim 1 broadly recites an "opening...configured to provide access." It does not include limitations from dependent claims, such as a "hinged door" (Claim 18) or a "load lock" (Claim 21), suggesting the term itself is not so constrained.
- Evidence for a Narrower Interpretation: The abstract and summary emphasize providing access to the interior and experimental volume ('320 Patent, col. 1:32-34). Embodiments show a door (125) providing access to the experimental volume (124) near the coldest part of the refrigerator ('320 Patent, FIG. 1, col. 13:5-14). A party could argue the term should be construed in light of these embodiments as a specific feature for accessing the experimental area, not just any service opening in the vacuum chamber.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant encourages infringement through its "websites, in their user manuals, in their product documentation, and in other advertising materials" (Compl. ¶34). It also pleads contributory infringement, alleging the Accused Products are a material part of the invention with no substantial noninfringing use (Compl. ¶39-40).
- Willful Infringement: Willfulness is alleged based on knowledge of the '320 Patent obtained "since at least as early as the service of this Complaint" (Compl. ¶32). The complaint does not allege pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the court's answers to two central questions:
- A core issue will be one of definitional scope: can the term "substantially planar surface," which is described in the patent in the context of integration with server racks, be construed to read on the overall form factor of the accused large-scale, free-standing ProteoxQX refrigerator?
- A key evidentiary question will be one of structural correspondence: does the "opening" on the Accused Products, as depicted in marketing materials and an augmented reality app, correspond to the specific access mechanism claimed in the patent, and what weight will be given to such non-traditional sources of technical evidence?