Volteon LLC v. Vertu Intl Corp Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (Texas)
  • Defendant: Vertu International Corporation Limited (Hong Kong)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01103, E.D. Tex., 11/05/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas 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 digital imaging capabilities.
• Technical Context: The technology concerns personal grooming devices, specifically augmenting electric shavers with cameras to provide users with a real-time, close-up view of the skin area being shaved.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or post-grant proceedings related to the patent-in-suit.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent's background section describes the difficulty of achieving a good shave due to poor visibility. It notes that mirrors may be unavailable, foggy, or in a dark environment, and that the user's hand and the shaver itself can obstruct the view of the skin. (’819 Patent, col. 2:3-12).
• The Patented Solution: The invention integrates a digital camera module into the housing of a portable electric shaver. This module captures a close-up image or video of the skin area being shaved, which is then transmitted to and displayed on a separate or integrated display unit, providing the user with real-time visual feedback. (’819 Patent, Abstract; col. 2:44-51). The system is depicted in use for facial shaving, with the image transmitted to a nearby display screen. (’819 Patent, Fig. 7).
• Technical Importance: This approach seeks to provide a "close, better and easier shaving experience" by allowing improved visualization of the skin without reliance on a traditional mirror, particularly in suboptimal lighting conditions. (’819 Patent, col. 2:31-38).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, instead referring to "Exemplary '819 Patent Claims" detailed in an unprovided exhibit. (Compl. ¶11, 16). For analytical purposes, independent claim 1 is representative.
• Independent Claim 1 of the ’819 Patent includes these essential elements:
  • An electrically operated hair removing device for removing hair from a skin area.
  • A casing.
  • A camera module within the casing for imaging at least part of the skin area.
  • The camera module containing an optical lens for focusing light.
  • A photosensitive image sensor array disposed at the image focal point plane of the lens for capturing the image and producing electronic image information.
  • An analog to digital (A/D) converter for generating digital data of the image.
• The complaint states that infringement of "one or more claims" is alleged. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products, referring generally to "Exemplary Defendant Products" identified in charts incorporated by reference as Exhibit 2. (Compl. ¶11). This exhibit was not filed with the complaint.

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 '819 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe by satisfying "all elements of the Exemplary '819 Patent Claims." (Compl. ¶16). It incorporates by reference claim charts from Exhibit 2, which is not provided. (Compl. ¶17). As such, a detailed claim chart summary cannot be constructed. The narrative infringement theory is limited to the conclusory statement that Defendant makes, uses, sells, or imports infringing products. (Compl. ¶11).

No probative visual evidence provided in complaint.

Identified Points of Contention

Lacking specific allegations, analysis must focus on general questions that are likely to arise based on the technology and the language of a representative claim such as Claim 1.

• Scope Questions: A central question may be how the structural limitations of the claims map onto the accused products. For example, does the accused product contain a "camera module" housed within the "casing" of the hair removal device itself, as opposed to a separate, attachable accessory?
• Technical Questions: The infringement analysis may turn on the specific technical implementation of the accused device. Key questions could include whether the accused product's image sensor is "disposed approximately at an image focal point plane" of its lens, and whether it includes an "A/D converter" that performs the function required by the claim.

V. Key Claim Terms for Construction

• The Term: "camera module"

  • Context and Importance: This term is central to the invention. Its construction will determine what combination of components (e.g., lens, sensor, processor, A/D converter) is required to meet the claim limitation. Practitioners may focus on this term because the complaint's lack of specificity suggests the accused product's imaging components may be configured differently than the embodiments described in the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 itself defines the module by its contents: an optical lens, an image sensor, and an A/D converter, suggesting that any structure containing these components could qualify. (’819 Patent, col. 4:26-40).
    • Evidence for a Narrower Interpretation: The specification describes the "camera module 31" as a comprehensive unit that also includes an image processor, video compressor, transceiver, and controller, suggesting a more integrated and functional system than the bare components listed in Claim 1. (’819 Patent, Fig. 3; col. 9:16-18).

• The Term: "disposed approximately at an image focal point plane"

  • Context and Importance: This term defines the physical relationship between the lens and the image sensor, which is critical for capturing a focused image. The scope of "approximately" will be a key issue in determining infringement, as it introduces a degree of ambiguity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "approximately" is a term of degree, which may be interpreted to allow for some deviation from the precise focal plane, as long as a usable image is captured. The patent does not provide a specific numerical range for this approximation.
    • Evidence for a Narrower Interpretation: A defendant may argue that "approximately" should be limited by the context of a shaver providing clear, real-time feedback, implying a high degree of focus that restricts the term's scope to very minor deviations from the true focal plane.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant's distribution of "product literature and website materials" that allegedly instruct end users on how to use the products in an infringing manner. (Compl. ¶14).
• Willful Infringement: The complaint bases its allegation of "Actual Knowledge" on the service of the complaint and its attached claim charts. (Compl. ¶13). This suggests the willfulness claim is based on alleged post-suit conduct.

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

Given the limited detail in the initial pleading, the case will likely focus on developing the factual record before substantive legal arguments can be made. The key open questions are:

1. A core issue will be one of identification and evidence: What specific products are accused of infringement, and what technical evidence does Plaintiff possess (presumably in the unprovided Exhibit 2) to demonstrate that these products contain each element of the asserted patent claims?
2. A second issue will be one of structural correspondence: Assuming the accused products have imaging capabilities, does their physical architecture meet the specific structural requirements of the claims, such as the location of the "camera module" within the shaver's "casing" and the precise physical arrangement of the optical components?
3. A final question will be one of definitional scope: How will the court construe key terms like "camera module"? The resolution will likely determine whether the specific technology implemented by the defendant falls within the bounds of the patent's claims.