Pineapple34 LLC v. Lenovo Group Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Pineapple34, LLC (Texas)
  • Defendant: Lenovo Group Limited (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 6:21-cv-01174, W.D. Tex., 12/15/2021
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s computer products infringe a patent related to modular user interface systems for portable computers.
• Technical Context: The technology concerns the integration of auxiliary input modules, such as numeric keypads, onto the platform of a portable computer to enhance functionality.
• Key Procedural History: The complaint is a First Amended Complaint. The patent-in-suit is a continuation-in-part of a prior application, which may be relevant for determining the effective filing date of the asserted claims.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 7,068,499 - "Modular computer user interface system," issued June 27, 2006

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem with portable "lap top" computers, where, in an effort to save space, features like a dedicated numeric keypad are often removed or consolidated with other keys, making tasks like numerical calculation "inconvenient and time consuming" (U.S. Patent No. 7,068,499, col. 1:36-50).
• The Patented Solution: The invention proposes a modular system where at least one "auxiliary module" (e.g., a numeric keypad) is secured to the computer's platform, such as the palm rest, in a "segregated relation" to the main keyboard ('499 Patent, col. 3:1-9; Abstract). This module connects to the computer's processor via an "interface assembly," allowing it to operate independently of the conventional keyboard ('499 Patent, col. 3:42-54). The specification describes various embodiments, including modules that are permanently fixed, removably seated in a recessed base, or detached as part of a peripheral assembly ('499 Patent, Fig. 1-3).
• Technical Importance: The described technology sought to provide users of portable computers with the "substantial functionality of a traditional desk top computer," particularly its keyboard capabilities, without defeating the advantages of a compact design ('499 Patent, col. 2:63-65).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims" and refers to "Exemplary '499 Patent Claims" without specifying them (Compl. ¶11). Independent claim 1 is a representative system claim.
• Independent Claim 1 recites a system comprising:
  • a processor;
  • a platform with a keyboard mounted on it, where the processor is electrically connected to the keyboard;
  • at least one auxiliary module secured to the platform in "segregated relation" to the keyboard;
  • an interface assembly to operatively interconnect the auxiliary module and the processor, which itself includes:
    • a "first adaptor structure" on the platform that helps define the operative interconnection; and
    • a "second adaptor structure" on the auxiliary module that is "communicatively associated" with the first adaptor structure.
• The complaint’s use of general phrasing ("one or more claims") suggests it reserves the right to assert additional independent or dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11). Specific product names or models are not listed in the body of the complaint but are said to be identified in an incorporated exhibit (Compl. ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality. It makes the conclusory allegation that the products "practice the technology claimed by the '499 Patent" by reference to an external exhibit not provided with the complaint (Compl. ¶13). No allegations regarding the products' commercial importance are made.

IV. Analysis of Infringement Allegations

The complaint’s infringement theory relies entirely on claim charts contained in "Exhibit 2," which was not filed with the public version of the complaint (Compl. ¶13-14). The complaint’s narrative theory is that the "Exemplary Defendant Products" satisfy all elements of the asserted claims (Compl. ¶13). Without access to the referenced exhibit, a detailed analysis of the specific infringement allegations is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central dispute may concern the scope of the claimed "interface assembly." The court will have to determine if this term, described in the patent with specific embodiments like a recessed base with electrical connectors ('499 Patent, col. 6:25-40), can be interpreted to cover the standard, multi-purpose ports (e.g., USB) presumably used by modern laptops.
  • Technical Questions: A key evidentiary question will be what proof Plaintiff can offer that Defendant's products contain both a "first adaptor structure" on the computer platform and a distinct "second adaptor structure" on the module that are "communicatively associated" as claimed. The complaint itself provides no technical facts to support this structural allegation.

V. Key Claim Terms for Construction

• The Term: "interface assembly" (comprising a "first adaptor structure" and a "second adaptor structure")

  • Context and Importance: This composite term is the structural core of the claimed invention's connection mechanism. The outcome of the infringement analysis will likely depend on whether the connection mechanisms in Defendant's products meet this two-part structural limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification mentions that a peripheral assembly embodiment could interface with the computer via a "uniform serial bus (usb) connection" ('499 Patent, col. 3:39-41). This could be used to argue that the "adaptor structures" are not limited to proprietary connectors and could encompass the corresponding male and female components of a standard interface.
    • Evidence for a Narrower Interpretation: The patent repeatedly describes and illustrates the "first adaptor" as a "base" (30, 30'), often with a recessed area, and proprietary "electrical connector" (34), which mates with a corresponding connector on the "second adaptor" of the module ('499 Patent, col. 4:11-15, col. 6:25-54). This language may support a narrower construction that requires more than just a standard port and plug.

• The Term: "auxiliary module secured to said platform"

  • Context and Importance: The definition of how a module is "secured to said platform" is critical. Practitioners may focus on this term because it raises questions about the required degree of physical integration between the module and the main computer body.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims require the module be "secured to" the platform, and the specification contemplates that this can be a "removably mounted" connection ('499 Patent, Abstract). This may support a construction where any form of stable, removable attachment (e.g., plugging a device into a port) is sufficient.
    • Evidence for a Narrower Interpretation: The preferred embodiments consistently depict the module as being physically integrated with the platform's surface, such as by fitting into a recessed "adaptor base" on the palm rest ('499 Patent, Fig. 2). An argument could be made that "secured to said platform" implies more than a simple peripheral connection and requires some form of physical housing or mounting on the surface of the computer's main body.

VI. Other Allegations

• Indirect Infringement: The complaint alleges only direct infringement (Compl. ¶11-12).
• Willful Infringement: The complaint does not contain the word "willful." However, the prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, which is the basis for awarding attorney's fees (Compl. p. 4). The complaint provides no specific factual allegations, such as pre-suit notice, to support a claim of willfulness or other conduct that might render a case exceptional.

VII. Analyst’s Conclusion: Key Questions for the Case

• A central issue will be one of claim construction and scope: can the term "interface assembly", which is described in the patent with specific physical embodiments like recessed bases and proprietary connectors, be construed broadly enough to read on the standard, general-purpose connection ports found on modern computer products?
• The case will also present a key evidentiary challenge for the Plaintiff: what specific technical evidence can be presented to demonstrate that the accused products, as a matter of fact, possess the distinct "first adaptor structure" and "second adaptor structure" required by the claims, a point on which the complaint is currently silent?