DCT
1:25-cv-02065
BelAir Electronics Inc v. AT&T Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: AT&T Inc. and AT&T Services, Inc. (Delaware)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-02065, W.D. Tex., 12/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants reside in the district, have committed acts of infringement there, and maintain a regular and established place of business, including numerous brick and mortar retail stores.
- Core Dispute: Plaintiff alleges that Defendant’s "Carson & Quinn" brand protective mobile device cases infringe three patents related to the design and structure of such protective masks.
- Technical Context: The technology concerns protective and customizable casings for mobile phones, a commercially significant segment of the consumer electronics accessory market.
- Key Procedural History: The complaint notes that the asserted patents are expired, and this action seeks only past damages. It also discloses that the patents are currently being challenged in ex parte reexamination proceedings at the U.S. Patent and Trademark Office by a third party, and that Plaintiff intends to seek a stay of this litigation pending the outcome of those proceedings.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Earliest Priority Date for Asserted Patents ('291, '195, '676) |
| 2007-03-20 | U.S. Patent No. 7,194,291 Issues |
| 2011-05-10 | U.S. Patent No. 7,941,195 Issues |
| 2018-10-09 | U.S. Patent No. 10,097,676 Issues |
| 2020-02-11 | Earliest evidence of Accused Product cited via web archive |
| 2021-10-23 | Approximate Expiration Date of '676 Patent |
| 2022-11-16 | Approximate Expiration Date of '291 and '195 Patents |
| 2025-12-17 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,194,291 - *“Protective Mask of Mobile Phone”*
Issued March 20, 2007 (the “’291 Patent”).
The Invention Explained
- Problem Addressed: The patent’s background section states that early mobile phones were "very smooth and delicate," making them susceptible to "abrasion... due to carelessness of a user." This could generate "ill-favored scars," deteriorating the phone's quality and value. Additionally, it notes that users often spend "a lot of money to change the mobile phone... to adhere to the fashion," resulting in waste. (’291 Patent, col. 1:22-33).
- The Patented Solution: The invention is a protective mask, comprised of an "upper cover body" and a "lower cover body," which are molded to sheathe the front and rear housings of a mobile phone. (’291 Patent, col. 2:23-26). The mask bodies are held in place by features such as flanges that retain the mask at the edge of the phone's housing, protecting the phone from scratches while also allowing its appearance to be easily and inexpensively changed. (’291 Patent, col. 2:30-35).
- Technical Importance: The technology provided a non-permanent method for both protecting and customizing the appearance of mobile devices at a time when such devices were becoming mainstream consumer products. (’291 Patent, col. 1:40-50).
Key Claims at a Glance
- The complaint asserts independent Claims 1, 6, and 9. (Compl. ¶26).
- Independent Claim 1: A protective mask comprising:
- a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone;
- the first mask portion having flanges to couple the first mask portion to the exterior housing to retain it;
- a second mask portion, molded to conform to the shape of a second portion of the exterior housing; and
- the second mask portion adapted to be coupled to the mobile phone to retain it.
- Independent Claim 6: A protective mask similar to Claim 1, which further requires the first mask portion to include "an opening that is associated with an opening in the exterior housing to permit access to a feature of the mobile phone."
- Independent Claim 9: A protective mask similar to Claim 6, which further requires the second mask portion to also include "an opening that is associated with an opening in the exterior housing to permit access to a feature of the mobile phone."
- The complaint reserves the right to assert dependent Claims 2, 3, 4, 5, 7, 8, and 10. (Compl. ¶29, ¶32, ¶35).
U.S. Patent No. 7,941,195 - *“Protective Mask of Mobile Phone”*
Issued May 10, 2011 (the “’195 Patent”).
The Invention Explained
- Problem Addressed: As a continuation of the application leading to the ’291 Patent, the ’195 Patent addresses the same problems of protecting mobile phones from abrasion and enabling cosmetic customization without replacing the device itself. (’195 Patent, col. 1:29-41).
- The Patented Solution: The invention is a protective mask for a mobile phone. While some claims describe a two-part structure similar to the parent ’291 Patent, other claims are directed to a single mask portion with "flanges to allow the first mask portion to be coupled to the mobile phone." (’195 Patent, Abstract; col. 4:34-37). This allows for protection of the phone's exterior housing via a form-fitting case. (’195 Patent, col. 2:32-41).
- Technical Importance: This patent family covers fundamental concepts of form-fitting protective cases that provide both physical protection and aesthetic customizability for mobile devices. (’195 Patent, col. 1:49-56).
Key Claims at a Glance
- The complaint asserts independent Claims 1, 6, and 9. (Compl. ¶39).
- Independent Claim 1: A protective mask comprising a "first mask portion" and a "second mask portion," each molded to conform to a portion of the phone's exterior housing and adapted to be coupled to the phone for retention.
- Independent Claim 6: A protective mask similar to Claim 1, which further requires the first mask portion to include an opening to permit access to a feature of the mobile phone.
- Independent Claim 9: A protective mask adapted to be coupled to a mobile phone, comprising a "first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone," where the first mask portion has "flanges to allow the first mask portion to be coupled to the mobile phone to retain" it.
- The complaint reserves the right to assert dependent Claims 2-5, 7-8, and 10-12. (Compl. ¶42, ¶45, ¶48).
U.S. Patent No. 10,097,676 - *“Protective Mask of Mobile Phone”*
Issued October 9, 2018 (the “’676 Patent”).
- Technology Synopsis: This patent, from the same family, describes a protective mask for a mobile phone focused on frictional retention. The invention is an "integrally-formed mask body" with an inner surface designed for "substantially continuous surface-to-surface contact" with the phone's housing, and "at least one retainer" that protrudes inwardly to secure the mask to an edge of the housing. (’676 Patent, Abstract; col. 3:32-62).
- Asserted Claims: Independent Claims 1, 5, 8, and 9. (Compl. ¶52).
- Accused Features: The complaint alleges that all Accused Products are single-piece, integrally-formed masks that frictionally fit a phone, featuring an inner surface in continuous contact with the phone and an inwardly protruding lip around the perimeter that acts as the claimed "retainer" to hold the case on the device. (Compl. ¶54).
III. The Accused Instrumentality
Product Identification
Protective masks for mobile devices sold under the "Carson & Quinn" and "CQ X Carson & Quinn” brand names (the "Accused Products"). (Compl. ¶8, ¶19). The complaint identifies a subset of these as "Two Portion Accused Products." (Compl. ¶21).
Functionality and Market Context
The Accused Products are cases designed to be coupled to a mobile device to protect it. (Compl. ¶22). They are molded to conform to the exterior shape of specific phone models and feature openings to allow user access to device inputs and outputs. (Compl. ¶22, ¶54.c). The complaint alleges these products are sold online and at Defendant's numerous brick and mortar retail stores across the United States. (Compl. ¶9, ¶11). A screenshot from Defendant's website shows a map with 15 store locations identified near Austin, TX. (Compl. p. 3). The complaint includes several photographs of a representative Accused Product, identified as a "Carson & Quinn Leather Case - iPhone 11," which appears to be a single-piece, snap-on style case. (Compl. ¶10, pp. 14-18).
IV. Analysis of Infringement Allegations
’291 Patent Infringement Allegations
The following allegations are asserted against the "Two Portion Accused Products." (Compl. ¶27).
| Claim Element (from Independent Claim 1) | 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 two-portion products allegedly include a first portion molded to conform to the shape of a first part of the phone's housing. | ¶28.a | col. 3:25-27 |
| the first mask portion having flanges to couple the first mask portion to the exterior housing of the mobile phone to retain the first mask portion to the first portion of the exterior housing... | This first portion allegedly has flanges that couple it to the phone's housing for retention. | ¶28.a | col. 3:27-31 |
| a second mask portion, molded to conform to the shape of a second portion of the exterior housing of the mobile phone, the second mask portion adapted to be coupled to the mobile phone to retain the second mask portion... | The accused two-portion products allegedly include a second portion molded to conform to the shape of a second part of the phone's housing and is adapted to be coupled to the phone for retention. | ¶28.b | col. 3:33-38 |
| wherein said first and second mask portions are retained to the exterior housing of the mobile phone. | The first and second portions are allegedly retained to the exterior of the phone. | ¶28.c | col. 3:40-41 |
Identified Points of Contention
- Factual Question: The primary question is evidentiary: what proof exists that Defendants sell "Two Portion Accused Products"? The complaint provides no visual evidence of such products, instead showing only single-piece cases, and asserts infringement by two-portion cases "upon information and belief." (Compl. ¶21-22, pp. 14-18).
- Scope Questions: If two-portion products are identified, a potential dispute may arise over whether their coupling mechanism constitutes "flanges" as understood in the context of the patent specification, which illustrates them as discrete, hook-like structures. (’291 Patent, Fig. 3).
’195 Patent Infringement Allegations
The following allegations are for Claim 9, asserted against all Accused Products, including the single-piece cases depicted in the complaint. (Compl. ¶46).
| 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 single-piece Accused Product is alleged to be the "first mask portion," and it is molded to conform to the shape of the phone’s exterior. | ¶47.a | col. 4:34-36 |
| 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... | The inwardly-projecting lip that wraps around the perimeter of the phone is alleged to be the "flanges" that couple and retain the case. A complaint photo with annotations points to these structures. (Compl. p. 17). | ¶47.b | col. 4:36-39 |
| so that the first mask portion covers the first portion of the exterior housing of the mobile phone. | The Accused Product allegedly covers the exterior housing of the phone. | ¶47.b | col. 4:39-41 |
Identified Points of Contention
- Scope Questions: A central dispute will likely be whether a single-piece phone case can satisfy the "first mask portion" limitation. The patent specification consistently frames the invention as a two-part system, raising the question of whether a claim to a "first" portion implies the existence of a second.
- Technical Questions: The infringement theory hinges on interpreting the continuous lip of the Accused Product as the claimed "flanges." The construction of "flanges" will be critical, specifically whether it can read on a continuous, integrally-molded lip or is limited to the discrete, separate structures shown in the patent's figures. (’195 Patent, Fig. 3).
V. Key Claim Terms for Construction
The Term: "first mask portion"
(asserted in '291 Claim 1 and '195 Claim 9)
- Context and Importance: This term's construction is central to the viability of the allegations against the single-piece Accused Products shown in the complaint. Plaintiff's case requires this term to read on a standalone, single-piece case, while a defendant would likely argue the term inherently implies the presence or requirement of a "second mask portion."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of Claim 9 of the ’195 Patent recites only "a first mask portion" and does not explicitly require a second portion, potentially supporting an argument that it can cover a single-component product. (Compl. ¶47; ’195 Patent, col. 4:32-41).
- Evidence for a Narrower Interpretation: The shared specification for the patents consistently describes the invention as comprising an "upper cover body 20 and a lower cover body 30." (’291 Patent, col. 2:23-24). All figures depict a two-part assembly, which may support an interpretation that a "first mask portion" is necessarily one part of a multi-part system. (’291 Patent, Figs. 3, 7).
The Term: "flanges"
(asserted in '291 Claim 1 and '195 Claim 9)
- Context and Importance: Plaintiff identifies the inwardly-projecting lip of the accused cases as the claimed "flanges." (Compl. ¶22, ¶47.b). The case may turn on whether this continuous structure is technically and legally equivalent to the "flanges" disclosed in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition for "flanges." The claim language describes their function: "to couple the first mask portion to the exterior housing... to retain" it. (’291 Patent, col. 3:27-30). An argument could be made that any structure performing this coupling and retaining function meets the limitation.
- Evidence for a Narrower Interpretation: The specification describes "a plurality of flanges 21" and Figure 3 depicts these flanges (21) as several discrete, tab-like structures extending from the mask body. (’291 Patent, col. 2:30-32; Fig. 3). This may support a narrower construction that excludes a single, continuous, integrally-molded lip.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain specific counts or factual allegations supporting claims for indirect infringement (induced or contributory).
- Willful Infringement: The complaint does not allege willful infringement or plead facts related to pre-suit knowledge of the patents by the Defendants.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "first mask portion," which arises from a patent specification focused on two-part protective systems, be construed to read on the modern, single-piece phone cases that constitute the primary Accused Products? The viability of several infringement counts depends on this interpretation.
- A second central issue will be one of structural interpretation: does the continuous, inwardly-projecting lip of a modern snap-on phone case constitute the "flanges" or "retainer" as described and depicted in the patents-in-suit, or is there a fundamental structural difference that places the accused design outside the claims' scope?
- A key evidentiary question will be whether Plaintiff can produce evidence that Defendants market or sell "Two Portion" phone cases. The infringement allegations for the entirety of the ’291 Patent and two of the three asserted claims of the ’195 Patent are explicitly limited to such products, for which no direct evidence is provided in the complaint.