Volteon LLC v. Reolink Digital Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: Reolink Digital Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00881, 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 infringes a patent related to a handheld device with multiple video cameras and wireless transmission capabilities.
• Technical Context: The technology at issue involves integrating multiple imaging sensors into a single portable device for capturing and wirelessly transmitting video data.
• 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

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

U.S. Patent No. 11,297,216 - "Electric Shaver with Imaging Capability"

• Patent Identification: U.S. Patent No. 11,297,216, "Electric Shaver with Imaging Capability," issued April 5, 2022.

The Invention Explained

• Problem Addressed: The patent's background describes the difficulty of achieving a good shave without proper visibility of the skin surface, noting that mirrors are not always available or effective and that the user's hand and the shaver itself can obstruct the view (ʼ216 Patent, col. 2:3-12).
• The Patented Solution: The invention proposes integrating a digital camera into an electric shaver to capture a close-up image of the shaving area. This image is then transmitted to a display unit, which can either be integrated into the shaver or housed in a separate device, providing the user with real-time visual feedback without relying on a mirror (ʼ216 Patent, Abstract; col. 2:41-51). Figure 7 of the patent illustrates a user shaving while viewing the captured image on a separate display unit (ʼ216 Patent, Fig. 7).
• Technical Importance: This approach aimed to provide a "close, better and easier shaving experience" by allowing clear visualization of the skin, even in dark environments, giving the user real-time feedback on the shaving activity (ʼ216 Patent, col. 2:30-38).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referencing charts in an unprovided exhibit (Compl. ¶11, ¶16). For the purpose of analysis, independent claim 1 is representative.
• Independent Claim 1:
  • A handheld device for capturing and displaying video data
  • Comprising a first video camera and a second video camera
  • A multiplexer coupled to the cameras for multiplexing their video data into a multiplexed signal
  • An antenna for transmitting a wireless signal
  • A wireless transmitter coupled between the antenna and the multiplexer
  • A rechargeable battery to power the components
  • A single portable and handheld casing housing the components, where the casing has two opposed exterior surfaces, with the first camera attached to the first surface and the second camera attached to the second surface
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products in its main body, instead referring to "Exemplary Defendant Products" identified in charts incorporated as Exhibit 2, which was not publicly available with the complaint (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '216 Patent" (Compl. ¶16). Based on the defendant's business as a manufacturer of digital cameras, the accused products are presumably security cameras or similar imaging devices. The allegations imply these devices incorporate features such as multiple cameras or lenses, wireless transmission capabilities, a battery, and a single housing, which correspond to elements of the asserted patent claims. The complaint does not provide specific details on the products' market positioning.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to an external claim chart exhibit that was not provided with the filing (Compl. ¶17). Therefore, a detailed element-by-element analysis based on the complaint's direct allegations is not possible.

The narrative theory of infringement, as implied by the assertion of the ’216 Patent against a digital technology company, appears to be that Defendant’s camera products meet the elements of the patent’s claims. For a representative claim like Claim 1, this theory would likely contend that an accused product is a "handheld device" containing two distinct video cameras (or lenses functioning as such), a multiplexer to combine their signals, a wireless transmitter and antenna for sending the video feed, a rechargeable battery, and a single casing housing these elements.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A primary question may be whether the term "handheld device for capturing and displaying video data," as used in the claims, can be construed to cover Defendant's products, which may be primarily designed for stationary mounting (e.g., security cameras). The patent's title and specification focus exclusively on the context of electric shavers, which could raise arguments about whether the preamble of Claim 1 is limiting.
• Technical Questions: A potential point of dispute could be whether a single device with multiple lenses constitutes "a first video camera" and "a second video camera" as distinct claim elements, or if it is a single camera with multiple optical inputs. The functionality of the device's internal processor will also be at issue—specifically, whether it performs the function of a "multiplexer" as required by the claim.

V. Key Claim Terms for Construction

Term for Construction: "handheld device" (from Claim 1)

• Context and Importance: The construction of this term is central to the dispute. Defendant's products may be primarily marketed and used as stationary, mounted devices. Whether they fall within the scope of a "handheld device" will likely be a threshold issue for infringement.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff may argue that the plain and ordinary meaning of "handheld" applies to any device that is capable of being held and operated by hand, regardless of its primary intended use. The claim language itself does not tie the device to shaving.
  • Evidence for a Narrower Interpretation: Defendant may argue that the patent specification defines the invention solely in the context of an "electric shaver" (e.g., ’216 Patent, Title, Abstract, col. 2:41-51). This consistent focus could be used to argue that a "handheld device" in the context of this patent is limited to a shaver-like form factor or application.

Term for Construction: "a first video camera that outputs a first video data; a second video camera that outputs a second video data" (from Claim 1)

• Context and Importance: This term is critical for determining if accused products with multiple lenses meet the claim requirements. The interpretation will determine whether two lenses feeding a single image sensor and processor can be considered two separate "video cameras."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Plaintiff may argue that each lens and its corresponding portion of a sensor that generates a distinct data stream constitutes a "video camera."
  • Evidence for a Narrower Interpretation: The patent specification describes embodiments with multiple distinct image capturing mechanisms, each with its own lens and sensor (e.g., ’216 Patent, Fig. 12, items 32a/39a and 32b/39b). Defendant may argue this disclosure limits the term "video camera" to a complete, independent module, not just a lens.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '216 Patent" (Compl. ¶14).

Willful Infringement

• The complaint alleges that Defendant has had "actual knowledge of infringement" since the service of the complaint and its attached claim charts (Compl. ¶13). This allegation appears to form the basis for post-suit willful infringement rather than pre-suit knowledge.

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

• A core issue will be one of definitional scope: Can the term "handheld device," which is described in the patent's specification exclusively in the context of an electric shaver, be construed broadly enough to cover Defendant's accused camera products, which may be designed for stationary use?
• A key technical question will be one of structural identity: Do the accused products, which may feature multiple lenses integrated into a single unit, contain the distinct "first video camera" and "second video camera" structures required by Claim 1, or is there a fundamental architectural difference that places them outside the claim's scope?
• An underlying evidentiary question will be one of infringement proof: Given the complaint's reliance on an unprovided exhibit, a central challenge for the Plaintiff will be to present sufficient factual evidence to plausibly demonstrate how the accused products meet each limitation of the asserted claims.