Volteon LLC v. LG Electronics USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Volteon LLC (TX)
  • Defendant: LG Electronics U.S.A., Inc. (DE)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00051, W.D. Tex., 02/04/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district, has committed acts of patent infringement in the district, and Plaintiff has suffered harm in the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe two U.S. patents related to an electric shaver with imaging capabilities and a motion-sensing device that provides feedback.
• Technical Context: The technologies at issue involve integrating consumer electronics features—such as digital cameras and accelerometers—into personal care or amusement devices to enhance their functionality and user experience.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

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

U.S. Patent No. 10,958,819, "Electric shaver with imaging capability," Issued March 23, 2021

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty of achieving a good shave due to poor visibility of the skin surface, noting that mirrors may be unavailable or provide an inadequate image, and that the user’s hand and the shaver itself can obstruct the view (’819 Patent, col. 2:3-12).
• The Patented Solution: The invention proposes integrating a digital camera into an electric shaver to capture close-up images of the shaving area. These images are then transmitted to a display unit—which can either be integrated into the shaver or housed in a separate device—to provide the user with a real-time, magnified view of the shaving activity (’819 Patent, Abstract; col. 2:41-51). Figure 7 illustrates a user shaving while viewing the captured image on a separate display screen (’819 Patent, Fig. 7).
• Technical Importance: The technology aims to provide real-time visual feedback to improve shaving precision and effectiveness, particularly in conditions where external mirrors are impractical or lighting is insufficient (’819 Patent, col. 2:30-38).

Key Claims at a Glance

• The complaint does not identify specific claims, referring only to the "Exemplary '819 Patent Claims" detailed in an unprovided exhibit (Compl. ¶12). Independent claim 1 is analyzed here as a representative claim.
• The essential elements of independent claim 1 include:
  • A handheld device for capturing and displaying images and for identifying and marking an element of a human body.
  • The device is for use with a cellular network that uses a licensed frequency band.
  • A first camera for capturing a first image.
  • A second camera for capturing a second image.
  • An image processor coupled to the cameras.
  • A display with a flat screen.
  • A cellular antenna for coupling to the cellular network.
  • A cellular transmitter for transmitting the captured images to the cellular network.
  • A rechargeable battery.
  • A single portable and handheld casing housing the components.
    (’819 Patent, col. 28:28-52)

U.S. Patent No. 9,630,062, "System and method for a motion sensing device which provides a visual or audible indication," Issued April 25, 2017

The Invention Explained

• Problem Addressed: The patent seeks to provide a method and system for adding "amusement, education, entertainment and a better user experience" to a toy, such as a game ball, without departing from its conventional "look and feel" (’062 Patent, col. 2:5-11).
• The Patented Solution: The invention describes a device, which may be housed in an object like a toy ball, containing a motion sensor (e.g., an accelerometer) and an "annunciator" that provides visual or audible signals. A controller processes the motion data and activates the annunciator based on predetermined logic, such as when the device's acceleration exceeds a certain threshold (’062 Patent, Abstract; col. 2:25-34).
• Technical Importance: This technology enables the creation of interactive toys and devices that can respond directly to physical manipulation (e.g., being thrown, kicked, or shaken), thereby adding a layer of electronic feedback and engagement to physical play (’062 Patent, col. 2:11-21).

Key Claims at a Glance

• The complaint does not identify specific asserted claims, referring to the "Exemplary '062 Patent Claims" in an unprovided exhibit (Compl. ¶21). Independent claim 1 is analyzed here as a representative claim.
• The essential elements of independent claim 1 include:
  • A device for displaying in response to a sensed acceleration, housed in a single portable enclosure.
  • A three-axis accelerometer for measuring device acceleration and producing a first output signal.
  • A flat-panel digital display.
  • A sensor coupled to the processor and having a second output responsive to a physical phenomenon.
  • A processor executing software to display information in response to the first and second output signals.
  • A rechargeable battery.
  • A battery charger for contactless charging of the battery.
    (’062 Patent, col. 33:55-col. 34:4)

III. The Accused Instrumentality

The complaint does not identify the accused products by name in its main body. It refers to "Exemplary Defendant Products" that are allegedly identified in claim chart exhibits attached to the complaint as Exhibits 3 and 4 (Compl. ¶12, ¶17, ¶21, ¶26). These exhibits were not filed with the public version of the complaint. Consequently, the complaint itself does not provide sufficient detail for analysis of the accused instrumentality's specific functionalities or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant directly infringes the ’819 and ’062 Patents by making, using, selling, or importing the "Exemplary Defendant Products" (Compl. ¶12, ¶21). The infringement contentions are presented in claim chart exhibits, which are incorporated by reference but are not included in the provided document (Compl. ¶18, ¶27). The complaint asserts that these charts demonstrate that the accused products "practice the technology claimed" and "satisfy all elements" of the asserted claims, either literally or under the doctrine of equivalents (Compl. ¶17, ¶26).

No probative visual evidence provided in complaint.

Identified Points of Contention

• ’819 Patent: A potential point of contention arises from the language of independent claim 1, which recites elements such as a "cellular transmitter" and a "second camera" (’819 Patent, col. 28:28-52). This language appears more aligned with a modern smartphone than with the electric shaver embodiment described in detail throughout the patent's specification. The infringement analysis may turn on whether the accused products, which may be personal grooming devices, contain these specific, claimed features.
• ’062 Patent: For the ’062 Patent, a key question may be whether the accused products contain the complete combination of elements required by independent claim 1, including not only a "three-axis accelerometer" but also a separate "sensor...responsive to a physical phenomenon" and a "battery charger for contactless charging" (’062 Patent, col. 33:55-col. 34:4). The dispute may focus on whether the accused products incorporate each of these distinct hardware components as claimed.

V. Key Claim Terms for Construction

Term from the ’819 Patent: "cellular transmitter"

• Context and Importance: This term appears central to defining the scope of claim 1. If the accused products are, for example, electric shavers as described in the patent's specification, they may not include functionality for transmitting data over a cellular network. The construction of this term could therefore be dispositive of the infringement question.
• Intrinsic Evidence for a Broader Interpretation: The specification mentions wireless communication generally, listing "cellular such as GSM, GPRS, 2.5G, 3G, UMTS" alongside other technologies like "WLAN" and "Bluetooth" as possible communication methods (’819 Patent, col. 3:17-20; col. 5:42-49). A party could argue this suggests the inventor contemplated various forms of wireless data transmission.
• Evidence for a Narrower Interpretation: Claim 1 specifies a "cellular transmitter" for use with a "cellular network that uses a licensed frequency band" (’819 Patent, col. 28:28-36). This explicit language may support a narrower construction limited to components capable of communicating over licensed telecommunication spectrum, as distinct from unlicensed short-range protocols like Wi-Fi or Bluetooth.

Term from the ’062 Patent: "a sensor...having a second output responsive to a physical phenomenon"

• Context and Importance: Claim 1 requires this "second sensor" in addition to the "three-axis accelerometer." Infringement requires an accused product to possess both. The construction of "sensor" will determine what type of component satisfies this limitation.
• Intrinsic Evidence for a Broader Interpretation: The patent specification is broad and does not provide specific examples of what this second sensor might be in the context of the claimed invention. A party might argue that this term should be construed broadly to include any component that detects a physical input, such as a button, switch, or temperature probe.
• Evidence for a Narrower Interpretation: The claim requires a "sensor" that produces an "output," which suggests an active component that transduces a physical property into a distinct electrical signal for the processor (’062 Patent, col. 33:65-67). A party could argue that this language requires more than a simple mechanical input and, in the absence of specific embodiments in the specification, the term's scope should be limited to what is clearly described and enabled.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement for both patents. It claims that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in an infringing manner (Compl. ¶15, ¶24). The complaint states that these materials are referenced in the unprovided Exhibits 3 and 4 (Compl. ¶15, ¶24).
• Willful Infringement: Willfulness allegations for both patents are based on alleged knowledge obtained from the service of the complaint itself (Compl. ¶14, ¶23). The complaint does not allege any pre-suit knowledge of the patents or infringement by the Defendant. The allegations therefore appear directed at post-filing conduct (Compl. ¶15-16, ¶25).

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

• A core issue for the '819 Patent will be one of definitional scope: can the elements of claim 1, which describe a dual-camera, cellular-enabled handheld device, be construed to read on the accused products, particularly if those products align more closely with the electric shaver technology detailed in the patent’s specification?
• A key evidentiary question for both patents will be one of factual proof: as the complaint's technical infringement allegations are contained entirely within unprovided exhibits, the case will depend on what specific evidence Plaintiff proffers to establish that the accused products practice every element of the asserted claims, including potentially challenging limitations like the "cellular transmitter" and the "second sensor."