7:25-cv-00052
Volteon LLC v. Sonim Tech Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Volteon LLC (Texas)
- Defendant: Sonim Technologies, Inc. (Delaware)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 7:25-cv-00052, W.D. Tex., 02/04/2025
- Venue Allegations: Venue is alleged as proper based on Defendant maintaining an established place of business within the Western District of Texas.
- Core Dispute: Plaintiff alleges that certain of Defendant's unspecified products infringe two patents related to an electric shaver with integrated imaging capabilities and a motion-sensing device that provides user feedback.
- Technical Context: The technologies at issue relate to the integration of electronic sensors and feedback mechanisms into consumer products, such as smart personal grooming devices and interactive toys.
- Key Procedural History: The complaint does not mention any prior litigation, administrative proceedings, or licensing history related to the patents-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2008-12-30 | U.S. Patent No. 10,958,819 Priority Date |
| 2011-03-25 | U.S. Patent No. 9,630,062 Priority Date |
| 2016-01-05 | U.S. Patent No. 9,630,062 Application Filing Date |
| 2017-04-25 | U.S. Patent No. 9,630,062 Issue Date |
| 2020-05-06 | U.S. Patent No. 10,958,819 Application Filing Date |
| 2021-03-23 | U.S. Patent No. 10,958,819 Issue Date |
| 2025-02-04 | Complaint Filing Date |
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 that effective shaving requires good visibility of the skin surface, which can be difficult to achieve with a mirror, in poor lighting, or because the user's hand and the shaver itself can obstruct the view (U.S. Patent No. 10,958,819, col. 2:3-12).
- The Patented Solution: The invention integrates a digital camera into the housing of an electric shaver to capture a close-up image of the shaving area. This image is then transmitted to a display unit—which can be integrated into the shaver or housed in a separate device—allowing the user to see a magnified, real-time view of the shaving activity without relying on a conventional mirror (’819 Patent, Abstract; col. 2:44-51). Figure 7 illustrates a user viewing a magnified image (73) of their face on a separate display (63) while using the camera-enabled shaver (60).
- Technical Importance: This approach provides users with direct, real-time visual feedback during shaving, potentially improving precision and effectiveness, particularly in conditions where external mirrors are impractical (’819 Patent, col. 2:30-38).
Key Claims at a Glance
- The complaint does not identify the specific independent or dependent claims asserted from the ’819 Patent. It alleges infringement of "the exemplary claims of the '819 Patent also identified in the charts incorporated into this Count," but the referenced exhibit containing these charts was not provided with the complaint (Compl. ¶12).
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 advance the art of toys and other amusement devices by providing a simple and cost-effective way to create a better and more interactive user experience without departing from the conventional "look and feel" of the object (U.S. Patent No. 9,630,062, col. 2:5-12).
- The Patented Solution: The invention describes a self-contained device, such as a toy ball or handheld unit, that includes a motion sensor (e.g., an accelerometer) and an "annunciator" (a component that provides a visual or audible signal). A controller activates the annunciator in response to sensed motion, according to a pre-determined logic, such as when acceleration exceeds a certain threshold (’062 Patent, Abstract; col. 2:25-34).
- Technical Importance: The technology enables the creation of interactive objects that can respond to physical actions like being thrown, shaken, or struck with light, sound, or other feedback, thereby enhancing user amusement (’062 Patent, col. 2:12-21).
Key Claims at a Glance
- The complaint does not identify the specific independent or dependent claims asserted from the ’062 Patent. It alleges infringement of "the exemplary claims of the '062 Patent also identified in the charts incorporated into this Count," but the referenced exhibit containing these charts was not provided with the complaint (Compl. ¶21).
III. The Accused Instrumentality
Product Identification
The complaint does not identify any specific accused products or services by name (Compl. ¶12, ¶21). It refers generally to "Exemplary Defendant Products" that are purportedly identified in Exhibits 3 and 4, which were not provided with the complaint (Compl. ¶17, ¶26).
Functionality and Market Context
The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality.
IV. Analysis of Infringement Allegations
The complaint incorporates by reference claim chart exhibits (Exhibits 3 and 4) that were not provided. The complaint's narrative allegations of infringement are conclusory, stating that the "Exemplary Defendant Products practice the technology claimed" and "satisfy all elements of the Exemplary...Patent Claims" (Compl. ¶17, ¶26). Without the asserted claims or any description of the accused products, a detailed infringement analysis is not possible.
No probative visual evidence provided in complaint.
Identified Points of Contention
The complaint does not provide sufficient detail for analysis of potential points of contention regarding infringement.
V. Key Claim Terms for Construction
The complaint does not provide sufficient detail for analysis of key claim terms, as it does not identify any specific claims being asserted from the patents-in-suit.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement for both the ’819 and ’062 Patents. The allegations are based on Defendant distributing "product literature and website materials inducing end users and others to use its products in the customary and intended manner." Knowledge and intent are alleged to exist at least since the date the complaint was served (Compl. ¶15-16, ¶24-25).
Willful Infringement
The complaint alleges that service of the complaint and its attached (but unprovided) claim charts constitutes "actual knowledge" of infringement for both patents (Compl. ¶14, ¶23). It further alleges that Defendant's infringement has continued despite this knowledge, forming a basis for post-suit willful infringement (Compl. ¶15, ¶24). The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285 (Compl., Prayer for Relief ¶ G.i).
VII. Analyst’s Conclusion: Key Questions for the Case
The complaint's sparse factual content raises fundamental questions that will likely shape the initial phases of the litigation.
- A primary issue will be one of pleading sufficiency: does a complaint that alleges infringement by incorporating by reference unprovided exhibits, without including substantive factual allegations in the body of the complaint identifying the accused products and mapping their features to patent claims, satisfy the plausibility standard required by federal pleading rules?
- A central factual question will be one of identification and operation: what are the specific "Exemplary Defendant Products," and what is their precise technical functionality? The absence of this information in the complaint suggests that defining the scope of the accused instrumentalities will be a key objective of early discovery.