DCT
1:25-cv-02044
BelAir Electronics Inc v. Amazon.com Services LLC
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Amazon.com Services LLC (Delaware / Washington)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-02044, W.D. Tex., 12/12/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains a regular and established place of business in the district, including numerous offices, fulfillment centers, and delivery stations, and has committed acts of infringement there.
- Core Dispute: Plaintiff alleges that Defendant’s "Amazon Basics" brand of protective cases for mobile devices infringes patents related to the structure of protective masks for mobile phones.
- Technical Context: The patents relate to form-fitting protective covers, or "masks," designed to prevent scratches and other damage to mobile phones while allowing for stylistic customization.
- Key Procedural History: The complaint notes that the asserted patents are currently subject to ex parte reexamination (EPR) proceedings at the USPTO, initiated by a third party. Plaintiff states its intention to seek a stay of the litigation pending the outcome of these reexaminations.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Priority Date for ’195 and ’676 Patents |
| 2011-05-10 | ’195 Patent Issued |
| 2018-10-09 | ’676 Patent Issued |
| 2021-04-09 | "Date First Available" for Accused iPhone 12 mini Case |
| 2021-12-13 | "Date First Available" for Accused Samsung Galaxy S21 Case |
| 2025-12-12 | Complaint Filed |
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 two problems with mobile phones of the era: their "smooth and delicate" housings are susceptible to "ill-favored scars" from abrasion, and users who wish to follow fashion trends must spend significant money to replace the entire device (’195 Patent, col. 1:36-47).
- The Patented Solution: The invention is a two-part protective mask, comprising a "first mask portion" and a "second mask portion," which are molded to conform to the front and rear housings of a mobile phone (’195 Patent, col. 3:27-46). The mask portions attach to the phone using "flanges" that grip the edges of the phone's housing, thereby sheathing the device to prevent scratches and allowing for easy stylistic changes without replacing the phone itself (’195 Patent, col. 2:38-41, Fig. 3).
- Technical Importance: The invention provided a method for both protecting a mobile device and customizing its appearance in a non-permanent way, addressing consumer desires for personalization and device preservation (’195 Patent, col. 2:51-57).
Key Claims at a Glance
- The complaint asserts independent Claim 9 (Compl. ¶24).
- The essential elements of Claim 9 are:
- A protective mask adapted to be coupled to a mobile phone's exterior housing.
- 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 the mobile phone and retain it, so that it covers the first portion of the housing.
U.S. Patent No. 10,097,676 - *"Protective Mask of Mobile Phone,"* issued October 9, 2018
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’195 Patent, the ’676 Patent addresses the same problems of preventing abrasion on "smooth and delicate" mobile phones and the high cost associated with changing phones to adhere to fashion trends (’676 Patent, col. 1:33-48).
- The Patented Solution: This patent describes a protective mask as a single "integrally-formed mask body" that is molded to "conform and frictionally-fit tightly against the exterior shape of the exterior housing" (’676 Patent, col. 3:41-44). Retention is achieved by "at least one retainer having an extension protruding laterally inward from the integrally-formed mask body," which engages an edge of the phone’s housing when the mask is coupled to the device (’676 Patent, col. 3:55-62).
- Technical Importance: This design reflects a move toward single-piece protective cases that rely on a combination of friction and mechanical engagement from an overlapping edge for retention and protection (’676 Patent, Abstract).
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9 (Compl. ¶30).
- The essential elements of Claim 1 are:
- An "integrally-formed mask body" molded to conform and "frictionally-fit tightly" against the phone's exterior housing.
- An inner surface of the mask body that is in "substantially continuous surface-to-surface contact with the exterior shape of the exterior housing, with no substantial space between" them.
- At least one opening in the mask body to permit user access to interfaces.
- "At least one retainer having an extension protruding laterally inward" from the mask body to participate in retaining the mask to the device.
- The complaint states that accused products also likely infringe dependent claims (Compl. ¶33, 36, 41).
III. The Accused Instrumentality
Product Identification
- The "Accused Products" are "Amazon Basics" branded protective cases for mobile devices, including smartphones and tablets (Compl. ¶16-17). Specific examples identified are the "Amazon Basics Hybrid Series Case for Samsung Galaxy S21" and the "Amazon Basics Shockproof and Protective Case For iPhone 12 mini" (Compl. ¶8).
Functionality and Market Context
- The complaint describes the accused cases as having a hybrid construction of "shock-resistant TPU bumpers with a hard PC back" (Compl. p. 17). They are marketed as providing protection against drops and scratches, with features like "raised bezels" to lift the screen and camera off surfaces and a "snug, precise fit" with cutouts for buttons and ports (Compl. pp. 17, 22). The complaint provides an annotated photograph showing an inward-protruding edge on an accused case, which is alleged to serve as a retainer (Compl. p. 20).
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 protective masks molded to conform to the exterior shape of the specific mobile phones they are designed for. | ¶26a | col. 2:35-38 |
| 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 allegedly possess a flange or retainer, identified as the lip or edge of the case that wraps around the phone to hold it in place. | ¶26b, 20 | col. 2:38-45 |
| ...so that the first mask portion covers the first portion of the exterior housing of the mobile phone. | When installed, the Accused Products cover the back and sides of the mobile phone. | ¶26b | col. 2:42-45 |
’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 described as single-piece cases with a "snug, precise fit" made of materials like TPU and polycarbonate, allegedly creating a tight, frictional fit. | ¶32a, p. 22 | col. 3:41-44 |
| an inner surface of the integrally-formed mask body ... in substantially continuous surface-to-surface contact with the exterior shape of the exterior housing... | The inner surface of the Accused Products is alleged to conform to and be in continuous contact with the phone's housing. | ¶32b | col. 3:45-51 |
| 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 Accused Products have "precision cutouts for access to all buttons and ports." An image of an accused case shows such openings (Compl. p. 17). | ¶32c, p. 17 | col. 3:52-54 |
| at least one retainer having an extension protruding laterally inward from the integrally-formed mask body ... participating in retaining the integrally-formed mask body... | The complaint alleges that the raised bumper edge that wraps around the front of the phone constitutes the claimed retainer. An annotated image highlights this feature (Compl. p. 25). | ¶32d, p. 25 | col. 3:55-62 |
- Identified Points of Contention:
- Scope Questions: A central dispute may arise over whether the terms "flanges" (in the ’195 Patent) and "retainer" (in the ’676 Patent) can be construed to read on the continuous, integrally-molded bumper lip of a modern smartphone case. The patents’ figures depict these features on older, multi-part flip phones, raising the question of whether the claim scope extends to the accused single-body case designs.
- Technical Questions: The infringement allegation for the ’676 Patent hinges on the case achieving a "frictionally-fit tightly" retention with "substantially continuous surface-to-surface contact." A potential point of contention is whether the primary retention mechanism of the accused cases is friction along the back surface, as the claim language suggests, or mechanical interference from the inwardly protruding lip (the alleged "retainer") engaging the front edge of the phone.
V. Key Claim Terms for Construction
The Term: "flanges" (’195 Patent, Claim 9)
Context and Importance: This term is the sole retention mechanism recited in the asserted claim of the ’195 Patent. Its construction will determine whether the continuous lip of the Accused Products can meet this limitation. Practitioners may focus on whether "flanges" requires discrete, separate structures or can describe a single, continuous one.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim requires flanges "to allow the first mask portion to be coupled to the mobile phone to retain" it. An argument could be made that any structure performing this function, including a continuous lip, meets the functional requirement of the claim.
- Evidence for a Narrower Interpretation: The specification consistently refers to "a plurality of flanges 21" and depicts them as discrete, tab-like structures in Figure 3 (’195 Patent, col. 2:38-39, Fig. 3). The use of the plural form "flanges" in the claim may suggest that more than one distinct structure is required.
The Term: "at least one retainer having an extension protruding laterally inward" (’676 Patent, Claim 1)
Context and Importance: This is the key retention element in the asserted claims of the ’676 Patent. The outcome of the case may depend on whether the entire bumper edge of the accused cases qualifies as a "retainer."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language is broad, requiring only "at least one retainer" that protrudes inward and helps retain the mask. The integrally molded lip of the accused cases functionally meets this description.
- Evidence for a Narrower Interpretation: The patent provides no explicit definition of "retainer" distinct from the claim language itself. A defendant may argue that in the context of the patent family (including the "flanges" of the parent ’195 Patent), a "retainer" implies a more specific structure than a uniform, continuous bumper edge that is inherent to the basic form of the case.
VI. Other Allegations
The complaint does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the terms "flanges" and "retainer," which are described in a patent family rooted in the technology of early 2000s multi-part phones, be construed to cover the integrated, continuous bumper lips that are a standard feature of modern, single-body smartphone cases?
- A second key issue will be a question of technical function: does the retention of the accused cases rely primarily on the "frictionally-fit" and "surface-to-surface contact" required by claims of the ’676 Patent, or is retention achieved predominantly through the mechanical engagement of the lip over the edge of the phone's screen, potentially creating a mismatch with the claim language?
- Finally, the procedural posture is significant: the plaintiff's stated intent to seek a stay pending the outcome of USPTO ex parte reexaminations suggests that the scope and validity of the patent claims are already under scrutiny, and the outcome of those proceedings could be dispositive of this litigation.