DCT

1:25-cv-01149

Teratech Corp v. Mindray Bio Medical Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01149, D. Del., 09/15/2025
  • Venue Allegations: Venue is asserted in the District of Delaware because Defendant Mindray USA is a Delaware corporation and Defendant Mindray Global is a foreign corporation subject to personal jurisdiction in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s "TE" family of ultrasound products infringes five U.S. patents related to portable, tablet-based, and touchscreen-controlled ultrasound systems.
  • Technical Context: The technology concerns the miniaturization of high-performance medical ultrasound systems from large, stationary consoles to portable, battery-powered devices suitable for point-of-care diagnostics.
  • Key Procedural History: The complaint alleges a prior Original Equipment Manufacturer (OEM) relationship between Teratech and Mindray from 2004-2005, during which Mindray allegedly gained access to Teratech's technology and know-how. The complaint further alleges that Mindray gained knowledge of Teratech’s patent portfolio through this relationship and through its own patent prosecution activities, where Teratech patents were cited as prior art.

Case Timeline

Date Event
2003-11-26 Priority Date for ’073 Patent
2004-01-01 Alleged start of OEM relationship between Teratech and Mindray
2012-03-26 Priority Date for ’480, ’023, and ’699 Patents
2013-09-25 Priority Date for ’363 Patent
2015-01-01 First accused TE7 product introduced and received FDA approval
2018-01-30 ’699 Patent Issued
2023-06-13 ’073 Patent Issued
2024-01-02 ’363 Patent Issued
2024-10-01 ’480 Patent Issued
2024-10-15 ’023 Patent Issued
2025-09-15 Complaint Filing Date

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

U.S. Patent No. 11,675,073 - "MODULAR PORTABLE ULTRASOUND SYSTEMS"

The Invention Explained

  • Problem Addressed: The patent’s background describes conventional ultrasound imaging systems as typically including a hand-held probe cabled to a large, rack-mounted console, which limited portability and point-of-care applications (’073 Patent, col. 1:15-22).
  • The Patented Solution: The invention provides a lightweight, portable ultrasound system where the processing unit, including beamformer electronics, is contained within a compact housing connectable to various transducer probes (’073 Patent, Abstract; col. 2:50-58). A key aspect is a handheld processing unit with an integrated touchscreen that can automatically identify a connected transducer and configure the appropriate imaging parameters, simplifying operation for the user (’073 Patent, col. 23:41-62).
  • Technical Importance: This approach facilitated the shift of high-resolution ultrasound imaging from dedicated hospital rooms to more flexible settings, enabling battery-powered, point-of-care diagnostics (Compl. ¶14, ¶17).

Key Claims at a Glance

  • The complaint asserts independent claim 41 (Compl. ¶22, ¶72).
  • Claim 41 requires, in summary:
    • A handheld medical ultrasound imaging device comprising:
    • at least one handheld transducer assembly (with probe, transducer array, cable, and connector); and
    • a handheld portable processing unit connectable to the transducer.
    • The processing unit must have an integrated touch screen display, a processor, memory, and a battery.
    • The processor must communicate with an ultrasound beamformer and be operative via finger input on the touchscreen to run a graphical user interface.
    • The interface must display automatically set imaging parameters upon connection of the transducer and selection of an anatomical structure.
    • The processor must be configured to operate several computer programs, including a scan conversion program, a Doppler processing program, an image parameter module, and a transducer identification program.
  • The complaint asserts claims 2-25, 27-40, and 42-55, which depend from other independent claims, but focuses its narrative on claim 41 (Compl. ¶21).

U.S. Patent No. 12,115,023 - "TABLET ULTRASOUND SYSTEM"

The Invention Explained

  • Problem Addressed: The patent identifies the limitations of conventional ultrasound systems that rely on physical keyboards and knobs, which can be bulky, difficult to clean in sterile environments, and complicated to use, particularly in a portable context (’023 Patent, col. 1:31-54).
  • The Patented Solution: The invention is a method of operating a cart-mounted medical ultrasound device that uses a tablet with a multi-touch screen display as the primary user interface (’023 Patent, Abstract). The method involves using touch gestures to select a transducer, operate imaging parameters via icons located outside the main image window, select from a list of anatomical presets to automatically set parameters, and then further alter those parameters using additional touch gestures (’023 Patent, col. 35:58-col. 36:44).
  • Technical Importance: This method replaced cumbersome physical controls with an intuitive, software-driven touchscreen interface, which is easier to maintain in sterile environments and streamlines the workflow for sonographers (Compl. ¶18-20).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶24, ¶120).
  • Claim 1 is a method claim requiring, in summary, the steps of:
    • Operating a cart-mounted medical ultrasound device that includes a tablet housing with a computer and a touch screen display.
    • Selecting a connected transducer via a touch actuated input on the touch screen.
    • Operating the transducer to display beamformed image data on the battery-powered touch screen.
    • The touch screen has a plurality of touch-actuated icons outside the image display area that operate imaging parameters.
    • Receiving a first touch gesture that selects an imaging parameter preset from a list of anatomic structures.
    • In response to a further touch gesture, altering at least one of the automatically set imaging parameters.
  • The complaint reserves the right to assert dependent claims 2-11, 13-16, and 18-27 (Compl. ¶23).

U.S. Patent No. 12,102,480 - "TABLET ULTRASOUND SYSTEM"

  • Technology Synopsis: The patent describes a portable, cart-mounted ultrasound imaging system comprising a touchscreen tablet that is responsive to touch gestures for selecting and performing various imaging procedures (e.g., cardiac, vascular). The system architecture specifically recites a field programmable gate array (FPGA) to manage the scan sequence and a complex programmable logic device (CPLD) to clock the scan (’480 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶26, ¶88).
  • Accused Features: The complaint accuses the Mindray TEX product, alleging it incorporates the claimed touchscreen tablet, cart-mounted configuration, processor, battery, FPGA, CPLD, and multiport transducer connector (Compl. ¶88).

U.S. Patent No. 11,857,363 - "TABLET ULTRASOUND SYSTEM"

  • Technology Synopsis: This patent is directed to a portable touchscreen ultrasound system that performs specific, advanced imaging procedures in response to gesture inputs. The claims focus on performing a cardiac imaging procedure that measures an ejection fraction value in response to a first gesture and a needle visualization procedure in response to a second gesture on the touchscreen display (’363 Patent, Abstract).
  • Asserted Claims: Independent claim 7 is asserted (Compl. ¶28, ¶104).
  • Accused Features: The complaint accuses the TE7 Accused Product, alleging its touchscreen interface allows users to perform gesture-based cardiac imaging and needle visualization procedures (Compl. ¶104).

U.S. Patent No. 9,877,699 - "TABLET ULTRASOUND SYSTEM"

  • Technology Synopsis: The patent claims a method of operating a handheld medical ultrasound imaging device with a tablet form factor. The method focuses on using touch inputs to actuate a needle guide operation and, in response to a second input, operating the beamformer to image an inserted needle, as well as displaying images in a split-screen format (’699 Patent, Abstract; col. 16:32-47).
  • Asserted Claims: Independent claim 45 is asserted (Compl. ¶30, ¶136).
  • Accused Features: The complaint accuses the TE7 Accused Product, alleging that its operation, particularly its "iNeedle+ technology," involves the claimed steps of receiving touch inputs to actuate a needle guide and image an inserted needle (Compl. ¶64, ¶136).

III. The Accused Instrumentality

Product Identification

  • Mindray’s "TE" family of ultrasound products, including at least the TE5, TE7, TE7 (Crystal), TE7 Max, TE X, and TEX 20 models (Compl. ¶61).

Functionality and Market Context

  • The complaint describes the accused products as tablet-based, portable ultrasound systems that can be mounted on a cart or operated separately (Compl. ¶61, ¶63). The complaint includes a photograph of the TE7 system mounted on a wheeled cart, showing a tablet-style display and a connected transducer probe (Compl. p. 19). A separate photograph shows the Mindray TEX device, also on a cart, which utilizes a larger touchscreen tablet (Compl. p. 20).
  • The devices are alleged to be battery-powered and to utilize touchscreen interfaces for all primary ultrasound operations, including image manipulation and quantitative measurements (Compl. ¶65). The complaint alleges that the beamformer circuitry is located within the tablet display housing, which also includes an integrated multiport connector for attaching transducers (Compl. ¶66, ¶69). Specific features mentioned include "iNeedle+ technology" for automatically detecting needle angle during interventional procedures (Compl. ¶64).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits that are not provided; therefore, the narrative infringement theories are summarized in prose and the claim-chart tables are omitted.

U.S. Patent No. 11,675,073 Infringement Allegations

The complaint alleges that the Mindray TE7 and TEX products directly infringe at least claim 41 of the ’073 Patent (Compl. ¶72). The infringement theory posits that the accused products constitute a "handheld medical ultrasound imaging device" as claimed. This system is alleged to comprise a handheld transducer assembly that connects to a "handheld portable processing unit"—the accused tablet component (Compl. ¶72). The complaint asserts the accused tablet contains the claimed integrated touch screen, processor, memory, and battery, and that its processor is configured with the specific software modules recited in the claim, such as for scan conversion, Doppler processing, and transducer identification (Compl. ¶22, ¶72). The visual of the TE7 system shows the distinct transducer and tablet components connected by a cable, which aligns with the structural elements of the claim (Compl. p. 19).

U.S. Patent No. 12,115,023 Infringement Allegations

The complaint alleges that the use of the Mindray TE7 product directly infringes at least method claim 1 of the ’023 Patent (Compl. ¶120). The theory is that operating the TE7 product involves performing the claimed method steps. This allegedly includes selecting a transducer using a touch input on the cart-mounted tablet display and operating it to display an image powered by a battery on the cart (Compl. ¶24, ¶120). The complaint further alleges that the TE7's touchscreen interface has touch-actuated icons outside the image area and that users employ touch gestures first to select from a list of imaging parameter presets and then to alter those parameters, as recited in the final steps of the claim (Compl. ¶24, ¶120). The depiction of the cart-mounted TEX device is consistent with the system described in the claim's preamble (Compl. p. 20).

Identified Points of Contention

  • Scope Questions: A potential dispute for the ’073 Patent is the scope of "handheld portable processing unit." Defendants may argue that a tablet mounted on a cart is not "handheld," while the Plaintiff may counter that its detachable nature brings it within the claim's scope. For the ’023 Patent, a question may arise as to whether the preamble term "cart mounted" is a strict limitation on the claimed method, potentially raising questions about infringement when the tablet is used detached from the cart.
  • Technical Questions: A key evidentiary question for the ’023 Patent will be whether the accused products' user interface performs the specific, sequential method steps of selecting a preset from a "touch actuated preset selection window" and then altering those parameters with a "further touch gesture." The analysis may focus on the precise workflow and software implementation of the accused devices compared to the claimed steps.

V. Key Claim Terms for Construction

"handheld portable processing unit" (’073 Patent, Claim 41)

  • Context and Importance: This term is central to defining the physical characteristics of the infringing device. The accused products are described as both cart-mountable and detachable (Compl. ¶61, ¶62). Practitioners may focus on this term because its construction will determine whether a device primarily used on a cart but capable of being handheld meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification illustrates embodiments where the processing unit is connected to a separate laptop computer, suggesting the "handheld" quality relates to portability rather than a requirement to be held in the hand during all operations (’073 Patent, Fig. 1; col. 6:21-26). The patent's title, "Modular Portable Ultrasound Systems," may also support a broader focus on portability.
    • Evidence for a Narrower Interpretation: The claim language itself repeats the term "handheld." The detailed description also refers to a "small handheld processing unit" designed to run on battery power (’073 Patent, as found in Compl. ¶14). Figure 2 of the patent shows a fully integrated, handheld device, which could be used to argue for a narrower construction limited to devices of a similar size and form factor.

"a touch actuated preset selection window that lists a plurality of anatomic structures" (’023 Patent, Claim 1)

  • Context and Importance: This term specifies a particular user interface element required by the method. The infringement analysis will depend on whether the accused products' interface for selecting imaging presets functions as a "window" that "lists" structures in the manner claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes a system intended to replace traditional keyboards and knobs with a more intuitive touchscreen interface (’023 Patent, col. 1:31-54). This purpose may support construing "window that lists" broadly to cover various graphical user interface elements that allow users to select from predefined anatomical settings.
    • Evidence for a Narrower Interpretation: The claim language is specific, requiring not just presets, but a "window" that "lists" them. Figures in related patents in the family depict specific graphical user interface layouts with menus and lists, which could be argued to limit the scope of this term to a more traditional drop-down menu or list box rather than a purely icon-based selection screen (’073 Patent, Fig. 15A, element 552).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants actively induce infringement by providing customers with extensive product brochures, onsite training, demonstrations, and instructional seminars that allegedly detail how to use the Accused Products in a manner that performs the steps of the asserted method claims (Compl. ¶58, ¶83, ¶99, ¶115, ¶131, ¶147).
  • Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint alleges pre-suit knowledge stemming from a 2004-2005 OEM relationship where Mindray gained intimate technical knowledge of Teratech's products (Compl. ¶32-37), Mindray's own patent prosecution history citing Teratech's patents (Compl. ¶39-46), and Mindray's stated corporate policy of conducting freedom-to-operate searches (Compl. ¶49-51). The complaint also pleads willful blindness as an alternative theory (Compl. ¶52). Post-suit willfulness is alleged based on continued infringement after the filing of the complaint (Compl. ¶60).

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

  • A central issue will be one of historical knowledge and intent: to what extent does the alleged prior OEM relationship and Mindray's patent prosecution record establish pre-suit knowledge sufficient to support a finding of willfulness? The detailed factual allegations suggest this will be a critical and heavily disputed aspect of the case.
  • A key question of claim scope will be whether a processing unit that is detachable from a cart can be considered "handheld" under the ’073 Patent, and conversely, whether the method of the ’023 Patent is practiced when the tablet is used detached from the "cart" explicitly recited in the claim preamble.
  • An evidentiary question of operational equivalence will be central to the method claims. The case may turn on whether the accused products' touchscreen user interface, when operated, performs the specific sequence of steps required—particularly the interaction with a "preset selection window"—or if there is a fundamental mismatch in its technical workflow compared to the patented method.