DCT
1:25-cv-12531
Bose Corp v. IngenioSpec LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Bose Corporation (Delaware)
- Defendant: IngenioSpec, LLC (California)
- Plaintiff’s Counsel: Bond, Schoeneck & King, PLLC
- Case Identification: 1:25-cv-12531, D. Mass., 09/10/2025
- Venue Allegations: Plaintiff Bose Corporation alleges venue is proper in the District of Massachusetts because a substantial part of the events occurred there, as Bose resides, designs, and sells products in Massachusetts, and Defendant IngenioSpec directed patent enforcement communications into the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its audio earbud products do not infringe four of Defendant’s patents related to head-worn electronic devices with features such as electrical connectors, charging systems, and wireless communication.
- Technical Context: The technology at issue resides in the highly competitive consumer electronics market for wearable audio devices, such as wireless earbuds, which integrate audio, communication, and power functions into compact form factors.
- Key Procedural History: This declaratory judgment action was filed by Bose following the voluntary dismissal of a patent infringement lawsuit previously filed by IngenioSpec against Bose in the Eastern District of Texas ("the Texas Suit"). Bose alleges that it filed a Motion to Dismiss for Improper Venue and a Rule 11 Motion for Sanctions in the Texas Suit, asserting that IngenioSpec’s venue allegations were demonstrably false, which precipitated the dismissal and created the justiciable controversy underlying this action.
Case Timeline
| Date | Event |
|---|---|
| 2003-04-15 | ’789 Patent Priority Date |
| 2004-07-28 | ’518, ’2901, and ’4901 Patents Priority Date |
| 2013-11-12 | ’789 Patent Issue Date |
| 2020-01-15 | Bose announces closure of all North American retail stores |
| 2020-01-31 | Bose's former retail store in Plano, Texas closes |
| 2023-11-28 | ’518 Patent Issue Date |
| 2023-12-26 | ’2901 Patent Issue Date |
| 2023-12-26 | ’4901 Patent Issue Date |
| 2024-06-20 | IngenioSpec sends license/sale offer communication to Bose's CEO |
| 2024-10-07 | IngenioSpec files the "Texas Suit" against Bose |
| 2024-11-27 | Bose files Motion to Dismiss for Improper Venue in Texas Suit |
| 2024-12-11 | IngenioSpec stipulates to dismissal of the Texas Suit |
| 2025-09-10 | Complaint for Declaratory Judgment Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,829,518 - Head-Worn Device with Connection Region (issued Nov. 28, 2023)
The Invention Explained
- Problem Addressed: The patent’s background section describes the inconvenience of using portable electronic devices, such as removing a music player from a pocket or being unable to view a mobile phone’s screen while holding it to one's ear for a call (ʼ518 Patent, col. 3:10-44).
- The Patented Solution: The invention proposes embedding electronic components directly into an eyewear frame to create a hands-free experience (ʼ518 Patent, col. 4:60-65). The specification describes a head-worn device, such as glasses, incorporating a speaker, microphone, rechargeable battery, touch-sensitive surface, and an electrical connector with conductive pads designed to removably couple with an external counterpart connector, for example, for charging or data transfer (ʼ518 Patent, Abstract; Fig. 5).
- Technical Importance: This approach sought to improve the usability of personal electronics by integrating their functions into a common wearable accessory, thereby reducing the need for users to handle multiple separate devices.
Key Claims at a Glance
- The complaint asserts non-infringement of at least Claim 1 (Compl. ¶43).
- The essential elements of independent Claim 1 are:
- A head-worn wireless electronic apparatus for producing audio outputs.
- A speaker.
- An electrical connector with at least two conductive pads on a surface of the apparatus.
- The conductive pads are configured to removably couple to corresponding contacts of a counterpart connector, at least via spring-force.
- A rechargeable battery.
- A microphone.
- A touch-sensitive input surface.
U.S. Patent No. 12,044,901 - System for Charging Embedded Battery in Wireless Head-Worn Personal Electronic Apparatus (issued Dec. 26, 2023)
The Invention Explained
- Problem Addressed: As with the related ʼ518 patent, the background addresses the cumbersome nature of handling separate portable electronic devices and the need for improved hands-free solutions (ʼ4901 Patent, col. 3:11-56).
- The Patented Solution: The invention claims a system that includes both a "head-worn personal electronic apparatus" and a corresponding "charging apparatus" (ʼ4901 Patent, col. 5:6-8). The head-worn device contains a speaker, battery, and touch surface within a "head-worn structure" and has an exposed conductive element. The charging apparatus has a mating connector, allowing the user to place the head-worn device into the charger to establish an electrical connection for recharging the battery (ʼ4901 Patent, Abstract).
- Technical Importance: This patent describes a dedicated, integrated charging system for wearable electronics, aiming to simplify the recharging process through a docking-style mechanism.
Key Claims at a Glance
- The complaint asserts non-infringement of at least Claim 1 (Compl. ¶54).
- The essential elements of independent Claim 1 are:
- A system comprising a head-worn personal electronic apparatus and a charging apparatus.
- The head-worn apparatus includes a "head-worn structure," a speaker, a touch sensitive surface, a rechargeable battery, electronic circuitry, wireless communication circuitry, and at least one partially exposed conductive element.
- The charging apparatus has a charging connector.
- Placement of the head-worn apparatus in the charging apparatus results in an electrical connection between the conductive element and the charging connector, enabling the battery to be recharged.
U.S. Patent No. 8,582,789 - Hearing Enhancement Systems (issued Nov. 12, 2013)
- Technology Synopsis: The ʼ789 Patent discloses a hearing enhancement apparatus that wirelessly couples to an audio system. The apparatus receives up-converted audio signals, down-converts them, and then modifies the signals "based on at least one hearing characteristic of the user" before outputting the sound through a speaker (ʼ789 Patent, Abstract; Compl. ¶67).
- Asserted Claims: At least Claim 1 is asserted, with Claim 13 provided as exemplary (Compl. ¶65, 67).
- Accused Features: IngenioSpec has accused Bose's hearing enhancement systems, which allegedly receive, down-convert, and modify wireless signals based on a user's hearing characteristic (Compl. ¶36).
U.S. Patent No. 11,852,901 - Wireless Headset Supporting Messages and Hearing Enhancement (issued Dec. 26, 2023)
- Technology Synopsis: The ʼ2901 Patent describes a wireless wearable device configured to be secured to a user's head to aid in hearing. The device includes capabilities to wirelessly receive text or audio messages from a mobile phone via Bluetooth and to provide a notification to the user, and it uses a multi-microphone arrangement to reduce ambient noise ('2901 Patent, Abstract; Compl. ¶78).
- Asserted Claims: At least Claim 10 is asserted (Compl. ¶76).
- Accused Features: IngenioSpec has accused Bose's "wireless wearable devices" (Compl. ¶37).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "Bose QuietComfort Ultra Earbuds" as the "Accused Products" based on allegations made in the prior Texas Suit (Compl. ¶33).
Functionality and Market Context
The complaint provides limited independent technical details about the accused products' operation. It primarily relays IngenioSpec’s prior allegations, which describe the products as "wireless electronic devices configured to produce audio output" that feature a touch-sensitive surface, a rechargeable battery, and are "configured to removably couple to conductive contacts of a counterpart connector" (Compl. ¶34, 35). The complaint's procedural history section includes a screenshot of a Google Maps search result for a former Bose retail store, which indicates the store is "Permanently closed" (Compl. ¶29). This visual is used to support Bose's contention that venue was improper in the Texas Suit, thereby establishing the controversy for this declaratory judgment action. Additionally, in a separate count for unfair competition, the complaint includes a screenshot of Defendant's "INGENIOAUDIO" earbuds from its website, which provides context for the general product category at issue (Compl. ¶87).
IV. Analysis of Infringement Allegations
As this is a complaint for declaratory judgment of non-infringement, the following tables summarize Plaintiff Bose’s stated non-infringement positions.
’518 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an electrical connector at the head-worn wireless electronic apparatus, wherein the electrical connector includes at least two conductive pads... configured to removably couple to corresponding conductive contacts of a counterpart connector... at least via spring-force... | The complaint argues the Accused Products do not contain conductive pads that couple via spring-force as required by the claim. | ¶48 | col. 8:8-10 |
| a rechargeable battery in the head-worn wireless electronic apparatus; | The complaint does not provide sufficient detail for analysis of this element. | col. 5:25-26 | |
| a microphone in the head-worn wireless electronic apparatus; and | The complaint does not provide sufficient detail for analysis of this element. | col. 5:27-28 | |
| a touch-sensitive input surface on the head-worn wireless electronic apparatus... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:34-40 |
’4901 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a head-worn structure configured to be worn by a user; | The complaint argues the Accused Products are not "head-worn structures," contending that all devices disclosed in the patent are eyewear and that the term is not used in the specification. | ¶59 | col. 5:10-11 |
| a speaker at least partially contained within the head-worn structure... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:12-15 | |
| a touch sensitive surface at least partially contained within the head-worn structure... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:40-43 | |
| at least one conductive element at least partially included within the head-worn structure... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:21-24 | |
| wherein on placement of the head-worn personal electronic apparatus in the charging apparatus, electrical connection results... | The complaint does not provide sufficient detail for analysis of this element. | col. 5:6-33 |
- Identified Points of Contention:
- Scope Questions: The dispute over the ʼ4901 patent raises the question of whether the claim term "head-worn structure" can be construed to cover in-ear earbuds when Bose alleges the patent’s specification only discloses eyewear devices. For the ʼ518 patent, a central question is the scope of "at least via spring-force," and whether it requires a particular type of mechanical connection that the accused products may not possess.
- Technical Questions: A key factual question will be how the electrical contacts on the Bose QuietComfort Ultra Earbuds and their charging case actually function. The analysis will require evidence comparing this real-world operation to the specific "spring-force" limitation recited in claim 1 of the ʼ518 patent.
V. Key Claim Terms for Construction
The Term: "head-worn structure" (from Claim 1 of the ʼ4901 Patent)
- Context and Importance: The definition of this term is dispositive for Bose's stated non-infringement theory regarding the ʼ4901 patent. A narrow construction limited to the eyewear embodiments disclosed in the specification would support a finding of non-infringement by Bose's earbuds. Practitioners may focus on this term because Bose’s complaint alleges that the specification exclusively discloses eyewear devices, raising a potential prosecution history estoppel or written description argument to limit the claim's scope (Compl. ¶59).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the claim term "head-worn structure" is facially broad and does not explicitly recite "eyewear."
- Evidence for a Narrower Interpretation: The complaint alleges that the specification of the ʼ4901 patent does not use the term and that all disclosed embodiments are eyewear devices (Compl. ¶59). The abstract of the related ʼ518 patent, which shares a common specification, refers to "an eyewear frame" ('518 Patent, Abstract).
The Term: "at least via spring-force" (from Claim 1 of the ʼ518 Patent)
- Context and Importance: This term is critical to Bose's non-infringement argument for the ʼ518 patent. The case may turn on whether the mechanism connecting the Bose earbuds to their charger meets this limitation, either literally or under the doctrine of equivalents.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The phrase "at least via" could be interpreted to mean that spring-force is one non-limiting example of a connection mechanism.
- Evidence for a Narrower Interpretation: The specification explicitly describes using the elasticity of "soft PVC material" to provide a "spring-force to keep the contacts connected" (ʼ518 Patent, col. 8:6-10). This specific disclosure of a physical, material-based spring action could be used to argue for a narrower construction that excludes other connection means, such as magnetism.
VI. Other Allegations
- Indirect Infringement: The complaint states that in the prior Texas Suit, IngenioSpec alleged that Bose induced infringement by "actively encourage[ing] and instruct[ing] customers and other companies to make, use, sell, import, and offer for sale" the Accused Products in infringing ways (Compl. ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "head-worn structure," which appears in a patent family with a specification heavily focused on eyewear embodiments, be construed broadly enough to read on the in-ear form factor of the accused earbuds?
- A key technical question will be one of mechanistic interpretation: does the limitation "at least via spring-force" require a specific type of mechanical spring action for an electrical connection, and does the charging mechanism of the accused Bose products operate in a fundamentally different manner?
- A procedural question will be the effect of the prior Texas litigation and dismissal on this action, particularly how the specific infringement allegations made in that case define the scope of the justiciable controversy for Bose's declaratory judgment claims.