DCT

4:25-cv-01324

Better Mouse Co LLC v. Partnerships Unincorp Associations

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01324, E.D. Tex., 12/04/2025
  • Venue Allegations: Venue is alleged to be proper on the basis that the defendants are foreign entities not residing in any U.S. judicial district.
  • Core Dispute: Plaintiff alleges that Defendants’ gaming computer mice infringe a patent related to adjusting mouse resolution using a physical hardware switch rather than software.
  • Technical Context: The technology addresses hardware-based, on-the-fly adjustment of computer mouse sensitivity (DPI), a feature of particular relevance in the computer gaming market for switching between fast movement and precision aiming.
  • Key Procedural History: The complaint does not reference prior litigation, administrative proceedings, or licensing history concerning the patent-in-suit. The action is filed against a group of unnamed Amazon storefronts alleged to be operating in concert from China.

Case Timeline

Date Event
2004-05-05 U.S. Patent No. 7,532,200 Priority Date
2005-01-18 U.S. Patent No. 7,532,200 Filing Date
2009-05-12 U.S. Patent No. 7,532,200 Issue Date
2025-12-04 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 7,532,200, "APPARATUS FOR SETTING MULTI-STAGE DISPLACEMENT RESOLUTION OF A MOUSE," issued May 12, 2009 (’200 Patent).

The Invention Explained

  • Problem Addressed: The patent’s background section describes the prior art method of adjusting mouse resolution as inconvenient, requiring users to install and navigate specific software drivers or tools on a connected computer. This process could be confusing, and the necessary software media (e.g., a CD-ROM) could be lost, preventing adjustment ('200 Patent, col. 1:15-33; Compl. ¶15).
  • The Patented Solution: The invention is an apparatus within the mouse itself that allows a user to set the resolution directly via a physical switch ('200 Patent, col. 1:38-41). The apparatus includes a displacement detector (e.g., an optical sensor), a switching circuit with at least one switch, and a mouse microcontroller. The microcontroller reads the state of the switch, sets a corresponding resolution value in an internal register, and then uses that value to translate the mouse's physical movement into cursor movement on the screen, all without requiring external software on the host computer ('200 Patent, col. 2:34-55; Fig. 1).
  • Technical Importance: This hardware-based approach allows for rapid, "on-the-fly" adjustment of mouse sensitivity, a feature that gained prominence in applications like computer gaming where users may desire different sensitivity levels for different tasks within the same session (Compl. ¶14).

Key Claims at a Glance

  • The complaint specifically alleges infringement of at least Claim 6 ('200 Patent, col. 4:27-54; Compl. ¶24).
  • The essential elements of independent Claim 6 include:
    • An X-Y axis plane displacement detector for sensing movement.
    • An N-stage switch with a button that can be manually switched to one of N positions, activating a connected resolution setting pin to indicate a state.
    • A mouse microcontroller with a register, coupled to the detector and the switch.
    • The microcontroller performs several functions: determining the resolution value based on the state of the setting pin, setting the mouse resolution, storing that resolution value in the register, and using the stored value to generate a control signal for moving the computer's cursor.
  • The complaint alleges infringement of "one or more claims," suggesting the right to assert other claims may be reserved (Compl. ¶23).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are "game mouse designed Infringing Products" sold by Defendants on various Amazon storefronts (Compl. ¶1, ¶19).
  • Functionality and Market Context: The complaint describes the accused products as "computer mice with adjustable DPI via a switch button" (Compl. ¶19). They are marketed as gaming mice and are alleged to contain optical sensors (Compl. ¶7). The complaint alleges these products are imported and sold to U.S. consumers, including those in Texas, and that fast shipping options indicate inventory is stored within the state (Compl. ¶1, ¶3).

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in Exhibit 3, which was not provided with the filing. The narrative infringement theory is summarized below. No probative visual evidence provided in complaint.

The complaint alleges that the accused gaming mice embody each element of Claim 6 of the ’200 Patent (Compl. ¶24). The theory suggests that the products’ optical sensors function as the claimed "X-Y axis plane displacement detector." The "adjustable DPI via a switch button" feature is alleged to meet the "N-stage switch" limitation (Compl. ¶19). Implicitly, the complaint alleges that these mice contain an internal microcontroller that reads the state of the DPI switch, stores a corresponding resolution value, and uses that value to control the cursor, thereby satisfying the final element of the claim. The complaint does not provide specific technical details about the internal architecture or operation of the accused mice to substantiate these allegations.

  • Identified Points of Contention:
    • Scope Questions: The infringement analysis may turn on the construction of "N-stage switch." A central question will be whether the accused products' potentially simple "DPI button" meets the claim's more specific requirement of a switch that is "manually switched to one of positions 1 to N" and "activat[es] a connected resolution setting pin to indicate a state."
    • Technical Questions: The complaint's allegations are functional rather than structural. A key technical question will be whether discovery reveals that the accused products' internal components operate in the specific manner required by the claim. For example, does the microcontroller determine the resolution "based on the state of the connected resolution setting pins" and subsequently perform the step of "storing the resolution value in the register," or does it employ a different internal logic or architecture?

V. Key Claim Terms for Construction

  • The Term: "N-stage switch"

    • Context and Importance: This term defines the core novel component of the invention—the physical user interface for adjusting resolution. Its construction will determine whether the claim reads on a broad range of modern DPI adjustment buttons or is limited to the specific switch configurations disclosed in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Plaintiff may argue the term should be understood functionally, as described in Claim 6, to cover any physical button that allows a user to select one of "N" discrete resolution states.
      • Evidence for a Narrower Interpretation: Defendant may argue the term is limited by the specification’s embodiments, which depict a DIP (Dual In-line Package) switch or a multi-position slide switch physically connected to multiple "resolution setting pins" that directly indicate a state to the microcontroller ('200 Patent, Fig. 2, Fig. 4, col. 3:17-30).

  • The Term: "storing the resolution value in the register"

    • Context and Importance: This limitation requires a specific internal operation within the mouse's microcontroller. The dispute will center on whether the accused products perform this precise action, as opposed to using an alternative method for applying the selected resolution setting.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Plaintiff may contend that "register" should be given its ordinary meaning in the context of microcontrollers, referring to any memory location used to hold the currently active resolution setting for processing.
      • Evidence for a Narrower Interpretation: Defendant could argue the term, in light of its depiction as a distinct block "register 41" within the microcontroller in Figure 1, requires a dedicated hardware register for storing the value, and that a different firmware or software-based memory management approach would not meet this limitation ('200 Patent, Fig. 1).

VI. Other Allegations

  • Indirect Infringement: The complaint focuses on allegations of direct infringement through Defendants' acts of selling, offering for sale, and importing the accused products (Compl. ¶1, ¶23). No separate count or specific factual allegations for indirect infringement are included.
  • Willful Infringement: The complaint alleges willful infringement based on Defendants having "actual notice of the Patent since at least the filing of this suit" (Compl. ¶23). This allegation is directed at post-filing conduct and does not assert pre-suit knowledge.

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

  • A core issue will be one of definitional scope: can the term "N-stage switch," which is described in the patent's embodiments as a multi-position switch that directly sets the state of dedicated pins, be construed to cover the single-button DPI-cycling mechanisms commonly found on modern gaming mice?
  • A key evidentiary question will be one of technical implementation: does the internal hardware and firmware of the accused products operate in the specific manner claimed—namely, by activating a "resolution setting pin" and "storing the resolution value in the register"—or do they achieve the same functional result through a technically distinct method that falls outside the literal scope of the claim?