DCT
7:25-cv-00519
Patentbridge Solutions LLC v. Apple Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: PatentBridge Solutions LLC (Texas)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Katz PLLC
- Case Identification: 7:25-cv-00519, W.D. Tex., 11/10/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant maintains multiple regular and established places of business in the district, including R&D labs and Apple Store locations. The complaint further cites a prior, unrelated patent case where venue over Apple in this district was affirmed by the U.S. Court of Appeals for the Federal Circuit.
- Core Dispute: Plaintiff alleges that Defendant’s Apple USB-C Digital AV Multiport Adapter infringes patents related to USB hubs that integrate complex power conversion circuitry to manage both data transmission and high-speed charging for connected devices.
- Technical Context: The technology addresses the convergence of data connectivity and power delivery in modern peripherals, particularly those using the USB-C standard, which allows for higher power throughput and bidirectional power flow.
- Key Procedural History: The complaint alleges that Defendant was notified of the Asserted Patents and the accused infringement via a letter received on September 22, 2025, approximately seven weeks prior to the filing of the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2015-01-12 | Earliest Priority Date for ’421 and ’939 Patents |
| 2018-01-09 | U.S. Patent No. 9,864,421 Issued |
| 2018-06-12 | U.S. Patent No. 9,997,939 Issued |
| 2025-09-22 | Defendant Allegedly Received Pre-Suit Notice Letter |
| 2025-11-10 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,864,421 - "Hub Having Complex Power Converters" (01/09/2018)
The Invention Explained
- Problem Addressed: The patent addresses the inconvenience faced by users of portable electronics who need to carry multiple accessories, such as a USB hub for data transfer and a separate power adapter for charging. It notes that standard USB hubs often provide insufficient power for the "rapid charge" capabilities of modern devices. ( ’421 Patent, col. 1:11-2:17).
- The Patented Solution: The invention is a hub that integrates a direct current to direct current (DC/DC) converter. This allows the hub to draw power from a host device (e.g., a laptop), regulate it, and deliver a stable voltage to a connected portable device, enabling simultaneous data transmission and high-speed charging through a single accessory. (’421 Patent, Abstract; Fig. 2A). The controller manages data flow, while the power converter specifically handles the electrical requirements for stable, rapid charging. (’421 Patent, col. 6:3-12, 39-50).
- Technical Importance: This integrated approach was designed to reduce accessory clutter and improve user convenience by creating a single, multi-function peripheral that satisfies both the data and power needs of an increasingly mobile ecosystem. (’421 Patent, col. 2:13-17).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1. (Compl. ¶32).
- Essential Elements of Claim 1:
- A hub for connecting electronic equipment and a portable device via a USB cable.
- A "first connector" for connecting to the electronic equipment.
- A "second connector" for connecting to the portable device.
- A "controller" connected between the first and second connectors to facilitate mutual data transmission.
- A "first direct current (DC)/DC converter" with an input connected to the electronic equipment and an output connected to the portable device, configured to output a stable voltage.
- The first connector is a "USB 3.1 Power Delivery (PD) type C port", and the electronic equipment is operable in a charged or power supplying mode.
- The complaint reserves the right to assert other claims. (Compl. ¶34).
U.S. Patent No. 9,997,939 - "Hub" (06/12/2018)
The Invention Explained
- Problem Addressed: As a continuation-in-part sharing a specification with the ’421 Patent, this patent addresses the same technical challenge: the need for a unified hub that can manage both data transfer and power delivery to peripherals, eliminating the need for multiple separate devices. (’939 Patent, col. 1:11-2:17).
- The Patented Solution: This patent claims a hub architecture focused on the connectivity and data path. The core of the claimed solution is a hub with at least two connectors that establishes a mutual data transmission pathway between the host electronic equipment and a portable device, passing through both the first and second connectors via a signal transmission line. (’939 Patent, Abstract; col. 6:3-20). It specifies that the hub operates using the USB Power Delivery protocol, allowing the host equipment to be either charged or act as a power source. (’939 Patent, col. 15:21-25).
- Technical Importance: The invention provides a foundational framework for a multi-port adapter that leverages the advanced data and power capabilities of the USB-C Power Delivery standard. (’939 Patent, col. 2:18-25).
Key Claims at a Glance
- The complaint asserts at least independent Claim 1. (Compl. ¶32).
- Essential Elements of Claim 1:
- A hub for connecting electronic equipment and a portable device via a USB cable.
- A "first connector" for connecting to the electronic equipment.
- "At least a second connector", communicatively connected to the first connector and electrically connected to the portable device.
- A "data transmission" path between the equipment and device that runs mutually via the signal line, the first connector, and the second connector.
- The first connector is a "Universal Serial Bus 3.1 Power Delivery type C port", and the electronic equipment can operate in a charged or power supplying mode.
- The complaint reserves the right to assert other claims. (Compl. ¶34).
III. The Accused Instrumentality
Product Identification
The Apple USB-C Digital AV Multiport Adapter. (Compl. ¶12).
Functionality and Market Context
The complaint alleges the Accused Product is a hub that connects to host electronic equipment, such as a MacBook, via a built-in USB-C cable. (Compl. ¶15). It provides multiple output ports, including USB-C for pass-through charging, HDMI for video output, and USB-A for legacy peripherals. (Compl. ¶15, p. 6 image). The complaint includes teardown photographs identifying a Cypress Semiconductor USB Type-C Port Controller (CYPD5225-96BZX) alleged to manage data transmission and Power Delivery functions, and a Monolithic Power Systems DC/DC Converter (MP8859) alleged to regulate voltage for charging. (Compl. ¶18, ¶19). The complaint alleges the Accused Product is marketed and sold as an essential accessory for Apple's USB-C-equipped laptops, enabling connectivity with a wide range of common peripherals.
IV. Analysis of Infringement Allegations
9,864,421 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first connector, electrically connected to the electronic equipment via the USB cable; | The adapter's built-in USB-C cable and connector that plug into a host device like a laptop. The complaint provides an annotated diagram showing this connection. (Compl. ¶16, p. 7 image). | ¶16 | col. 6:3-6 |
| a second connector, electrically connected to the portable device via the USB cable; | The adapter's USB-A port, which connects to portable devices. The complaint provides an annotated diagram showing this connection. (Compl. ¶17, p. 8 image). | ¶17 | col. 6:7-8 |
| a controller, electrically connected between the first connector and the second connector, the controller has data transmission between the portable device and the electronic equipment... | The Cypress Semiconductor CYPD5225-96BZX integrated circuit, which the complaint alleges is a USB Type-C Port Controller that manages data flow between the host device and peripherals. (Compl. ¶18, p. 9 image). | ¶18 | col. 6:8-12 |
| a first direct current (DC)/DC converter... applied to output stable voltage to the portable device; | The Monolithic Power Systems MP8859 integrated circuit, which the complaint alleges is a DC/DC buck-boost converter used to regulate and provide stable voltage for charging. (Compl. ¶19, p. 10 image). | ¶19 | col. 6:39-50 |
| wherein the first connector is USB 3.1 Power Delivery (PD) type C port, and the electronic equipment is operable either in a charged mode or in a power supplying mode... | The adapter's input connector is identified as a USB-C port, and the complaint alleges the MP8859 component's functionality "meet[s] the USB power delivery (PD) requirement," enabling bidirectional power flow. | ¶20, ¶21 | col. 4:1-3 |
9,997,939 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first connector, electrically connected to the electronic equipment via the Universal Serial Bus cable; | The adapter's integrated USB-C cable and connector that attach to the host electronic equipment. (Compl. ¶25, p. 14 image). | ¶25 | col. 6:3-6 |
| at least a second connector, communicatively connected to the first connector and electrically connected to the portable device... | The adapter's USB-A port is identified as a second connector, connected to the first connector to facilitate communication with a portable device. (Compl. ¶26, p. 15 image). | ¶26 | col. 6:7-8 |
| a data transmission between the portable device and the electronic equipment mutually is via the signal transmission line, the first connector, and the second connector; | The complaint alleges the Cypress Semiconductor CYPD5225-96BZX controller provides for this mutual data transmission between the host and peripheral through the adapter's connectors. | ¶27 | col. 6:8-12 |
| wherein the first connector is Universal Serial Bus 3.1 Power Delivery type C port, and electronic equipment can be either in a charged mode or in a power supplying mode... | The adapter's input is a USB-C port, and the complaint points to the presence of the MP8859 DC/DC converter as evidence that the adapter and connected equipment operate via the USB PD protocol to manage power. | ¶28, ¶29 | col. 4:1-3 |
- Identified Points of Contention:
- Scope Questions: Claim 1 of the ’421 Patent recites "a second connector" (singular). The complaint maps this to the USB-A port. A potential issue is whether this singular recitation can read on an accused product that has multiple, distinct output ports (USB-A, HDMI, USB-C). This may raise the question of whether the claim scope covers a multi-port hub or is limited to a single input/output device.
- Technical Questions: The infringement theories rely on identifying specific integrated circuits from teardown photos and linking them to claim elements. A potential point of contention will be whether the internal wiring and actual operation of these components in the Apple product precisely match the connections and functions required by the claims (e.g., whether the input of the MP8859 converter is electrically connected to the "electronic equipment" and its output to the "portable device" in the manner the patent requires).
V. Key Claim Terms for Construction
The Term: "controller" (’421 Patent, Claim 1; ’939 Patent, Claim 1)
- Context and Importance: This term is central to the data handling functions of the claimed hub. The complaint identifies a specific Cypress chip as the "controller". Defendant may argue that this chip is a highly integrated "System on a Chip" that performs functions beyond just the "data transmission" role described in the patent's specification, potentially creating a mismatch with the claim's narrower functional definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the controller functionally as being "suitable for having data transmission with the portable device 30 mutually." (’421 Patent, col. 6:9-10). Plaintiff may argue this functional language covers any component that performs this role, regardless of other integrated functions.
- Evidence for a Narrower Interpretation: The patent's block diagrams, such as Figure 2A, depict the "controller" (120) as a discrete logical block separate from the power management circuitry (111, 112, 113). Defendant may argue that this depiction limits the term to a component primarily or solely dedicated to data transmission, distinguishing it from an integrated USB-C Power Delivery controller that manages both power negotiation and data.
The Term: "a second connector" (’421 Patent, Claim 1)
- Context and Importance: The claim's use of the singular "a second connector" may be a focal point. The Accused Product has three distinct output ports. The construction of this term—whether it can mean "at least one connector" or is strictly limited to a single connector—could be dispositive for literal infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's introduction describes a general problem of insufficient USB ports and the need for hubs to "expand the amount of the USB ports." (’421 Patent, col. 1:50-54). Plaintiff could argue this context supports a reading where "a second connector" is exemplary, not limiting, and that the patent contemplates a hub with multiple outputs. Figure 1 of the patent also depicts a hub with multiple output ports.
- Evidence for a Narrower Interpretation: Defendant may argue that while the specification discusses hubs generally, the specific language of Claim 1 deliberately uses the singular "a" to claim a more basic one-to-one architecture. The Federal Circuit standard often holds that "a" or "an" means "one or more" unless the context suggests otherwise, but the argument remains available.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant's instructional materials, product packaging, and marketing encourage customers to use the Accused Product in an infringing manner. (Compl. ¶34). It also alleges contributory infringement under § 271(c), stating the product is especially designed to operate in an infringing way and has no substantial non-infringing uses. (Compl. ¶35).
- Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the patents since its receipt of a notice letter on September 22, 2025. (Compl. ¶38). The complaint further alleges that Defendant was willfully blind to Plaintiff's patent rights by maintaining a policy of not reviewing third-party patents and that it continued its infringing conduct post-notice without attempting a non-infringing redesign. (Compl. ¶38, ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: Can the term "a second connector" in the ’421 Patent, which is singular, be construed to read on a device with multiple, distinct output ports (USB-C, USB-A, HDMI), or does this structural difference place the accused product outside the literal scope of the claim?
- A second issue will be one of technical mapping: The infringement case is built on high-level component identification from teardown photos. A key evidentiary question will be whether the specific, detailed electrical connections and operational logic of the accused adapter's circuits align with the functional and structural requirements laid out in the patent claims, particularly the input/output connections of the alleged DC/DC converter.
- A third question will be one of functional equivalence: For the ’939 Patent, the case may turn on whether "data transmission" can be interpreted broadly enough to cover the varied signal types handled by the multiport adapter, including the primarily one-way video data stream for the HDMI port, or if it is limited to the bidirectional communication typical of a standard USB data connection.