Volteon LLC v. Shenzhen Doogee Heng Tong Technology Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: Shenzhen Doogee Heng Tong Technology Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01099, E.D. Tex., 11/05/2025
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation, and the complaint asserts that Defendant has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to motion-sensing devices that provide a visual or audible indication in response to movement.
• Technical Context: The technology concerns embedding motion sensors and annunciators (e.g., lights, speakers) into objects, such as toys or balls, to create interactive experiences based on physical movement.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 9,630,062 - "System and method for a motion sensing device which provides a visual or audible indication"

• Issued: April 25, 2017

The Invention Explained

• Problem Addressed: The patent seeks to enhance conventional toys, such as balls, by providing a cost-effective way to add "amusement, education, entertainment and a better user experience" without significantly departing from the traditional "look and feel" of the object (’062 Patent, col. 2:3-22).
• The Patented Solution: The invention is a self-contained device, often housed within a single enclosure like a ball, that includes a motion sensor (e.g., an accelerometer), an "annunciator" for signaling (e.g., an LED light or a speaker), and a controller or logic that activates the annunciator in response to sensed motion according to predetermined rules (’062 Patent, Abstract; Fig. 2). The logic can trigger the annunciator based on acceleration magnitude exceeding a threshold, direction of motion, or a count of motion events, and can do so in a predictable or random manner (’062 Patent, col. 4:35-54).
• Technical Importance: The patent describes a self-contained electronic system for making passive objects interactive, reflecting a trend of embedding simple electronics into everyday items to increase user engagement.

Key Claims at a Glance

• The complaint does not identify any specific claims asserted against the Defendant. It refers generally to infringement of "one or more claims of the ’062 Patent" and references "Exemplary ’062 Patent Claims" detailed in an un-provided exhibit (Compl. ¶11, 16).
• For illustrative purposes, representative independent claim 1 of the patent includes the following essential elements:
  • A device for displaying in response to a sensed acceleration, with a single portable enclosure.
  • A three-axis accelerometer for measuring device acceleration and producing a first output signal.
  • A flat-panel digital display for displaying graphical or text information.
  • A sensor coupled to the processor with a second output responsive to a physical phenomenon.
  • A processor executing software, coupled to the accelerometer and display, for displaying information in response to the first and second output signals.
  • A rechargeable battery and a battery charger for contactless charging.
• The complaint generally alleges infringement of "one or more claims," which may implicitly reserve the right to assert dependent claims (Compl. ¶11, 15).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers to them as "Exemplary Defendant Products" that are identified in charts incorporated by reference as Exhibit 2, which was not filed with the complaint (Compl. ¶11, 16).

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 only that the products "practice the technology claimed by the '062 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are asserted by incorporating by reference an external document, Exhibit 2, which was not provided (Compl. ¶17). The complaint alleges in a conclusory manner that the "Exemplary Defendant Products" identified in the exhibit satisfy all elements of the "Exemplary '062 Patent Claims" (Compl. ¶16). Without the referenced exhibit or any narrative description of the infringing functionality, a detailed analysis of the infringement theory is not possible based on the complaint alone. No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not identify any specific asserted claims or provide any details regarding the accused products. Therefore, the complaint does not provide sufficient detail for analysis of key claim terms.

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 ’062 Patent" (Compl. ¶14). The specific content of these materials is purportedly detailed in the un-provided Exhibit 2 (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful infringement." However, it alleges that the service of the complaint and its attached claim charts "constitutes actual knowledge of infringement" (Compl. ¶13). This allegation may form a basis for seeking enhanced damages for any post-filing infringement. The prayer for relief also requests a declaration that the case is "exceptional" under 35 U.S.C. § 285 (Compl. p. 5).

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

Based on the initial pleading, the case appears to present foundational questions of notice and evidence before any substantive technical disputes can be addressed. The key questions are:

• A primary evidentiary question: What specific products are accused of infringement, and what are their precise technical functionalities? The complaint's reliance on an un-provided exhibit leaves the identity and operation of the accused instrumentalities entirely undefined.
• A core issue of claim assertion: Which specific claims of the ’062 Patent does the Plaintiff contend are infringed? Resolution of this question is a prerequisite to any meaningful claim construction or infringement analysis.
• A question of induced infringement: What specific instructions or encouragements in Defendant's product literature and website materials are alleged to direct users to infringe the asserted patent claims?