DCT

1:25-cv-00942

Reaction Labs LLC v. Shenzhen Jinchi Technology Co Ltd

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00942, W.D. Tex., 06/19/2025
  • Venue Allegations: Venue is asserted based on Defendants' alleged business contacts, sales, offers for sale, and other commercial activities directed at the State of Texas and the Western District of Texas. For the foreign-domiciled defendants, venue is also asserted under federal statutes governing suits against foreign parties.
  • Core Dispute: Plaintiff alleges that Defendants’ magnetic USB cables infringe a patent related to magnetized cables for improved cable management and tangle prevention.
  • Technical Context: The technology concerns self-coiling magnetic cables, designed to reduce tangling and improve storage convenience for consumer electronics power and data cables.
  • Key Procedural History: The complaint notes that Plaintiff has exclusively licensed the asserted patent to a third party, Statik, which sells authorized products under the "MagStack" brand, and that Defendants' products are in direct competition.

Case Timeline

Date Event
2023-01-27 '881 Patent Priority Date (Provisional App.)
2023-06-22 '881 Patent Application Filing Date
2024-04-30 '881 Patent Issue Date
2025-06-19 Complaint Filing Date

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

U.S. Patent No. 11,972,881 - "Magnetized Cable for Improved Cable Management"

  • Patent Identification: U.S. Patent No. 11,972,881, titled "Magnetized Cable for Improved Cable Management", issued on April 30, 2024 ('881 Patent). (Compl. ¶1, 14).

The Invention Explained

  • Problem Addressed: The patent addresses the common problem of cables for electronic devices becoming tangled when not in use, which causes user frustration. (’881 Patent, col. 1:20-22).
  • The Patented Solution: The invention is a cable incorporating an "elongated flexible magnetized component" (EFMC) that produces a persistent magnetic field. (’881 Patent, col. 2:33-35). This field is configured to create an attraction between adjacent portions of the cable when it is coiled, allowing it to "snap" into and hold a neat, coiled shape without external ties. (’881 Patent, col. 5:15-18). A key embodiment describes a cable with a substantially rectangular cross-section where the two large, flat "major surfaces" have opposite magnetic polarities (e.g., one north, one south), which maximizes the attractive force when the cable is coiled upon itself. (’881 Patent, col. 2:62-col. 3:6).
  • Technical Importance: This design offers a self-contained solution for cable management, eliminating the need for separate clips, ties, or winders to keep cables organized. (’881 Patent, col. 2:24-34).

Key Claims at a Glance

  • The complaint asserts infringement of exemplary claims 1, 2, and 6. Independent claims 1 and 6 are central to the allegations. (Compl. ¶20, 25).
  • Independent Claim 1 requires:
    • one or more electrically conductive wires;
    • an elongated flexible magnetized component (EFMC) that produces a persistent magnetic force;
    • the EFMC includes a pliable polymer binder with magnetic particles distributed within it;
    • the cable has a substantially rectangular cross-section with a pair of substantially planar and parallel major surfaces; and
    • the first major surface lies within a first magnetic polarity region and the second major surface lies within a second, different polarity region.
  • Independent Claim 6 requires:
    • one or more electrically conductive wires; and
    • an elongated flexible magnetized component (EFMC) that produces a persistent magnetic force, wherein at least one of the conductive wires is embedded in and surrounded by the EFMC.
  • The complaint implicitly reserves the right to assert additional claims. (Compl. ¶19).

III. The Accused Instrumentality

Product Identification

  • The "Accused Products" are identified as "magnetic 4-in-1 USB-C Cables" and "magnetic USB-C Cables" sold under the "Skegic" brand. (Compl. ¶19).

Functionality and Market Context

  • The Accused Products are described as USB cables for charging and data transfer, with marketing materials that state "Data transfer up to 480 Mbps." (Compl. ¶21).
  • Their key feature relevant to the lawsuit is a "magnetic design" advertised to keep the cables "tangle-free." (Compl. ¶22). The complaint provides an image from the defendants' website showing two coiled magnetic cables, one black and one silver, to illustrate the accused products. (Compl. ¶19, Exhibit B).
  • The complaint alleges that these products are in direct competition with products sold by the Plaintiff and its exclusive licensee. (Compl. ¶28).

IV. Analysis of Infringement Allegations

'881 Patent Infringement Allegations

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 their marketed function for data transfer and power delivery. ¶21 col. 2:35-36
an elongated flexible magnetized component (EFMC) configured to produce a persistent magnetic force... The Accused Products are alleged to have a magnetic component that produces a magnetic force, marketed with the slogan "Stay tangle-free." ¶22 col. 2:33-41
the EFMC includes a pliable polymer binder and magnetic particles distributed within the pliable polymer binder The complaint alleges the Accused Products' EFMC includes a pliable polymer binder with distributed magnetic particles. ¶23 col. 2:41-45
the magnetic cable has a substantially rectangular cross section defining a pair of substantially planar and parallel major surfaces The Accused Products are alleged to have a substantially rectangular cross-section defining two major surfaces. ¶24 col. 2:62-65
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 of the persistent magnetic field The complaint alleges the first major surface is within a first polarity region and the second is within an opposing polarity region. ¶24 col. 2:62-col. 3:6

Identified Points of Contention

  • Scope Questions: A central dispute may arise over the term "substantially rectangular." The complaint alleges the accused cables meet this limitation based on product imagery (Compl. ¶24, Exhibit B), but whether the actual cross-sectional geometry of the flat-style accused cables falls within a proper construction of this term will be a question for the court.
  • Technical Questions: The complaint alleges the internal composition of the accused cable includes a "pliable polymer binder and magnetic particles" (Compl. ¶23). As this is not verifiable from external observation or marketing materials, a key evidentiary question is what proof Plaintiff can provide, likely through technical analysis or discovery, to demonstrate this internal structure and the specific alignment of magnetic polarities on the major surfaces as required by Claim 1.

V. Key Claim Terms for Construction

The Term: "substantially rectangular"

  • Context and Importance: This term is critical to the infringement analysis for Claim 1, as it defines the required physical shape of the cable, which in turn enables the claimed magnetic alignment on opposing "major surfaces." The case may turn on whether the accused cables, which appear to be flat or slightly oval, meet this geometric requirement.
  • Intrinsic Evidence for a Broader Interpretation: The specification suggests some flexibility, noting that embodiments may have "optional rounded or beveled corners." (’881 Patent, col. 4:42-43). It also states that the benefits of the invention "may be realized in other configurations including, without limitation, circular and other elliptical cross section configurations," which a party could argue supports a construction not strictly limited to four-cornered shapes. (’881 Patent, col. 4:5-9).
  • Intrinsic Evidence for a Narrower Interpretation: The claim language itself requires "a pair of substantially planar and parallel major surfaces," which may imply a more defined geometric structure than a simple oval. Figure 2 of the patent depicts a distinct rectangle, and a party could argue that "substantially rectangular" must be interpreted in light of this clear embodiment to mean a shape with discernible, mostly flat opposing sides. (’881 Patent, Fig. 2; col. 4:43-45).

The Term: "pliable polymer binder"

  • Context and Importance: This term defines the material matrix that holds the magnetic particles within the EFMC. Proving that the material used in the accused products constitutes a "pliable polymer binder" is essential to satisfying a key limitation of Claim 1.
  • Intrinsic Evidence for a Broader Interpretation: The patent provides a non-exhaustive list of materials, including "rubber, silicon, silicon-rubber, or chlorinated polyethylene or other material," suggesting the term is not confined to the specific examples given. (’881 Patent, col. 2:41-44). The use of "or another suitable material" could support a broader definition encompassing any flexible polymer that can serve as a binding agent for magnetic particles.
  • Intrinsic Evidence for a Narrower Interpretation: A defendant might argue that the term should be limited by the specific characteristics of the examples provided, such as their particular flexibility, durability, or manufacturing properties. (’881 Patent, col. 4:27-33). The term "binder" itself has a technical meaning, and a dispute could arise over whether the accused product's material functions as a "binder" in the manner described in the patent.

VI. Other Allegations

Indirect Infringement

  • The complaint does not plead a separate count for indirect infringement. While a jurisdictional allegation makes a passing reference to inducing infringement, the substantive infringement count focuses on direct infringement under 35 U.S.C. § 271 for acts of making, using, selling, offering for sale, and importing. (Compl. ¶10, 19, 26).

Willful Infringement

  • The complaint does not allege willful infringement.

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

  • A key evidentiary question will be one of internal composition: Can the Plaintiff produce evidence, through reverse engineering or discovery, to prove that the Accused Products contain the claimed "pliable polymer binder and magnetic particles" and that the magnetic field is aligned on opposing "major surfaces" as specifically required by Claim 1?
  • The case may hinge on a question of definitional scope: How will the court construe the term "substantially rectangular"? The answer will determine whether the accused flat-style cables, as depicted in the complaint's exhibits, are within the geometric scope of the asserted claims.