DCT
1:25-cv-01872
BelAir Electronics Inc v. T-Mobile USA Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: T-Mobile USA, Inc. (dba GoTo) (Delaware)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-01872, W.D. Tex., 11/19/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains multiple "Business Sales" offices and numerous retail stores within the district, is registered to do business in Texas with a registered agent in Austin, and has committed alleged acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "GoTo" brand of protective mobile phone cases infringes two patents related to protective masks for mobile phones.
- Technical Context: The technology at issue concerns protective cases for mobile phones, a mature and highly competitive segment of the consumer electronics accessory market.
- Key Procedural History: The complaint discloses that the claims of the asserted patents are currently undergoing ex parte reexamination proceedings at the U.S. Patent and Trademark Office, initiated by a third party. Plaintiff states its intention to seek a stay of this litigation pending the resolution of those proceedings. Both asserted patents are expired.
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 |
| 2019-11-19 | Alleged Start of Damages Period |
| 2021-10-23 | Alleged Expiration of ’676 Patent |
| 2022-11-16 | Alleged Expiration of ’195 Patent |
| 2025-11-19 | 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 (’195 Patent)
The Invention Explained
- Problem Addressed: The patent's background describes mobile phones as "very smooth and delicate," making them susceptible to abrasion and "ill-favored scars" from user carelessness, which deteriorates their quality and value. It also notes the "waste of money" when users replace entire phones simply to follow fashion trends (’195 Patent, col. 1:29-41).
- The Patented Solution: The invention is a protective mask composed of separate upper and lower cover bodies that can be joined to the front and rear housings of a mobile phone, respectively, to "sheathe" the device and prevent damage (’195 Patent, col. 2:30-41). The mask is retained on the phone by a "plurality of flanges" that engage the edge of the phone's housing (’195 Patent, col. 2:37-41, Fig. 3). These masks can be produced with various patterns or designs, allowing users to change the phone's appearance without replacing the device itself (’195 Patent, col. 1:52-59).
- Technical Importance: The technology provided a method for creating non-permanent, customizable protection for mobile devices that addressed both physical durability and aesthetic personalization in a cost-effective manner (’195 Patent, col. 1:52-59).
Key Claims at a Glance
- The complaint asserts independent Claim 9 of the ’195 Patent (Compl. ¶22).
- The 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 it to be coupled to and retained on the mobile phone.
U.S. Patent No. 10,097,676 - Protective Mask of Mobile Phone, issued October 9, 2018 (’676 Patent)
The Invention Explained
- Problem Addressed: As a continuation of the ’195 Patent, the ’676 Patent addresses the same technical problems of preventing abrasion and "ill-favored scars" on delicate mobile phones and avoiding the economic burden of replacing devices to keep up with fashion trends (’676 Patent, col. 1:32-47).
- The Patented Solution: This patent describes a protective mask as a single, "integrally-formed mask body" designed for "frictional retention" on a phone's housing (’676 Patent, col. 3:36-44). The solution emphasizes a close fit, with an inner surface in "substantially continuous surface-to-surface contact" with the phone's exterior. Retention is achieved by "at least one retainer having an extension protruding laterally inward" that engages an edge of the housing (’676 Patent, col. 3:56-62).
- Technical Importance: The invention describes a single-piece, friction-fit protective case that is simple to install and remove while maintaining a slim profile and tight fit to the device (’676 Patent, col. 3:40-44).
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9 of the ’676 Patent (Compl. ¶28).
- The essential elements of independent Claim 1 include:
- A protective mask molded for frictional retention to a mobile phone's exterior housing;
- an integrally-formed mask body molded to conform and frictionally-fit tightly against the exterior housing;
- an inner surface in substantially continuous surface-to-surface contact with the exterior housing, with no substantial space between them;
- at least one opening for user access to interfaces; and
- at least one retainer with an extension protruding laterally inward that is retained at an exterior housing edge.
- 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 protective masks for mobile devices sold under Defendant's "GoTo" brand, including product lines such as Define, Dot, Flex (MagSafe), Pro, and others (Compl. ¶16). The complaint identifies a "GoTo Define Cell Phone Case for T-Mobile REVVL 5G" as a representative product purchased for analysis (Compl. ¶7).
Functionality and Market Context
- The complaint alleges the accused products are protective masks that couple to a mobile device to prevent it from falling out (Compl. ¶18). Their function relies on a "flange or retainer" and "substantial surface to surface contact" between the case's inner surface and the phone's outer surface to provide protection (Compl. ¶18). These products are sold online through Defendant's website and at its brick-and-mortar retail stores (Compl. ¶8).
IV. Analysis of Infringement Allegations
’195 Patent Infringement Allegations
| Claim Element (from Independent Claim 9) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 are allegedly molded to conform to the shape of the exterior housing of the mobile phones they are designed to protect. | ¶24a | col. 2:33-37 |
| 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 are alleged to have flanges or retainers that couple the mask to the mobile phone. The annotated photograph on page 13 of the complaint highlights the inner lip of the case as the claimed "flanges." (Compl. p. 13). | ¶24b | col. 2:37-41 |
’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 are alleged to be an integrally-formed body molded to conform and frictionally fit the shape of the phone’s housing. | ¶30a | col. 3:40-44 |
| an inner surface of the integrally-formed mask body... conforming to and in substantially continuous surface-to-surface contact with the exterior shape of the exterior housing, with no substantial space between the inner surface... and the exterior shape... | The inner surface of the Accused Products allegedly conforms to and maintains substantially continuous contact with the phone's exterior. | ¶30b | col. 3:45-52 |
| at least one opening defined by the integrally-formed mask body permitting user access to at least the user input and output interfaces | The Accused Products are alleged to include openings for access to ports, buttons, and other interfaces. | ¶30c | col. 3:53-55 |
| 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 allegedly have at least one retainer that protrudes inward to engage the edge of the phone, retaining the mask. The complaint's close-up photograph of the case's interior edge is presented as evidence of this structure. (Compl. p. 13). | ¶30d | col. 3:56-62 |
Identified Points of Contention
- Scope Questions: A central question for the ’195 Patent will be whether the accused product's continuous, single-piece retaining lip constitutes a plurality of "flanges" as depicted in the patent's figures. For the ’676 Patent, a dispute may arise over whether the fit of the accused cases achieves "substantially continuous surface-to-surface contact" as claimed, or if minor gaps or internal textures negate this limitation.
- Technical Questions: The complaint uses the terms "flange" and "retainer" interchangeably to describe the accused products (Compl. ¶18). The litigation may require a technical distinction between the "flanges" of the ’195 Patent and the "retainer" of the ’676 Patent and an analysis of whether the accused structure meets either or both definitions.
V. Key Claim Terms for Construction
The Term: "flanges" (’195 Patent, Claim 9)
- Context and Importance: The definition of this plural term is critical because the accused products are modern, single-body cases with a continuous retaining lip, whereas the patent figures show discrete, tab-like structures. Practitioners may focus on this term because the infringement allegation for the '195 patent hinges on whether a modern, continuous structure can be read on a claim term illustrated with older, multi-part features.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the function of the flanges as being "retained at the edge of the front phone housing," without explicitly requiring them to be structurally separate from one another (’195 Patent, col. 2:39-40).
- Evidence for a Narrower Interpretation: The patent consistently uses the plural "flanges" and explicitly labels multiple, distinct structures as element 21 in its figures, which could support an interpretation requiring more than one discrete retaining element (’195 Patent, Fig. 3).
The Term: "retainer" (’676 Patent, Claims 1, 5, 8, 9)
- Context and Importance: This term defines the core retaining mechanism in the asserted claims of the later patent. Its construction will be central to determining infringement and differentiating the scope of the ’676 Patent from its parent ’195 Patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 1 requires "at least one retainer," and the specification describes its function as an "extension protruding laterally inward" that is "retained to the exterior housing at an exterior housing edge," which could be read broadly on any portion of the case lip that performs this function (’676 Patent, col. 3:56-62).
- Evidence for a Narrower Interpretation: A defendant may argue that the patentee's choice to use the term "retainer" in this patent, rather than "flanges" as used in the parent '195 patent, implies a deliberate distinction in meaning. The complaint's own interchangeable use of "flange or retainer" (Compl. ¶18) could be used to argue the terms are synonymous, tying the interpretation of "retainer" to the potentially narrower, multi-part depiction of "flanges."
VI. Other Allegations
No willful or indirect infringement is alleged in the complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
- Claim Scope vs. Technology Evolution: A core issue will be whether the term "flanges" in the ’195 Patent, rooted in the context of older, multi-part phone designs, can be construed to cover the continuous, integrally-molded retaining lip of a modern, single-body smartphone case.
- Claim Differentiation and Prosecution History: A key legal question will be one of claim differentiation: did the patentee, by claiming a "retainer" in the later '676 patent, create a distinction from the "flanges" claimed in the parent '195 patent? The court may need to analyze whether these terms describe distinct structures or are functionally synonymous in the context of the invention's evolution.
- Impact of USPTO Reexamination: The most immediate question is procedural: how will the pending ex parte reexaminations at the USPTO affect this litigation (Compl. ¶5)? The outcome of the agency's review could narrow or invalidate the asserted claims, potentially resolving the dispute before the district court addresses the merits.