Mobile Motherboard Inc v. MeLE Tech Shenzhen Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Mobile Motherboard Inc. (Texas)
  • Defendant: MeLE Technologies (Shenzhen) Co., Ltd (China)
  • Plaintiff’s Counsel: Direction IP Law
• Case Identification: 6:23-cv-00445, W.D. Tex., 06/13/2023
• Venue Allegations: Venue is alleged to be proper for a foreign defendant under 28 U.S.C. § 1391(c)(3), which permits such a defendant to be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s line of “Compute Stick” products, when combined with a display such as an HD TV or monitor, infringes a patent related to a portable, external motherboard system.
• Technical Context: The technology concerns modular and portable computing, where a small, self-contained processing unit provides computing functionality to a display or other device that lacks its own processor.
• Key Procedural History: The patent-in-suit is a reissue patent, U.S. Reissued Patent No. RE48,365, which reissued from U.S. Patent No. 7,990,724. This procedural history may be relevant to the scope of the asserted claims, particularly with respect to any subject matter surrendered during the reissue process.

Case Timeline

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

U.S. Reissued Patent No. RE48,365 - "Mobile Motherboard," Issued Dec. 22, 2020

The Invention Explained

• Problem Addressed: The patent describes a time when personal computers were geographically fixed, and their internal components, like the motherboard, were difficult to access for upgrades or replacement (RE’365 Patent, col. 1:18-24, 1:36-41). This "dedicated" nature limited the motherboard's utility to a single host computer (RE’365 Patent, col. 1:43-48).
• The Patented Solution: The invention is a "portable motherboard" that is external to a main "computer box" (RE’365 Patent, Abstract). This external unit contains a processor and can connect to a computer box that lacks one, thereby providing it with the "brains" to operate. Alternatively, it can connect to an existing computer to "boost the brainpower of the slow computer" (RE’365 Patent, col. 4:54-65). This external configuration is also described as improving heat dissipation by exposing the motherboard to natural air flow (RE’365 Patent, col. 4:29-36).
• Technical Importance: The invention proposed a modular approach to computing power, seeking to make microprocessors more "efficient and ubiquitous" by decoupling the core processing unit from a single, fixed computer chassis (RE’365 Patent, col. 4:61-65).

Key Claims at a Glance

• The complaint asserts at least Claim 1 (Compl. ¶13).
• Independent Claim 1 requires:
  • A computer system comprising a computer box without a processor for performing computing operations
  • The computer box includes a housing, internal circuitry, an internal bus, and a first communication port
  • A portable and handholdable motherboard external to the housing
  • The motherboard includes a central processor, a motherboard bus, and a motherboard connector for engaging the computer box's first communication port
  • The connection enables the computer box to perform computing operations
  • The motherboard includes Northbridge and Southbridge circuitry
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused products are various models of MeLE "Compute Sticks," including the "MeLE PCG02 GLE Fanless PC Stick" and "PCG02 APO Fanless PC Stick" (Compl. ¶13).

Functionality and Market Context

The Accused Instrumentalities are described as small, self-contained computers in a "stick" form factor that are designed to be plugged into an HD TV, monitor, or projector (Compl. ¶13). The complaint alleges that this combination creates a functional computer system, with the display acting as a "computer box without a processor" and the Compute Stick acting as the "portable motherboard" (Compl. ¶17). An image in the complaint depicts the Accused Instrumentality connecting to a variety of display types, including a monitor, TV, and projector (Compl. p. 5). The products are marketed as "Mini Yet Powerful" and portable, with one complaint visual comparing the device's size to a smartphone (Compl. p. 7).

IV. Analysis of Infringement Allegations

RE’365 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question may be whether a modern television or monitor qualifies as a "computer box without a processor" as contemplated by the patent. The patent's specification and figures appear to describe a traditional desktop PC tower (RE’365 Patent, FIG. 1, FIG. 3). The infringement theory depends on construing this term broadly enough to read on a consumer display device.
• Technical Questions: The claim requires "Northbridge and Southbridge circuitry." In modern System-on-a-Chip (SoC) architectures, like the Intel Gemini Lake processors cited in the complaint (Compl. ¶23), these functions are typically integrated directly into the processor die, rather than existing as discrete chips on a motherboard as was common when the patent application was filed (priority date 2006). The case may turn on whether the integrated functionality of the accused processors meets this claim limitation, which the complaint alleges it does "regardless how configured" (Compl. ¶23).

V. Key Claim Terms for Construction

• The Term: "computer box"

• Context and Importance: This term's construction is fundamental. The infringement allegation hinges on the theory that a standard HD TV or monitor is a "computer box without a processor" (Compl. ¶17). The viability of the claim depends on whether the term, in the context of the patent, can be interpreted this broadly.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent defines "computer box" as "a housing of any form factor that in the prior art contains a motherboard with central processing unit" (RE’365 Patent, col. 2:58-60). Plaintiff may argue this language is not limiting and can encompass any housing that could conceivably contain a motherboard, such as a monitor.
  • Evidence for a Narrower Interpretation: The patent’s own figures depict a conventional desktop computer tower as the "computer box" (RE’365 Patent, FIG. 1, element 5). The background discusses the difficulty of accessing parts inside such a box (RE’365 Patent, col. 1:36-41), which may suggest a traditional, user-accessible PC chassis rather than a sealed consumer electronics device like a TV.

• The Term: "Northbridge and Southbridge circuitry"

• Context and Importance: This limitation defines a specific motherboard architecture. The accused products utilize modern SoCs where these functions are integrated. Practitioners may focus on this term because the infringement allegation requires mapping these claimed architectural elements onto a technologically different hardware implementation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim requires the "circuitry" itself, without specifying that it must be on separate chips. Plaintiff will likely argue that as long as the Northbridge functions (e.g., memory controller) and Southbridge functions (e.g., I/O controller) are present, the limitation is met, "regardless how configured" (Compl. ¶23).
  • Evidence for a Narrower Interpretation: The patent’s detailed description and figures, such as Figure 4, explicitly depict the North Bridge and South Bridge as distinct functional blocks mediating between the CPU, memory, and peripherals (RE’365 Patent, FIG. 4). A defendant may argue this disclosure limits the claim to an architecture with physically or logically distinct bridge circuits, not a fully integrated SoC.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that the Defendant encourages its customers to perform the infringing act of connecting the Accused Instrumentalities to a display through marketing and instructions (Compl. ¶28, ¶29). It also alleges contributory infringement, claiming the products are "especially made" for infringement and have "no substantial non-infringing uses" (Compl. ¶27, ¶30).
• Willful Infringement: Willfulness is alleged based on Defendant’s awareness of the patent and its infringement, with the complaint dating this knowledge to "at least as of the date of the service of the original Complaint" (Compl. ¶30).

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

This dispute appears to center on questions of technological translation and definitional scope. The outcome may depend on how the court addresses two key issues:

1. A core issue will be one of definitional scope: can the term "computer box," which the patent illustrates as a traditional PC tower, be construed to encompass a modern HD television or monitor as alleged by the Plaintiff?

2. A key technical question will be one of architectural equivalence: does the "Northbridge and Southbridge circuitry" required by the claim read on the integrated functions of a modern System-on-a-Chip (SoC) processor, or is the claim limited to the discrete chipset architecture prevalent at the time of the invention?