DCT
1:23-cv-04762
Fantasia Trading LLC v. Ministrap LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fantasia Trading, LLC d/b/a AnkerDirect (Delaware/California)
- Defendant: Ministrap, LLC., and Joseph Schultz (Georgia)
- Plaintiff’s Counsel: Rimon P.C.; Taylor English Duma LLP
- Case Identification: 1:23-cv-04762, N.D. Ga., 10/18/2023
- Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because Defendant Ministrap, LLC is a Georgia company with its principal place of business in the district, and Defendant Joseph Schultz is a resident of the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Anker-branded charging cables do not infringe three of Defendants’ patents related to secure strap systems.
- Technical Context: The technology at issue involves reusable, self-fastening straps, often made of hook-and-loop material, designed for organizing and bundling elongated objects such as consumer electronics cables.
- Key Procedural History: This declaratory judgment action was filed in response to a series of patent infringement lawsuits filed by Defendant Ministrap on July 14, 2023, in the Eastern District of Texas against several of Plaintiff’s major retail partners, including Best Buy, Costco, Target, and Walmart, alleging infringement by the same Anker products.
Case Timeline
| Date | Event |
|---|---|
| 2001-03-07 | Priority Date for ’796, ’000, and ’824 Patents |
| 2009-09-15 | U.S. Patent No. 7,587,796 Issues |
| 2013-02-12 | U.S. Patent No. 8,371,000 Issues |
| 2016-07-12 | U.S. Patent No. 9,386,824 Issues |
| 2023-07-14 | Ministrap files infringement lawsuits against Anker resellers |
| 2023-10-18 | Fantasia (Anker) files this Declaratory Judgment Complaint |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,587,796 - Secure Strap Systems, issued September 15, 2009 (’796 Patent)
The Invention Explained
- Problem Addressed: The patent’s background identifies a need for a fastening system that can securely bundle multiple sets of objects (e.g., a power cord and its plug) while allowing for the selective and independent release of one set without unfastening the other (’796 Patent, col. 2:1-6). Prior art single-loop straps were described as insufficient for this purpose (’796 Patent, col. 1:57-65).
- The Patented Solution: The invention is a unitary fastening strap constructed with at least two elongated strap portions and an aperture positioned between them. This structure allows for the formation of two independent loops, enabling a user to bundle two separate items or sets of items with a single strap device (’796 Patent, Abstract; col. 12:1-10). The patent describes specific geometric configurations, including one where the two strap portions are arranged in a "parallel and collinear" relationship (’796 Patent, col. 14:43-48, Fig. 6).
- Technical Importance: This design offers enhanced organizational capability over simple single-loop cable ties by providing a single, integrated solution for managing multiple, related objects independently (’796 Patent, col. 2:3-6).
Key Claims at a Glance
- The complaint’s first claim for relief focuses on independent claim 1 of the ’796 Patent (Compl. ¶27).
- Essential elements of independent claim 1 include:
- A fastening strap system with at least a first and a second elongated strap portion and at least one aperture.
- The system "consists essentially of a unitary portion of flexible sheet material" with complementary first and second fastening surfaces.
- A specific geometric arrangement where "all said at least one first elongated strap portions and all said at least one second elongated strap portions are parallel and collinear."
- The aperture is located between the end portions of the first and second strap portions.
- The aperture is sized to receive the first elongated strap portion to allow for cinching.
- The complaint states that Plaintiff has not infringed any independent claims or their dependents (Compl. ¶26).
U.S. Patent No. 8,371,000 - Secure Strap Systems, issued February 12, 2013 (’000 Patent)
The Invention Explained
- Problem Addressed: The patent addresses the same technical problem as the ’796 Patent: the limitations of prior art straps in independently securing multiple bundles of items (’000 Patent, col. 2:1-10).
- The Patented Solution: This patent describes a similar dual-loop strap system but focuses on an alternative geometric configuration. The solution is a unitary strap where a second strap portion is "offset parallel" from a first strap portion by a specific distance, namely "a distance about equal to said at least one first strap width" (’000 Patent, col. 3:11-16). This offset design, illustrated in figures such as Fig. 3, also facilitates the creation of two independent fastening loops from a single device (’000 Patent, col. 17:3-9).
- Technical Importance: Like the ’796 Patent, this design provides a more versatile cable management solution than a standard single-loop strap by allowing for the independent bundling of multiple objects (’000 Patent, col. 2:3-6).
Key Claims at a Glance
- The complaint’s second claim for relief focuses on independent claim 1 of the ’000 Patent (Compl. ¶35).
- Essential elements of independent claim 1 include:
- A fastening strap system with at least first and second strap portions and a joining strap portion.
- The system has complementary first and second fastening surfaces.
- A specific geometric and dimensional arrangement where "said at least one second strap portion is offset parallel from said first strap portion a distance about equal to said at least one first strap width."
- All first and second strap portions are parallel.
- The complaint states Plaintiff has not infringed any independent claims or their dependents (Compl. ¶34).
Multi-Patent Capsule: U.S. Patent No. 9,386,824 - Secure Strap Systems, issued July 12, 2016 (’824 Patent)
- Technology Synopsis: This patent, part of the same family, also describes a secure strap system for independently bundling multiple sets of elongated objects (’824 Patent, Abstract). The invention is a unitary strap made of a flexible material with at least two elongated strap portions arranged in an "offset parallel" configuration, which allows for the creation of two distinct, cinching loops to secure objects independently of one another (’824 Patent, col. 2:2-11).
- Asserted Claims: The complaint's third claim for relief identifies independent claim 1 (Compl. ¶43).
- Accused Features: The complaint alleges that the Anker products do not have the claimed structure of a "second elongated strap portion" that is "offset parallel from said first elongated strap portion a distance about equal to said at least one first strap width" (Compl. ¶43).
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused instrumentalities as "Anker Relevant Product," which are various Anker-branded charging cables that include integrated straps or strap systems (Compl. ¶¶ 15-19). Specific examples pictured in the complaint exhibits include the "Anker PowerLine Select+ USB-A Cable with Lightning Connector" and the "Anker Powerline+ II Braided USB-A to Lightning Cable" (Compl. Ex. D, ¶18; Ex. G, ¶19).
Functionality and Market Context
- The relevant functionality is an integrated strap used for cable management, allowing a user to keep the cable coiled for storage or transport (Compl. Ex. G, ¶19). A screenshot from a retailer website shows an Anker cable coiled and secured by its integrated strap within a carrying case (Compl. Ex. G, p. 9). The complaint asserts that Anker is a "global leader in technology for charging electronics" and its products are distributed through major U.S. retail channels (Compl. ¶11).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement, arguing that the Anker products lack key structural limitations of the asserted claims.
’796 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality (as argued by Plaintiff) | Complaint Citation | Patent Citation |
|---|---|---|---|
| all said at least one first elongated strap portions and all said at least one second elongated strap portions are parallel and collinear | The Anker Relevant Products are alleged not to include this feature, as they do not have two distinct strap portions arranged in a parallel and collinear configuration. | ¶27 | col. 22:8-10 |
’000 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality (as argued by Plaintiff) | Complaint Citation | Patent Citation |
|---|---|---|---|
| said at least one second strap portion is offset parallel from said first strap portion a distance about equal to said at least one first strap width | The Anker Relevant Products are alleged not to include this feature, as they do not have two distinct strap portions with the claimed offset parallel relationship and dimensions. | ¶35 | col. 31:7-9 |
- Identified Points of Contention:
- Scope Questions: The central dispute for all three patents raises the question of whether the claims require a strap manufactured with at least two physically distinct and geometrically arranged "portions" (as depicted in the patent figures), or if a simple, single-body strap that can be folded or wrapped could be interpreted as meeting these structural limitations. For example, does the claim term "at least one first elongated strap portion" require a structure that is physically distinct from the "at least one second elongated strap portion"? The complaint's photographs of the Anker products, such as the multi-pack of cables, appear to show a simple, single-tongue strap on each cable (Compl. Ex. E, p. 6).
- Technical Questions: For the ’000 and ’824 Patents, a key technical question is whether the Anker straps, in any configuration, create an offset that is "about equal to said at least one first strap width." This introduces a specific dimensional requirement that Plaintiff argues its products do not meet (Compl. ¶¶ 35, 43). The evidence presented will need to address the actual physical structure and dimensions of the accused straps.
V. Key Claim Terms for Construction
For the ’796 Patent:
- The Term: "parallel and collinear"
- Context and Importance: This geometric term is the explicit basis for Plaintiff's non-infringement argument for the ’796 Patent (Compl. ¶27). The construction of this term will be critical, as it defines the required spatial relationship between the "first" and "second" strap portions.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant might argue that the term "portion" does not require two physically separate arms and that a single strap folded back on itself could create sections that are temporarily "parallel and collinear."
- Evidence for a Narrower Interpretation: The plain meaning of "collinear" suggests lying on the same straight line. The patent explicitly uses the heading "parallel-relationship two-ended strap" to describe the embodiment in Fig. 6, which shows two distinct, side-by-side arms extending from a common base, reinforcing a specific, manufactured structure rather than a temporary fold (’796 Patent, col. 14:43-44, Fig. 6).
For the ’000 Patent and ’824 Patent:
- The Term: "offset parallel from said first strap portion a distance about equal to said at least one first strap width"
- Context and Importance: This phrase combines geometric ("offset parallel") and dimensional ("distance about equal to... width") limitations and is the core of the non-infringement argument for the ’000 and ’824 Patents (Compl. ¶¶ 35, 43). Practitioners may focus on this term because it is highly specific and appears to describe a distinct physical structure.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A defendant could argue that the term "about equal" provides significant flexibility and that various folded configurations of a single strap could satisfy this limitation.
- Evidence for a Narrower Interpretation: The patent specification repeatedly describes the invention in terms of its specific structure for creating two independent loops (’000 Patent, col. 2:3-10). The figures corresponding to this embodiment, such as Fig. 3, depict a unitary strap manufactured with a specific, permanent offset shape, suggesting the claim requires this structure rather than a temporary arrangement created by a user (’000 Patent, Fig. 3).
VI. Other Allegations
- Indirect Infringement: Plaintiff seeks a declaratory judgment that it has not induced infringement by its customers, distributors, or end-users (Compl. ¶22). The complaint anticipates that a claim of inducement would be based on Plaintiff making the accused products available for sale and use (Compl. ¶21).
- Willful Infringement: While not a claim made by Plaintiff, the complaint alleges that Defendants' lawsuits against its resellers were filed "purposefully and maliciously" and with knowledge that the Anker products could not infringe the patents (Compl. ¶52). This allegation forms the basis for Plaintiff's state-law tortious interference claim and its request for a finding that the case is "exceptional" under 35 U.S.C. § 285, which would entitle it to attorneys' fees (Compl. ¶52; Prayer for Relief ¶e).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this declaratory judgment action will likely depend on the court's determination of the following key questions:
- A core issue will be one of structural scope: Do the claims require a fastening strap to be manufactured with a specific, multi-portion geometry (e.g., "parallel and collinear" or "offset parallel"), as depicted in the patent figures, or can the claim language be construed to cover the seemingly conventional, single-body strap used on the accused Anker products?
- A key evidentiary question will be one of factual correspondence: Assuming the claims are construed to require specific geometric and dimensional relationships, does the physical evidence show that the accused Anker straps meet these limitations, either literally or under the doctrine of equivalents? The dispute centers on whether the accused products have the claimed "first" and "second" strap portions at all.
- A significant procedural question is whether the plaintiff's preemptive declaratory judgment action in Georgia will take precedence over or otherwise affect the earlier-filed infringement actions by the defendant against the plaintiff's customers in the Eastern District of Texas.