Volteon LLC v. Shenzhen Gotron Electronic Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: Shenzhen Gotron Electronic Co., LTD. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01100, E.D. Tex., 11/05/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation and has committed acts of patent infringement in the district, causing harm.
• Core Dispute: Plaintiff alleges that Defendant infringes two U.S. patents, one related to an electric shaver with integrated imaging capabilities and another related to a motion-sensing device that provides feedback.
• Technical Context: The patents-in-suit relate to the fields of consumer electronics and personal care devices, specifically the integration of sensors (image and motion) to provide real-time user feedback.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving the patents-in-suit.

Case Timeline

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

U.S. Patent No. 10,958,819 - “Electric shaver with imaging capability,” issued March 23, 2021

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of achieving an effective shave due to poor visibility of the skin surface, particularly without a mirror or in low-light conditions, where the user's hand and the shaver itself can obstruct the view (’819 Patent, col. 2:3-12).
• The Patented Solution: The invention proposes integrating a digital camera system into the housing of 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, allowing the user to see the shaving area in real-time (’819 Patent, Abstract; Fig. 3).
• Technical Importance: This approach seeks to provide users with real-time visual feedback on their shaving activity, potentially improving precision and effectiveness without reliance on external mirrors (’819 Patent, col. 2:25-29).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" but does not identify specific claims, instead referring to an unprovided exhibit (Compl. ¶12). Independent claim 1 is representative of the patent's core novelty.

• Independent Claim 1: A handheld device for capturing images and identifying elements on a human body, comprising:
  • A first camera for capturing a first image via a first optical lens.
  • A second camera for capturing a second image via a second optical lens.
  • An image processor coupled to the cameras for processing the captured images.
  • A display for visually displaying the captured images.
  • A cellular antenna for coupling to a cellular network using a licensed frequency band.
  • A cellular transmitter for transmitting the captured images to the cellular network.
  • A rechargeable battery to power the components.
  • A single portable handheld casing that houses all the above components.

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 background describes a need to enhance simple toys, such as game balls, with interactive features that provide amusement and a better user experience without departing from the object's conventional "look and feel" (’062 Patent, col. 2:3-12).
• The Patented Solution: The invention proposes a self-contained device that includes a motion sensor (e.g., an accelerometer), an "annunciator" that provides visual or audible signals, and a controller. The controller processes signals from the motion sensor and, based on embedded logic, activates the annunciator in response to the sensed motion (’062 Patent, Abstract; Fig. 2).
• Technical Importance: This technology allows for the creation of interactive objects that can react to physical handling, such as being thrown, shaken, or tilted, thereby adding a layer of electronic feedback to physical play (’062 Patent, col. 2:13-16).

Key Claims at a Glance

The complaint alleges infringement of "one or more claims" but does not identify specific claims, referring to an unprovided exhibit (Compl. ¶21). Independent claim 1 is representative.

• Independent Claim 1: A device for displaying information in response to sensed acceleration, comprising a single portable enclosure containing:
  • A three-axis accelerometer for measuring device acceleration and producing a first output signal.
  • A flat-panel digital display.
  • A second sensor responsive to a physical phenomenon, which provides a second output signal.
  • 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.
  • A battery charger for contactless charging of the battery.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name or model number (Compl. ¶¶12, 21). It refers generally to "Exemplary Defendant Products" that are purportedly identified in Exhibits 3 and 4, which were not filed with the complaint (Compl. ¶¶17, 26).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context.

IV. Analysis of Infringement Allegations

The complaint incorporates infringement allegations by reference to claim chart Exhibits 3 and 4, which were not provided with the public filing (Compl. ¶¶18, 27). The complaint's narrative theory alleges that the unspecified "Exemplary Defendant Products" practice the technology claimed by the patents-in-suit and "satisfy all elements" of the asserted claims, either literally or under the doctrine of equivalents (Compl. ¶¶17, 26). Without the claim charts or product identification, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of the representative independent claims, several key questions for the infringement analysis may arise once the accused products are identified.
  • For the ’819 Patent: Claim 1 recites highly specific hardware: a "first camera" and a "second camera," as well as a "cellular transmitter" for use with a "cellular network that uses a licensed frequency band." An infringement analysis will depend on evidence that an accused product contains two distinct cameras and hardware for licensed cellular communication, as opposed to other wireless technologies like Wi-Fi or Bluetooth.
  • For the ’062 Patent: Claim 1 requires a combination of a "three-axis accelerometer," a "flat-panel digital display," a second, different "sensor responsive to a physical phenomenon," and a "battery charger for contactless charging." The infringement case will turn on demonstrating that an accused product integrates all of these specific and distinct hardware features within a single enclosure.

V. Key Claim Terms for Construction

• Term from the ’819 Patent: "cellular transmitter"

  • Context and Importance: This term appears central to defining the communication capability of the claimed device. Practitioners may focus on this term because its construction will determine whether the claim is limited to devices with traditional cellular (e.g., 4G/5G) capabilities or could be interpreted more broadly to cover other forms of wireless transmission.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Narrower Interpretation: The specification explicitly lists "cellular such as GSM, GPRS, 2.5G, 3G, UMTS, DCS, PCS and CDMA" separately from other wireless standards like "Bluetooth, IEEE802.15, IEEE802.11" (’819 Patent, col. 5:46-54). A party could argue this demonstrates a clear distinction, limiting the term "cellular" to its conventional meaning related to licensed mobile phone networks.
    • Evidence for a Broader Interpretation: A party might argue that in the context of the patent, "cellular" is used as one example of long-range wireless communication and should not be a rigid limitation, although the explicit mention of "licensed frequency band" in claim 1 may counter this argument (’819 Patent, col. 28:57-58).

• Term from the ’062 Patent: "a sensor...responsive to a physical phenomenon"

  • Context and Importance: This element is recited in claim 1 in addition to the primary three-axis accelerometer. Its construction is critical because the term is broad, and its required identity and function could be a key point of dispute.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The plain language of claim 1 does not limit the type of physical phenomenon, suggesting any component that detects a physical input—such as a button (pressure), microphone (sound), or light sensor—could satisfy the limitation (’062 Patent, col. 34:10-12).
    • Evidence for a Narrower Interpretation: Dependent claims specify particular types of sensors, such as a "voltage or current sensor" (claim 40), a "light sensor" (claim 41), and a "force sensor" (claim 43). A party might argue that these dependent claims suggest the independent claim's "sensor" should be construed as a component that measures a physical property, rather than simply detecting a binary state like a button press.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. It asserts that Defendant provides "product literature and website materials" that direct and encourage end users to use the accused products in a manner that infringes the patents (Compl. ¶¶15, 24).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that service of the complaint constitutes "Actual Knowledge of Infringement" and that Defendant's infringement has continued "Despite such actual knowledge," which may form the basis for a claim of post-suit willful infringement (Compl. ¶¶14-15, 23-24).

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

1. A threshold evidentiary question will be one of hardware correspondence: Does discovery reveal that the accused products contain the specific and cumulative sets of hardware components recited in the asserted claims, such as the dual-camera and cellular transmitter combination of the ’819 Patent or the accelerometer, display, second sensor, and contactless charging combination of the ’062 Patent?
2. A central issue of claim construction for the ’819 Patent will be the definitional scope of "cellular transmitter." The case may turn on whether this term is limited to its conventional meaning involving licensed cellular networks or can be construed to read on other wireless technologies like Wi-Fi or Bluetooth that may be present in the accused products.
3. A key legal and factual question for the ’062 Patent will concern the identity of the claimed second "sensor responsive to a physical phenomenon." The resolution of the case may depend on what component in the accused products is alleged to meet this limitation and whether that component's functionality falls within the construed scope of the claim term.