Volteon LLC v. Umidigi Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: UMIDIGI Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01102, E.D. Tex., 11/05/2025
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas on the basis that the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a handheld device, such as an electric shaver, that incorporates an imaging system to capture and display views of a skin area during grooming.
• Technical Context: The technology involves integrating digital camera capabilities into personal care devices to provide users with real-time, magnified visual feedback, potentially enhancing precision beyond what is possible with a traditional mirror.
• Key Procedural History: The face of the asserted patent indicates it is subject to a terminal disclaimer, which may limit its enforceable term to that of an earlier patent in the family. The complaint does not mention any prior litigation or administrative proceedings involving the patent.

Case Timeline

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

U.S. Patent No. 10,958,819 - "Electric shaver with imaging capability"

• Patent Identification: U.S. Patent No. 10,958,819, "Electric shaver with imaging capability," issued March 23, 2021 (’819 Patent).

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of achieving good visibility of the skin during shaving, noting that a mirror may not be available or effective in foggy or dark environments, and that 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 module directly into a portable, handheld hair removal device like an electric shaver. This allows a close-up image of the shaving area to be captured and transmitted to a display unit, which can be either integrated into the shaver's casing or housed in a separate device, providing the user with real-time visual feedback on the shaving activity (’819 Patent, Abstract; col. 2:44-51). Figure 7 of the patent illustrates a user looking at a separate display screen showing a magnified view of his face while using the shaver (’819 Patent, Fig. 7).
• Technical Importance: This approach sought to improve the precision and effectiveness of shaving by providing a direct, magnified electronic view of the skin, thereby reducing reliance on external mirrors and overcoming visibility challenges (’819 Patent, col. 2:23-29).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims of the '819 Patent" without identifying specific claims in the body of the complaint (Compl. ¶11). The first independent claim of the patent is Claim 1.
• The essential elements of independent Claim 1 include:
  • A handheld device for capturing and displaying images and for identifying and marking an element of a human body.
  • The device is for use with a cellular network that uses a licensed frequency band.
  • A first camera for capturing a first image and a second camera for capturing a second image.
  • An image processor coupled to the cameras.
  • A display with a flat screen coupled to the cameras.
  • A cellular antenna and a cellular transmitter for transmitting the captured images to the cellular network.
  • A rechargeable battery.
  • A single portable and handheld casing housing the cameras, image processor, cellular antenna, cellular transmitter, and display.
• The complaint notes that infringement is alleged for "at least the exemplary claims" identified in charts incorporated by reference, suggesting the right to assert additional claims is reserved (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint accuses "Exemplary Defendant Products" that are identified in charts referenced as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not filed with the complaint.

Functionality and Market Context

• The complaint does not describe the specific functionality of the accused products. It alleges that the products "practice the technology claimed by the '819 Patent" and "satisfy all elements of the Exemplary '819 Patent Claims" as set forth in the unprovided claim charts (Compl. ¶16). The complaint does not provide sufficient detail for analysis of the accused instrumentality's features or market context.

IV. Analysis of Infringement Allegations

The complaint's substantive infringement allegations are incorporated by reference from "the attached claim charts" in Exhibit 2, which was not provided (Compl. ¶13, ¶17). The complaint itself alleges in a conclusory manner that Defendant directly infringes by making, using, selling, and importing the accused products, and that Defendant's employees also use the products for internal testing (Compl. ¶11-12). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the language of the '819 Patent's Claim 1 and the general nature of the dispute, several points of contention may arise.

• Scope Questions: A central question may be whether the accused products, presumably consumer electronics or personal care devices, meet the specific limitations of Claim 1 requiring a "cellular transmitter" and "cellular antenna" for use with a "cellular network that uses a licensed frequency band." Practitioners may question whether a device using other wireless technologies, such as Wi-Fi or Bluetooth, could be construed to meet this limitation. Further, a dispute could arise over whether the accused devices contain both a "first camera" and a "second camera" as recited in the claim.
• Technical Questions: A key evidentiary issue may concern the "image processor" limitation. It will be a question of fact as to what evidence the complaint or discovery provides to show that the accused products' software performs the specific functions of "identifying and marking of an element that is part of a human body" as required by Claim 1, beyond simply displaying a video feed.

V. Key Claim Terms for Construction

The Term: "cellular transmitter"

• Context and Importance: The construction of this term is critical to determining the scope of Claim 1. The infringement analysis will depend on whether the accused devices' wireless communication hardware falls within the definition of a "cellular transmitter," which is conventionally understood to mean a component for communicating over a licensed mobile telecommunications network (e.g., 4G LTE, 5G).
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses a wide range of wireless technologies, listing "cellular such as GSM, GPRS, 2.5G, 3G, UMTS, DCS, PCS and CDMA" alongside non-cellular standards like "Bluetooth, IEEE802.15, [and] IEEE802.11" ('819 Patent, col. 3:19-24). A party could argue this broad disclosure suggests the inventor did not intend to limit the invention strictly to one type of wireless technology.
  • Evidence for a Narrower Interpretation: The claim language itself is specific, reciting not just a "cellular transmitter" but also use with a "cellular network that uses a licensed frequency band" (’819 Patent, Claim 1). This explicit language distinguishes it from technologies like Wi-Fi and Bluetooth that typically operate in unlicensed spectrum and may support a narrower construction limited to conventional mobile network technology.

The Term: "image processor...for...identifying and marking of an element"

• Context and Importance: This term recites a specific data processing function, not just data handling. Practitioners may focus on this term because the dispute could turn on whether the accused device's software merely displays an image or actively analyzes the image content to identify and graphically highlight specific features as described in the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent describes this functionality in terms of identifying "individual hairs as well as hairy areas" (’819 Patent, col. 22:7-8). This could be argued to encompass a variety of software-based highlighting or overlay features.
  • Evidence for a Narrower Interpretation: The specification provides specific visual examples of this function, such as placing circles around individual hairs (Fig. 17, 182a) or applying a colored overlay to an unshaved area (Fig. 18, 184) (’819 Patent, col. 22:15-30). These embodiments could be cited to argue that the claim requires a specific algorithmic recognition and graphical annotation function, rather than a simple digital zoom or display feature.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶14). The allegation of knowledge is based on the service of the complaint and its associated claim charts (Compl. ¶15).
• Willful Infringement: The complaint alleges that Defendant has "actual knowledge of infringement" from the service of the complaint and continues to infringe despite this knowledge (Compl. ¶13-14). While the term "willful" is not used, these allegations form a basis for a claim of post-suit willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which is often associated with findings of willful infringement or litigation misconduct (Compl. p. 5).

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

• A core issue will be one of technological correspondence: do the accused products incorporate the specific hardware recited in Claim 1, namely two distinct cameras and a "cellular transmitter" for communication over a licensed network, or is there a fundamental mismatch between the accused technology and the claim language?
• A key evidentiary question will be one of functional performance: does the software in the accused products perform the active, analytical function of "identifying and marking" elements on the human body as taught in the patent, or does it provide a passive image display that may not meet this claim limitation?
• A threshold procedural question may arise regarding the sufficiency of the pleadings: given that the complaint's specific factual basis for infringement is contained entirely within an unprovided exhibit, the court may need to address whether the complaint, on its face, provides sufficient detail to support a plausible claim of infringement for each element of the asserted claims.