DCT

1:25-cv-09254

Yakar Tech LLC v. High Rail LLC

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-09254, S.D.N.Y., 11/05/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Southern District of New York because Defendant maintains a regular and established place of business in the district and has allegedly committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s phone accessory products infringe a patent related to magnetic mounts for electronic devices that include an integrated, movable support leg.
  • Technical Context: The technology addresses mounting systems for increasingly heavy consumer electronics, like smartphones and tablets, aiming to combine the convenience of magnetic attachment with the stability of physical support.
  • Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has previously entered into settlement licenses with other entities regarding its patents. It further alleges that these licenses did not grant rights to produce a patented article, a point raised in a detailed section addressing compliance with patent marking statutes.

Case Timeline

Date Event
2014-07-23 ’309 Patent Priority Date
2021-06-15 ’309 Patent Issue Date
2025-11-05 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 11,034,309, "Heavy Duty Magnet Mount," issued June 15, 2021.

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inadequacy of existing mounting solutions for large and heavy electronic devices. It notes that simple magnet mounts may lack sufficient force, while cradle-style mounts may not provide adequate clamping. It also characterizes exposed ferromagnetic plates attached to devices as aesthetically undesirable (’309 Patent, col. 1:31-49).
  • The Patented Solution: The invention is a mount that supplements magnetic attraction with a physical support structure. It discloses a mount body containing a magnet and featuring at least one leg that can move from a "stored position," where it is flush or coplanar with the mount's face, to a "support position," where it extends outward to physically hold the bottom of the electronic device (’309 Patent, Abstract; col. 3:40-50; Fig. 4). This dual-support mechanism is intended to reliably hold heavier devices, while a ferromagnetic element can be positioned inside the device's case to maintain a clean aesthetic (’309 Patent, col. 5:10-18).
  • Technical Importance: The described approach seeks to provide a more robust mounting solution for the growing market of large-screen smartphones and tablets, particularly for use in environments subject to motion, such as vehicles (’309 Patent, col. 1:34-38).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 3, and 6, and reserves the right to assert dependent claims 2, 4-5, and 7-9 (Compl. ¶15).
  • Independent Claim 1 requires, in part:
    • A ferromagnetic element "positionable inside a cover of the electronic device."
    • A mount body with a magnet and "at least one leg" movable from a stored position to a support position to "directly support the device."
    • 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 "substantially normal to the face plate."
  • Independent Claim 3 requires, in part:
    • A ferromagnetic element "positionable inside a cover of the electronic device."
    • A mount body with a magnet and "at least one leg" movable to a support position.
    • The leg comprises a "pair of leg extensions rotatably mounted to the leg" to form a support.
  • Independent Claim 6 requires, in part:
    • A mount body comprising a front and back plate, a magnet, a magnet cover, and "at least one leg."
    • The leg is movable from a "stored position coplanar with the face to a support position substantially perpendicular to the face."
    • A ferromagnetic element positioned within the electronic device such that the "body of the electronic device is between the ferromagnetic plate and the mount body."

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products broadly as "WIX's Phone Accessories" and "infringing mounting devices" (Compl. ¶¶13, 15).

Functionality and Market Context

  • The complaint does not provide specific technical details about the operation of the accused products. It alleges they are devices used "to mount a device such as a cell phone or other PDA" (Compl. ¶17). The complaint references Exhibits B-E for further detail, but these exhibits were not attached to the publicly filed complaint. No probative visual evidence provided in complaint. The complaint alleges the products are widely commercialized throughout the United States (Compl. ¶¶15, 21).

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts in Exhibits B-E, which were not provided with the pleading (Compl. ¶16). The infringement theory must therefore be summarized from the complaint’s narrative allegations.

The core of the infringement allegation is that Defendant's "mounting devices" incorporate the combination of features claimed in the ’309 Patent (Compl. ¶15). This suggests Plaintiff will seek to prove that the accused WixGear phone accessories contain both a magnetic coupling mechanism and a movable leg structure that shifts from a stored position to a support position to physically hold an electronic device, as recited in the asserted independent claims. The allegations cover literal infringement and infringement under the doctrine of equivalents for claims 1-9 of the ’309 Patent (Compl. ¶15).

  • Identified Points of Contention:
    • Factual Question: A central factual dispute will likely be whether the accused products possess the specific mechanical leg structure recited in the claims. The complaint's lack of detail on this point suggests that the existence and functionality of any support leg on the accused products will be a primary focus of discovery.
    • Scope Questions: The analysis may turn on the interpretation of claim limitations describing the leg's movement and final position. Questions for the court could include: What range of motion satisfies the requirement that the leg move from a "stored position coplanar with the face" to a "support position substantially normal to the face" (’309 Patent, col. 6:20-24, 6:58-62)? Does the accused product's leg, if one exists, meet the "adjustably extendible" limitation of claim 1 (’309 Patent, col. 6:16-17)?

V. Key Claim Terms for Construction

  • The Term: "support position"

  • Context and Importance: This term is critical because it defines the functional endpoint for the movable leg, which must be "substantially normal to the face plate" (Claim 1) and "configured to directly support the device" (Claim 1). The viability of the infringement case depends on whether the accused device's leg, if any, can be shown to achieve this claimed position and function.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims themselves do not impose further structural limitations on the "support position" beyond its orientation and function, which may support an argument for applying its plain and ordinary meaning to cover any configuration that props up the device from below.
    • Evidence for a Narrower Interpretation: The specification repeatedly depicts the support position as one where the legs fold out to create a perpendicular, shelf-like support for the bottom edge of an electronic device (’309 Patent, Figs. 17-18; col. 3:45-50). A party could argue this consistent depiction limits the term to this specific perpendicular arrangement.
  • The Term: "adjustably extendible"

  • Context and Importance: Claim 1 uniquely requires that the leg be "adjustably extendible from the mount body." This limitation appears to require that the leg can change in length, in addition to folding or moving. Infringement of this claim will hinge on whether an accused product has a mechanism for length adjustment.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent mentions a "leg extension assembly" but states it "is known in the art and will not be described further herein" (’309 Patent, col. 3:51-54). This lack of specific definition in the patent may support a broader construction covering any mechanism that allows for a change in the leg's length.
    • Evidence for a Narrower Interpretation: A defendant may point to the embodiment shown in Figure 4, which depicts a distinct multi-part "leg extension assembly (or leg base) 114," to argue that "adjustably extendible" requires a similar telescoping or compound structure, rather than a simple unfolding motion.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. It asserts inducement based on Defendant allegedly encouraging and instructing customers on infringing uses through "product instruction manuals" (Compl. ¶¶17-18). It supports the contributory infringement claim by alleging the products are not staple articles of commerce and have no substantial non-infringing use (Compl. ¶18).
  • Willful Infringement: The complaint alleges Defendant has known of the ’309 Patent and the underlying technology "from at least the filing date of the lawsuit" (Compl. ¶¶17-18), forming a basis for post-suit willfulness. The prayer for relief also asks the court to declare infringement willful if discovery reveals pre-suit knowledge of the patent (Compl. p. 8, ¶e).

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

  1. A primary issue will be one of evidentiary proof: does the accused line of "WixGear Phone Accessories" actually contain the specific mechanical support leg described in the ’309 Patent? The infringement case appears to depend entirely on the presence and operation of a leg that moves from a flush, stored position to an extended, perpendicular support position.
  2. The case may also turn on a question of definitional scope: how will the court construe key claim terms such as "support position" and "adjustably extendible"? The outcome of claim construction will determine whether the specific mechanics of the accused products, once established, fall within the patent's legal boundaries.
  3. Given Plaintiff's status as a non-practicing entity and the complaint's detailed discussion of prior licensing and patent marking law, a significant focus will be on damages: specifically, the determination of a reasonable royalty and Plaintiff's entitlement to pre-suit damages under 35 U.S.C. § 287.