DCT
1:25-cv-04252
National Products Inc v. C T A Digital Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: National Products Inc. (Washington)
- Defendant: CTA Digital Inc. (New York)
- Plaintiff’s Counsel: Fenwick & West LLP
- Case Identification: 1:25-cv-04252, E.D.N.Y., 07/30/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of New York because Defendant has its headquarters and a regular and established place of business in the district, and has committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s lines of protective tablet cases and conductive charging systems infringe six patents related to combination hand straps/stands and docking sleeves with electrical adapters.
- Technical Context: The dispute concerns accessories for portable electronic devices, a market where ergonomic handling, hands-free viewing, and efficient charging are key features.
- Key Procedural History: The complaint alleges that Defendant has had actual knowledge of the patents-in-suit and their infringement since at least July 15, 2025, when Plaintiff provided notice, forming the basis for a willfulness allegation.
Case Timeline
| Date | Event |
|---|---|
| 2014-02-24 | Earliest Priority Date (’458, ’141, ’142, ’550 Patents) |
| 2015-07-02 | Earliest Priority Date (’622, ’227 Patents) |
| 2020-03-24 | U.S. Patent No. 10,595,622 Issues |
| 2021-02-02 | U.S. Patent No. 10,905,227 Issues |
| 2021-11-02 | U.S. Patent No. 11,165,458 Issues |
| 2024-11-12 | U.S. Patent No. 12,143,141 Issues |
| 2024-11-12 | U.S. Patent No. 12,143,142 Issues |
| 2025-06-24 | U.S. Patent No. 12,341,550 Issues |
| 2025-07-15 | Plaintiff alleges it notified Defendant of infringement |
| 2025-07-30 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,595,622 - “Combination Strap and Stand Support for Tablets and Hand Held Electronic Devices”
The Invention Explained
- Problem Addressed: The patent’s background section notes that prior art supports for electronic devices, such as hand straps and surface stands, are limited in their flexibility and typically do not offer both functionalities in a single integrated, convenient design (ʼ622 Patent, col. 1:25-30).
- The Patented Solution: The invention is a support for a portable electronic device that integrates a hand strap and a stand onto a single rotatable base attached to the back of a protective case. This allows a user to either hold the device securely with the strap or prop it up on a surface using the stand, with the stand and strap being coupled to the base independently of one another (’622 Patent, Abstract; col. 3:21-33).
- Technical Importance: This integrated approach sought to provide a single accessory that could serve two common but distinct use cases for tablet users: mobile, handheld operation and stationary, hands-free viewing (’622 Patent, col. 1:31-38).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶36).
- Essential elements of claim 1 include:
- A case structured for receiving a portable electronic device.
- A rotatable base positioned on a back plane of the case and rotatable relative to the case.
- A strap with two ends both attached to the base, configured for fitting around a user's appendage.
- A support stand attached to the base independently of the strap, swivelable between a stowed and a deployed position for supporting the base on an external surface.
- The support stand maintains a same shape in both the deployed and stowed positions.
- A swivel mechanism attached to the support stand and the base, wherein the mechanism is attached to the base between the points where the strap is attached, so that the strap extends over the swivel mechanism.
U.S. Patent No. 10,905,227 - “Combination Strap and Stand Support for Tablets and Hand Held Electronic Devices”
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’622 Patent, the ’227 Patent addresses the same problem of providing a flexible, integrated support system for portable electronic devices (’227 Patent, col. 1:21-26).
- The Patented Solution: The invention described is structurally similar to that of the ’622 Patent, comprising a case with a rotatable base featuring an independent hand strap and support stand. The claims of the ’227 Patent, however, focus on a support stand that can be deployed into multiple different viewing angles, rather than just a single deployed position (’227 Patent, Abstract; col. 1:52-55). This variability is achieved, for example, through a swivel mechanism with multiple fixed deployment angles (’227 Patent, col. 5:56-62).
- Technical Importance: The solution aims to enhance the utility of the integrated stand by allowing users to adjust the viewing angle of the device to suit different situations or preferences, a feature not explicitly claimed in the parent ’622 Patent (’227 Patent, col. 1:52-55).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶48).
- Essential elements of claim 1 include:
- A case configured for receiving the portable electronic device.
- A rotatable base positioned on a back plane of the case and rotatable relative to the case.
- A strap with two ends both attached to the base, configured for fitting around a user's appendage.
- A support stand attached to the base independently of the strap, swivelable between a stowed position and a plurality of deployed positions.
- The base and support stand are joined at an acute deployment angle, different for each deployed position.
U.S. Patent No. 11,165,458 - “Docking Sleeve With Electrical Adapter”
- Technology Synopsis: This patent describes a protective arrangement for an electronic device, such as a flexible cover or "skin." The cover includes a built-in electrical adapter with a male plug (e.g., USB-C) that connects to the device's internal port, and an external contactor that exposes electrical contacts on the outside of the cover, enabling the encased device to be charged or synced in a docking station without being removed from its protective sleeve (’458 Patent, Abstract; col. 1:55-66).
- Asserted Claims: At least independent claim 12 is asserted (Compl. ¶59).
- Accused Features: The CTA Digital "VersaGuard with conductive charging line of products" are accused of infringement (Compl. ¶59).
U.S. Patent No. 12,143,141 - “Docking Sleeve With Electrical Adapter”
- Technology Synopsis: This patent, from the same family as the ’458 Patent, also relates to a protective case that allows for pass-through electrical connectivity. The claims focus on the structural arrangement of a protective case with an internal male plug and an array of external contacts that are electrically coupled to the internal plug, facilitating connection to an external device or dock (’141 Patent, Abstract).
- Asserted Claims: At least independent claim 1 is asserted (Compl. ¶69).
- Accused Features: The CTA Digital "VersaGuard with conductive charging line of products" are accused of infringement (Compl. ¶69).
U.S. Patent No. 12,143,142 - “Docking Sleeve With Electrical Adapter”
- Technology Synopsis: This patent continues the theme of the ’458 and ’141 patents, describing a docking system that includes both the protective case with pass-through contacts and a multi-device docking station. The docking station has connectors, such as spring-loaded "pogo pins," configured to mate with the external contacts on the protective case, allowing multiple encased devices to be charged simultaneously (’142 Patent, Abstract).
- Asserted Claims: At least independent claim 1 is asserted (Compl. ¶80).
- Accused Features: The CTA Digital "VersaGuard with conductive charging line of products" are accused of infringement (Compl. ¶80).
U.S. Patent No. 12,341,550 - “Docking Sleeve With Electrical Adapter”
- Technology Synopsis: The complaint does not attach this patent, but based on its title and the infringement allegations, it appears to be part of the same family as the '458, '141, and '142 patents. The technology likely involves a protective case with an integrated electrical adapter that facilitates docking and charging. The claims asserted relate to a protective case with an internal male plug and an external contactor with contacts exposed on a side surface of the case's skirt (Compl. ¶¶ 94-96).
- Asserted Claims: At least independent claim 13 is asserted (Compl. ¶92).
- Accused Features: The CTA Digital "VersaGuard with conductive charging line of products" are accused of infringement (Compl. ¶92).
III. The Accused Instrumentality
- Product Identification: The complaint identifies two lines of accused products:
- CTA Digital's "Protective Tablet Case with Kickstand and Hand Strap" line of products (Compl. ¶36).
- CTA Digital's "VersaGuard with conductive charging" line of products, which includes protective cases and powered docking systems (Compl. ¶59).
- Functionality and Market Context:
- The "Protective Tablet Case with Kickstand and Hand Strap" is alleged to be a support for tablets that includes a protective enclosure, a rotating hand-grip on the back, and a built-in kickstand for hands-free viewing (Compl. ¶¶ 38-40). A promotional video screenshot in the complaint shows a user's hand under a strap on the back of the device, with graphics indicating 360-degree rotation (Compl. p. 9). Another image shows the device propped up by a stand extending from the back (Compl. p. 8).
- The "VersaGuard with conductive charging" products are alleged to comprise a protective case and a docking system. The case internally receives an electronic device and connects to its charging port, while providing external charging contacts described as "POGO Pin and USB-C Charging Ports" (Compl. ¶¶ 61-62, p. 19). This allows the device to be charged by placing it in a corresponding multi-unit docking station without physically plugging in a cable (Compl. ¶¶ 82, 84-85). An image from the complaint shows the case with an internal plug and external contacts, illustrating the pass-through charging design (Compl. p. 20).
IV. Analysis of Infringement Allegations
10,595,622 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a case structured for receiving the portable electronic device | The accused products comprise a case that is structured for receiving and holding a portable electronic device, such as an iPad. | ¶38 | col. 3:5-8 |
| a rotatable base positioned on a back plane of the case and rotatable relative to the case | The accused products include a base on the back of the case that is shown to be rotatable. | ¶39 | col. 3:25-28 |
| a strap comprising a first end and a second end opposite the first end, wherein the first and second ends of the strap are both attached to the base... | A hand strap is attached at both ends to the rotatable base, allowing a user to support the device. | ¶39 | col. 3:21-25 |
| a support stand that is attached to the base independently of the strap and is swivelable...between a stowed position and a deployed position | The accused products feature a "built-in kickstand" that is attached to the base and can be swiveled from a stowed position to a deployed, supporting position. | ¶40 | col. 3:21-33 |
| wherein the support stand maintains a same shape in both the deployed and stowed positions | The complaint alleges the support stand maintains a same shape in both positions. | ¶40 | col. 9:40-42 |
| a swivel mechanism attached to the support stand and the base...wherein the swivel mechanism is attached to the base at a position on the base between positions at which the first and second ends of the strap are attached to the base so that the strap extends over the swivel mechanism | The complaint alleges a swivel mechanism for the stand is attached to the base, and that the strap extends over this mechanism. | ¶41 | col. 9:43-50 |
- Identified Points of Contention:
- Scope Question: The complaint alleges the kickstand "maintains a same shape in both the deployed and stowed positions" (Compl. ¶40). A defendant may argue that a stand which unfolds or whose components move relative to each other does not maintain the "same shape." The construction of this term may be a point of dispute.
- Factual Question: The complaint provides a visual of the kickstand in a stowed position with the hand strap over it (Compl. p. 11), which may support the "strap extends over the swivel mechanism" limitation. The factual question will be whether the underlying mechanism for the stand is physically located between the attachment points of the strap as claimed.
10,905,227 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a case configured for receiving the portable electronic device | The accused products comprise a case configured to receive a portable electronic device. | ¶50 | col. 3:4-8 |
| a rotatable base positioned on a back plane of the case that is rotatable relative to the case | The accused products include a base on the back of the case that is alleged to be rotatable. | ¶51 | col. 4:26-33 |
| a strap...attached to the base, wherein the strap is configured for fitting around an appendage of a user | A hand strap is attached to the base for a user to hold the device. | ¶51 | col. 4:49-53 |
| a support stand that is attached to the base independently of the strap and is swivelable...between a stowed position and a plurality of deployed positions for supporting the support on an external surface | The complaint alleges the product includes a support stand that is swivelable between a stowed position and a "plurality of deployed positions." | ¶52 | col. 1:47-52 |
| in an angled arrangement in which the base and the support stand are joined together at an acute deployment angle, different for each deployed position, opposite the external surface | The complaint alleges that the support can be supported in an angled arrangement at an acute deployment angle that is different for each deployed position. | ¶52 | col. 1:52-56 |
- Identified Points of Contention:
- Evidentiary Question: The central distinguishing feature of claim 1 of the ’227 patent is the requirement for a "plurality of deployed positions" at "different" acute angles. The complaint alleges this element is met but provides only generic images of the kickstand in a single deployed position (e.g., Compl. p. 14). A key question for the court will be what evidence Plaintiff provides to demonstrate that the accused stand is, in fact, capable of stably supporting the device in multiple, distinct deployed positions as claimed.
V. Key Claim Terms for Construction
- The Term: "plurality of deployed positions" (from claim 1 of the ’227 Patent)
- Context and Importance: This term is critical because it distinguishes the ’227 patent's asserted claim from that of the parent ’622 patent. The infringement analysis will likely turn on whether the accused kickstand, as a matter of fact, has more than one stable deployed position. Practitioners may focus on this term because the complaint's visual evidence does not explicitly show multiple positions, suggesting this could be a point of significant factual and legal dispute.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes a swivel mechanism that "permits stand 22 to swivel to angles within a range of deployment angles 56, for example but not limited to, between about 0 degrees and 90 degrees" (’227 Patent, col. 5:62-65). This language may support an interpretation that any number of stable positions within that range constitutes a "plurality."
- Evidence for a Narrower Interpretation: The detailed description discloses specific embodiments using a ratchet mechanism with "mating toothed members" to fix the stand at discrete angles (’227 Patent, col. 7:5-24; Fig. 15). A defendant might argue that "plurality of deployed positions" should be construed to require a mechanism that provides multiple, distinct, and intentionally designed locking positions, not merely the ability to rest at slightly different angles due to friction.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all asserted patents, stating that CTA Digital provides customers with the accused products and advertises them for their intended infringing use through its website and third-party sites (Compl. ¶¶ 42, 53, 63, 74, 86, 97). The complaint also alleges contributory infringement by supplying key components of the patented systems (e.g., protective covers, docking cradles) with knowledge of the patents and asserting that the components are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶¶ 43, 54, 64, 75, 87, 98).
- Willful Infringement: Willfulness is alleged for all asserted patents. The complaint claims that CTA Digital has had "actual knowledge" of the patents and their infringement "since at least July 15, 2025, when NPI notified CTA Digital" (Compl. ¶¶ 45, 56, 66, 77, 89, 100). The allegation of continued infringement after this date forms the basis for the willfulness claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of functional capability: For the ’227 patent, can Plaintiff produce evidence showing that the accused "built-in kickstand" is designed for and capable of stably maintaining a "plurality of deployed positions" at different acute angles, as required by the claim, or does it functionally offer only a single deployed state?
- A key issue for the four patents related to docking sleeves will be one of claim construction and scope: The claims for the docking sleeves (’458, ’141, ’142, ’550 patents) recite specific structural arrangements of panels, skirts, internal plugs, and external contactors. The case will likely depend on how the court construes these detailed limitations and whether the physical construction of the accused "VersaGuard" products falls within that construed scope.