Complaint

Complaint Analysis

Prosecution History analysis

Examiner Search analysis

Invalidity Framework analysis

## I. Executive Summary and Procedural Information

*   **Parties & Counsel:**
    *   **Plaintiff:** [Gametronics LLC](https://ai-lab.exparte.com/party/gametronics-llc) (Delaware)
    *   **Defendant:** [Razer USA LTD](https://ai-lab.exparte.com/party/razer-usa-ltd). (Delaware)
    *   **Plaintiff’s Counsel:** [Rabicoff Law LLC](https://ai-lab.exparte.com/law-firm/19289)
*   **Case Identification:** [7:25-cv-00278](https://ai-lab.exparte.com/case/dct/txwd/7:25-cv-00278), W.D. Tex., 06/19/2025
*   **Venue Allegations:** Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has committed alleged acts of infringement there.
*   **Core Dispute:** Plaintiff alleges that Defendant’s unspecified products infringe three patents related to ergonomic data input devices, such as keyboards and controllers.
*   **Technical Context:** The patents address ergonomic input devices designed to reduce physical stress and repetitive strain injuries associated with conventional keyboards by replacing finger-actuated keys with palm- or thumb-operated controllers.
*   **Key Procedural History:** The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

#### Case Timeline

| **Date** | **Event** |
| :--- | :--- |
| 2000-11-14 | Earliest Priority Date for ’762, ’872, and ’667 Patents |
| 2005-11-18 | Application Filed for ’872 Patent |
| 2006-06-27 | Application Filed for ’667 Patent |
| 2007-08-28 | ’762 Patent Issued |
| 2013-07-16 | ’872 Patent Issued |
| 2013-12-24 | ’667 Patent Issued |
| 2019-06-03 | Application Filed for ’762 Patent |
| 2025-06-19 | Complaint Filed |

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

### U.S. Patent No. 7,262,762 - *"APPARATUS AND METHOD FOR GENERATING DATA SIGNALS"*
*   **Issued:** August 28, 2007
*   **The Invention Explained:**
    *   **Problem Addressed:** The patent’s background describes physical problems such as carpal tunnel syndrome, fatigue, and other neuromuscular injuries that can result from the repetitive hand, wrist, and finger motions required to operate conventional typewriter-like keyboards (’762 Patent, col. 1:39-51).
    *   **The Patented Solution:** The invention is an ergonomic input device featuring one or two dome-shaped palm supports designed to fit the user’s hands in a relaxed state (’762 Patent, col. 3:29-39; FIG. 1). Instead of pressing individual keys, the user generates data signals by sliding a dome in various directions from a central home position (’762 Patent, col. 3:21-25). This design aims to eliminate finger movement and reduce stressful hand and wrist motions (’762 Patent, Abstract).
    *   **Technical Importance:** The technical approach sought to directly address the primary biomechanical factors—force, repetition, and posture—identified as causes of keyboard-related injuries by obviating the need for finger-tip actuation (’762 Patent, col. 2:54-65).
*   **Key Claims at a Glance:**
    *   The complaint does not identify any specific claims of the ’762 Patent asserted against the Defendant, instead referring to “Exemplary ’762 Patent Claims” contained within an exhibit not provided with the complaint (Compl. ¶13).

---
### U.S. Patent No. 8,487,872 - *"APPARATUS AND METHOD FOR GENERATING DATA SIGNALS"*
*   **Issued:** July 16, 2013
*   **The Invention Explained:**
    *   **Problem Addressed:** The patent addresses the same ergonomic problems as the parent ’762 Patent, noting the need for data input devices that reduce physical trauma and can accommodate users with musculoskeletal disabilities or special needs (’762 Patent, col. 1:21-51, col. 2:61-65, incorporated by the ’872 Patent).
    *   **The Patented Solution:** This patent focuses on handheld embodiments of the ergonomic input concept, featuring a pair of thumb-operated controllers integrated into a main body (’872 Patent, Abstract). A user manipulates the thumb controllers to generate electrical signals, which a processing module resolves into alphanumeric characters or other functions, such as video game state changes (’872 Patent, Abstract). Handheld embodiments are illustrated in the specification shared with the ’762 patent (’762 Patent, FIG. 9A; col. 17:23-28).
    *   **Technical Importance:** This approach miniaturizes the ergonomic principles of the parent patent for use in portable electronics and gaming devices, where thumb-operated controls are prevalent and can also cause strain (’872 Patent, Abstract).
*   **Key Claims at a Glance:**
    *   The complaint does not identify any specific claims of the ’872 Patent asserted against the Defendant, instead referring to “Exemplary ’872 Patent Claims” contained within an exhibit not provided with the complaint (Compl. ¶22).

---
### U.S. Patent No. 8,614,667 - *"APPARATUS AND METHOD FOR GENERATING DATA SIGNALS"*
*   **Issued:** December 24, 2013 (Compl. ¶11)
*   **Technology Synopsis:** As a divisional of the application leading to the ’872 Patent, the ’667 Patent relates to the same core technology of ergonomic data input devices. The invention replaces conventional key-based typing with palm- or thumb-operated controllers that are moved radially from a home position to generate data signals, with the goal of reducing repetitive stress injuries (’667 Patent, Abstract).
*   **Asserted Claims:** The complaint does not identify any specific asserted claims, referring to “Exemplary ’667 Patent Claims” in an exhibit not provided with the complaint (Compl. ¶28).
*   **Accused Features:** The complaint does not specify which features of the accused products allegedly infringe the ’667 Patent; it makes only a general allegation against "Exemplary Defendant Products" (Compl. ¶28).

## III. The Accused Instrumentality

*   **Product Identification:** The complaint does not identify any accused products of the Defendant by name (Compl. ¶¶ 13, 22, 28). It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim chart exhibits not attached to the filed complaint (Compl. ¶¶ 18, 24, 33).
*   **Functionality and Market Context:** The complaint does not provide any description of the functionality or market context of the accused products.

No probative visual evidence provided in complaint.

## IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s "Exemplary Defendant Products" practice the technology claimed by the Patents-in-Suit and satisfy all elements of the asserted claims (Compl. ¶¶ 18, 24, 33). However, because the complaint does not identify specific asserted claims, name the accused products, or include the referenced claim chart exhibits, a detailed analysis of the infringement allegations is not possible. The complaint’s infringement theory is presented only in general terms, alleging that Defendant directly infringes by making, using, selling, and importing the accused products, as well as by having employees internally test and use them (Compl. ¶¶ 13-14, 22-23, 28-29).

## V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of key claim terms, as no specific asserted claims from any of the patents-in-suit are identified.

## VI. Other Allegations

*   **Indirect Infringement:** The complaint alleges induced infringement of the ’762 and ’667 Patents. The allegations are based on Defendant’s distribution of "product literature and website materials," which allegedly instruct and encourage end users to use the accused products in an infringing manner (Compl. ¶¶ 16, 31). The complaint does not allege indirect infringement of the ’872 Patent.
*   **Willful Infringement:** The complaint does not use the term "willful." However, for the ’762 and ’667 Patents, it alleges that service of the complaint constitutes "actual knowledge" of infringement and that Defendant has continued its allegedly infringing conduct despite this knowledge (Compl. ¶¶ 15-16, 30-31). These allegations may form the basis for a claim of post-suit willful infringement. No facts are alleged to support pre-suit knowledge.

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

The complaint's lack of specificity raises foundational questions that will likely precede any substantive technical or legal disputes. The case appears poised to turn on the following issues:

*   A core procedural question will be one of **pleading sufficiency:** does the complaint’s failure to identify any specific accused product or any asserted patent claim meet the plausibility standard required to state a claim for patent infringement?
*   Should the case proceed, a central issue will be one of **technological mapping:** how do the specific functionalities of Defendant’s commercial products, which are primarily in the gaming peripheral space, correspond to the claim elements of patents directed at ergonomic data input, particularly elements describing movable domes and specific underlying mechanical structures?
*   A key legal question will concern **claim construction:** can claim terms rooted in the patents’ disclosure of palm-operated domes and specific mechanical guides (e.g., "flower pedal shaped impression") be construed broadly enough to read on the thumbsticks, buttons, or other control mechanisms common to modern gaming controllers?

Gaming giant Razer faces a patent lawsuit over its controllers, accused of infringing ergonomic tech for a `“dome-shaped palm support”` to prevent hand strain.

7:25-cv-00278

Gametronics LLC v. Razer USA Ltd