Mobile Motherboard Inc v. Partnerships Unincorp Associations

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobile Motherboard Inc. (Texas)
  • Defendant: The Partnerships and Unincorporated Associations Identified on Schedule A (People's Republic of China)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 1:24-cv-08703, N.D. Ill., 10/28/2024
• Venue Allegations: Venue is based on allegations that Defendants target business activities toward consumers in the United States, including Illinois, through interactive commercial internet stores that ship to the district and accept payment in U.S. dollars.
• Core Dispute: Plaintiff alleges that Defendants’ online sales of certain computing devices infringe a U.S. patent related to portable, externally-connected motherboards.
• Technical Context: The technology concerns modular computer architectures where a portable, external unit containing a central processor can provide or augment the computing power of a computer chassis, such as a desktop tower or a display monitor.
• Key Procedural History: The asserted patent is a reissue of U.S. Patent No. 7,990,724. The complaint alleges that Plaintiff sent a notice letter to the Defendants' alleged common administrator on December 22, 2020, informing them of the patent and inviting a license discussion, which may form the basis for allegations of willful infringement.

Case Timeline

Date	Event
2006-12-19	Priority Date for U.S. Reissued Patent No. RE48,365 E
2011-08-02	Issue Date of original U.S. Patent No. 7,990,724
2020-12-22	Issue Date of U.S. Reissued Patent No. RE48,365 E
2020-12-22	Plaintiff allegedly sent notice letter to Defendants' administrator
2024-10-28	Complaint Filing Date

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

U.S. Reissued Patent No. RE48,365 E, "Mobile Motherboard", issued December 22, 2020

The Invention Explained

• Problem Addressed: The patent describes conventional computer motherboards as being integrated inside a "computer box," which makes them difficult to access for upgrades or repairs. This integration also dedicates the motherboard's processing power to a single device, limiting its utility if the host device is idle (RE48,365 E Patent, col. 1:35-52).
• The Patented Solution: The invention is a "portable motherboard" that remains external to the computer's main housing. It connects to the "computer box" through an externally accessible port, thereby providing the system's "brains" (e.g., the central processing unit). This external unit can either bring computing functionality to a "dumb" chassis that lacks a processor or connect to an existing computer to "boost the brainpower" of its internal processor (RE48,365 E Patent, Abstract; col. 2:53-68). Figure 3 illustrates this concept, showing a portable motherboard (300) connecting to an external socket (200) on a computer box (20).
• Technical Importance: The described technology aims to make processing power modular and portable, decoupling the central processor from a single, fixed computer chassis and allowing it to be used with multiple devices (RE48,365 E Patent, col. 1:48-52).

Key Claims at a Glance

• The complaint asserts independent claims 1, 11, 23, and 24, as well as several dependent claims (Compl. ¶21, ¶25, ¶27). The full analysis will focus on independent claims 1 and 11, which represent two distinct embodiments.
• Independent Claim 1: A computer system comprising:
  • A computer box without a processor for performing computing operations, which includes a housing and internal bus.
  • A "portable and handholdable motherboard external to the housing" that includes a central processor, a motherboard bus, and a connector.
  • Connection of the external motherboard to the computer box enables the box to perform computing operations.
  • The motherboard includes "Northbridge and Southbridge circuitry."
• Independent Claim 11: A computer system comprising:
  • A computer box that already includes a first central processor.
  • A "portable and handholdable motherboard external to the housing" that includes a second central processor.
  • Connection of the external motherboard "enables said second central processor to add to the central processing functions of said first central processor."
  • The motherboard includes "Northbridge and Southbridge circuitry."
• The complaint reserves the right to assert additional claims, including dependent claims 3, 7, 13, 17, 21, 22, and 23 (Compl. ¶21, ¶25).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "the computing device shown in Exhibit 1" and refers to them generally as the "Infringing Products" (Compl. ¶5).

Functionality and Market Context

The complaint alleges that Defendants sell these products through various online storefronts (Compl. ¶2). The infringement theory appears to be that the Infringing Products function as the claimed "portable and handholdable motherboard," while a separate device owned by the customer—such as an HD TV, monitor, or projector—functions as the claimed "computer box" (Compl. ¶26, ¶27). The complaint references an image of the accused product in its Exhibit 1, which shows the computing device at issue (Compl. ¶5). The products are alleged to be sold to consumers for use with screens, which Defendants allegedly admit (Compl. ¶22).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits 3 and 4) that are not provided with the pleading itself. Therefore, a detailed element-by-element analysis is not possible. The infringement theory must be summarized from the narrative allegations in the complaint.

The central infringement theory is one of divided infringement. Plaintiff alleges that the Defendants sell a component of the patented system—the "Infringing Products" which allegedly satisfy the "motherboard" limitations—and that direct infringement occurs when customers combine this component with their own hardware (e.g., a TV or monitor) that allegedly satisfies the "computer box" limitation (Compl. ¶26, ¶27). To support this, Plaintiff alleges that Defendants induce infringement by "explicitly instruct[ing] their customers to use the Infringing Products with a 'computer box'" through marketing materials and claim charts (Compl. ¶26).

• Identified Points of Contention:
  • Divided Infringement: A central issue will be whether Plaintiff can prove the elements of induced infringement. The analysis will question whether Defendants' instructions or marketing materials establish that they knew of the patent and specifically intended for their customers to perform the final, infringing step of combining the product with a "computer box" in the manner claimed. The complaint's reference to user instructions is intended to support this point (Compl. ¶26).
  • Technical Questions: The asserted independent claims require the portable motherboard to include "Northbridge and Southbridge circuitry" ('365 Patent, claims 1, 11, 23, 24). A key technical question will be whether the accused products, which may be modern System-on-a-Chip (SoC) devices, contain architectures that can be fairly characterized as having separate Northbridge and Southbridge chipsets, as that architecture is largely obsolete.
  • Scope Questions: The infringement theory depends on construing a customer's television or monitor as the claimed "computer box." A point of contention may be whether the term "computer box," which is illustrated in the patent as a traditional desktop PC tower (e.g., '365 Patent, Fig. 1), can be interpreted to cover modern display devices that may have their own integrated processing capabilities.

V. Key Claim Terms for Construction

• The Term: "computer box"

• Context and Importance: This term is critical because the plaintiff’s infringement theory requires a customer's TV or monitor to meet this limitation. The outcome of the case may depend on whether this term is construed broadly enough to cover such devices.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification states, "By 'computer box' is meant a housing of any form factor that in the prior art contains a motherboard with central processing unit" ('365 Patent, col. 2:57-60). Parties advocating for a broad reading may argue that "any form factor" is inclusive language not limited to the embodiment shown.
  • Evidence for a Narrower Interpretation: The patent’s figures consistently depict a traditional desktop PC tower (e.g., Fig. 1, element 5; Fig. 3, element 20). Parties advocating for a narrower reading may argue that the term should be limited to such housings, which are distinct from integrated display devices like modern televisions.

• The Term: "without a processor for performing computing operations"

• Context and Importance: This limitation from independent claim 1 is central to distinguishing it from claim 11. Practitioners may focus on this term because many modern TVs and monitors (the alleged "computer boxes") contain their own processors or SoCs for smart functions, potentially creating a significant factual dispute over whether they are truly "without a processor."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The complaint does not provide detail for this analysis.
  • Evidence for a Narrower Interpretation: The patent appears to contemplate a truly "dumb" terminal or housing, as the purpose of the invention in this embodiment is to "bring[] life to a computer box" that otherwise has no processing capability ('365 Patent, Abstract). An opponent could argue this language implies a complete absence of computing functionality.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendants provide the "motherboard" component and instruct customers, via marketing materials and other means, to combine it with a "computer box" (e.g., a TV or monitor) to create the infringing system (Compl. ¶25-¶26). It further alleges contributory infringement, asserting the products are specially made for infringement and have no substantial non-infringing uses (Compl. ¶27).
• Willful Infringement: Willfulness is alleged based on both pre- and post-suit conduct (Compl. ¶18, ¶28). The complaint alleges pre-suit knowledge based on a notice letter sent to the Defendants' administrator on December 22, 2020 (Compl. ¶26).

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

• A core issue will be one of divided infringement: can Plaintiff provide sufficient evidence that Defendants, with knowledge of the patent, specifically intended to cause their customers to assemble the final, patented system, thereby satisfying the high bar for induced infringement?
• The case will also turn on a question of definitional scope: can the term "computer box," which is rooted in the patent's depiction of a PC tower, be construed to cover the modern smart televisions and monitors that customers allegedly use with the accused devices?
• Finally, a key evidentiary question will be one of technical equivalency: do the accused products, likely based on modern System-on-a-Chip designs, contain the specific "Northbridge and Southbridge circuitry" explicitly required by all asserted independent claims, or is there a fundamental mismatch in their technical architecture compared to what is claimed?