DCT

4:19-cv-00246

Guangzhou Shirui Electronic Technology Co Ltd v. Newline Interactive Technology Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:19-cv-00246, E.D. Tex., 04/01/2019
  • Venue Allegations: Venue is alleged to be proper for Defendant Newline because it is a resident of the district with a principal place of business in Plano, Texas. Venue over Defendant Hitevision, a Chinese corporation, is asserted on the basis that a non-resident of the U.S. may be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ interactive display products infringe a patent related to a system for providing seamless touch-control functionality across multiple input channels.
  • Technical Context: The technology concerns "all-in-one" interactive displays, which combine a large-format screen, a touch interface, and integrated computing (e.g., an Android main board and an optional internal PC module), and are used in educational and corporate environments.
  • Key Procedural History: The complaint is the initial pleading in this action. No prior litigation, administrative proceedings, or licensing history between the parties is mentioned.

Case Timeline

Date Event
2013-04-07 '424 Patent Priority Date
2018-05-15 '424 Patent Issue Date
2019-04-01 Complaint Filing Date

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

U.S. Patent No. 9,971,424 - All-in-one machine and method and computer memory medium for realizing quick touch in all channels thereof

Issued May 15, 2018

The Invention Explained

  • Problem Addressed: The patent describes a problem in conventional all-in-one interactive displays where switching touch control between different sources (e.g., an internal PC and an external device) is inconvenient. When the USB connection for the touch frame is switched to a new source, there is a delay as the new source must identify the USB device, preventing immediate touch interaction ('424 Patent, col. 5:45-65).
  • The Patented Solution: The invention proposes a hardware architecture that uses two separate data paths for touch inputs. A primary path, controlled by a USB selecting switch, routes touch data to the currently active channel (e.g., an internal PC). A second, independent data path permanently connects the touch frame to the system's main board via a Micro Control Unit (MCU). This allows the main board to process certain touch commands, such as calling a system-wide settings menu, instantly, regardless of which primary channel is active, thereby eliminating the USB re-identification delay ('424 Patent, Abstract; col. 9:32-65; FIG. 1).
  • Technical Importance: This architecture aims to provide a more fluid user experience by enabling "quick touch in all channels," making universal controls immediately responsive without interrupting the operation of the primary displayed source ('424 Patent, col. 5:55-63).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶19).
  • The essential elements of independent claim 1 include:
    • An all-in-one machine comprising a touch frame, a USB selecting switch, an internal PC module, a main board, and a display screen.
    • A Micro Control Unit (MCU) connected between a "second data port" of the touch frame and the main board.
    • The MCU is also connected to the USB selecting switch via a GPIO port.
    • The MCU is configured to detect the currently connected channel, control the USB switch accordingly, and determine when to call a "touch menu" application on the main board.
    • The MCU is also configured to receive touch data from the touch frame, "simulate itself as a standard USB touch device," and transmit the touch data to the main board via a "first USB port."
    • The main board is configured to start the touch menu application based on information received from the MCU.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The "accused interactive display products" are identified as the TruTouch X series, VN series, and RS series (Compl. ¶18).

Functionality and Market Context

  • The complaint alleges these products are "all-in-one machines" that include a "touch frame, a USB selecting switch, an internal PC module, a main board and a display screen" (Compl. ¶20).
  • The complaint asserts these components are integrated in a manner that meets the requirements of the asserted claim (Compl. ¶20). A marketing image depicts several models of the accused interactive displays, including the TruTouch X series (Compl. p. 6). A screenshot from a user manual shows the home screen interface of the TruTouch X9 model, identifying various on-screen toolbars and buttons (Compl. p. 6).
  • The complaint alleges Defendants are "one of the world's largest manufacturers and sellers of interactive displays and white boards" (Compl. ¶4).

IV. Analysis of Infringement Allegations

The complaint does not include a claim chart. The infringement allegations are presented in a high-level narrative.

’424 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An all-in-one machine, comprising a touch frame, a USB selecting switch, an internal PC module, a main board and a display screen... The TruTouch products are "all-in-one machines that include a touch frame, a USB selecting switch, an internal PC module, a main board and a display screen." ¶20 col. 9:32-36
a MCU connected between the second data port of the touch frame and the main board... The complaint makes a general allegation that the "components of the accused interactive display products are integrated in a manner as required by at least Claim 1 of the ‘424 Patent." ¶20 col. 9:42-44
the MCU is further connected to the USB selecting switch via GPIO... The complaint makes a general allegation that the "components of the accused interactive display products are integrated in a manner as required by at least Claim 1 of the ‘424 Patent." ¶20 col. 9:45-47
the MCU is configured to detect which channel is currently connected to the main board, control the USB selecting switch... determine whether there is an action to call a touch menu... and inform the main board to start a touch menu application program... The complaint does not allege specific facts regarding the functionality of any MCU in the accused products. ¶20 col. 9:48-58
the MCU is also configured to receive the touch data within the area of the touch menu... simulate itself as a standard USB touch device, and transmit the touch data... to the main board... The complaint does not allege specific facts regarding the functionality of any MCU in the accused products. ¶20 col. 9:58-65
the main board is configured to start the touch menu application program based on the information from the MCU... The complaint does not allege specific facts regarding the functionality of the main board in relation to an MCU. ¶10:1-3

Identified Points of Contention

  • Architectural Questions: The infringement analysis will likely focus on whether the accused products possess the specific architecture recited in claim 1. Key questions include: Do the products contain a distinct component that meets the definition of an "MCU"? Is that MCU connected "between" a "second data port" of the touch frame and the main board, while also being connected to the USB switch via GPIO? The complaint's general assertion that the required components are "integrated in a manner" as claimed will require significant factual support.
  • Functional Questions: A central dispute may arise over whether any component in the accused products performs the specific functions recited for the MCU, such as "simulat[ing] itself as a standard USB touch device" to communicate with the main board. The complaint does not provide evidence on how the accused products achieve their touch-switching functionality.

V. Key Claim Terms for Construction

  • The Term: "MCU (Micro Control Unit)"

  • Context and Importance: The MCU is the technological core of claim 1, acting as the intelligent intermediary that enables the "quick touch" feature. The presence, location, and function of a component meeting this term's definition will be dispositive for infringement. Practitioners may focus on this term because the accused products could achieve a similar user-facing result with a different hardware architecture (e.g., using a more integrated System-on-a-Chip on the main board rather than a distinct MCU).

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the MCU's function in general terms, such as being "configured to detect which channel is currently connected to the main board" ('424 Patent, col. 6:62-64), which could potentially describe a function performed by various types of processing units.
    • Evidence for a Narrower Interpretation: Claim 1 recites a very specific set of connections for the MCU: "between the second data port of the touch frame and the main board" and "further connected to the USB selecting switch via GPIO" ('424 Patent, col. 9:42-47). The specification also describes it performing the specific task of "simulat[ing] itself as a standard USB touch device" ('424 Patent, col. 9:59-60), suggesting it is a discrete component with a defined role, not just any processor.

  • The Term: "second data port"

  • Context and Importance: The invention's solution to the stated problem relies on the existence of two distinct data paths from the touch frame. The infringement case hinges on proving the accused products have this dual-path architecture. Whether the accused products have a distinct physical or logical "second data port" for touch data, separate from the primary switched USB path, will be a critical factual question.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent suggests some flexibility in implementation, stating the "second data port may be a serial port or a USB port" ('424 Patent, col. 6:33-34).
    • Evidence for a Narrower Interpretation: The claim requires this "second data port" to be functionally distinct from the "first data port," which is routed through the USB selecting switch ('424 Patent, col. 9:39). The second port connects to the MCU, creating a separate, non-switched path to the main board. This distinct routing and purpose strongly imply a structurally separate port.

VI. Other Allegations

  • Indirect Infringement: While the jurisdictional allegations mention "inducing others to commit acts of patent infringement" (Compl. ¶9), the complaint does not contain a formal count for indirect infringement or plead the specific factual elements of knowledge and intent required to support such a claim.
  • Willful Infringement: The complaint alleges that Defendants have had knowledge of the ’424 Patent "at least as of the date when it was notified of the filing of this action" (Compl. ¶21). This allegation supports a claim for post-filing willfulness only and does not assert pre-suit knowledge of the patent.

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

  • A core issue will be one of architectural correspondence: do the accused products embody the specific three-part control system (USB switch, MCU, main board) with the dual-data-path touch input architecture as recited in claim 1, or do they achieve a similar result through a different, non-infringing hardware design?
  • A key evidentiary question will be one of technical proof: given the high-level nature of the complaint, the case will depend on whether discovery and technical analysis can demonstrate that the accused products contain a discrete component that functions as the claimed "MCU" and utilizes a "second data port" from the touch frame in the manner required by the patent.