Volteon LLC v. Gofleet Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: GoFleet Inc. (Canada)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00880, E.D. Tex., 08/26/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to an electric shaver with integrated imaging capabilities for improved visibility during use.
• Technical Context: The technology concerns personal grooming devices, specifically augmenting traditional electric shavers with digital cameras and displays to provide real-time visual feedback to the user.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 11,297,216 - "Electric shaver with imaging capability"

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of shaving certain areas of skin, noting that direct eye-contact is often impossible, mirrors may not be available or clear, and the user's hand or the shaver itself can obstruct the view of the area being shaved (’216 Patent, col. 2:4-12).
• The Patented Solution: The invention proposes integrating a digital camera into the housing of an electric shaver to capture a close-up image of the skin area. This image is then transmitted to a display unit for the user to view in real-time (’216 Patent, Abstract). The system can consist of a shaver with an integrated camera module (FIG. 3) that transmits data to a separate display unit (FIG. 4), or a shaver with a fully integrated, self-contained display (’216 Patent, col. 2:58-62).
• Technical Importance: The described technology aims to provide real-time, magnified visual feedback during shaving, potentially improving precision and effectiveness without reliance on external mirrors and under various lighting conditions (’216 Patent, col. 2:21-28).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and references "Exemplary '216 Patent Claims" in an attached exhibit, but does not identify specific claims in the body of the complaint (Compl. ¶11). Claim 1 is the first independent claim of the patent.
• Essential elements of Independent Claim 1 include:
  • A first video camera that outputs first video data
  • A second video camera that outputs second video data
  • A multiplexer for combining the first and second video data
  • An antenna for transmitting a wireless signal
  • A wireless transmitter coupled between the multiplexer and antenna
  • A rechargeable battery to power the components
  • A single portable and handheld casing that houses the cameras, transmitter, and multiplexer
  • The casing has two opposed first and second exterior surfaces, with the first camera on the first surface and the second camera on the second surface

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products in its text. It refers to "Exemplary Defendant Products" that are identified in charts incorporated by reference as Exhibit 2 (Compl. ¶11, 16). This exhibit was not provided.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges generally that Defendant makes, uses, sells, and imports infringing products (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an external document, Exhibit 2, which was not provided (Compl. ¶17). The complaint alleges that these charts demonstrate how the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '216 Patent Claims" (Compl. ¶16). Without access to the claim charts or identification of the accused products, a detailed element-by-element infringement analysis is not possible. No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of Claim 1, several technical and legal questions may arise in the dispute.
  • Scope Questions: Claim 1 requires "two opposed first and second exterior surfaces" with a camera attached to each (’216 Patent, col. 28:50-57). A central issue may be the construction of "opposed." Does this term require the surfaces to be parallel and directly opposite (e.g., the front and back of the device), or could it encompass other non-parallel orientations?
  • Technical Questions: A key factual question will be whether the accused products actually possess the specific dual-camera architecture required by Claim 1. The claim recites a first video camera and a second video camera, along with a multiplexer to combine their signals. The complaint provides no facts to suggest the accused products contain such a multi-camera system.

V. Key Claim Terms for Construction

• The Term: "a single portable and handheld casing housing the video cameras, the wireless transmitter, and the multiplexer" (from Claim 1)

• Context and Importance: This term defines the physical integration of the claimed invention. The defendant may argue for a narrow construction requiring all listed components to be fully contained within the casing's primary envelope, while the plaintiff may argue for a broader meaning that includes components attached to the exterior. Practitioners may focus on this term because the precise location and integration of components like antennas and cameras in an accused product could determine infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes embodiments where the "enclosure 17, which is commonly hand-held, is shown as a rectangular, 'box-like' enclosure" (’216 Patent, col. 2:41-43), suggesting a general form factor. Figure 13 shows multiple lenses (55a-d) mounted on different walls of the casing, which could support an argument that "housing" includes integrating components onto various external surfaces.
  • Evidence for a Narrower Interpretation: The claim's recitation of a "single...casing housing" multiple components could be interpreted to mean a unitary, self-contained device. The abstract describes the system as having a digital camera "integrated with the electric shaver," which may support an interpretation that all operative imaging components are contained within the main body of the device (’216 Patent, Abstract).

• The Term: "two opposed first and second exterior surfaces" (from Claim 1)

• Context and Importance: The definition of "opposed" is critical to the scope of Claim 1's structural limitations. Infringement will depend entirely on whether an accused product's camera placement meets this geometric requirement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent does not explicitly define "opposed." A plaintiff could argue for its plain and ordinary meaning, which might not strictly require perfect parallel alignment, but could include surfaces that generally face away from each other.
  • Evidence for a Narrower Interpretation: The patent's figures, such as the front, rear, and side views in FIG. 5 and FIG. 13, depict a device with generally parallel front and back faces and parallel side faces. A defendant may argue that these embodiments limit the term "opposed" to surfaces that are substantially parallel and on opposite sides of the device's main axis.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14).
• Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that the service of the complaint constitutes "actual knowledge of infringement" and that Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" infringing products despite this knowledge (Compl. ¶13-14). These allegations may form the basis for a claim of post-suit willfulness.

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

• A central issue will be one of structural correspondence: does the accused product architecture meet the specific limitations of the asserted claims, particularly the requirement in Claim 1 for two distinct video cameras mounted on "opposed" exterior surfaces of a single handheld casing?
• A key evidentiary question will be one of factual sufficiency: given that the complaint's infringement allegations rely entirely on an unprovided exhibit, the case will turn on whether the specific product details, once revealed, support the conclusory allegations that every claim element is met.