Volteon LLC v. Thinkware Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: THINKWARE Corporation (South Korea)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00882, E.D. Tex., 08/26/2025
• Venue Allegations: Plaintiff asserts venue is proper because Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to an electric shaver with integrated imaging and display capabilities.
• Technical Context: The technology involves embedding digital cameras into personal grooming devices to provide users with a real-time, close-up view of the skin area being treated, thereby improving visibility and precision.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or other significant procedural events 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, titled “Electric shaver with imaging capability,” issued on April 5, 2022 (’216 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section identifies the difficulty of achieving a good shave when visibility of the skin is poor. It notes that mirrors may not always be available or effective (e.g., in dark or foggy environments) and that the user's hand and the shaver itself can obstruct the view of the shaving area (’216 Patent, col. 2:3-12).
• The Patented Solution: The invention integrates a digital camera system into a portable, hand-held electric shaver. This system captures a close-up image of the skin, processes it, and transmits it to a display unit, which can either be integrated into the shaver or housed in a separate device (’216 Patent, Abstract; col. 2:41-48). This provides the user with real-time visual feedback on the shaving activity without needing an external mirror (’216 Patent, col. 2:35-38). The specification details various configurations, including wired and wireless communication between the shaver and a display unit (’216 Patent, Fig. 3, 9).
• Technical Importance: This approach aims to make shaving more convenient and effective by providing a direct, magnified view of the skin and hair, independent of ambient light conditions or the availability of a mirror (’216 Patent, col. 2:19-28).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead incorporating by reference "Exemplary '216 Patent Claims" from an unprovided exhibit (Compl. ¶11, 16). Independent claim 1 is presented here as a representative claim.
• Independent Claim 1:
  • A handheld device for capturing and displaying video data, the device comprising:
  • a first video camera that outputs a first video data;
  • a second video camera that outputs a second video data;
  • a multiplexer coupled to the first and second cameras for multiplexing the first and second video data into a multiplexed signal;
  • an antenna for transmitting a wireless signal over a wireless network;
  • a wireless transmitter coupled between the antenna and the multiplexer for transmitting the multiplexed signal;
  • a rechargeable battery coupled to power the video cameras, the wireless transmitter, and the multiplexer; and
  • a single portable and handheld casing housing the video cameras, the wireless transmitter, and the multiplexer, wherein the casing comprises two opposed first and second exterior surfaces, the first video camera is attached to the first surface and the second video camera is attached to the second surface.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to “Exemplary Defendant Products” that are allegedly identified in charts incorporated by reference but not attached to the pleading (Compl. ¶11, 16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct and indirect infringement but incorporates the specific factual basis for these allegations by reference to claim charts in an exhibit that was not filed with the complaint (Compl. ¶16-17). As such, a detailed claim chart summary cannot be constructed. The infringement theory is stated generally, alleging that Defendant's products "practice the technology claimed by the '216 Patent" and "satisfy all elements of the Exemplary '216 Patent Claims" (Compl. ¶16).

Identified Points of Contention

Based on the language of representative Claim 1 of the ’216 Patent and the general nature of the allegations, the infringement analysis may raise several key questions.

• Scope Questions: Claim 1 requires a specific and complex hardware arrangement, including two video cameras housed in a single casing and "attached to" two "opposed... exterior surfaces." A central question will be whether the accused products, once identified, possess this dual-camera architecture on opposite sides of the device. The interpretation of "opposed" surfaces could be a point of dispute.
• Technical Questions: What evidence does the complaint provide that an accused product contains the internal components required by the claim, such as a "multiplexer" for combining video data from two separate cameras before wireless transmission? This element describes a specific signal processing architecture that may not be present in all devices with imaging capabilities.

V. Key Claim Terms for Construction

The complaint does not offer a basis for claim construction analysis. However, based on the text of representative Claim 1, the following terms may become central to the dispute.

• The Term: "attached to the [first/second] surface"
• Context and Importance: This term is critical because Claim 1 requires two cameras to be attached to "opposed first and second exterior surfaces" of the handheld casing. The definition will determine whether cameras that are recessed, integrated flush with the casing, or part of a modular component meet this limitation, which is a key structural differentiator of the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification's figures depict various camera placements. Figure 13, for example, shows multiple lenses (55a, 55b, 55c, 55d) integrated into different surfaces of the shaver housing, suggesting "attached to" could encompass being built into the surface as an integral part rather than being affixed externally (’216 Patent, Fig. 13).
  • Evidence for a Narrower Interpretation: The claim's use of "attached to the... exterior surfaces" could be argued to require a physical connection to the outermost boundary of the casing, potentially excluding cameras that are deeply recessed or located behind a transparent window that is itself part of the surface.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement based on Defendant's distribution of "product literature and website materials" that allegedly instruct users on how to use the accused products in an infringing manner (Compl. ¶14). Knowledge is alleged to exist at least from the date of service of the complaint (Compl. ¶15).

Willful Infringement

The complaint does not use the term "willful." However, it alleges "Actual Knowledge of Infringement" arising from the service of the complaint and attached claim charts (Compl. ¶13). It further alleges that Defendant "continues to make, use, test, sell, offer for sale, market, and/or import" the accused products despite this knowledge, which may form a basis for alleging post-filing willfulness (Compl. ¶14).

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

Given the limited factual detail in the pleading, the case will likely focus on fundamental questions of evidence and claim scope once discovery commences.

• A core issue will be one of structural correspondence: Do the accused products, once identified, actually implement the specific dual-camera architecture recited in representative Claim 1, which requires two cameras on "opposed exterior surfaces" of a single handheld casing? A mismatch on this highly specific limitation could be a significant hurdle for the infringement case.
• A key evidentiary question will be one of internal operation: Can the plaintiff demonstrate that the accused products contain the specific internal components and data pathways claimed, such as a "multiplexer" that combines signals from two cameras into a single signal for wireless transmission, or will discovery reveal a different technical architecture?