DCT
0:18-cv-00188
Ideative Product Ventures Inc v. Milestone Av Tech LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ideative Product Ventures, Inc. (Texas)
- Defendant: Milestone AV Technologies LLC d/b/a Sanus (Delaware)
- Plaintiff’s Counsel: Larkin Hoffman Daly & Lindgren LTD.
- Case Identification: 0:18-cv-00188, D. Minn., 01/23/2018
- Venue Allegations: Venue is alleged to be proper in the District of Minnesota because the Defendant has its principal place of business in Eden Prairie, Minnesota, and sells the accused products within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Pivoting Head HDMI Cables infringe a patent related to electronic connectors with multiple degrees of rotational freedom.
- Technical Context: The technology concerns articulating connectors for audio/visual cables and other peripherals, designed to allow connections in confined spaces where rigid connectors are impractical.
- Key Procedural History: The patent-in-suit is a continuation of an earlier U.S. application that issued as a patent. No other prior litigation, licensing history, or post-grant proceedings are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2002-08-02 | Earliest Priority Date for U.S. Patent 7,494,343 |
| 2009-02-24 | U.S. Patent 7494343 Issues |
| 2018-01-23 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,494,343 - “Multiple Degrees Of Freedom Connectors And Adapters”
- Patent Identification: U.S. Patent No. 7,494,343 (“Multiple Degrees Of Freedom Connectors And Adapters”), issued February 24, 2009.
The Invention Explained
- Problem Addressed: The patent addresses the problem of rigid electronic connectors that extend directly from a device, making them susceptible to damage and making it difficult to connect peripherals in tight spaces, such as behind wall-mounted televisions or next to other equipment (’343 Patent, col. 1:26-40). The patent notes that physical conflicts between the housings of a host device and a peripheral can prevent a successful connection (’343 Patent, col. 1:47-54).
- The Patented Solution: The invention is a connector mechanism that provides multiple, distinct degrees of rotational freedom. It describes a central "intermediate member" with two connection axes set at a right angle, allowing two connector "heads" to rotate independently in two orthogonal planes (’343 Patent, Abstract; col. 2:16-23). This structure is illustrated in Figures 2A and 2B, which show rotation in a side-view plane (Y-Z plane) and a top-view plane (X-Z plane) (’343 Patent, Figs. 2A, 2B).
- Technical Importance: This approach allows a connected cable or peripheral device to be folded or rotated into a low-profile position close to the host device, overcoming the physical constraints imposed by traditional, fixed connectors (’343 Patent, col. 2:7-12).
Key Claims at a Glance
- The complaint alleges infringement of "one or more claims" without specifying them, but the allegations map closely to the elements of independent claims 1 and 33 (Compl. ¶15). Independent Claim 1 is representative.
- Independent Claim 1 requires:
- An intermediate member with first and second ends defining substantially orthogonal connection axes.
- A first head rotatably connected to the first end, limited to rotation in a first plane.
- A first electronic connector on the first head.
- A second head rotatably connected to the second end, limited to rotation in a second plane.
- A second electronic connector on the second head, in electrical communication with the first.
- At least one of the heads must be rotatable more than 90-degrees relative to the intermediate member.
III. The Accused Instrumentality
Product Identification
- The accused products are the "10' Pivoting Head HDMI Cable" and "6' Pivoting Head HDMI Cable," sold under the Sanus brand (Compl. ¶4). The complaint identifies the "Sanus SOA-PH6 360 Degree Pivoting HDMI Cable" as a representative product (Compl. ¶19).
Functionality and Market Context
- The accused products are described as HDMI cables with articulating connectors designed to "allow connecting HDMI cables in tight spaces behind HD components such as mounted flat screen TVs without having to bend cables sharply" (Compl. ¶9). The complaint alleges the connector mechanism includes an "intermediate member" that facilitates rotation around two separate, orthogonal axes (Compl. ¶20). An annotated photograph in the complaint identifies this "Intermediate Member" as the elbow-shaped component of the connector housing (Compl. ¶20, p. 6).
- The complaint alleges Defendant sells these products through consumer electronics dealers and its own e-commerce website (Compl. ¶6).
IV. Analysis of Infringement Allegations
Claim Chart Summary
- The following table summarizes the infringement allegations for the representative independent claim, mapping the elements of Claim 1 of the ’343 Patent to the accused product features as described in the complaint.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an intermediate member having a first end defining a first connection axis and having a second end defining a second connection axis, the first and second connection axes being substantially orthogonal | The accused cable has an "intermediate member" with a first connection axis permitting rotation perpendicular to the page and a second connection axis permitting rotation parallel to the page. The complaint provides an annotated image highlighting this L-shaped component. | ¶20 | col. 5:7-11 |
| a first head rotatably connected to the first end of the intermediate member and limited to rotation in a first plane on the first connection axis | The accused cable has a "rotatable head" attached to the intermediate member that rotates in a first plane. | ¶21 | col. 5:12-15 |
| a first electronic connector on the first head connectable to a first electronic device | The first head of the accused product has an electronic HDMI connector. | ¶22 | col. 5:16-18 |
| a second head rotatably connected to the second end of the intermediate member and limited to rotation in a second plane on the second connection axis | The accused cable has a second head that "rotates in a plane parallel to this page when the cable is oriented as shown." | ¶23 | col. 5:19-22 |
| a second electronic connector on the second head connectable to a second electronic device, the second electronic connector in electrical communication with the first electronic connector through the intermediate member | The accused product has a second electronic connector on the far end of the cable that is in electrical communication with the first, allowing it to carry an HDMI signal. | ¶24 | col. 5:23-27 |
| wherein at least one of the first and second heads is rotatable on its connection axis more than 90-degrees relative to the intermediate member | The complaint alleges the accused cable can rotate about its second connection axis "180-degrees relative to the intermediate member" and provides a visual showing this range of motion. | ¶25 | col. 5:27-29 |
Identified Points of Contention
- Scope Questions: A potential dispute may arise over the term "substantially orthogonal." The patent's figures depict a clear 90-degree angle, but the use of "substantially" introduces ambiguity. The case may require the court to determine how much deviation from a perfect right angle is permissible for the accused product's two rotational axes to fall within the claim scope.
- Technical Questions: The claims require movement to be "limited to rotation" in two distinct planes. The complaint's photographic evidence shows the connector in different positions but does not detail the internal mechanics that would prove the movement is constrained as required. A key question for the court will be whether the accused connector's joints restrict motion to two specific planes or if they permit more complex, multi-axis movement that might fall outside the literal scope of the claims.
V. Key Claim Terms for Construction
The Term: "intermediate member"
- Context and Importance: This term describes the core structural component that links the two rotating heads and their orthogonal axes. Its construction is critical, as the complaint’s infringement theory relies on identifying a specific part of the accused connector housing as this "intermediate member" (Compl. ¶20, p. 6).
- Intrinsic Evidence for a Broader Interpretation: The patent summary describes a "connection mechanism coupling the first and second connector heads," suggesting a functional definition that could encompass any structure performing that role (’343 Patent, col. 2:18-20).
- Intrinsic Evidence for a Narrower Interpretation: The patent figures consistently depict this element as a distinct, L-shaped structural component that houses the two separate rotation mechanisms (’343 Patent, Figs. 2A, 6A, 7A). A party could argue that the term is limited to this specific illustrated embodiment.
The Term: "limited to rotation in a first plane"
- Context and Importance: This term defines the nature of the claimed mechanical movement. The infringement analysis depends on whether the accused device's joints are constrained to planar rotation, as opposed to, for example, a ball-and-socket joint that allows non-planar movement.
- Intrinsic Evidence for a Broader Interpretation: The patent does not provide a detailed mechanical description of the joint itself, which a party could argue supports a more general interpretation covering any joint that primarily facilitates rotation in a single plane, even with some incidental wobble.
- Intrinsic Evidence for a Narrower Interpretation: The specification discusses using "a hinge for rotation and friction for holding a connector in place" (’343 Patent, col. 3:61-63). This, combined with the clear planar motion depicted in figures like 2A and 2B, could support a narrower construction requiring a true hinge-like mechanism that strictly confines movement to a single plane.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain factual allegations to support a claim for either induced or contributory infringement. The prayer for relief includes a request for an injunction against "indirect" infringement, but the body of the complaint lacks the necessary assertions of knowledge, intent, or non-staple uses (Compl. p. 15).
- Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It alleges that Defendant has had "actual notice of the existence of the '343 Patent since at least the time it received this complaint," which may form the basis for seeking enhanced damages for any post-filing infringement (Compl. ¶18).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "intermediate member," which the patent illustrates as a discrete component, be construed to read on the integrated, molded elbow of the accused cable's connector housing? The outcome may depend on whether the term is defined by its function or by the specific structure shown in the patent's embodiments.
- A key evidentiary question will be one of mechanical constraint: does the accused connector's pivoting mechanism actually "limit" rotation to two distinct, orthogonal planes as required by the claim? The infringement analysis will likely require evidence beyond photographs, such as technical specifications or expert testimony on the internal construction of the joints, to resolve whether the device’s movement matches the patented invention’s specific kinematics.