Maybell Quantum Industries Inc v. QD Oxford Uk Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Maybell Quantum Industries, Inc. (Delaware)
  • Defendant: QD Oxford UK Limited (United Kingdom) and Quantum Design International Inc. (California)
  • Plaintiff’s Counsel: Shaw Keller LLP
• Case Identification: 1:25-cv-00949, D. Del., 02/06/2026
• Venue Allegations: Plaintiff asserts that venue is proper because Defendants have stipulated that they will not challenge venue in the District of Delaware for this litigation.
• Core Dispute: Plaintiff alleges that Defendants’ ProteoxQX line of dilution refrigerators infringes a patent related to integrated and scalable cryogenic systems.
• Technical Context: The technology relates to dilution refrigerators, which are critical for achieving the near-absolute zero temperatures required for quantum computing and advanced physics research.
• Key Procedural History: The original complaint was filed on July 29, 2025, against Oxford Instruments. On January 2, 2026, Quantum Design acquired the Oxford Nanoscience business, including all liabilities related to the lawsuit. Consequently, the court substituted the current Defendants into the case.

Case Timeline

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

U.S. Patent No. 12,313,320 - "Integrated Dilution Refrigerators"

• Patent Identification: U.S. Patent No. 12,313,320, “Integrated Dilution Refrigerators,” issued May 27, 2025 (the “’320 Patent”).

The Invention Explained

• Problem Addressed: Conventional dilution refrigerators are described as occupying a large footprint, making them difficult to scale for applications like quantum computing that may require multiple units Compl. ¶15 They are also presented as being difficult to maintain, requiring significant space and potentially specialized procedures for access ’320 Patent, col. 4:14-22
• The Patented Solution: The invention is a dilution refrigerator designed for improved scalability and ease of use, featuring an outer vacuum chamber with at least one "substantially planar surface" and an opening on that surface to provide access to the internal experimental volume ’320 Patent, abstract This design is intended to allow for integration into standard commercial server rack infrastructure, addressing the scalability and maintenance challenges of prior art systems Compl. ¶16 ’320 Patent, col. 2:20-27
• Technical Importance: This approach seeks to shift dilution refrigerator design from bespoke, room-sized installations to a more modular, rack-mountable form factor, which could lower the barrier to scaling up quantum computing infrastructure Compl. ¶16

Key Claims at a Glance

• The complaint asserts independent claims 1, 17, and 18 ’320 Patent, col. 24:26-25:14 Compl. ¶33
• Claim 1 recites the core elements of the invention:
  • 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.
• Claim 17 adds a limitation that the planar surface comprises a first surface disposed in a plane perpendicular to the floor.
• Claim 18 adds a limitation that the opening comprises a hinged door.
• The complaint states that infringement allegations are exemplary and does not foreclose the assertion of other claims Compl. ¶19

III. The Accused Instrumentality

Product Identification

• Defendants’ ProteoxQX systems (the “Accused Products”) Compl. ¶20

Functionality and Market Context

• The complaint describes the Accused Products as large, modular dilution refrigerators Compl. ¶28 A key touted feature is a "removable side-loading insert" that allegedly offers time savings and maximum uptime, allowing for "scalability from prototyping to full-scale implementation" Compl. ¶28 The complaint alleges these advantages result from the novel designs claimed in the ’320 Patent Compl. ¶28 The Accused Products are marketed on Defendants' website, which features the "ProteoxQX" brand, as depicted in a screenshot included in the complaint Compl. at 10 The complaint further relies on a publicly available augmented reality application that purports to provide an accurate, life-size depiction of the Accused Products and their components Compl. ¶20

IV. Analysis of Infringement Allegations

Claim Chart Summary

• The complaint does not include a claim chart exhibit but makes narrative allegations that map to the elements of the asserted claims. The following chart summarizes these allegations for representative Claim 1.

’320 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central dispute may arise over the proper construction of "substantially planar surface." The patent specification connects this feature to a "rectangular prism" shape suitable for integration into server racks ’320 Patent, col. 2:50-55 The litigation may explore whether the accused "modular" design falls within this claimed geometry.
• Technical Questions: The infringement analysis may focus on the nature of the "access" provided by the opening in the Accused Products. The complaint alleges the accused "removable side-loading insert" provides this access Compl. ¶28 A key question for the court could be whether this mechanism is structurally and functionally equivalent to the "opening" described and claimed in the ’320 Patent.

V. Key Claim Terms for Construction

"substantially planar surface"

• Context and Importance: This term is foundational to the asserted claims and appears to be a primary point of novelty. Its construction will likely determine whether the geometry of the Accused Products reads on the claims. Practitioners may focus on this term because the patent's description of a "rectangular prism" and server rack integration could be used to argue for a narrower scope than simply "mostly flat."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not explicitly limit the term to a specific shape beyond being "substantially planar," which may support an argument for its plain and ordinary meaning.
  • Evidence for a Narrower Interpretation: The specification states that in some embodiments, planar surfaces are "arranged as a rectangular prism" ’320 Patent, col. 2:50-55 and that the "server rack-type container is configured to integrate with commercial server rack infrastructure" ’320 Patent, col. 2:23-25 This context may be used to argue the term is limited to a shape compatible with such infrastructure.

"opening"

• Context and Importance: The configuration of the "opening" is critical for the patent's goal of providing easier access. The dispute will likely involve comparing the access mechanism of the Accused Products (a "removable side-loading insert") to this claim term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not highly technical and could be interpreted broadly to cover any aperture that allows access.
  • Evidence for a Narrower Interpretation: Dependent claim 18 specifies a "hinged door" ’320 Patent, col. 25:13-14, and the specification describes a door that can be sealed with a "hinge and/or a clamp" ’320 Patent, col. 19:14-17 Defendants may argue that these specific embodiments limit the general term "opening" to a door-like structure, potentially distinguishing it from a "removable insert."

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement of infringement, asserting that Defendants actively encourage customers to use the Accused Products in an infringing manner through marketing materials and blog posts that highlight the accessibility and scalability of the systems Compl. ¶¶41-43

Willful Infringement

• The complaint alleges that the original defendant, Oxford Instruments, had knowledge of the ’320 Patent as of September 19, 2025 Compl. ¶36 It further alleges that the current Defendants knew of the patent and infringement allegations as of at least January 23, 2026, when they formally assumed the liabilities of the business Compl. ¶37 The claim for willfulness is based on Defendants’ continued marketing and sale of the Accused Products after having this knowledge Compl. ¶38

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

The resolution of this case may depend on the court's answers to several key questions:

• A core issue will be one of definitional scope: Will the term "substantially planar surface" be interpreted broadly as "mostly flat," or will it be narrowed by the specification's repeated references to a "rectangular prism" form factor designed for integration with commercial server racks?
• A second central question will be one of structural equivalence: Does the Accused Products' "removable side-loading insert" constitute an "opening" within the meaning of the claims, or does its design and operation place it outside the scope of the patented invention?
• A final key question will relate to willfulness: Given that Defendants acquired a business with knowledge of pending litigation, what evidentiary standard will be required to prove that their subsequent marketing and sales of the accused product line rose to the level of willful infringement?