DCT
1:25-cv-01856
BelAir Electronics Inc v. Apple Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-01856, W.D. Tex., 11/17/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains multiple corporate campuses, operates numerous retail stores, is registered to do business in the state, and has a registered agent in Texas, thereby constituting a regular and established place of business where acts of infringement have allegedly occurred.
- Core Dispute: Plaintiff alleges that Defendant’s protective cases for its iPhone and iPad product lines infringe two patents related to protective masks for mobile phones.
- Technical Context: The technology concerns form-fitting protective covers, or "masks," designed to prevent abrasion and cosmetic damage to the exterior housing of mobile electronic devices.
- Key Procedural History: The complaint states that the asserted patents are currently undergoing ex parte reexamination (EPR) proceedings at the USPTO, initiated by a third party. Plaintiff indicates its intent to seek a stay of this litigation pending the resolution of the EPRs. Both asserted patents are noted as having expired prior to the filing of the complaint, limiting the action to a claim for past damages.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Priority Date for ’195 and ’676 Patents |
| 2011-05-10 | ’195 Patent Issue Date |
| 2018-10-09 | ’676 Patent Issue Date |
| 2019-11-17 | Alleged Start of Recoverable Damages Period |
| 2021-10-23 | Approximate Expiration Date of ’676 Patent |
| 2022-11-16 | Approximate Expiration Date of ’195 Patent |
| 2025-11-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,941,195 - "Protective Mask of Mobile Phone", Issued May 10, 2011
The Invention Explained
- Problem Addressed: The patent’s background section identifies that mobile phone housings are often "very smooth and delicate," making them susceptible to abrasion from user carelessness, which can generate "ill-favored scars thereon, resulting in the deterioration of the quality of the mobile phone and the fall of its value" (’195 Patent, col. 1:32-38).
- The Patented Solution: The invention proposes a protective mask, comprising a "first mask portion" and a "second mask portion," designed to sheathe the front and rear of a mobile phone housing (’195 Patent, col. 2:29-35). These portions are molded to conform to the phone's shape and are coupled to the exterior housing using features like "flanges" to cover and protect the phone's surfaces from damage (’195 Patent, col. 2:39-44).
- Technical Importance: This approach provided a way to protect a mobile device's cosmetic appearance and resale value without permanently altering the device itself.
Key Claims at a Glance
- The complaint asserts independent Claim 9 (Compl. ¶22).
- Essential elements of Claim 9 include:
- A protective mask adapted to be coupled to an exterior housing of a mobile phone.
- A first mask portion, molded to conform to the shape of a first portion of the exterior housing.
- The first mask portion having flanges to allow the first mask portion to be coupled to the mobile phone to retain it to the exterior housing.
U.S. Patent No. 10,097,676 - "Protective Mask of Mobile Phone", Issued October 9, 2018
The Invention Explained
- Problem Addressed: The ’676 Patent, a continuation of the family that includes the ’195 Patent, addresses the same problem of preventing abrasion and cosmetic damage to delicate mobile phone housings (’676 Patent, col. 1:32-38).
- The Patented Solution: This patent describes a protective mask as a single, "integrally-formed mask body" molded for "frictional retention" against the phone's exterior (’676 Patent, Abstract). The solution emphasizes a tight, conforming fit with "substantially continuous surface-to-surface contact" and "at least one retainer" that has an extension protruding inward to help secure the mask to the device (’676 Patent, col. 4:1-32).
- Technical Importance: This refined the concept toward a single-piece, friction-fit design that has become common in the smartphone accessory market.
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9 (Compl. ¶28).
- Essential elements of Claim 1 (representative) include:
- A protective mask molded for frictional retention to an exterior housing of a mobile phone.
- An integrally-formed mask body molded and contoured to conform and frictionally-fit tightly against the exterior shape.
- An inner surface of the mask body in substantially continuous surface-to-surface contact with the exterior housing, with no substantial space between them.
- At least one opening permitting user access to interfaces.
- At least one retainer having an extension protruding laterally inward from the mask body to participate in retaining the mask.
- The complaint reserves the right to assert dependent Claims 2, 3, 4, 6, 7, 10, 11, and 12 (Compl. ¶¶31, 34, 39).
III. The Accused Instrumentality
Product Identification
The accused products are various categories of protective cases for Apple's mobile devices, including the "Clear Case; Silicone Case; Leather Case; Leather Folio; Smart Battery Case; and Smart Case" for numerous models of the iPhone and iPad (Compl. ¶¶16-17). The "iPhone 11 Pro Silicone Case - Black" is identified as a representative product (Compl. ¶7).
Functionality and Market Context
The complaint alleges the Accused Products are protective masks designed to be "coupled to a portion of a mobile device so that the mobile device will not fall out of the protective mask" (Compl. ¶18). They are described as providing "non-permanent, temporary protection" by conforming to the contour of the device's outer surface (Compl. ¶18). A key alleged feature is the presence of a "flange or retainer" used to secure the case to the device (Compl. ¶18). The complaint provides a photograph of the packaging for the representative iPhone 11 Pro Silicone Case (Compl. p. 9).
IV. Analysis of Infringement Allegations
’195 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A protective mask adapted to be coupled to an exterior housing of a mobile phone... | The Accused Products are protective masks for mobile devices. | ¶23 | col. 3:26-34 |
| a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone; | The Accused Products comprise a first mask portion molded to conform to the shape of the exterior housing of the mobile phone. | ¶24a | col. 3:29-31 |
| the first mask portion having flanges to allow the first mask portion to be coupled to the mobile phone to retain the first mask portion to the first portion of the exterior housing... | The Accused Products' first mask portion has flanges that allow it to be coupled to and retained on the mobile phone's exterior housing. | ¶24b | col. 2:39-44 |
’676 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an integrally-formed mask body molded and contoured to conform and frictionally-fit tightly against the exterior shape of the exterior housing; | The Accused Products comprise an integrally-formed mask body molded to conform and frictionally-fit tightly against the phone's exterior housing. | ¶30a | col. 4:1-4 |
| an inner surface... in substantially continuous surface-to-surface contact with the exterior shape of the exterior housing, with no substantial space between [them]; | The inner surface of the mask body is in substantially continuous surface-to-surface contact with the exterior of the phone, with no substantial space between them. | ¶30b | col. 4:8-14 |
| at least one opening defined by the integrally-formed mask body permitting user access to at least the user input and output interfaces; and | The mask body defines at least one opening that permits user access to the phone's input and output interfaces. | ¶30c | col. 4:15-18 |
| at least one retainer having an extension protruding laterally inward from the integrally-formed mask body... wherein the at least one retainer is retained to the exterior housing at an exterior housing edge... | The Accused Products have at least one retainer with an extension protruding laterally inward from the mask body, which is retained at the edge of the housing. | ¶30d | col. 4:19-29 |
Identified Points of Contention
- Scope Questions: The ’195 Patent’s specification primarily describes a two-part protective mask (upper and lower cover bodies), while the accused Apple cases are single, integrally formed pieces. This raises the question of whether a single-piece case can meet the "first mask portion" limitation of Claim 9.
- Technical Questions: A central technical question will be whether the continuous lip around the perimeter of the accused Apple cases, which the complaint highlights in photographs with red markings (Compl. p. 10), constitutes the "flanges" required by the ’195 Patent or the "retainer" required by the ’676 Patent. Defendant may argue that this feature is merely the side wall of the case and not a distinct structural element as claimed.
V. Key Claim Terms for Construction
For the ’195 Patent:
- The Term: "flanges"
- Context and Importance: This term is the primary structural element recited in Claim 9 for coupling the mask to the phone. Its construction will be critical to determining if the single-piece accused products, with their continuous perimeter lip, can infringe a claim rooted in a patent describing a two-part cover system.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires "flanges" (plural) but does not specify their shape, number, or structure, which may support an argument that any protruding lip-like structure that aids retention meets the limitation.
- Evidence for a Narrower Interpretation: The specification explicitly shows "a plurality of flanges 21" as discrete, hook-like structures on the rear side face of the "upper cover body 20" (’195 Patent, Fig. 3; col. 2:39-41). This could support an interpretation that "flanges" must be distinct, separate elements rather than a continuous, uniform lip.
For the ’676 Patent:
- The Term: "at least one retainer having an extension protruding laterally inward"
- Context and Importance: This term serves a similar function to "flanges" in the earlier patent but is used in the context of an integrally-formed, friction-fit mask. The dispute will likely focus on whether the simple inward-facing lip of the accused case is a "retainer" or simply an integral part of the case wall.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language requires only "at least one retainer," which is an expansive term. The functional language—that it "participat[es] in retaining the integrally-formed mask body"—could be argued to cover any structure that contributes to holding the case on the phone, including a continuous lip.
- Evidence for a Narrower Interpretation: While the specification of the ’676 patent does not provide a detailed drawing of the "retainer" in its own figures, it incorporates the ’195 patent by reference. A party could argue the term should be understood in light of the more defined "flanges 21" shown in the parent patent family, suggesting a structure with more distinct geometry than a simple edge.
VI. Other Allegations
- Indirect Infringement: The complaint exclusively alleges direct infringement under 35 U.S.C. § 271(a) (Compl. ¶¶26, 41). There are no allegations of induced or contributory infringement.
- Willful Infringement: The complaint does not contain an allegation of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- Procedural Impact of Reexamination: The primary threshold question is the impact of the ongoing ex parte reexaminations. The outcome of these USPTO proceedings, which will re-evaluate the patentability of the asserted claims, could significantly narrow the claims or invalidate them entirely, potentially resolving the dispute before substantive litigation proceeds beyond the anticipated stay.
- Definitional Scope: A core issue will be one of claim construction: can the terms "flanges" (’195 Patent) and "retainer" (’676 Patent) be construed to read on the continuous, integrally formed lip that runs along the screen-side perimeter of the accused single-piece cases? The case may turn on whether these terms require discrete, separately identifiable structures or can encompass a uniform, continuous feature.
- Structural Equivalence: A key question for the ’195 Patent will be whether a single-piece protective case can satisfy the "first mask portion" limitation. The analysis may focus on whether the structure of the accused product is fundamentally different from the two-part assembly described and claimed in the patent.