DCT
2:22-cv-00068
Longhorn HD LLC v. Bullitt Group Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Longhorn HD LLC. (Texas)
- Defendant: Bullitt Group Ltd. (United Kingdom)
- Plaintiff’s Counsel: Fabricant LLP; Rubino IP; Truelove Law Firm, PLLC
- Case Identification: 2:22-cv-00068, E.D. Tex., 03/07/2022
- Venue Allegations: Venue is asserted on the basis that Defendant is not a resident of the United States and may therefore be sued in any judicial district pursuant to 28 U.S.C. § 1391(c)(3).
- Core Dispute: Plaintiff alleges that Defendant’s Cat-branded smartphones, which are compatible with the Android Operating System, infringe a patent related to systems and methods for backing up information from a handheld device.
- Technical Context: The technology concerns methods for transferring data between a handheld electronic device, such as a smartphone, and an external or internal storage medium, a critical function for data security and device migration.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2006-06-01 | ’924 Patent Priority Date |
| 2014-05-13 | ’924 Patent Issue Date |
| 2022-03-07 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,725,924 - “Information Backup System with Storing Mechanism and Method of Operation Thereof,” Issued May 13, 2014
The Invention Explained
- Problem Addressed: The patent addresses the risk of data loss when handheld devices are lost, stolen, or damaged, and the difficulty of transferring information to a replacement device, particularly one of a different make or model with an incompatible interface (ʼ924 Patent, col. 1:31-54).
- The Patented Solution: The invention proposes an information backup system centered on a "host microcontroller." This microcontroller serves as an intermediary, connecting to both a handheld device (e.g., a smartphone) and a mass storage device. By functioning as a "host" to both devices, it can manage and facilitate the direct transfer of data between the phone and the storage medium, bypassing compatibility issues between different phone models (ʼ924 Patent, Abstract; col. 2:20-41). Figure 7, for example, depicts an "information backup device" (702) containing a host microcontroller (706) that connects to a handheld device (104) and a mass storage device (710).
- Technical Importance: The described solution provides a device-agnostic architecture for backing up and restoring data locally, offering an alternative to manufacturer-specific software or nascent cloud-based services, thereby increasing user control and data portability (ʼ924 Patent, col. 3:34-44).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶14).
- The complaint reserves the right to assert other claims (Compl. ¶13).
- Independent Claim 1 (Method Claim) Elements:
- supplying a power to a first communication port and a second communication port with an internal power supply;
- electrically connecting a host microcontroller to the first communication port for connecting a handheld device;
- electrically connecting the host microcontroller to the second communication port for connecting a mass storage device, the host microcontroller is for functioning as a host to the second communication port and the first communication port; and
- transferring data between the first communication port and the second communication port.
III. The Accused Instrumentality
Product Identification
- The accused products are the Bullitt/Cat mobile devices, including at least the CAT S62, CAT S62 Pro, and CAT S42, which are compatible with the Android Operating System (Compl. ¶10).
Functionality and Market Context
- The complaint alleges these devices include "information backup systems" that perform the patented method (Compl. ¶10, ¶14). The allegedly infringing functionality involves the use of the devices' internal components to transfer data. Specifically, the complaint points to the devices' internal battery as the "internal power supply," their Snapdragon processor as the "host microcontroller," and their various connection capabilities (WIFI, Bluetooth, NFC, USB) as the claimed "communication ports" (Compl. ¶15-16). The complaint provides a specification sheet for the CAT S62 Pro, which lists connectivity options including USB 2.0, Bluetooth, and NFC (Compl. p. 5).
IV. Analysis of Infringement Allegations
’924 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A method of operation of an information backup system comprising: supplying a power to a first communication port and a second communication port with an internal power supply; | The Accused Products perform a method wherein an internal power supply (the battery of the device) supplies power to a first communication port (WIFI, Bluetooth, or NFC connection ports) and a second communication port (the device's storage). | ¶15 | col. 8:5-11 |
| electrically connecting a host microcontroller to the first communication port for connecting a handheld device; | The Accused Products feature a host microcontroller (the Snapdragon processor) electrically connected to the first communication port. | ¶16 | col. 8:16-20 |
| electrically connecting the host microcontroller to the second communication port for connecting a mass storage device, the host microcontroller is for functioning as a host to the second communication port and the first communication port; | The Snapdragon processor is electrically connected to the second communication port (for connecting a mass storage device) and functions as a host to both the first and second communication ports. | ¶16 | col. 8:37-41 |
| and transferring data between the first communication port and the second communication port. | The Accused Products transfer data between the first and second communication ports, as described in user instructions for file transfers. The complaint includes a screenshot detailing how to transfer files via USB (Compl. p. 5). | ¶16 | col. 8:42-45 |
- Identified Points of Contention:
- Scope Questions: A principal question is whether a self-contained smartphone can constitute the claimed "information backup system." The patent specification and figures consistently depict the "information backup device" (e.g., Fig. 7, item 702) as a separate hardware entity that connects to the "handheld device" (item 104). The complaint's theory, however, appears to map the claim elements onto the internal components of a single accused smartphone.
- Technical Questions: The infringement theory raises the question of whether a smartphone's primary processor (e.g., Snapdragon) can be considered the claimed "host microcontroller" that functions as a "host to" the phone's own communication ports. This may introduce a dispute over whether a component can logically act as a "host" to the very device of which it is a part.
V. Key Claim Terms for Construction
The Term: "host microcontroller"
- Context and Importance: The definition of this term appears central to the dispute. The case may turn on whether the accused smartphone’s internal processor (e.g., Snapdragon) can be construed as the claimed "host microcontroller." Practitioners may focus on this term because the patent's description and figures seem to illustrate it as a component within a separate, intermediary backup device, whereas the complaint alleges it is the phone's own main processor (Compl. ¶16).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term is not explicitly defined with limiting language in the claims themselves. A party could argue that any processor that manages data flow between two I/O ports in a host capacity meets the plain and ordinary meaning of the term.
- Evidence for a Narrower Interpretation: The specification repeatedly describes the "host microcontroller" (e.g., 706) as part of a distinct "information backup device" (702) which connects externally to the "handheld device" (104) (ʼ924 Patent, Fig. 7). This consistent depiction may be used to argue that the term implies a component external to the handheld device it is backing up.
The Term: "information backup system"
- Context and Importance: The scope of this system term is critical. A determination must be made as to whether the "system" can be embodied entirely within a single smartphone, as the complaint's allegations suggest, or if it necessarily comprises at least two separate devices (the handheld device and the backup device).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that if all the recited structural components (power supply, ports, microcontroller) are found within a single smartphone, then that phone itself constitutes the claimed "system."
- Evidence for a Narrower Interpretation: The patent's abstract, detailed description, and figures consistently differentiate between the "information backup device" and the "handheld device" as separate components that connect to each other (ʼ924 Patent, Fig. 1; Fig. 7). This may support an interpretation that the "system" requires more than a single, self-contained smartphone.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "step-by-step instructions on transferring data from one Bullitt/Cat phone ... to another" and thereby intends for end-users to perform the infringing method (Compl. ¶19).
- Willful Infringement: The complaint alleges that Defendant has knowledge of its infringement at least as of the date the complaint was filed, supporting a claim for post-suit willfulness (Compl. ¶18). It further alleges Defendant acted with intent or was "willfully blind" to the infringement (Compl. ¶19). The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, which can be a basis for awarding attorney's fees (Compl. Prayer for Relief ¶d).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may depend on the court's interpretation of the patent's fundamental architecture. The key questions appear to be:
- A core issue will be one of system scope: Can the claims for an "information backup system," which the patent specification consistently illustrates as an intermediary device connecting to a smartphone, be construed to read on the internal components of a single, standalone smartphone?
- A related key question will be one of component identity: Does a smartphone’s own main processor meet the claim requirement of a "host microcontroller" that functions as "a host to... the first communication port" of the handheld device itself, or does the claim language require a logical and physical separation between the host and the device it is hosting?