DCT

2:25-cv-06186

Yakar Tech LLC v. Lax Gadgets Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-06186, E.D.N.Y., 11/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of New York because Defendant has regular and established places of business in the district and has committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s phone accessories infringe patents related to magnetic mounts for electronic devices that include a movable leg for additional physical support.
  • Technical Context: The technology concerns mounts for portable electronics, such as smartphones, which combine the convenience of magnetic attachment with the stability of mechanical support structures.
  • Key Procedural History: The complaint discloses that Plaintiff is a non-practicing entity and has entered into prior settlement licenses with other entities, which it contends did not require patent marking because they did not involve the production of a patented article.

Case Timeline

Date Event
2014-07-23 Priority Date for ’058 and ’309 Patents
2017-12-19 U.S. Patent No. 9,845,058 Issues
2021-06-15 U.S. Patent No. 11,034,309 Issues
2025-11-05 Complaint Filed

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

U.S. Patent No. 9,845,058 - “Heavy Duty Magnet Mount”

The Invention Explained

  • Problem Addressed: The patent describes a problem with existing mounts for electronic devices, noting that as devices become larger and heavier, purely magnetic mounts may not be strong enough to hold them securely, particularly in a moving vehicle. It also notes that exposed ferromagnetic plates on a device are often considered unsightly by users (’058 Patent, col. 1:30-48).
  • The Patented Solution: The invention proposes a hybrid mount that combines a magnet with at least one foldable leg. This leg can be moved from a “stored position,” where it is flush with the mount’s face plate, to a “support position,” where it extends to physically hold the electronic device (’058 Patent, Abstract; col. 3:40-50). This dual-system approach aims to provide both the ease of magnetic attachment and the reliable support of a mechanical structure.
  • Technical Importance: The technology provides a solution for securely mounting increasingly large and heavy portable electronics in environments subject to movement and vibration, such as vehicles.

Key Claims at a Glance

  • The complaint asserts independent claim 1 and dependent claims 2-10 (Compl. ¶16).
  • Independent Claim 1 of the ’058 patent includes the following essential elements:
    • A ferromagnetic element securable to an electronic device.
    • A mount body comprising a magnet, a face plate, and at least one leg.
    • The magnet is secured in the face plate.
    • The leg is movable from a stored position to a support position.
    • The leg further comprises a pair of leg extensions rotatably mounted to the leg, where the extensions are rotatable to form a support for the device.

U.S. Patent No. 11,034,309 - “Heavy Duty Magnet Mount”

The Invention Explained

  • Problem Addressed: As a continuation of the application leading to the ’058 patent, the ’309 patent addresses the same technical challenge: providing a secure mount for heavy or oversized electronic devices that overcomes the limitations of purely magnetic or cradle-style mounts (’309 Patent, col. 1:31-40).
  • The Patented Solution: The ’309 patent also discloses a magnetic mount featuring a movable support leg. The claims of this patent focus on specific configurations, such as the ferromagnetic element being designed for placement inside a device's protective cover and the leg being both extendible and foldable to a position substantially normal to the face plate (’309 Patent, Abstract; col. 6:18-24).
  • Technical Importance: This patent refines the design of a hybrid magnetic-mechanical mount, with claims directed to particular structural and functional characteristics of the support leg and the associated ferromagnetic element.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 3, and 6, and dependent claims 2, 4-5, and 7-9 (Compl. ¶25).
  • Independent Claim 1 of the ’309 patent includes the following essential elements:
    • A ferromagnetic element shaped and configured to be positionable inside a cover of the electronic device.
    • A mount body comprising a magnet, a face plate, and at least one leg configured to directly support the device.
    • The leg is movable from a stored position to a support position.
    • The leg is adjustably extendible from the mount body.
    • The leg is extendible in a direction coplanar with the face plate and is foldable to a support position that is substantially normal to the face plate.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "LAX's Phone Accessories," available through the defendant's website (Compl. ¶14).

Functionality and Market Context

The accused products are described as "mounting devices" for items such as a "cell phone or other PDA" (Compl. ¶16, ¶18). The complaint alleges these products are commercialized throughout the United States, including within the Eastern District of New York (Compl. ¶22). No specific product models are named in the complaint.

IV. Analysis of Infringement Allegations

The complaint states that preliminary claim charts supporting the infringement allegations are attached as Exhibits B (for the ’058 patent) and D (for the ’309 patent) (Compl. ¶17, ¶26). However, these exhibits were not included with the filed complaint. The complaint alleges that Defendant’s mounting devices infringe one or more claims of each patent, including claims 1-10 of the ’058 patent and claims 1-9 of the ’309 patent (Compl. ¶16, ¶25). No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • For the ’058 Patent, a central technical question may be whether the accused products contain a leg that includes "a pair of leg extensions rotatably mounted to the leg," as required by independent claim 1. The analysis will likely focus on the specific structure and movement of the accused support mechanism.
    • For the ’309 Patent, a key dispute may arise over whether the accused ferromagnetic element is "shaped and configured to be positionable inside a cover of the electronic device," as recited in independent claim 1. This raises the question of whether a generic metal plate that can be placed inside a case meets this limitation. Further, the analysis will question whether the accused leg is "adjustably extendible from the mount body" in a manner "coplanar with the face plate" before folding to a support position.

V. Key Claim Terms for Construction

  • ’058 Patent, Claim 1

    • The Term: "a pair of leg extensions rotatably mounted to the leg"
    • Context and Importance: This term defines a specific mechanical arrangement for the support structure. The infringement analysis will depend on whether the accused device’s support feature is a unitary piece or comprises separate "extensions" that are "rotatably mounted" to a central "leg."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests some flexibility, stating that "legs 104 may comprise a single molded piece with two leg extensions, or alternatively, individually rotatable leg extensions 104A and 104B" (’058 Patent, col. 3:28-32). This could support an interpretation where a single, forked component satisfies the limitation.
      • Evidence for a Narrower Interpretation: The phrase "rotatably mounted to the leg" could be argued to require three distinct components: a primary "leg" and two separate "extensions" affixed to it. Figure 4, showing extensions 104A and 104B as part of a single sliding assembly 114, could be used to argue for a specific structural configuration.

  • ’309 Patent, Claim 1

    • The Term: "shaped and configured to be positionable inside a cover"
    • Context and Importance: This limitation applies to the ferromagnetic element, not the mount itself. The dispute will likely focus on whether this requires a special design for the element or if a standard, thin metal plate that happens to fit inside a phone case meets the claim.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification’s general description of placing a ferromagnetic plate inside a device or case could support a reading that any plate thin enough for this purpose is covered (’309 Patent, col. 5:53-59).
      • Evidence for a Narrower Interpretation: The explicit "shaped and configured" language suggests an element with specific design attributes intended for internal placement, distinguishing it from a generic plate. Figure 16, which shows a ferromagnetic plate 502 being placed inside a device back 602, illustrates this intended use but does not detail a specific shape (’309 Patent, col. 5:10-14, Fig. 16).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Defendant actively encourages and instructs its customers on how to use the accused products in an infringing manner (Compl. ¶18, ¶27). Contributory infringement is alleged on the grounds that the accused products are not staple commercial items and have no substantial non-infringing use (Compl. ¶19, ¶28).
  • Willful Infringement: The complaint alleges that Defendant has known of the patents "from at least the filing date of the lawsuit" (Compl. ¶18, ¶27). This allegation, as pleaded, would only support a claim for post-filing willfulness. The prayer for relief seeks a finding of willfulness if discovery reveals pre-suit knowledge (Compl. Prayer for Relief ¶e).

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

  • A core issue will be one of structural correspondence: Do the accused "Phone Accessories" possess the specific mechanical features recited in the independent claims, such as the ’058 patent’s "pair of leg extensions rotatably mounted to the leg" and the ’309 patent’s leg that is "adjustably extendible... in a direction coplanar with the face plate"? The absence of detailed product information in the complaint leaves this as a primary question for discovery.
  • A second key question will be one of definitional scope: For the ’309 patent, can a generic ferromagnetic plate be considered "shaped and configured to be positionable inside a cover," or does this language require a purpose-built design? The construction of this term will be critical to the infringement analysis for that patent.
  • Finally, an evidentiary question of intent will be central to the indirect and willful infringement claims. Plaintiff will need to produce evidence, such as user manuals or marketing materials, that demonstrate Defendant specifically instructed users to perform the claimed methods and knew or should have known its actions constituted infringement.