Lyden v. Turtle Beach Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Robert Michael Lyden (Minnesota)
  • Defendant: Turtle Beach Corporation (Nevada); Voyetra Turtle Beach, Inc. (Delaware); Performance Designed Products, LLC (California)
  • Plaintiff’s Counsel: Pro Se
• Case Identification: 0:25-cv-03843, D. Minn., 10/03/2025
• Venue Allegations: Venue is alleged to be proper based on Defendants' commission of infringing acts within the District of Minnesota and the Plaintiff's residence in the district.
• Core Dispute: Plaintiff alleges that Defendants’ Victrix Gambit and Victrix Pro BFG game controllers infringe a patent related to customizable controllers that use a plurality of removable gates with different geometric shapes to alter the movement of a thumbstick control.
• Technical Context: The technology relates to the field of high-performance and professional gaming peripherals, where controller modularity and physical customization are significant market differentiators.
• Key Procedural History: The complaint alleges that the published U.S. patent application corresponding to the patent-in-suit was cited by the U.S. Patent and Trademark Office during the prosecution of at least eight of Defendants' own design patents, with the earliest citation occurring before April 9, 2019. The complaint also details multiple pre-suit communications from the Plaintiff to Defendants in July and August 2025, which allegedly included a copy of the patent and notice of its relevance to the accused products.

Case Timeline

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

U.S. Patent No. 10,507,385 - Game Controller

• Patent Identification: U.S. Patent No. 10,507,385, "Game Controller," issued December 17, 2019.

The Invention Explained

• Problem Addressed: The patent background describes a market with many different types of game controllers from various manufacturers, implying a need for greater customization beyond the standard, fixed designs offered by major console makers (’385 Patent, col. 1:11-68).
• The Patented Solution: The invention provides a system for physically customizing the play of a thumbstick control by using a "plurality of removable gates" (’385 Patent, col. 18:63-68). These gates, which can be integrated into removable rings, feature openings of different geometric shapes (e.g., circular, octagonal) that are positioned around the thumbstick. By swapping these gates, a user can change the physical boundaries of the thumbstick's range of motion (’385 Patent, col. 12:6-34; Fig. 23).
• Technical Importance: This approach allows for physical, rather than purely software-based, customization of controller feel and response, a feature of interest to competitive gamers seeking to tailor equipment to specific games or play styles (’385 Patent, Abstract).

Key Claims at a Glance

• The complaint asserts infringement of independent claim 1 and dependent claims 8, 9, 10, 12, 14, and 15 (Compl. ¶¶ 33-34).
• Independent Claim 1:
  • A game controller comprising a case with standard components (handle portions, shoulder portions, etc.).
  • At least one control (e.g., a thumbstick) supported by the case.
  • A plurality of removable gates, each having an opening with a different geometric shape, for positioning around the control to customize its play.

III. The Accused Instrumentality

Product Identification

• The "Victrix Gambit" and "Victrix Pro BFG" game controllers, including various named versions such as the "Victrix Gambit Prime Tournament Controller" and "Victrix Pro BFG Reloaded Wireless Modular Controller" (Compl. ¶¶ 16-18).

Functionality and Market Context

• The complaint alleges that the accused products are high-performance game controllers that include features for customization (Compl. ¶18). Specifically, they are alleged to include "a plurality of removable gates having different geometric shapes" (Compl. ¶18). The complaint provides an annotated image of the Victrix Gambit controller, labeling a feature around the thumbstick as a "Removable Gate (Round and Octagonal Options)" (Compl. p. 10). The controllers are alleged to be sold by the Defendants throughout the United States, including in the District of Minnesota (Compl. ¶¶ 8, 18).

IV. Analysis of Infringement Allegations

Claim Chart Summary

• The complaint references a separate claim chart exhibit that was not attached to the publicly filed document (Compl. ¶29, Exhibit R). The narrative allegations are summarized below for Claim 1.

Identified Points of Contention

• Scope Questions: The infringement analysis may focus on whether the accused products' "four different rings which have integral gates" (Compl. ¶21) meet the definition of "a plurality of removable gates" as claimed. The patent specification describes "retaining rings 28" that "can include an integral gate 30" (’385 Patent, col. 12:13-16), raising the question of how the terms "ring" and "gate" will be construed relative to each other.
• Technical Questions: A key factual question will be the mechanism by which the accused gates are made "removable." The complaint alleges the Accused Products use "male snap fit appendages" that insert into "female snap fit openings," mirroring the mechanism described in the patent (Compl. ¶22; ’385 Patent, col. 12:20-24). The case may turn on evidence demonstrating the precise structure and operation of the attachment mechanism in the accused controllers.

V. Key Claim Terms for Construction

• The Term: "removable gates"
• Context and Importance: This term is the central feature of the asserted independent claim. The dispute will likely hinge on whether the interchangeable components supplied with the Accused Products fall within the scope of this term. Practitioners may focus on this term because the patent discloses a specific snap-fit embodiment for removal, and the scope of "removable" could be contested.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not specify a particular mechanism for removal, only that the gates are removable. The summary of the invention also broadly describes "at least one removably attachable gate" without limiting the attachment means (’385 Patent, col. 2:62-64).
  • Evidence for a Narrower Interpretation: The detailed description and Figure 23 illustrate a specific embodiment where "male snap fit appendages 79" engage with "female snap fit openings 80" (’385 Patent, col. 12:20-24). A party could argue that "removable" should be construed in light of this primary, and only, disclosed embodiment for attachment.

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement of infringement, stating that Defendants provide user manuals, instructions, and promotional materials that encourage and instruct customers on how to use the Accused Products in an infringing manner, specifically by swapping the customizable gates (Compl. ¶¶ 35-36).

Willful Infringement

• The complaint alleges willfulness based on both pre-suit and post-suit knowledge. Pre-suit knowledge is alleged based on the citation of the ’385 Patent’s published application in the prosecution history of Defendants' own design patents, beginning before April 9, 2019 (Compl. ¶¶ 15, 30, 44). The complaint also alleges Defendants were given actual notice of the patent and its relevance via email communications from the Plaintiff prior to the lawsuit (Compl. ¶¶ 25, 27, 44).

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

• A core issue will be one of claim construction: whether the term "removable gates" is limited to the specific snap-fit mechanism disclosed in the patent's specification, or if it can be construed more broadly to cover any mechanism that allows for the interchange of geometrically different thumbstick surrounds.
• A second central question will be one of willfulness and damages: the complaint alleges that Defendants had knowledge of the underlying patent application years before the lawsuit via citations in their own patent prosecution files. This raises a key evidentiary question regarding whether Defendants' subsequent launch and sale of the accused products constituted objectively reckless disregard of the patent holder's rights.