DCT
2:24-cv-00493
Pinn Inc v. Shenzhen Soundsoul Information Technology Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Pinn, Inc. (California)
- Defendant: Shenzhen Tektek Technology Co., Ltd. and Shenzhen Soundsoul Information Technology Co., Ltd. (doing business as Soundpeats) (China)
- Plaintiff’s Counsel: Connor Lee and Shumaker PLLC
- Case Identification: 2:24-cv-493, E.D. Tex., 07/05/2024
- Venue Allegations: Plaintiff alleges venue is proper because Defendants are foreign corporations that have committed acts of infringement in the Eastern District of Texas by selling, advertising, distributing, and importing products into the district.
- Core Dispute: Plaintiff alleges that Defendant’s Soundpeats brand of wireless earbud products infringes three U.S. patents related to the functional interaction between wireless earbuds and their charging/base stations.
- Technical Context: The technology at issue involves systems where wireless earbuds physically connect to a base station (charging case) to initiate functions like charging, wired data communication, and managing wireless pairing with a smartphone.
- Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2015-04-03 | Earliest Patent Priority Date (’066, ’061, ’340 Patents) |
| 2019-10-22 | Issue Date: U.S. Patent No. 10,455,066 |
| 2021-08-24 | Issue Date: U.S. Patent No. 11,102,340 |
| 2023-12-19 | Issue Date: U.S. Patent No. 11,849,061 |
| 2024-07-05 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,455,066 - "Mobile System with Wireless Earbud"
- Issued: October 22, 2019
The Invention Explained
- Problem Addressed: The patent describes the inconvenience of accessing the functions of modern mobile devices like smartphones, which are often stored in a pocket or purse, making them difficult to operate without being physically handled ('066 Patent, col. 1:7-22).
- The Patented Solution: The invention is a "personal wireless media station" composed of a base station and a detachable wireless earbud ('066 Patent, col. 5:5-12). The system is designed to seamlessly manage audio playback and other functions based on whether the earbud is physically docked in the base station. When docked, the system can use the base station's speaker; when undocked, audio is automatically redirected to the earbud ('066 Patent, Abstract). This configuration provides a more convenient and accessible interface to the user's primary mobile device ('066 Patent, col. 5:36-40).
- Technical Importance: The claimed solution provides for an automatic and intuitive audio handoff between a public listening mode (base station speaker) and a private listening mode (earbud), a feature aimed at improving user experience in the growing wireless audio market.
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶29).
- Essential elements of Claim 1 include:
- A base station comprising a connection hole, a user input button, a processor, memory, and circuitry.
- A wireless earbud configured to plug into the connection hole to form an integrated body with the base station.
- The system is capable of wirelessly pairing with a smartphone for the earbud to receive audio data.
- Pressing the user input button initiates processing for the wireless pairing.
- Plugging the earbud into the connection hole initiates charging of the earbud's battery.
- When plugged in, the earbud electrically connects with the base station's circuitry and performs wired data communication with the base station.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,849,061 - "Mobile System with Wireless Earbud"
- Issued: December 19, 2023
The Invention Explained
- Problem Addressed: This patent, related to the ’066 Patent, addresses the same problem of convenient user access to a primary mobile device ('061 Patent, col. 1:23-34).
- The Patented Solution: The invention is a mobile system with a base station and at least one wireless earbud, where the system's behavior is governed by the docking state of the earbud ('061 Patent, col. 1:44-50). A key feature of this patent's claims is the processor being configured to "initiate cessation of wireless communication" between the earbud and the smartphone when the earbud is docked in the base station, in addition to initiating charging and performing wired data communication ('061 Patent, col. 33:58-62).
- Technical Importance: This approach suggests a power management and communication-routing strategy where the system intelligently disables the earbud's direct wireless link to the phone when it is physically connected to the base station, potentially conserving power and streamlining data flow.
Key Claims at a Glance
- The complaint asserts at least independent Claim 1 (Compl. ¶32).
- Essential elements of Claim 1 include:
- A system with a mobile base station (comprising a docking bay, button/sensor, processor, memory, and rechargeable battery) and at least one wireless earbud (comprising a wireless module and rechargeable battery).
- The system initiates Bluetooth pairing in response to a user input.
- Docking the earbud initiates charging of the earbud battery.
- Docking the earbud also causes the processor to initiate cessation of wireless communication between the earbud and the smartphone.
- When docked, the earbud electrically connects to and performs wired data communication with the base station.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 11,102,340 - "Mobile System with Wireless Earbud"
- Issued: August 24, 2021
Technology Synopsis
- This patent describes a mobile system comprising a base station and a wireless earbud that form an integrated body when connected. The system pairs with a smartphone to receive audio, and the base station's processor executes instructions based on user input (e.g., pressing a button to initiate pairing) and physical state (e.g., plugging in the earbud to initiate charging) ('340 Patent, Abstract; col. 33:50-34:21).
Asserted Claims
- At least independent Claim 1 is asserted (Compl. ¶35).
Accused Features
- The complaint alleges the Accused Products infringe based on their overall system architecture, which includes a base station with a connection hole, user input button, and circuitry, and a wireless earbud that plugs into the hole to charge, perform wired data communication, and wirelessly pair with a smartphone (Compl. ¶¶13-24).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" include numerous wireless earbud models sold under the Soundpeats brand, such as Capsule 3 Pro, Opera03, Opera05, Engine4, Life, Air 3 Deluxe, Air4, and others (Compl. ¶14).
Functionality and Market Context
- The Accused Products are described as systems comprising wireless earbuds and a "base station case" (Compl. ¶15). The complaint alleges that the earbuds "plug into respective connection holes" in the case, where they are "magnetically secured" (Compl. ¶16).
- Functionally, the products are alleged to wirelessly pair with a smartphone via Bluetooth to receive audio data (Compl. ¶¶13, 17). The complaint provides an image showing the "Capsule 3 Pro Base Station Circuitry and Memory," alleging the presence of at least one processor and memory (Compl. ¶19, p. 8).
- A user input button on the base station is allegedly used to "initiate processing for the wireless pairing" (Compl. ¶20). The complaint includes a diagram from a user manual illustrating this process (Compl. ¶22, p. 13).
- When an earbud is placed in its connection hole, a processor allegedly executes instructions to "initiate charging of the wireless earbud battery" (Compl. ¶23).
- The complaint further alleges that charging occurs via contacts that also facilitate "wired two-way data communication" (Compl. ¶24).
IV. Analysis of Infringement Allegations
U.S. Patent No. 10,455,066 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a base station comprising a connection hole, a user input button, at least one processor, at least one memory, and circuitry; | The accused Soundpeats products include a base station case with connection holes, a user input button, and internal circuitry containing at least one processor and memory. | ¶¶13, 15, 16, 19, 20 | col. 33:17-20 |
| a wireless earbud configured for plugging into the connection hole of the base station to form an integrated body with the base station, | The Soundpeats wireless earbuds are alleged to plug into connection holes within the base station case to form a magnetically secured, integrated body. | ¶16 | col. 33:21-24 |
| wherein the system is capable of wirelessly pairing with a smartphone for the wireless earbud to receive audio data originated from the smartphone, | The earbuds wirelessly pair with a smartphone using Bluetooth to receive audio data for playback. | ¶¶13, 17, 22 | col. 33:25-28 |
| wherein, in response to pressing of the user input button, the at least one processor is configured to execute computer program instructions...to initiate processing for the wireless pairing with the smartphone... | A user input button on the base station, when pressed, is alleged to execute instructions that initiate the Bluetooth pairing process with a smartphone. | ¶20 | col. 33:29-35 |
| wherein, in response to plugging the wireless earbud into the connection hole, the at least one processor is configured to execute computer program instructions...to initiate charging of a battery of the wireless earbud, | When the earbuds are placed in the connection holes, the processor is allegedly configured to execute instructions to begin charging the earbud's battery. | ¶23 | col. 33:36-40 |
| wherein, when the wireless earbud is plugged into the connection hole...the wireless earbud is configured to electrically connect with the circuitry of the base station and further configured to performing wired data communication with the base station. | The earbuds are alleged to make electrical contact for charging and to perform "wired two-way data communication" with the base station when docked. | ¶24 | col. 33:41-44 |
- Identified Points of Contention:
- Scope Questions: The complaint's use of images depicting standard charging cases raises the question of whether a simple charging receptacle qualifies as the "connection hole" recited in the claim, especially in light of the patent's detailed description of a "docking bay" with mechanical locking features ('066 Patent, col. 7:8-42).
- Technical Questions: A central evidentiary question may be the nature of the "wired data communication" (Compl. ¶24). The litigation may explore whether this communication involves substantive data transfer as contemplated by the patent or is limited to basic charging status handshakes, which a defendant might argue does not meet the claim limitation.
U.S. Patent No. 11,849,061 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| ...a mobile base station comprising a docking bay...and at least one rechargeable base station battery; | The accused products include a portable base station case with receptacles for the earbuds and an internal battery for charging. | ¶¶15, 16, 23 | col. 33:17-22 |
| ...at least one wireless earbud includes a wireless module and a rechargeable earbud battery and is configured to dock into the docking bay... | The earbuds are wireless and contain rechargeable batteries; they are placed into the case's receptacles to charge. | ¶¶13, 16, 23 | col. 33:23-26 |
| ...in response to docking...the at least one processor is further configured to execute...instructions...to initiate cessation of wireless communication between the at least one wireless earbud and the smartphone, | The complaint alleges that the Soundpeats earbuds are "not capable of wirelessly communicating with the mobile base station," which may be Plaintiff's basis for alleging cessation of communication when docked. | ¶25 | col. 33:58-62 |
| ...while the at least one wireless earbud is docked...is configured to electrically connect with...and further configured to perform wired data communication with the mobile base station. | The earbuds allegedly make electrical contact via charging pins and perform "wired two-way data communication" when placed in the case. | ¶24 | col. 34:1-4 |
- Identified Points of Contention:
- Scope Questions: The term "initiate cessation of wireless communication" will be a critical point of dispute. The analysis may turn on whether this requires the earbud's Bluetooth radio to be fully powered down or merely to enter an idle state, and what level of "cessation" the accused products actually perform.
- Technical Questions: Plaintiff's allegation that the earbuds are "not capable of wirelessly communicating with the mobile base station" (Compl. ¶25) is a factual assertion that will require technical evidence. A defendant may argue this is inaccurate or that any change in communication status when docked does not meet the specific requirements of the claim.
V. Key Claim Terms for Construction
The Term: "connection hole" ('066 Patent, Claim 1)
- Context and Importance: This term defines the physical interface between the two core components of the claimed system. Its construction is critical because it determines whether the claim reads on a wide variety of modern wireless earbud charging cases or is limited to a more specific mechanical structure. Practitioners may focus on this term because the complaint uses it to describe what appear to be standard charging receptacles.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "hole" itself is simple and generic. Claim 1 does not add structural limitations to the term, suggesting it should be given its plain and ordinary meaning as a recess or opening designed to receive the earbud.
- Evidence for a Narrower Interpretation: The specification extensively describes a "docking bay" with "two docking arms," a "locking device," and "locking protrusion" ('066 Patent, col. 7:8-28). A defendant may argue that these detailed descriptions of a specific embodiment should inform and limit the scope of the broader term "connection hole" used in the claim.
The Term: "initiate cessation of wireless communication" ('061 Patent, Claim 1)
- Context and Importance: This functional limitation is a key differentiator in Claim 1 of the ’061 patent. The case may hinge on whether the accused products' behavior upon being placed in the charging case meets this requirement. Its definition will determine whether merely halting an audio stream is sufficient or if a more definitive termination of the wireless link is required.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not specify a degree of cessation. Plaintiff may argue that any processor-controlled action that stops the active wireless data link between the earbud and smartphone upon docking—such as pausing media and entering a standby state—satisfies this limitation.
- Evidence for a Narrower Interpretation: A defendant may argue "cessation" implies a more complete termination, such as powering down the Bluetooth radio or formally severing the pairing connection. The specification describes a system where the base station can take over communication, relaying data to the earbud via a wired connection, suggesting a fundamental shift in communication modality rather than a simple pause ('061 Patent, col. 20:5-16).
VI. Other Allegations
- Indirect Infringement: The complaint does not contain explicit counts or allegations of indirect infringement (either induced or contributory).
- Willful Infringement: The complaint does not allege facts to support a claim of willful infringement, such as pre-suit knowledge of the patents by the Defendant. However, the prayer for relief includes a request for "enhanced and/or treble damages" (Compl., Prayer for Relief ¶3).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute appears to center on the functional details of how wireless earbuds interact with their charging cases. The key questions for the court will likely be:
- A core issue will be one of definitional scope: can the term "connection hole," as used in the ’066 patent, be construed to cover the charging receptacles of the accused products, or is it implicitly limited by the patent's specification to a more complex mechanical "docking bay"?
- A key evidentiary question will be one of technical operation: what is the specific nature of the "wired two-way data communication" (Compl. ¶24) alleged in the accused products, and does the act of docking them "initiate cessation of wireless communication" ('061 Patent, cl. 1) in a manner that falls within the scope of the claims?
- A final question will be one of functionality: does the user input button on the accused base stations perform the specific function of "initiat[ing] processing for the wireless pairing" as claimed, or is its function more general-purpose, with pairing being primarily managed by the smartphone's operating system?