DCT
1:25-cv-02163
BelAir Electronics Inc v. Target Corp
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: BelAir Electronics, Inc. (Illinois)
- Defendant: Target Corporation (Minnesota)
- Plaintiff’s Counsel: Haller Law PLLC
- Case Identification: 1:25-cv-02163, W.D. Tex., 12/30/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s "heyday" brand protective cases for mobile devices infringe patents related to a "protective mask" designed to prevent abrasion and conform to a phone's exterior housing.
- Technical Context: The technology relates to form-fitting protective cases for smartphones and other mobile electronic devices, a ubiquitous and highly competitive consumer product category.
- Key Procedural History: The complaint discloses that the asserted patents' claims are currently being challenged in ex parte reexamination (EPR) proceedings at the U.S. Patent and Trademark Office. Plaintiff states its intent to seek a stay of this litigation pending the outcome of those reexaminations, a development that could significantly impact the case by potentially narrowing or invalidating the asserted claims before substantive litigation proceeds.
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 |
| 2019-12-30 | Start of Alleged Damages Period |
| 2021-10-23 | Alleged Expiration Date of ’676 Patent |
| 2022-11-16 | Alleged Expiration Date of ’195 Patent |
| 2025-12-30 | 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 describes mobile phones of the era as being "very smooth and delicate," making them susceptible to abrasion and "ill-favored scars" from normal use. It also notes that users spend "a lot of money" to change phones to adhere to fashion trends, resulting in "waste of money" (’195 Patent, col. 1:33-45).
- The Patented Solution: The invention provides a protective mask, comprising an upper and lower cover body, that can be joined to the front and rear housings of a mobile phone (’195 Patent, Abstract). This two-part "mask" is designed to sheathe the phone, preventing scratches while also allowing a user to change the phone's appearance for fashion purposes without replacing the device itself (’195 Patent, col. 2:50-57; Fig. 3).
- Technical Importance: The invention addresses the dual consumer demands for device protection and aesthetic customization in the burgeoning mobile phone market.
Key Claims at a Glance
- The complaint asserts independent Claim 9 (Compl. ¶24).
- Essential elements of Claim 9 include:
- A protective mask adapted to be coupled to an exterior housing of a mobile phone.
- The mask comprises a first mask portion, molded to conform to the shape of a first portion of the exterior housing.
- The first mask portion has flanges to allow it to be coupled to the mobile phone to retain it.
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 family that includes the ’195 Patent, the ’676 Patent addresses the same problem: preventing abrasion on "smooth and delicate" mobile phone housings and avoiding the cost of replacing phones to keep up with fashion trends (’676 Patent, col. 1:32-48).
- The Patented Solution: The solution is a protective mask that frictionally retains the mobile device. The patent describes an "integrally-formed mask body" with an inner surface that conforms to the phone's exterior in "substantially continuous surface-to-surface contact" to provide a tight fit (’676 Patent, col. 4:45-50). Flanges or retainers are used to secure the mask to the edges of the phone's housing (’676 Patent, col. 2:41-47; Fig. 3).
- Technical Importance: This patent refines the concept of a protective cover with specific claim limitations directed at the method of retention (frictional fit) and the close conformity between the case and the device.
Key Claims at a Glance
- The complaint asserts independent Claims 1, 5, 8, and 9 (Compl. ¶30).
- Essential elements of Claim 1 (representative) include:
- A protective mask molded for frictional retention to a mobile phone's exterior housing.
- An integrally-formed mask body molded and contoured to conform and frictionally-fit tightly against the exterior housing.
- An inner surface of the mask body 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 permitting user access to interfaces.
- At least one retainer with an extension "protruding laterally inward" from the mask body to be retained at an exterior housing edge.
- The complaint notes that dependent claims may also be asserted (Compl. ¶¶33, 36, 41).
III. The Accused Instrumentality
Product Identification
The Accused Products are protective cases sold under the "heyday" brand name for a wide range of mobile devices, including numerous generations of Apple iPhones and iPads (Compl. ¶¶7, 18-19). The complaint identifies three representative products: an "Abstract Floral" case for iPhone 12 Pro Max, a "Black Tort" case for iPhone 12 mini, and a "Light Tort" case for iPhone 11/XR (Compl. ¶9).
Functionality and Market Context
The Accused Products are single-piece protective cases designed to be coupled to a mobile device to protect it from damage (Compl. ¶20). They are molded to conform to the shape of the device and include openings for cameras, ports, and buttons. The complaint alleges these cases use a "flange or retainer" to hold the device securely (Compl. ¶20). The images provided show typical modern smartphone cases with a raised lip that wraps around the perimeter of the phone's front screen. An image of the "Abstract Floral" case shows it being sold in retail packaging (Compl. p. 10). The products are sold online at target.com and in Target's physical retail stores (Compl. ¶10).
IV. Analysis of Infringement Allegations
U.S. Patent No. 7,941,195 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 phones. | ¶25 | col. 3:26-31 |
| a first mask portion, molded to conform to the shape of a first portion of the exterior housing of the mobile phone; | The body of the Accused Products is molded to conform to the shape of the mobile phone's exterior housing. | ¶26a | col. 3:32-34 |
| 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 have raised edges or lips that couple to the phone and retain it within the case. This feature is highlighted with red arrows in a provided photograph (Compl. p. 12). | ¶26b | col. 2:39-44 |
U.S. Patent No. 10,097,676 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A protective mask molded for frictional retention to an exterior housing of a mobile phone... | The Accused Products are protective masks designed to frictionally retain a mobile phone. | ¶31 | col. 3:33-35 |
| 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 single-piece cases molded to fit tightly against the phone's exterior. | ¶32a | col. 4:40-43 |
| an inner surface...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 conforms closely to the phone's shape. | ¶32b | col. 4:45-50 |
| 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 have openings for cameras, ports, and buttons. A photograph shows cutouts along the bottom edge of the case (Compl. p. 17). | ¶32c | col. 4:51-54 |
| 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 a raised lip or edge that protrudes inward over the edge of the phone's screen to hold it in place. This is illustrated with annotated photographs (Compl. pp. 15, 18). | ¶32d | col. 4:55-62 |
- Identified Points of Contention:
- Structural Questions: A potential dispute for the ’195 Patent is whether a single-piece phone case (the Accused Product) can meet the "a first mask portion" limitation of Claim 9. The patent specification and other claims consistently describe the invention as a two-part system with a "first mask portion" and a "second mask portion" (’195 Patent, col. 3:42-50), which raises the question of whether Claim 9 can be read to cover a unitary structure.
- Scope Questions: For the ’676 Patent, the analysis may focus on the scope of "at least one retainer." The complaint alleges this is met by the continuous raised lip of the accused cases. The question for the court will be whether this structure meets the claim limitation, particularly when read in light of the patent's figures, which depict more distinct, hook-like "flanges (21)" (’676 Patent, Fig. 3, 5).
V. Key Claim Terms for Construction
Term 1 (’195 Patent, Claim 9): "a first mask portion"
- Context and Importance: The construction of this term is critical because the Accused Products are single-piece cases, whereas the ’195 Patent's disclosure heavily emphasizes a two-part mask. Whether a single-piece product can infringe Claim 9, which only recites the "first" portion, will be a central issue.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that because Claim 9, unlike Claim 1, does not explicitly recite a "second mask portion," it is not limited to a two-part structure and should cover any mask that performs the claimed function of the first portion.
- Evidence for a Narrower Interpretation: Defendant may argue that the term "first" inherently implies a "second," and that the specification, which exclusively describes a two-part embodiment (’195 Patent, col. 2:31-33), limits the scope of all claims. The consistent use of "upper cover body 20" and "lower cover body 30" throughout the detailed description may be used to argue that "a first mask portion" cannot be read in isolation.
Term 2 (’676 Patent, Claim 1): "at least one retainer"
- Context and Importance: The infringement allegation hinges on whether the continuous raised lip on the accused heyday cases constitutes a "retainer." Practitioners may focus on this term because it defines the core mechanism for securing the phone within the mask.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses the general term "retainer," and the functional language "protruding laterally inward...retained to the exterior housing at an exterior housing edge" could be argued to describe the function of the lip on the accused cases (’676 Patent, col. 4:55-62).
- Evidence for a Narrower Interpretation: The specification repeatedly refers to "flanges 21" when describing the retaining mechanism (’676 Patent, col. 2:41-47). The figures appear to show these flanges as discrete, hook-like structures rather than a continuous, uniform lip (’676 Patent, Fig. 3, 5). This could support an argument that "retainer" is limited to the specific structures disclosed.
VI. Other Allegations
The complaint does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This case presents several focused questions of claim interpretation and procedure. The key issues for the court will likely be:
- A core issue will be one of structural scope: Does Claim 9 of the ’195 Patent, reciting only "a first mask portion," read on the accused single-piece phone cases, or is its scope limited by the patent's consistent disclosure of a two-part protective system?
- A second core issue will be one of definitional scope: Can the term "retainer" in the ’676 Patent be construed broadly to cover the continuous, uniform lip common on modern phone cases, or does the patent's specification and figures limit the term to the more specific "flange" structures depicted?
- A determinative procedural question is the impact of the ongoing ex parte reexaminations: How will the USPTO's review of the asserted claims affect this litigation? The potential for a stay, combined with the possibility of claim amendment or cancellation, introduces significant uncertainty and may resolve the dispute before extensive district court proceedings occur.