DCT
1:25-cv-00458
Reaction Labs LLC v. Liquipel LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Reaction Labs LLC a/k/a Lup (Texas)
- Defendant: Liquipel, LLC (California)
- Plaintiff’s Counsel: Scardino LLP
- Case Identification: 1:25-cv-00458, W.D. Tex., 03/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant conducts business in the state and sells the accused products through retailers in the district, including a specific store in Austin, Texas.
- Core Dispute: Plaintiff alleges that Defendant’s “Simple” brand of magnetic charging cables infringes a patent related to self-organizing cables that use an integrated magnetic component for improved cable management.
- Technical Context: The technology addresses the common problem of tangled consumer electronics cables by embedding magnetic properties into the cable itself, allowing it to coil neatly for storage.
- Key Procedural History: The complaint notes that Plaintiff has exclusively licensed the asserted patent to Statik, a seller of authorized products under the brand "MagStack." No other prior litigation or administrative proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2023-01-27 | Priority Date for U.S. Patent No. 11,972,881 |
| 2023-06-22 | Application filed for U.S. Patent No. 11,972,881 |
| 2024-04-30 | U.S. Patent No. 11,972,881 Issued |
| 2025-03-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,972,881 - "Magnetized Cable for Improved Cable Management," Issued April 30, 2024
The Invention Explained
- Problem Addressed: The patent’s background section identifies the common consumer frustration that cables for electronic devices frequently become entangled when not in use (’881 Patent, col. 1:18-21).
- The Patented Solution: The invention is a cable that incorporates an “elongated flexible magnetized component” (EFMC). This component, made from a pliable polymer binder mixed with magnetic particles, generates a persistent magnetic field along the cable’s length (’881 Patent, col. 2:34-50). This field is configured so that when the cable is coiled, adjacent loops attract each other, holding the cable in a neat, coiled state without external ties while still allowing a user to easily uncoil it by hand (’881 Patent, col. 2:26-33). The specification particularly describes an embodiment with a rectangular cross-section where the opposing flat "major surfaces" have opposite magnetic polarity (e.g., north and south) to facilitate this self-attraction (’881 Patent, col. 2:62-65).
- Technical Importance: This design provides an integrated solution for cable management that simplifies storage and handling, a stated goal of the invention (’881 Patent, col. 4:51-56).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 6 (Compl. ¶¶ 18, 23).
- Independent Claim 1:
- one or more electrically conductive wires;
- an elongated flexible magnetized component (EFMC) configured to produce a persistent magnetic force causing portions of the cable to attract when coiled;
- wherein the EFMC includes a pliable polymer binder and magnetic particles distributed within the binder;
- the magnetic cable has a substantially rectangular cross section defining a pair of substantially planar and parallel major surfaces; and
- a first of the major surfaces lies within a first polarity region of the persistent magnetic field and a second of the major surfaces lies within a second polarity region.
- Independent Claim 6:
- one or more electrically conductive wires;
- an elongated flexible magnetized component (EFMC) configured to produce a persistent magnetic force causing portions of the cable to attract when coiled;
- wherein at least one of the one or more electrically conductive wires is embedded in and surrounded by the EFMC.
- The complaint does not explicitly reserve the right to assert dependent claims, but infringement allegations are made against "one or more claims" (Compl. ¶18).
III. The Accused Instrumentality
Product Identification
- The accused products are Defendant Liquipel’s magnetic charging cables sold under the brand “Simple,” specifically including its 4 ft and 6 ft USB-C and USB-A cables (Compl. ¶17).
Functionality and Market Context
- The complaint alleges that the accused products are magnetized cables designed for "automatic cable management" to prevent tangling (Compl. ¶20). The product packaging, shown in a photograph provided in the complaint, promotes a feature for "automatic magnetic cable management" (Compl. p. 5). The complaint alleges the products achieve this using "Magnetic Injection Technology" that "enhances the magnetic properties of their Tough Knit braided cables, providing strong magnetic attraction" (Compl. ¶18).
IV. Analysis of Infringement Allegations
'881 Patent Infringement Allegations (Claim 1)
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| one or more electrically conductive wires | The accused products contain one or more wires, as evidenced by product packaging stating, "This cable can be used to charge and transfer data..." | ¶19 | col. 2:35 |
| an elongated flexible magnetized component (EFMC) configured to produce a persistent magnetic force... | The accused products are alleged to have an EFMC that provides "strong magnetic attraction" for "automatic cable management," which facilitates coiling and prevents tangling. | ¶20 | col. 2:34-40 |
| the EFMC includes a pliable polymer binder and magnetic particles distributed within the pliable polymer binder | The accused product's "Magnetic Injection Technology" is alleged to involve a process of "blending magnetic materials, such as neodymium-iron-boron (NdFeB) powders, with a polymer binder." | ¶21 | col. 2:40-50 |
| the magnetic cable has a substantially rectangular cross section defining a pair of substantially planar and parallel major surfaces | The complaint alleges that the accused products have a "substantially rectangular cross section defining a pair of substantially planar and parallel major surfaces." A photograph of the accused product coiled in its packaging is provided as visual evidence. (Compl. p. 5). | ¶22 | col. 2:62-64 |
| a first of the major surfaces lies within a first polarity region... and a second of the major surfaces lies within a second polarity region... | The complaint alleges that the accused products have a first major surface within a first polarity region and a second major surface within a second polarity region. | ¶22 | col. 2:64-col. 3:5 |
'881 Patent Infringement Allegations (Claim 6)
| Claim Element (from Independent Claim 6) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| one or more electrically conductive wires | The complaint incorporates its earlier allegations regarding the presence of electrically conductive wires. | ¶23 | col. 8:11 |
| an elongated flexible magnetized component (EFMC) configured to produce a persistent magnetic force... | The complaint incorporates its earlier allegations regarding the EFMC, which is configured to produce a magnetic force for automatic coiling. | ¶23 | col. 8:12-19 |
| wherein at least one of the one or more electrically conductive wires is embedded in and surrounded by the EFMC | The complaint alleges that in the accused products, "at least one of the one or more electrically conductive wires is embedded in and surrounded by the EFMC." | ¶23 | col. 8:20-22 |
Identified Points of Contention
- Structural Questions (Claim 1): A central factual dispute may concern the physical structure of the accused cable. The analysis will question whether the accused product's cross-section is "substantially rectangular" and whether it exhibits the specific magnetic field orientation required by the claim, with opposing polarities on its opposing "major surfaces." The complaint makes these allegations, but they will likely require evidentiary support such as product teardowns and magnetic field analysis.
- Structural Questions (Claim 6): The infringement allegation for Claim 6 hinges on whether the conductive wires are physically "embedded in and surrounded by the EFMC." The patent specification discloses alternative embodiments where the wires are adjacent to, but not embedded within, the EFMC (e.g., ’881 Patent, Fig. 3). The case may turn on evidence of the accused product's internal construction to determine if it meets this specific limitation.
V. Key Claim Terms for Construction
The Term: "elongated flexible magnetized component (EFMC)"
- Context and Importance: This term is the core of the invention and appears in both asserted independent claims. The infringement case rests on whether the accused product's "Magnetic Injection Technology" and resulting structure meet this definition. Practitioners may focus on this term because its scope will determine whether a broad range of self-coiling magnetic cables, or only those with a specific material composition and structure, are covered.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims define the EFMC functionally as being "configured to produce a persistent magnetic force" that attracts the cable to itself when coiled (’881 Patent, col. 8:1-22). A party could argue that any flexible, magnetized part of the cable that performs this function meets the definition, regardless of the specific manufacturing process.
- Evidence for a Narrower Interpretation: The specification consistently describes the EFMC as comprising a "pliable polymer base or binder" combined with "a plurality of magnetic particles" (’881 Patent, col. 2:40-45). A party may argue that this description limits the term to a composite material, potentially excluding cables magnetized through other means. The specific examples of materials like "rubber, silicon, silicon-rubber, or chlorinated polyethylene" could also be used to argue for a narrower construction (’881 Patent, col. 2:40-43).
The Term: "embedded in and surrounded by the EFMC"
- Context and Importance: This limitation is the key distinguishing feature of Claim 6. Its construction is critical because the patent discloses other arrangements, such as wires placed in voids next to the EFMC within an outer sheath (’881 Patent, Fig. 3, col. 5:30-41), which would not meet the literal language of this claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that "surrounded by" does not require 360-degree physical contact with the EFMC material itself, but could mean being enclosed within the overall component structure that provides the magnetic function. This interpretation seems less likely given the plain language.
- Evidence for a Narrower Interpretation: The plain meaning of "embedded in and surrounded by" suggests the wire must be physically inside the material of the EFMC. This is strongly supported by Figure 2 of the patent, which depicts wires (203) fully encased within the material of the EFMC (201) (’881 Patent, Fig. 2). The specification further states that in some embodiments, "one or more of the wires may be embedded within and surrounded by the EFMC" (’881 Patent, col. 2:9-10), contrasting this with other disclosed embodiments.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant has "committed, contributed to, and induced acts of patent infringement" (Compl. ¶8). Factual support may be drawn from allegations that the product packaging and marketing materials for the accused products promote their use for "automatic cable management," thereby encouraging an infringing use by consumers (Compl. ¶¶18, 20).
- Willful Infringement: The complaint does not contain allegations of pre-suit knowledge or other facts sufficient to support a claim for willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of structural proof: Can the plaintiff provide evidence, likely from product teardowns and testing, that the accused "Simple" cables possess the specific physical and magnetic properties required by Claim 1—namely, a "substantially rectangular" cross-section with opposing polarities on its two major surfaces?
- The case will also present a key structural distinction: Does the internal construction of the accused product show wires that are physically "embedded in and surrounded by" the magnetic material, as required by Claim 6, or are they merely adjacent to it within a shared sheath, an arrangement that the patent itself presents as a distinct, alternative embodiment?
- Finally, the dispute may involve a question of definitional scope: Will the term "elongated flexible magnetized component (EFMC)" be construed broadly to cover any flexible, magnetized cable body, or will it be limited by the specification's examples to a composite of magnetic particles distributed within a polymer binder?