Patentbridge Solutions LLC v. Apple Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: ZephyrHub LLC (Texas)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: Katz PLLC
• Case Identification: 7:25-cv-00519, W.D. Tex., 01/23/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas based on Defendant’s multiple "regular and established places of business" in Austin, including a large corporate campus and retail stores. The complaint further cites a recent Federal Circuit decision upholding venue over Apple in the same district.
• Core Dispute: Plaintiff alleges that Defendant’s Apple USB-C Digital AV Multiport Adapter infringes patents related to hubs that manage both power delivery and data transmission for portable electronic devices.
• Technical Context: The technology addresses the need for compact, multi-function peripheral hubs that can simultaneously charge portable devices at a high rate while also facilitating data transfer, a key requirement in the ecosystem of modern laptops and mobile devices.
• Key Procedural History: The complaint alleges that Plaintiff sent a notice letter to Defendant on September 17, 2025, which was received on September 22, 2025. This letter allegedly identified both asserted patents and the accused product, forming a basis for the allegations of pre-suit knowledge and willful infringement.

Case Timeline

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

U.S. Patent No. 9,864,421 - “Hub Having Complex Power Converters” (Issued Jan. 9, 2018)

The Invention Explained

• Problem Addressed: The patent’s background section describes the inadequacy of common USB hubs, which often provide insufficient power for "rapid charge" functions, cannot simultaneously transmit data and charge devices quickly, and require users to carry multiple inconvenient accessories like separate power adapters (’421 Patent, col. 2:1-13).
• The Patented Solution: The invention proposes a hub that integrates a direct current to direct current (DC/DC) converter. The hub connects to host "electronic equipment" (like a laptop) and a "portable device." A controller manages data flow, while the DC/DC converter draws power from the host equipment and provides a stable voltage to the portable device, enabling simultaneous rapid charging and data transmission through a single accessory (’421 Patent, Abstract; col. 6:39-49).
• Technical Importance: This integrated approach aimed to solve a common usability problem by consolidating power management and data hub functions into a single portable device, eliminating the need for separate power bricks for peripherals (’421 Patent, col. 2:14-18).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶45).
• Essential elements of claim 1 include:
  • A hub for connecting electronic equipment and a portable device via a USB cable.
  • A first connector for the electronic equipment and a second connector for the portable device.
  • A controller for mutual data transmission between the equipment and the device.
  • A first DC/DC converter with an input connected to the electronic equipment and an output connected to the portable device to provide a stable voltage.
  • A requirement that the first connector is a USB 3.1 Power Delivery (PD) type C port and the electronic equipment operates under the USB PD protocol.
• The complaint reserves the right to assert additional claims (Compl. ¶47).

U.S. Patent No. 9,997,939 - “Hub” (Issued Jun. 12, 2018)

The Invention Explained

• Problem Addressed: Similar to the ’421 Patent, the ’939 Patent addresses the problem that conventional USB hubs lack the functionality to both rapidly charge portable devices and transmit data at the same time, forcing users to carry multiple adapters and cables (’939 Patent, col. 2:1-15).
• The Patented Solution: The patent describes a hub architecture facilitating mutual data transmission between a host device and a portable device through a "communicatively connected" first and second connector. A key aspect is the use of a USB 3.1 Power Delivery (PD) type C port as the first connector, allowing the host electronic equipment to operate in either a charging or power-supplying mode via the USB PD protocol (’939 Patent, Abstract; col. 2:28-53).
• Technical Importance: The invention focuses on the connectivity and protocol-level interactions that enable a single hub to serve as a versatile power and data interface for modern electronics (’939 Patent, col. 2:16-20).

Key Claims at a Glance

• The complaint asserts independent claim 1 (Compl. ¶45).
• Essential elements of claim 1 include:
  • A hub for connecting electronic equipment and at least one portable device via a USB cable.
  • A first connector for the electronic equipment.
  • At least a second connector that is "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 through the signal line, the first connector, and the second connector.
  • A requirement that the first connector is a USB 3.1 Power Delivery type C port and the equipment can operate in a charged or power-supplying mode via the USB PD protocol.
• The complaint reserves the right to assert additional claims (Compl. ¶47).

III. The Accused Instrumentality

Product Identification

• The Apple USB-C Digital AV Multiport Adapter ("Accused Product") (Compl. ¶22).

Functionality and Market Context

• The Accused Product is an adapter that connects to a host device (e.g., MacBook, iPad) via a USB-C cable. It provides three ports: an HDMI port for video output, a standard USB-A port for connecting peripherals, and a USB-C port for pass-through charging of the host device (Compl. ¶51). The complaint alleges the adapter contains specific internal components, including a Cypress Semiconductor CYPD5225 USB Type-C Port Controller and a Monolithic Power Systems MP8859 DC/DC Converter, which are alleged to perform the functions recited in the patent claims (Compl. ¶¶29, 30). The complaint includes a diagram from the product's packaging showing its use to connect a host computer to a display and a portable device simultaneously (Compl. ¶26, p. 7).

IV. Analysis of Infringement Allegations

’421 Patent Infringement Allegations

• Identified Points of Contention:
  • Technical Question: A central factual question may be whether the MP8859 DC/DC converter in the Accused Product operates as claimed. The claim requires the converter's input to be connected to the "electronic equipment" (host) and its output to the "portable device" (peripheral). A potential dispute may arise over the actual power flow path within the adapter's circuitry—specifically, whether this component powers the peripheral from the host, or whether its primary function relates to managing pass-through power from an external charger to the host.

’939 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Question: The dispute for the ’939 Patent may focus on the scope of "communicatively connected." While the complaint alleges the internal controller fulfills this role, the precise nature of that connection as required by the patent could be a point of construction and factual debate.

V. Key Claim Terms for Construction

• The Term: "a first direct current (DC)/DC converter" (’421 Patent, claim 1)

  • Context and Importance: This term is the central technical element distinguishing the ’421 Patent. The infringement case hinges on mapping this claim element to the MP8859 component in the Accused Product. The dispute will likely focus on whether the component's function and circuit connections in the Apple product align with the patent's definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the converter's function broadly as being "applied to output stable voltage to the portable device" (’421 Patent, Abstract) and having "the function of regulation" (’421 Patent, col. 6:52-53). Plaintiff may argue that any component performing this voltage stabilization function between the host and peripheral meets the claim.
    • Evidence for a Narrower Interpretation: Defendant may point to embodiments that couple the converter with a "power controller" and "current detector" to limit the output power of the host equipment (’421 Patent, col. 7:1-15; Fig. 2A). This could support an argument that the term implies a converter integrated into a specific power management architecture, not just any voltage-regulating chip.

• The Term: "communicatively connected" (’939 Patent, claim 1)

  • Context and Importance: This term defines the required relationship between the hub's first and second connectors. Its construction will determine what type of data pathway is necessary to meet the claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that "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" (’939 Patent, claim 1). This language suggests that if a mutual data path exists through the connectors, they are "communicatively connected."
    • Evidence for a Narrower Interpretation: The specification provides little explicit language to narrow this term. A party seeking a narrower construction might argue that the context of the invention requires more than a simple electrical connection, perhaps implying a specific logical or protocol-level link managed by a controller, though this is not explicitly stated.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant’s marketing materials, website content, product packaging, and in-store advice instruct and encourage end-users to use the Accused Product in an infringing manner (e.g., connecting a host, a peripheral, and power simultaneously) (Compl. ¶¶48, 51-53).
• Willful Infringement: The willfulness allegation is based primarily on alleged pre-suit knowledge stemming from the notice letter received by Defendant on September 22, 2025 (Compl. ¶¶57-58). The complaint also alleges willful blindness based on a purported corporate policy of not reviewing third-party patents (Compl. ¶57).

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

• A core issue will be one of technical function: Does the accused adapter's internal MP8859 DC/DC converter perform the specific role required by claim 1 of the ’421 patent—namely, taking power from the host "electronic equipment" to provide a stable voltage to a connected "portable device"—or is its primary function materially different, such as managing power from an external adapter for pass-through charging?
• A second central question will be one of knowledge and intent: Given the specific pre-suit notice letter alleged in the complaint, the analysis will focus on whether Defendant’s continued sales of the Accused Product were objectively reckless. The scope and clarity of the notice will be critical in determining whether Defendant had the requisite knowledge for a finding of willful or induced infringement.