DCT
2:24-cv-00793
Fantasia Trading LLC v. Ministrap LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Fantasia Trading, LLC d/b/a AnkerDirect (Delaware)
- Defendant: Ministrap, LLC (Georgia)
- Plaintiff’s Counsel: Rimon P.C.; Buchalter
- Case Identification: 1:23-cv-04762, N.D. Ga., 09/06/2024
- Venue Allegations: Venue is alleged to be proper in the Northern District of Georgia because Defendant Ministrap is a Georgia LLC registered to do business in the forum, with its principal place of business in Atlanta.
- Core Dispute: Plaintiff seeks a declaratory judgment that its Anker-branded electronic cables, which include integrated fastening straps, do not infringe three of Defendant’s patents related to secure strap systems.
- Technical Context: The technology concerns reusable, self-fastening straps, often made of hook-and-loop material, designed for organizing and bundling objects like electrical cords.
- Key Procedural History: The complaint states that this declaratory judgment action arises in response to a series of patent infringement lawsuits filed by Defendant Ministrap against several of Plaintiff Fantasia’s major retail customers, including Best Buy, Costco, Target, and Walmart. Those lawsuits, filed in the Eastern District of Texas, accuse the retailers of infringing the same patents-in-suit by selling Fantasia’s Anker-branded products, thereby creating, in Fantasia's view, a justiciable controversy between Fantasia and Ministrap.
Case Timeline
| Date | Event |
|---|---|
| 2001-03-07 | Priority Date for ’796, ’000, and ’824 Patents |
| 2009-09-15 | U.S. Patent No. 7,587,796 Issues |
| 2013-02-12 | U.S. Patent No. 8,371,000 Issues |
| 2016-07-12 | U.S. Patent No. 9,386,824 Issues |
| 2023-07-14 | Ministrap files infringement lawsuits against Plaintiff's retailers |
| 2023-11-20 | Ministrap serves infringement contentions in retailer lawsuits |
| 2024-09-06 | Plaintiff files Second Amended Complaint for Declaratory Judgment |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,587,796 - "Secure Strap Systems," Issued Sep. 15, 2009
The Invention Explained:
- Problem Addressed: The patent describes limitations with prior art single-strap fasteners, such as the difficulty of integrally connecting one bundled set of objects to another, or the inability to selectively release one bundle while leaving another secured ('796 Patent, col. 1:60-col. 2:6).
- The Patented Solution: The invention is a unitary strap system with at least two distinct elongated strap portions and an aperture positioned between them ('796 Patent, col. 2:60-col. 3:15). This configuration allows each strap portion to be independently looped and cinched, enabling a user to, for example, secure a bundle of cables with one strap portion and then use the second strap portion to anchor that bundle to another object, like a table leg ('796 Patent, Fig. 3-5).
- Technical Importance: This design sought to provide more versatility than a simple, single-loop strap by allowing for the independent and secure management of multiple objects or bundles with a single, integrated fastener ('796 Patent, col. 2:36-44).
Key Claims at a Glance:
- The complaint identifies independent claim 1 as a basis for its non-infringement declaratory judgment action (Compl. ¶¶29-31).
- Essential Elements of Independent Claim 1:
- A fastening strap system with at least one first and one second elongated strap portion.
- The system consists of a unitary portion of flexible sheet material with a first (hook) and second (complementary) fastening surface.
- An aperture is located between the first and second strap portions.
- A key structural requirement that "all said at least one first elongated strap portions and all said at least one second elongated strap portions are parallel and collinear" ('796 Patent, col. 22:8-10).
- The complaint also seeks a declaratory judgment of non-infringement for all dependent claims (Compl. ¶28).
U.S. Patent No. 8,371,000 - "Secure Strap Systems," Issued Feb. 12, 2013
The Invention Explained:
- Problem Addressed: The patent addresses the same technical problems as the parent '796 Patent, namely the need for a more versatile strap system capable of selectively binding multiple bundles of items and allowing for their independent release ('000 Patent, col. 1:59-col. 2:10).
- The Patented Solution: The '000 Patent also discloses a strap system made from a unitary piece of material with two or more strap portions ('000 Patent, Abstract). The solution focuses on an "offset parallel" configuration where the strap portions are parallel but not aligned along the same axis, a design intended to facilitate independent looping and cinching around separate objects ('000 Patent, Fig. 3; col. 3:11-16).
- Technical Importance: The offset design aimed to improve the ergonomics and functionality of bundling two separate items by creating distinct, non-interfering cinching paths for each strap portion ('000 Patent, col. 14:21-34).
Key Claims at a Glance:
- The complaint identifies independent claim 1 as the focus of its non-infringement argument (Compl. ¶¶37-39).
- Essential Elements of Independent Claim 1:
- A fastening strap system with at least first and second strap portions made from a unitary piece of material.
- The material has first and second opposing fastening surfaces.
- A key geometric requirement that "said at least one second strap portion is offset parallel from said first strap portion a distance about equal to said at least one first strap width" ('000 Patent, col. 31:7-9).
- All first and second strap portions are parallel.
- The complaint also seeks a declaratory judgment of non-infringement for claims that depend on the independent claims (Compl. ¶36).
Multi-Patent Capsule: U.S. Patent No. 9,386,824 - "Secure Strap Systems," Issued Jul. 12, 2016
- Technology Synopsis: The '824 Patent continues the theme of the family, describing a strap system for selectively binding longitudinal objects. It discloses systems made from a unitary piece of flexible material with at least two distinct strap portions, and also describes fasteners with three-dimensional, mushroom-shaped hook geometries for enhanced gripping ('824 Patent, col. 4:1-14; Abstract).
- Asserted Claims: The complaint focuses its non-infringement allegations on independent claim 1 (Compl. ¶45).
- Accused Features: The complaint alleges that the "Anker Relevant Products" do not meet the limitations of claim 1, specifically the requirement that "the second elongated strap portion is offset parallel from said first elongated strap portion a distance about equal to said at least one first strap width" (Compl. ¶45).
III. The Accused Instrumentality
- Product Identification: The complaint identifies the accused instrumentalities as the "Anker Relevant Products," which encompass various Anker-branded charging cables that are sold with integrated fastening straps (Compl. ¶10). Specific product lines mentioned or depicted include "Anker PowerLine Select+," "PowerLine II," and "Powerline+ II Braided" cables (Compl. ¶¶11, 13; Ex. D, E, G).
- Functionality and Market Context: The products are consumer electronics charging cables (e.g., USB to Lightning, USB-C) used for powering and syncing devices like smartphones and tablets. The relevant feature is the attached strap, typically made of a hook-and-loop-type material, which allows users to neatly coil and store the cable when not in use. The complaint provides a product image showing an Anker cable coiled and secured by its strap within a carrying case, illustrating the strap's cable management function (Compl. Ex. G, p. 10, ¶19). The complaint alleges these products are sold through major national retailers, indicating significant commercial presence (Compl. ¶6).
IV. Analysis of Infringement Allegations
The complaint is for declaratory judgment of non-infringement. The following tables summarize the Plaintiff’s central arguments for why its products do not meet the asserted claims.
’796 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality - |
|---|---|
| all said at least one first elongated strap portions and all said at least one second elongated strap portions are parallel and collinear. | Plaintiff Fantasia asserts that the straps on its Anker Relevant Products do not have strap portions that are "parallel and collinear" as required by the claim. The complaint provides photographs of the accused products, such as the Anker PowerLine Select+ USB-A Cable, for visual inspection (Compl. Ex. D, p. 4, ¶18). |
’000 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality - |
|---|---|
| said at least one second strap portion is offset parallel from said first strap portion a distance about equal to said at least one first strap width. | Plaintiff contends that its Anker Relevant Products do not satisfy this geometric limitation. The complaint provides visual examples of the products at issue, such as the "Anker PowerLine Select+ Lightning Cable Bundle," inviting a direct comparison against the claim language (Compl. Ex. E, p. 6, ¶18). |
- Identified Points of Contention:
- Scope Questions: The core of the dispute for both the '796 and '000 patents revolves around the construction and application of precise geometric terms ("parallel and collinear," "offset parallel"). The case will question whether the physical configuration of the straps on the Anker products, which are simple cable ties, falls within the scope of these terms as used in patents describing more complex, multi-part binding systems.
- Technical Questions: The complaint does not provide a detailed technical breakdown of why the Anker straps fail to meet the "parallel and collinear" or "offset parallel" limitations. An evidentiary question will be what factual evidence, such as expert testimony and product measurements, Fantasia will present to prove its assertion that the geometry of its products is distinct from that claimed in the patents.
V. Key Claim Terms for Construction
1. "parallel and collinear" ('796 Patent, Claim 1)
- Context and Importance: Plaintiff’s entire non-infringement argument for the '796 Patent rests on this term (Compl. ¶29). The court’s interpretation of whether the two strap portions must lie along the exact same line ("collinear") will be dispositive for this patent. Practitioners may focus on this term because it appears to be a very specific geometric constraint that may not be met by a simple, single-body cable tie.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the purpose as allowing independent bundling. A party could argue that any configuration enabling this function, even if not perfectly collinear in a geometric sense, should be covered.
- Evidence for a Narrower Interpretation: The patent explicitly depicts a "parallel-relationship two-ended strap" in Figure 6, where the two strap portions (130a, 130b) are shown as distinct, parallel, and lying along a common axis ('796 Patent, Fig. 6; col. 15:46-49). This embodiment may be used to argue that "collinear" has a strict, literal geometric meaning.
2. "offset parallel... a distance about equal to said at least one first strap width" ('000 Patent, Claim 1)
- Context and Importance: This term is the foundation of Plaintiff's non-infringement argument for the '000 Patent (Compl. ¶37). The term of degree, "about equal to," is a classic source of claim construction disputes. The outcome will depend on how much deviation from the exact "first strap width" is permitted.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "about" suggests the patentee did not intend to be limited to a precise, single distance. A party might argue it covers any offset that is functionally similar and not radically different from the strap width.
- Evidence for a Narrower Interpretation: Figure 3 depicts an "offset-relationship two-ended strap" where the offset (126) appears visually similar to the width of the strap portions (124) ('000 Patent, Fig. 3; col. 12:1-14). This specific depiction could be used to argue that "about equal" requires a close approximation, and that straps on the accused products lack any such defined, proportional offset.
VI. Other Allegations
- Indirect Infringement: Plaintiff seeks a declaratory judgment that it has not induced infringement by its customers, distributors, or end-users (Compl. ¶¶23, 34, 42). The complaint anticipates that Ministrap would base an inducement claim on Fantasia's act of making the Anker products available for sale (Compl. ¶23).
- Willful Infringement: Willfulness is not directly alleged, as this is a non-infringement action. However, the procedural posture is defined by Ministrap’s prior lawsuits against Fantasia's retailers (Compl. ¶¶10-19). These prior suits establish that Fantasia has had knowledge of the patents-in-suit since at least July 2023, a fact that would be central to any future willfulness allegation made by Ministrap.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to be a preemptive strike by a supplier whose retail channels are being targeted. The case will likely turn on the following central questions:
A central issue will be one of definitional scope: can the specific geometric terms "parallel and collinear" ('796 Patent) and "offset parallel from said first strap portion a distance about equal to said at least one first strap width" ('000 and '824 Patents), which are rooted in the patents' descriptions of multi-part binding systems, be construed to read on the simple, integrated cable ties sold with Anker products?
A key evidentiary question will be one of factual comparison: assuming the claim terms are construed, does the physical structure of the Anker cable straps actually meet those specific geometric limitations? The dispute will likely evolve into a "battle of the experts," with both sides presenting testimony and technical analysis on the precise dimensions and configuration of the accused straps.