DCT
1:25-cv-02076
BelAir Electronics Inc v. Walmart Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Walmart Inc. (Delaware)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-02076, W.D. Tex., 12/18/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains numerous brick and mortar retail stores, including at least seven near Austin, and has a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s "onn" brand protective cases for mobile devices infringe three U.S. patents related to protective masks for mobile phones.
- Technical Context: The technology at issue involves protective cases designed to prevent damage to and allow for customization of a mobile electronic devices, a mature and high-volume consumer product category.
- Key Procedural History: The complaint discloses that the asserted patents are currently undergoing ex parte reexamination (EPR) 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 the EPRs, a procedural move that acknowledges the reexaminations could result in the invalidation or narrowing of the asserted patent claims. All asserted patents are expired, limiting potential remedies to past damages.
Case Timeline
| Date | Event |
|---|---|
| 2000-11-17 | Earliest Priority Date for ’291, ’195, and ’676 Patents |
| 2007-03-20 | ’291 Patent Issued |
| 2011-05-10 | ’195 Patent Issued |
| 2018-10-09 | ’676 Patent Issued |
| 2019-12-18 | Alleged Damages Period Begins |
| 2021-10-23 | ’676 Patent Expired (approximate date per complaint) |
| 2022-11-16 | ’291 and ’195 Patents Expired (approximate date per complaint) |
| 2025-12-18 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,194,291 - *"Protective Mask of Mobile Phone"*
- Patent Identification: U.S. Patent No. 7,194,291, "Protective Mask of Mobile Phone," issued March 20, 2007.
The Invention Explained
- Problem Addressed: The patent’s background section notes that mobile phones of the era were "very smooth and delicate," making them susceptible to abrasion and "ill-favored scars" from normal use, which deteriorated their quality and value. It also identifies the high cost for consumers wishing to change their phone's appearance to "adhere to the fashion" (’291 Patent, col. 1:22-33).
- The Patented Solution: The invention is a protective "mask" composed of an upper and lower cover body that can be joined with the front and rear housings of a mobile phone, respectively (’291 Patent, Abstract). The mask is retained on the phone using "a plurality of flanges" that engage the edge of the phone's housing, sheathing the device to prevent abrasion and allowing its appearance to be easily and inexpensively changed (’291 Patent, col. 2:25-40; Fig. 3).
- Technical Importance: The invention provided a method for both protecting and customizing early-generation mobile devices, addressing practical concerns of durability and aesthetic personalization in a burgeoning consumer market.
Key Claims at a Glance
- The complaint asserts independent claims 1, 6, and 9 (’291 Patent, col. 3:21-4:59; Compl. ¶25).
- Independent Claim 1, asserted against "Two Portion Accused Products," includes these essential elements:
- A protective mask adapted to be coupled to a mobile phone's exterior housing.
- A first mask portion, molded to conform to a first portion of the housing, having flanges to couple and retain the first mask portion to that housing portion.
- A second mask portion, molded to conform to a second portion of the housing, adapted to be coupled and retained to that housing portion.
- Wherein the first and second mask portions are retained to the exterior housing.
- The complaint also notes the potential infringement of dependent claims 2, 3, 4, and 5 (Compl. ¶28).
U.S. Patent No. 7,941,195 - *"Protective Mask of Mobile Phone"*
- Patent Identification: U.S. Patent No. 7,941,195, "Protective Mask of Mobile Phone," issued May 10, 2011.
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 delicate mobile phones from abrasion and enabling cost-effective customization (’195 Patent, col. 1:23-37).
- The Patented Solution: The solution is again a protective mask that sheathes the phone. While the specification also describes a two-part embodiment, the asserted claims are directed more broadly. For example, Claim 9 describes a single mask portion with flanges that allow it to be coupled to the phone's housing, which covers the structure of a one-piece, snap-on style case (’195 Patent, col. 4:32-41).
- Technical Importance: This patent continues the same line of invention as the ’291 Patent, with claims that may be construed to cover single-piece protective cases in addition to multi-piece designs.
Key Claims at a Glance
- The complaint asserts independent claims 1, 6, and 9 (’195 Patent, col. 3:26-4:41; Compl. ¶38).
- Independent Claim 9, asserted against "All Accused Products," includes these essential elements:
- A protective mask adapted to be coupled to a mobile phone's exterior housing.
- A first mask portion, molded to conform to a first portion of the housing.
- The first mask portion having 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 10, 11, and 12 (Compl. ¶47).
U.S. Patent No. 10,097,676 - *"Protective Mask of Mobile Phone"*
- Patent Identification: U.S. Patent No. 10,097,676, "Protective Mask of Mobile Phone," issued October 9, 2018.
- Technology Synopsis: This patent, from the same family, describes a protective mask for "frictional retention" to a mobile phone housing (’676 Patent, col. 3:32). Instead of "flanges," the claims recite "at least one retainer having an extension protruding laterally inward" that engages an edge of the housing to hold the mask in place (’676 Patent, col. 4:55-62). This appears to be an evolution of the original concept using different terminology.
- Asserted Claims: Independent Claims 1, 5, 8, and 9 (Compl. ¶51).
- Accused Features: The complaint alleges that "All Accused Products" infringe by having an "integrally-formed mask body" with at least one "retainer" that protrudes inward to retain the mask on the mobile device (Compl. ¶¶52, 53).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are "onn" brand protective masks (i.e., cases) for mobile devices sold by Defendant Walmart (Compl. ¶¶ 7, 17). The complaint identifies a broad range of "Case Styles," including Clear, Rugged, Dual Layer, and Silicone, designed for numerous devices from manufacturers like Apple and Samsung (Compl. ¶¶ 18-19).
Functionality and Market Context
The products function as protective covers for mobile phones. The complaint distinguishes between "All Accused Products" (infringing the ’195 and ’676 Patents) and a subset of "Two Portion Accused Products" (also infringing the ’291 Patent) (Compl. ¶20). An exemplary two-portion product identified is the "onn. Slim Rugged Phone Case Samsung Galaxy A03s - Red," which consists of a flexible inner liner and a rigid outer shell (Compl. ¶9; p. 14). An exemplary single-portion product is the "onn. Phone Case for iPhone 11 / iPhone XR - Iridescent Illusion" (Compl. ¶9; p. 11). The complaint alleges these products are advertised and sold online via walmart.com and in Defendant's brick-and-mortar stores (Compl. ¶10).
IV. Analysis of Infringement Allegations
’291 Patent Infringement Allegations
| 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 "Two Portion Accused Products" are alleged to have a first piece, such as the inner flexible portion of the "Slim Rugged" case. | ¶27(a) | col. 2:25-28 |
| the first mask portion having flanges to couple the first mask portion to the exterior housing... to retain the first mask portion... | The inner portion of the two-piece case is alleged to have flanges, identified in annotated photographs as inwardly projecting lips that grip the phone. An image with red arrows highlights these alleged "flanges" on the inner piece of a two-part case (Compl. p. 15). | ¶27(a) | col. 2:30-34 |
| a second mask portion, molded to conform to the shape of a second portion of the exterior housing... | The "Two Portion Accused Products" are alleged to have a second piece, such as the outer hard-shell portion of the "Slim Rugged" case. | ¶27(b) | col. 2:25-28 |
| ...adapted to be coupled to the mobile phone to retain the second mask portion... | The second piece is alleged to couple to the phone to retain itself to the housing. | ¶27(b) | col. 2:35-37 |
- Identified Points of Contention:
- Scope Questions: The primary dispute may center on the meaning of "flanges." The patent specification illustrates "flanges" as discrete, spaced-apart tabs (’291 Patent, Fig. 3, element 21). The complaint's visual evidence points to continuous lips or edges on the accused products (Compl. pp. 15-16). A key question will be whether the term "flanges" can be construed broadly enough to read on the continuous retaining structures of the accused cases.
- Technical Questions: For the two-portion cases, a factual question is whether both the first and second portions are independently "retained to the exterior housing of the mobile phone" as required by the claim, or if the second portion is primarily retained by coupling to the first portion rather than directly to the phone's housing.
’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... | "All Accused Products," including single-piece cases, are alleged to be a first mask portion molded to conform to the phone's shape. | ¶46(a) | col. 4:35-37 |
| 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... | The cases are alleged to have flanges that couple the mask to the phone. The complaint provides an annotated photograph of a single-piece case where red arrows indicate that the inwardly-curved perimeter of the case functions as the claimed "flanges" (Compl. p. 13). | ¶46(b) | col. 4:38-41 |
- Identified Points of Contention:
- Scope Questions: As with the ’291 Patent, the construction of "flanges" will be dispositive. The question is whether the patent’s disclosure of discrete tabs limits the claim scope, or if the term can cover the integrally formed, continuous retaining edge of a modern snap-on phone case.
- Technical Questions: Does the "frictional fit" of a modern phone case, achieved by a continuous, slightly undersized perimeter, constitute the "coupling" and "retaining" function of the claimed "flanges," or does it represent a different technical mechanism for retention?
V. Key Claim Terms for Construction
’291 and ’195 Patents
- The Term: "flanges"
- Context and Importance: This term is the central structural element for retention in the asserted claims of the first two patents. The entire infringement analysis for these patents may depend on whether the inwardly-projecting lips of the accused cases fall within the legal definition of "flanges" as used in the patents. Practitioners may focus on this term because the patent figures depict a specific structure (discrete tabs) while the accused products employ a more common, modern alternative (a continuous lip).
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims themselves do not specify the shape, quantity, or continuous nature of the "flanges," simply requiring that they function "to couple" and "to retain" the mask portion to the housing (’291 Patent, col. 3:29-32). Plaintiff may argue that any structure performing this function is a flange.
- Evidence for a Narrower Interpretation: The detailed description repeatedly refers to "a plurality of flanges 21," and the only embodiment shown in the figures depicts these as distinct, spaced-apart tabs (’291 Patent, col. 2:30-34, Fig. 3). Defendant may argue this disclosure limits the term "flanges" to such discrete structures, implicitly disclaiming a continuous retaining lip.
VI. Other Allegations
The complaint does not provide sufficient detail for analysis of indirect or willful infringement. Each count alleges only "direct infringement" (Compl. ¶¶ 25, 38, 51).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "flanges," disclosed in the patent specifications as discrete tabs, be construed to cover the continuous, inwardly-curved retaining lip common to the accused modern phone cases? The same question applies to the term "retainer" in the ’676 patent.
- A critical procedural question is the impact of the parallel USPTO reexaminations: Given Plaintiff's stated intent to seek a stay, the outcome of the EPRs—which could result in the narrowing or cancellation of the asserted claims—will likely dictate whether this case proceeds in its current form, if at all.
- For the two-piece accused products, a key factual question will be one of technical operation: Does the outer shell of the accused two-part cases function as a "second mask portion" that is independently "retained to the exterior housing of the mobile phone" as claimed in the ’291 Patent, or is it primarily retained by its connection to the inner liner, potentially avoiding infringement?