DCT

2:26-cv-00096

Zephyrhub LLC v. Anker Innovations Ltd

Key Events
Complaint
complaint

I. Executive Summary and Procedural Information

  • Case: ZephyrHub LLC v. Anker Innovations Ltd.
  • Case Identification: 2:26-cv-00096, E.D. Tex., 02/05/2026
  • Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation (organized under the laws of Hong Kong) and may be sued in any U.S. judicial district pursuant to 28 U.S.C. § 1391(c)(3).
  • Core Dispute: Plaintiff alleges that Defendant’s USB-C hubs infringe two patents related to integrated power conversion and management for simultaneous data transmission and device charging.
  • Technical Context: The technology at issue involves USB hubs that not only expand the number of available ports but also incorporate sophisticated power electronics to manage and deliver stable, high-current power to connected devices like laptops and smartphones.
  • Key Procedural History: The complaint states that Plaintiff’s predecessor-in-interest sent a notice letter identifying the patents-in-suit and accused product categories to Defendant, which was allegedly received on September 22, 2025, a fact central to the allegations of pre-suit knowledge and willful infringement.

Case Timeline

Date Event
2015-01-12 Earliest Priority Date ('421 and '939 Patents)
2018-01-09 U.S. Patent No. 9,864,421 Issued
2018-06-12 U.S. Patent No. 9,997,939 Issued
2025-09-17 Notice Letter Sent to Defendant
2025-09-22 Notice Letter Received by Defendant
2026-02-05 Complaint Filed

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

U.S. Patent No. 9,864,421 - "Hub Having Complex Power Converters"

  • Patent Identification: U.S. Patent No. 9,864,421, titled “Hub Having Complex Power Converters,” issued on January 9, 2018.

The Invention Explained

  • Problem Addressed: The patent’s background section describes the inadequacy of conventional USB hubs, which often provide insufficient power for "rapid charge" of modern portable devices and create inconvenience by requiring users to carry separate power adapters '421 Patent, col. 1:49-61 col. 2:6-13
  • The Patented Solution: The invention is a hub that integrates a controller for data transmission with a "first DC/DC converter" '421 Patent, abstract As depicted in Figure 2A, this converter is positioned to draw power from an "electronic equipment" (such as a host computer) via a power transmission line and deliver a regulated, stable voltage to a connected "portable device," thereby enabling both data transfer and effective charging through a single device '421 Patent, abstract; '421 Patent, FIG. 2A
  • Technical Importance: This integration of power management circuitry directly within the hub allows a single accessory to reliably provide high-current charging while simultaneously expanding port connectivity, a significant improvement in convenience and functionality for users of power-intensive mobile electronics '421 Patent, col. 2:14-18

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶43
  • The essential elements of Claim 1 include:
    • A hub for connecting electronic equipment and a portable device via a USB cable.
    • A first connector for the electronic equipment and a second connector for the portable device.
    • A controller connected between the connectors for mutual data transmission.
    • A first DC/DC converter with an input connected to the electronic equipment and an output connected to the portable device, configured to output a stable voltage.
    • A requirement that the first connector is a USB 3.1 Power Delivery (PD) type C port, and the electronic equipment can operate in a charged or power supplying mode via the USB PD protocol.

U.S. Patent No. 9,997,939 - "Hub"

  • Patent Identification: U.S. Patent No. 9,997,939, titled “Hub,” issued on June 12, 2018.

The Invention Explained

  • Problem Addressed: The patent addresses a similar problem as the ’421 Patent: the need for a single hub that can manage both data and high-power charging, while also accommodating external power sources beyond a host computer '939 Patent, col. 1:5-10 col. 2:7-16
  • The Patented Solution: The invention is a hub architecture where data transmission occurs between an "electronic equipment" and a "portable device" via a signal line, while a DC/DC converter draws power from the electronic equipment to provide stable voltage to the portable device '939 Patent, abstract The specification and figures further describe embodiments with additional converters to handle power from an external AC source, allowing the hub to blend power from multiple inputs '939 Patent, FIG. 4
  • Technical Importance: This design creates a versatile hub capable of functioning as a traditional bus-powered device while also acting as a high-power, standalone charging station when connected to a wall outlet, thus accommodating a wider range of usage scenarios '939 Patent, col. 2:10-16

Key Claims at a Glance

  • The complaint asserts at least independent claim 1 Compl. ¶43
  • The essential elements of Claim 1 include:
    • A hub connecting electronic equipment and a portable device via a USB cable with signal and power transmission lines.
    • A first connector for the electronic equipment and a second connector for the portable device.
    • Data transmission between the devices occurring mutually via the signal line, first connector, and second connector.
    • A first DC/DC converter with its input connected to the electronic equipment and its output connected to the portable device to provide stable voltage.
    • A requirement that the first connector is a USB 3.1 PD type C port and the electronic equipment operates in a charged or power supplying mode via the USB PD protocol.

III. The Accused Instrumentality

Product Identification

The complaint accuses "Anker's line of hubs that contain a DC/DC converter," with the Anker PowerExpand 7-in-1 USB-C PD hub (model 341) used as a primary exemplary product Compl. ¶¶20, 23

Functionality and Market Context

The Anker 341 is a multi-port adapter that connects to a host device's USB-C port Compl. ¶24 Its key accused feature is "Power Delivery Pass-Through Charging," which allows it to receive power from an external charger (up to 100W) and pass a portion of that power (up to 85W) to the host laptop, using the remaining power for its own operation and to power connected peripherals Compl. ¶28 Compl. p. 6 The complaint alleges the device contains a Via Labs VL162 controller for data switching and a Genesys Logic GL3510 Hub Controller, which it claims includes the infringing DC/DC converter functionality in the form of an "on-chip power regulator" Compl. ¶¶27-28 The complaint provides product marketing images that highlight the hub's ability to manage 100W input and 85W output simultaneously Compl. p. 13

IV. Analysis of Infringement Allegations

'421 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a hub electrically connecting to electronic equipment and a portable device located in an external environment via a Universal Serial Bus (USB) cable... The accused Anker 341 hub connects to electronic equipment (a charger) and a portable device (a laptop) via a USB cable. ¶24 col. 5:57-6:2
a first connector, electrically connected to the electronic equipment via the USB cable; The first connector is identified as the end of the USB cable that inserts into the portable device (laptop). The complaint treats the external charger as the "electronic equipment." ¶25 col. 13:43-44
a second connector, electrically connected to the portable device via the USB cable; The second connector is identified as one of the connection ports on the hub itself, to which the portable device (laptop) connects. ¶26 col. 13:45-46
a controller, electrically connected between the first connector and the second connector, the controller has data transmission between the portable device and the electronic equipment mutually via the signal transmission line The hub contains a Via Labs VL162 controller that allegedly facilitates data transmission for negotiating power requirements between the charger ("electronic equipment") and the laptop ("portable device") per USB-C PD protocol. ¶27 col. 6:5-12
a first direct current (DC)/DC converter, an input terminal...is electrically connected to the electronic equipment...an output terminal...is electrically connected to the portable device...the first DC/DC converter is applied to output stable voltage to the portable device; The hub allegedly contains a Genesys Logic GL3510 chip with an "on-chip power regulator" that functions as the DC/DC converter. This is inferred from the hub's ability to take 100W input power and provide 85W output power. ¶28 col. 6:39-48
wherein the first connector is USB 3.1 Power Delivery (PD) type C port, and the electronic equipment is operable either in a charged mode or in a power supplying mode via the USB PD protocol. The complaint alleges the GL3510 chip is compliant with the USB 3.1 specification, enabling the connected charger ("electronic equipment") to operate in different power supply modes based on the laptop's needs. The complaint provides an exemplary usage diagram from the product manual showing the charger, hub, and laptop connected Compl. p. 8 ¶29 col. 4:1-4

'939 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A hub, electrically connecting to an electronic equipment and at least a portable device located in external environment via an Universal Serial Bus cable... The accused Anker 341 product is a hub that connects to electronic equipment (charger) and a portable device (laptop) via USB cable for data and power. ¶32 col. 5:2-6
a first connector, electrically connected to the electronic equipment via the Universal Serial Bus cable; The first connector is alleged to be the end of the USB cable that connects to the portable device (laptop). The charger is treated as the "electronic equipment." ¶33 col. 15:10-12
at least a second connector, communicatively connected to the first connector and electrically connected to the portable device...wherein a data transmission between the portable device and the electronic equipment mutually is via the signal transmission line... The second connector is alleged to be a port on the hub itself. Data transmission is alleged to occur via a Via Labs VL162 controller, which negotiates power between the charger and laptop. The complaint references an image of the controller chip on the hub's circuit board Compl. p. 25 ¶¶34-35 col. 15:13-20
a first DC/DC converter, an input terminal...is electrically connected to the electronic equipment...an output terminal...is electrically connected to the portable device...applied to output stable voltage... The hub's Genesys Logic GL3510 chip, which contains an on-chip power regulator, is alleged to be the DC/DC converter. Its function is inferred from the hub's 100W input / 85W output power specification. ¶36 col. 15:21-27
wherein the first connector is Universal Serial Bus 3.1 Power Delivery type C port, and electronic equipment can be either in a charged mode or in a power supplying mode via the Universal Serial Bus Power Delivery protocol. The complaint alleges the hub operates according to the USB PD protocol, allowing the charger ("electronic equipment") to vary its power supply based on signals from the laptop. This is supported by the GL3510 chip's datasheet showing USB 3.1 compliance Compl. p. 28 ¶¶37-39 col. 5:35-41

Identified Points of Contention

  • Scope Questions: The complaint's infringement theory appears to identify the "first connector" as the plug connecting to the portable device (laptop) and the "electronic equipment" as the power source (charger) Compl. ¶¶25, 33 This may create a point of contention, as the patent figures appear to show the "electronic equipment" as the host device (e.g., a computer) from which the hub extends '421 Patent, FIG. 2A The case may turn on whether the term "electronic equipment" can be construed to mean a simple power adapter rather than a data-capable host computer.
  • Technical Questions: The complaint identifies an "on-chip power regulator" within the Genesys Logic GL3510 hub controller as the claimed "first DC/DC converter" Compl. ¶¶28, 36 A key technical question will be what evidence demonstrates that this specific internal regulator performs the claimed function of delivering stable voltage to the portable device via the main power transmission line, as opposed to regulating power for the chip's own internal logic.

V. Key Claim Terms for Construction

  • The Term: "electronic equipment"

  • Context and Importance: This term's definition is fundamental to the infringement case. The complaint's theory requires "electronic equipment" to be interpreted as the external power source (charger), while the patent's description and common industry parlance could suggest it refers to the host computer. The mapping of the claim's connectors and power flow depends entirely on this construction.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent specification describes the "electronic equipment" as potentially being an "AIO (All in one) PC, a desktop computer, or a notebook computer" '421 Patent, col. 5:61-63 Plaintiff may argue this list is exemplary, not exhaustive, and that any device providing power and data signals over USB qualifies.
    • Evidence for a Narrower Interpretation: The patent consistently discusses data transmission between the "electronic equipment" and the portable device '421 Patent, abstract, which may support an interpretation that the "electronic equipment" must be a data-processing device like a computer, not a simple charger which may only participate in power negotiation signals.
  • The Term: "first DC/DC converter"

  • Context and Importance: Practitioners may focus on this term because the complaint maps it to an "on-chip power regulator" inside a larger controller IC Compl. ¶¶28, 36 The dispute will likely center on whether this integrated sub-component is structurally and functionally the same as the claimed converter.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The claims define the converter functionally: its input is connected to the electronic equipment, its output to the portable device, and it "is applied to output stable voltage" '421 Patent, cl. 1 Plaintiff may argue that any component performing this function, regardless of its physical integration, meets the limitation.
    • Evidence for a Narrower Interpretation: The patent's block diagrams (e.g., '421 Patent, FIG. 2A) depict the "First DC/DC converter" as a distinct functional block, separate from the "Controller." Defendant may argue this implies a structural requirement that is not met by a regulator integrated within the controller chip itself, especially if that regulator's primary purpose is for internal chip logic.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides instructional materials, user guides, and marketing that "specifically teach end-users" to connect a charger, the hub, and a laptop in the allegedly infringing configuration Compl. ¶¶46-47 It further alleges contributory infringement, arguing the Accused Products are specially designed to infringe and lack substantial non-infringing uses Compl. ¶49 Knowledge is alleged from the date of a pre-suit notice letter Compl. ¶46
  • Willful Infringement: Willfulness allegations are based on Defendant's alleged pre-suit knowledge of the patents, stemming from its receipt of a notice letter on or about September 22, 2025 Compl. ¶¶18, 52 The complaint further alleges that Defendant acted despite an "objectively high likelihood" of infringement and maintains a "policy or practice of not reviewing the patents of others" Compl. ¶¶52-53

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

  • A core issue will be one of definitional scope: can the term "electronic equipment," as used in the patents, be construed to cover a power-only source like a wall charger, which is essential to the complaint's infringement theory, or is it limited to a data-capable host device like a computer? The viability of the Plaintiff's claim mapping hinges on this question.
  • A key evidentiary question will be one of component function: does the "on-chip power regulator" within the accused hub's controller chip constitute the claimed "first DC/DC converter"? This will require a technical analysis of whether that specific component performs the claimed function of regulating power from the main input for delivery to the external portable device, or if it serves a more limited, internal purpose for the chip's own logic, creating a potential mismatch in operation.