DCT

2:23-cv-00449

Universal Connectivity Tech Inc v. Lenovo Group Ltd

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00449, E.D. Tex., 09/28/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has transacted business and committed acts of infringement within the Eastern District of Texas, including through sales via its website and authorized retailers.
  • Core Dispute: Plaintiff alleges that Defendant’s laptops, desktops, monitors, docking stations, and adapters that support data communication standards such as DisplayPort and Universal Serial Bus (USB) infringe eight U.S. patents related to data packet transmission, protocol encapsulation, and device connectivity.
  • Technical Context: The lawsuit concerns the foundational technologies for high-speed data and video interfaces that are ubiquitous in modern consumer and commercial electronics, enabling devices to connect and exchange large amounts of information.
  • Key Procedural History: The complaint details extensive pre-suit licensing discussions between Plaintiff’s parent company (WiLAN) and Defendant, beginning with a notice letter sent on June 30, 2022, and continuing through numerous calls until March 30, 2023, when Defendant declined to take a license. Plaintiff also notes that the asserted patents were previously assigned to a member of the Video Electronics Standards Association (VESA) and the USB Implementers Forum (USB-IF), potentially raising questions regarding standards-essential patent (SEP) and fair, reasonable, and non-discriminatory (FRAND) licensing obligations.

Case Timeline

Date Event
2000-11-22 Earliest Priority Date ('905, '307, '798 Patents)
2004-06-28 Earliest Priority Date ('265 Patent)
2006-12-26 U.S. Patent No. 7,154,905 Issues
2007-01-05 Earliest Priority Date ('520, '231 Patents)
2007-03-06 U.S. Patent No. 7,187,307 Issues
2007-12-20 Earliest Priority Date ('712 Patent)
2010-06-29 U.S. Patent No. 7,746,798 Issues
2010-12-21 U.S. Patent No. 7,856,520 Issues
2011-04-05 U.S. Patent No. 7,921,231 Issues
2013-03-29 Earliest Priority Date ('103 Patent)
2014-03-25 U.S. Patent No. 8,680,712 Issues
2016-01-05 U.S. Patent No. 9,232,265 Issues
2017-12-26 U.S. Patent No. 9,852,103 Issues
2022-06-30 Plaintiff's parent (WiLAN) sends notice letter to Lenovo
2022-07-11 Lenovo confirms receipt of letter, establishing alleged knowledge date for certain patents
2023-09-28 Complaint Filed

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

U.S. Patent No. 7,154,905 - “Method and system for nesting of communications packets”

The Invention Explained

  • Problem Addressed: The patent’s background section describes inefficiencies in existing serial communication protocols, such as Fibre Channel, where transmitting large data blocks (e.g., to a disk drive) can create high overhead and delay if the data must be divided into many small packets, each with its own header (’905 Patent, col. 2:31-44).
  • The Patented Solution: The invention proposes a communication architecture where the transmission of a lower-priority packet (e.g., a large data packet) can be temporarily interrupted, or preempted, to allow for the immediate transmission of a higher-priority packet (e.g., a control packet). Special signals ("primitives") are used to manage the interruption and resumption of the preempted packet, ensuring urgent communications are not delayed by large, routine data transfers (’905 Patent, Abstract; col. 5:1-17; Fig. 13).
  • Technical Importance: This packet preemption or "nesting" technique enables more efficient and responsive handling of mixed data traffic in high-speed serial communication networks, particularly in storage area networks where timely delivery of control commands is critical for system performance (’905 Patent, col. 1:4-6).

Key Claims at a Glance

  • The complaint asserts independent claim 21 (Compl. ¶16).
  • The essential elements of independent claim 21 include:
    • A transmission component that transmits a first packet.
    • A preemption component that signals the transmission component to stop transmitting the first packet.
    • The preemption component then transmits a preempt indicator, transmits a second packet, and signals the transmission component to continue transmitting the first packet.
    • The packets include "in-band symbols" while the indicators include one or more "out-of-band symbols."
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

U.S. Patent No. 7,187,307 - “Method and system for encapsulation of multiple levels of communication protocol functionality within line codes”

The Invention Explained

  • Problem Addressed: Traditional communication protocols are described using a layered model (such as the seven-layer OSI model), where each layer performs distinct functions. Implementing these separate layers in hardware or software can be complex and inefficient (’307 Patent, col. 1:21-30).
  • The Patented Solution: The invention proposes a method to encapsulate functionalities from multiple protocol layers directly into the "line code"—the symbols transmitted at the physical level. A data "cell" is defined that contains both application data and various control bits. The function of each control bit (e.g., whether it serves a link-level, network-level, or application-level purpose) is determined by its specific position within the cell structure, effectively merging multiple protocol layers into a single, efficient data structure (’307 Patent, Abstract; col. 5:35-51; Fig. 2).
  • Technical Importance: This architecture allows for the creation of more efficient and less complex communication systems by integrating protocol functionalities that are typically handled by separate and more resource-intensive higher-level software or hardware stacks (’307 Patent, col. 5:35-42).

Key Claims at a Glance

  • The complaint asserts independent claim 68 (Compl. ¶27).
  • The essential elements of independent claim 68 include:
    • A packetizing circuit that generates M-bit input words, which are indicative of application data and control bits.
    • Encoding circuitry that uses a block code to convert the M-bit words into a sequence of N-bit code words (where N>M).
    • The sequence of code words is indicative of at least one "cell" which includes at least two control bits.
    • Crucially, these two or more control bits have "multiple levels of communication protocol functionality."
  • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

Multi-Patent Capsules

  • Patent Identification: U.S. Patent No. 7,746,798, “Method and system for integrating packet type information with synchronization symbols,” issued June 29, 2010.

  • Technology Synopsis: The patent addresses the need for a receiver in a serial communication system to quickly identify the type of an incoming data packet (e.g., control vs. data). The solution integrates the packet-type information directly into the synchronization symbols that precede the packet, allowing the physical or link layer to identify the packet type without having to parse the packet header (’798 Patent, Abstract).

  • Asserted Claims: Independent claim 19 is asserted (Compl. ¶38).

  • Accused Features: The complaint accuses products supporting USB 3.0 and later versions (Compl. ¶37).

  • Patent Identification: U.S. Patent No. 9,232,265, “Method, apparatus and system for transitioning an audio/video device between a source mode and a sink mode,” issued January 5, 2016.

  • Technology Synopsis: The patent addresses devices that can act as both a source (e.g., sending video) and a sink (e.g., receiving video). The invention provides a method where such a device defaults to a "sink" mode to prevent electrical conflicts and then uses a detection process to determine if it should safely switch to "source" mode (’265 Patent, Abstract).

  • Asserted Claims: Independent claim 8 is asserted (Compl. ¶49).

  • Accused Features: The complaint accuses products supporting USB-C Revision 1.0 and later (Compl. ¶48).

  • Patent Identification: U.S. Patent No. 8,680,712, “Power delivery over digital interaction interface for video and audio (DiiVA),” issued March 25, 2014.

  • Technology Synopsis: The patent describes a system for delivering electrical power over the same serial cable used for transmitting high-speed digital video and audio. The system uses filtering to separate the DC power from the high-frequency data signals, allowing a single cable to provide both data and power (’712 Patent, Abstract).

  • Asserted Claims: Independent claim 1 is asserted (Compl. ¶60).

  • Accused Features: The complaint accuses products supporting USB-C Version 1.0 and later (Compl. ¶59).

  • Patent Identification: U.S. Patent No. 7,856,520, “Control bus for connection of electronic devices,” issued December 21, 2010.

  • Technology Synopsis: The invention addresses the need to simplify connections between devices by merging multiple control signals onto a single, bi-directional control bus. It describes a protocol where standard control signals are converted into data packets for transmission over this single-line bus, reducing pin counts and cable complexity (’520 Patent, Abstract).

  • Asserted Claims: Independent claim 12 is asserted (Compl. ¶71).

  • Accused Features: The complaint accuses products supporting DisplayPort Alt Mode on USB Type-C Version 1.0 and later (Compl. ¶70).

  • Patent Identification: U.S. Patent No. 7,921,231, “Discovery of electronic devices utilizing a control bus,” issued April 5, 2011.

  • Technology Synopsis: The patent describes a method for a device to discover the type of device it is connected to over a control bus. A device transitions between different states (e.g., "disconnect," "pending," "discovered") based on detecting voltage levels and signal pulses on the control and power lines, allowing it to identify whether it is connected to, for example, a standard or mobile device (’231 Patent, Abstract).

  • Asserted Claims: Independent claim 10 is asserted (Compl. ¶81).

  • Accused Features: The complaint accuses products supporting DisplayPort Alt Mode on USB Type-C Version 1.0 and later (Compl. ¶80).

  • Patent Identification: U.S. Patent No. 9,852,103, “Bidirectional transmission of USB data using audio/video data channel,” issued December 26, 2017.

  • Technology Synopsis: This invention provides a method for sending bidirectional USB data over a multimedia link primarily designed for unidirectional audio/video transmission (like MHL or HDMI). It uses time-division multiplexing (TDM) to create time slots for both forward (source-to-sink) and backward (sink-to-source) data transmission on the same physical channel (’103 Patent, Abstract).

  • Asserted Claims: Independent claim 21 is asserted (Compl. ¶91).

  • Accused Features: The complaint accuses products supporting USB 4 Version 1.0 and later (Compl. ¶90).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as a broad category of Lenovo-branded products, including laptops, desktops, monitors, docking stations, and adapters (Compl. ¶4). Specific representative products mentioned include the Qreator 27 UHD Monitor, ThinkCentre M75s Gen 2 Desktop, ThinkPad USB-C Dock Gen 2, and Legion 7 Gen 6 & 7 Gaming Laptops (Compl. ¶15, ¶26).

Functionality and Market Context

The accused functionality is the products' implementation of industry-standard communication protocols, including DisplayPort (version 1.2 and later), USB (version 3.0 and later), USB-C (version 1.0 and later), DisplayPort Alternate Mode over USB-C, and USB 4 (Compl. ¶15, ¶37, ¶48, ¶59, ¶70, ¶80, ¶90). These standards are alleged to enable the transfer of data, audio, video, and power between the accused products and other devices. The complaint alleges these products are sold throughout the United States via Lenovo's website and retail partners (Compl. ¶4). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products directly infringe the asserted claims and refers to external claim chart exhibits (e.g., Exhibits 3 and 7) for detailed element-by-element comparisons (Compl. ¶16, ¶27). As these exhibits were not provided with the complaint, the following charts summarize the infringement theory based on the complaint's narrative allegations, which link infringement to the products' support for specific industry standards.

U.S. Patent No. 7,154,905 Infringement Allegations

Claim Element (from Independent Claim 21) Alleged Infringing Functionality Complaint Citation Patent Citation
a transmission component that transmits a first packet The hardware and software in the Accused Products that transmit data packets in accordance with the DisplayPort 1.2 (or later) standard. ¶15 col. 7:12-25
a preemption component that signals the transmission component to stop transmitting the first packet, transmits a preempt indicator indicating that a second packet is to be transmitted, transmits the second packet, and signals the transmission component to continue transmitting the first packet Logic within the Accused Products' DisplayPort implementation that interrupts a lower-priority data stream (e.g., video) to transmit a higher-priority packet (e.g., control information) and then resumes the original stream, a process inherent to managing mixed data types in the standard. ¶15, ¶18 col. 19:21-42
wherein packets include in-band symbols and the indicators include one or more out-of-band symbols The use of different symbol types within the DisplayPort protocol to distinguish between normal data payload ("in-band") and special control signals ("out-of-band"), such as those used to manage packet preemption. ¶15, ¶18 col. 11:48-61

U.S. Patent No. 7,187,307 Infringement Allegations

Claim Element (from Independent Claim 68) Alleged Infringing Functionality Complaint Citation Patent Citation
a packetizing circuit configured to generate M-bit input words, wherein the input words are indicative of application data and control bits The circuitry in the Accused Products that assembles data cells for transmission under the DisplayPort 1.0 (or later) standard, where such cells contain both payload data and various control bits. ¶26 col. 8:27-38
encoding and transmission circuitry coupled to the packetizing circuitry and configured to encode the input words in accordance with a block code to generate a code word sequence of N-bit code words, where N>M The circuitry that performs line coding (e.g., 8b/10b encoding) as specified by the DisplayPort standard to convert the data cells into symbols suitable for physical transmission. ¶26, ¶29 col. 9:1-6
the code word sequence is indicative of at least one cell of the input words, the cell includes at least two of the control bits, and said at least two of the control bits have multiple levels of communication protocol functionality The structure of a DisplayPort data packet, which allegedly contains distinct control bits serving different protocol functions (e.g., link-layer flow control, application-layer content identification) within the same packet structure. ¶26, ¶29 col. 5:35-42

Identified Points of Contention

  • Scope Questions: A central question for the ’905 Patent will be whether the DisplayPort standard's method for prioritizing and managing different data streams constitutes "packet nesting" with "preempt indicators" as those terms are defined and used in the patent. For the ’307 Patent, a key dispute may arise over whether the different types of control information within a standard DisplayPort packet (e.g., framing, addressing, payload type) constitute "multiple levels of communication protocol functionality" in the hierarchical sense (e.g., OSI model) contemplated by the patent.
  • Technical Questions: The analysis will depend on evidence demonstrating how the accused Lenovo products actually implement the DisplayPort and USB standards. A question for the court will be whether the specific hardware and software logic in the accused products performs the functions recited in the claims, or if there is a functional difference between the standardized implementation and the patented methods.

V. Key Claim Terms for Construction

  • The Term: "preempt indicator" (’905 Patent, claim 21)

  • Context and Importance: The infringement case for the ’905 Patent hinges on whether control signals used in the DisplayPort standard to interrupt a data stream are construed as a "preempt indicator." Practitioners may focus on this term because its definition will determine if the patent reads on standardized technology or is limited to the specific "preempt primitive" embodiment described in the specification.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim language itself is functional ("indicating that a second packet is to be transmitted") and does not recite a specific structure, which may support a construction covering any signal that performs this function (’905 Patent, col. 38:6-8).
    • Evidence for a Narrower Interpretation: The specification repeatedly describes the indicator as a specific "preempt primitive," which is an "out-of-band" control symbol distinct from data packets (’905 Patent, col. 20:11-16; Fig. 13). This could support an argument that the term is limited to this specific type of implementation.

  • The Term: "multiple levels of communication protocol functionality" (’307 Patent, claim 68)

  • Context and Importance: This term is the core of the asserted ’307 claim. The dispute will likely focus on whether the various control bits within a DisplayPort or USB packet (e.g., for error checking, addressing, flow control) represent distinct "levels" of a protocol stack (like the OSI model referenced in the patent), or are merely different functions within a single protocol layer.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claim is written broadly and does not explicitly tie the "levels" to the specific seven-layer OSI model, suggesting it could cover any set of control bits with functionally distinct roles, such as link management versus application data identification (’307 Patent, col. 62:38-42).
    • Evidence for a Narrower Interpretation: The patent’s background is grounded in the OSI and TCP/IP models, describing layers like "application, presentation, session, transport, network, link, and physical" (’307 Patent, col. 1:22-26). This context suggests the term may be limited to encapsulating functions from these traditionally separate hierarchical layers, not just different functions within a single layer.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. Inducement is based on allegations that Lenovo provides product specifications and user manuals that instruct and encourage customers to use the accused products in an infringing manner (e.g., by connecting a monitor via a DisplayPort cable) (Compl. ¶18, ¶29). Contributory infringement is based on the allegation that components supporting the accused standards are a material part of the invention and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶19, ¶30).
  • Willful Infringement: Willfulness allegations for the ’905, ’307, ’798, ’265, and ’712 patents are based on alleged pre-suit knowledge stemming from a notice letter sent on June 30, 2022, and subsequent licensing discussions (Compl. ¶22, ¶33, ¶44, ¶55, ¶66). For the ’520, ’231, and ’103 patents, willfulness is based on knowledge obtained from the filing and service of the complaint itself (Compl. ¶72, ¶82, ¶92).

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

  • A central issue will be one of claim construction and scope: can claim terms rooted in the patents' specific "Storage Link" and protocol encapsulation architectures be construed broadly enough to cover the now-ubiquitous, standardized implementations of DisplayPort and USB, or is there a fundamental mismatch between the patented inventions and how these industry standards operate?
  • A key legal and evidentiary question will concern the patents' relationship to industry standards. The complaint’s reference to the patents' prior ownership by a VESA and USB-IF member (Compl. ¶99) raises the question of whether the patents are encumbered by FRAND licensing obligations, which would directly impact the availability of injunctive relief and the calculation of a reasonable royalty.
  • The dispute will also turn on a question of technical mapping: what factual evidence will demonstrate that the specific functions performed by the accused Lenovo products, as they implement the relevant standards, are the same as, or equivalent to, the specific functions recited in the asserted claims, particularly regarding concepts like "packet nesting" and "multiple protocol levels"?