DCT
7:23-cv-04368
Dali Wireless Inc v. Fujikura America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Dali Wireless, Inc. (Delaware)
- Defendant: Fujikura America, Inc. (d/b/a AFL GLOBAL) (Delaware)
- Plaintiff’s Counsel: Wyche, P.A.; Folio Law Group PLLC
- Case Identification: 7:23-cv-04368, D.S.C., 08/30/2023
- Venue Allegations: Venue is alleged to be proper in the District of South Carolina because Defendant maintains a principal place of business and 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 L-Series of sliding patch panels for telecommunications equipment infringes a patent related to a rear drawer latching mechanism.
- Technical Context: The technology concerns mechanical components for rack-mounted telecommunications equipment, specifically features that improve usability and protect fiber optic cables during maintenance.
- Key Procedural History: Plaintiff Dali Wireless, Inc. is the exclusive licensee of the patent-in-suit, with the right to enforce it. The complaint notes that the former patent owner, CommScope Technologies, LLC, sold and marked products that practiced the patent.
Case Timeline
| Date | Event |
|---|---|
| 2007-06-06 | U.S. Patent No. 7,567,744 Priority Date |
| 2009-07-28 | U.S. Patent No. 7,567,744 Issued |
| 2023-08-30 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,567,744 - "Rear Drawer Latch," Issued July 28, 2009
The Invention Explained
- Problem Addressed: In telecommunications infrastructures, sliding drawers used for cable management can inadvertently close during installation or maintenance procedures. This can cause damage to sensitive components and unsecured fiber optic cables (’744 Patent, col. 1:26-34).
- The Patented Solution: The invention is a cable management panel with a drawer that includes a "releasable rear drawer latch assembly." This assembly is designed to automatically engage and lock the drawer in its fully open position, preventing it from accidentally sliding shut. A technician must then manually release the latch to close the drawer ('744 Patent, Abstract; col. 2:40-45). The latch mechanism itself includes a body that moves vertically and a spring that biases it toward the locked position ('744 Patent, col. 5:31-41).
- Technical Importance: This mechanical safety feature provides technicians with stable, hands-free access to the drawer's interior, which is critical when working with high-density and fragile fiber optic connections ('744 Patent, col. 1:31-36).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶19).
- The essential elements of independent claim 1 are:
- A cable management panel, comprising:
- a) a chassis;
- b) a drawer mounted to the chassis, configured to slide between an open and closed position; and
- c) a rear drawer latch assembly located at the rear of the drawer, including:
- i) a latch body that vertically moves between an unlocked and a locked position, the latch body including a foot that prevents closing movement of the drawer when the latch body is in the locked position; and
- ii) a spring that biases the latch body toward the locked position.
- The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims" (Compl. ¶19).
III. The Accused Instrumentality
Product Identification
The Accused Patch Panel Products are the L-Series AM-1RU, AM-2RU, AM-3RU, and AM-4RU Sliding Patch Panels (Compl. ¶2, ¶19). The L-Series AM-2RU Sliding Patch Panel is identified as being representative of the accused product line (Compl. ¶21).
Functionality and Market Context
The accused products are modular patch panels for telecommunications racks, designed for cable termination and management (Compl. ¶22; FIG. 2). They feature a "sliding tray for ease of installation," which allows technicians to access internal components (Compl. ¶25, FIG. 3). The complaint alleges these products incorporate an "[i]ntegrated spring-loaded tray stop" that functions as the claimed latching mechanism (Compl. ¶29, FIG. 3). A technical drawing from the Defendant's product documentation depicts the chassis and its material specifications (Compl. ¶24, FIG. 2).
IV. Analysis of Infringement Allegations
'744 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A cable management panel, comprising: | The accused L-Series products are advertised and function as cable management panels, offering "flexibility to the end-user" for installation and reconfiguration (Compl. ¶22). | ¶22 | col. 2:36-38 |
| [a] a chassis; | The accused products provide a chassis, as identified in Defendant's product specifications. An included screenshot of a specifications table explicitly lists a "2RU MODULAR PATCH PANEL CHASSIS" (Compl. ¶24, FIG. 2). | ¶24 | col. 2:45-46 |
| [b] a drawer mounted to the chassis, the drawer having a front and a rear, the drawer being configured to slide between an open position and a closed position relative to the chassis; | The accused products feature a "sliding tray" that moves between open and closed positions for installation access. A diagram from the accused product's installation guide shows the "Sliding tray" in both "closed position" and "open position" relative to the chassis (Compl. ¶25, ¶27, FIG. 4). | ¶25, ¶27 | col. 2:38-42 |
| [c] a rear drawer latch assembly located at the rear of the drawer, the rear drawer latch assembly including: | The accused products feature an "[i]ntegrated spring-loaded tray stop" at the rear of the sliding tray, which allegedly functions as the claimed latch assembly. A close-up, annotated photograph highlights this assembly within the product (Compl. ¶29, ¶30, FIG. 5). | ¶29, ¶30 | col. 4:4-10 |
| [i] a latch body that vertically moves between an unlocked position and a locked position, the latch body including a foot that prevents closing movement of the drawer... | The complaint alleges the "spring-loaded tray stop" incorporates a vertically moving latch body with a foot that prevents the drawer from closing when locked. An annotated photograph labels the "Body of tray stop (latch body)" and the "Foot of the tray stop" (Compl. ¶32, FIG. 6). | ¶32 | col. 5:44-50 |
| [ii] a spring that biases the latch body toward the locked position. | The accused latch body is alleged to include a spring that biases it toward the locked position, as described in product marketing materials identifying a "spring-loaded tray stop" (Compl. ¶34, FIG. 3). | ¶34 | col. 4:5-7 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused "[i]ntegrated spring-loaded tray stop" constitutes a "rear drawer latch assembly" as that term is used in the patent. The defense may argue that the term implies a more complex or distinct structure than the accused component.
- Technical Questions: The complaint alleges the accused latch body "vertically moves," a key limitation explicitly recited in the claim. The case may turn on evidence of how the accused mechanism actually operates. The question will be whether the accused "Body of tray stop" (Compl. ¶32, FIG. 6) performs a linear, vertical translation as described in the patent, or if its motion is functionally different (e.g., pivotal or rotational).
V. Key Claim Terms for Construction
The Term: "latch body that vertically moves"
Context and Importance: This term is critical because it defines the specific motion of the core latching component. The infringement analysis will depend on whether the accused product's "tray stop" performs this exact type of linear motion. Practitioners may focus on this term because the patent specification contrasts this vertical translation with other types of movement, stating the body "linearly (i.e., vertically) translates... as opposed to rotating or pivoting between positions" ('744 Patent, col. 5:44-47).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "vertically moves" should be given its plain and ordinary meaning, which might encompass any movement that has a primary vertical component, even if accompanied by minor incidental motion in other directions.
- Evidence for a Narrower Interpretation: The specification provides a strong basis for a narrow construction, explicitly stating the linear, vertical movement is an alternative to "rotating or pivoting" ('744 Patent, col. 5:44-47). Further, dependent claim 16 specifies that the latch body "vertically moves," reinforcing the importance of this specific motion to the invention.
The Term: "foot"
Context and Importance: The structure and function of the "foot" are essential for the latching function of preventing drawer closure. The analysis will require determining if the component labeled "Foot of the tray stop" in the complaint's visual evidence (Compl. ¶32, FIG. 6) has the structure and performs the function described in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "foot" itself is not explicitly defined, which may support an interpretation that covers any downward-projecting structure that performs the stopping function.
- Evidence for a Narrower Interpretation: The specification describes the foot in some detail, noting it extends downward from shoulders on the latch body and includes a "rear-facing stop surface" that contacts a portion of the slide assembly to prevent movement ('744 Patent, col. 4:17-24; col. 5:54-57). This description may be used to argue for a more limited definition requiring these specific structural characteristics.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b), asserting that Defendant's knowledge of the patent and infringement began at least as of the filing of the lawsuit (Compl. ¶37). The inducement is allegedly based on Defendant instructing customers on how to use the accused products through marketing materials that highlight features like the "[s]liding tray for ease of installation" and by providing customer support (Compl. ¶38).
- Willful Infringement: The complaint alleges that Defendant's infringement is willful and requests enhanced damages, but the factual basis for willfulness appears to be tied to post-suit conduct (Compl. ¶37, Prayer for Relief ¶B).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case will likely depend on the court’s determination of two central issues:
- A core issue will be one of mechanics and claim scope: Does the accused "spring-loaded tray stop" operate by the specific "vertical movement" required by Claim 1? The patent’s explicit distinction between linear vertical movement and pivotal motion suggests this will be a heavily contested point of claim construction and infringement analysis.
- A key evidentiary question will be one of structural correspondence: Does the component identified as the "foot" in the accused product possess the structure and perform the blocking function of the "foot" as described and claimed in the '744 patent, particularly with respect to its interaction with the drawer's slide assembly?