DCT

2:15-cv-00087

Denmel Holdings v. Bluelounge Distribution

Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:15-cv-00087, D. Utah, 02/09/2015
  • Venue Allegations: Venue is alleged to be proper in the District of Utah because Defendants' acts of infringement, including sales or offers for sale, took place within the district, or because Defendants placed infringing products into the stream of commerce with the expectation of purchase by Utah residents.
  • Core Dispute: Plaintiffs allege that Defendants’ "Charging Stations" for electronic devices infringe a patent related to an accessory for holding and charging multiple mobile telephones from a single power source.
  • Technical Context: The technology addresses the common household or office problem of managing and charging a growing number of personal electronic devices, aiming to reduce clutter by consolidating them into a single station.
  • Key Procedural History: The patent's inventor, Denis Reah, passed away in 2009. The patent was subsequently assigned to his widow, Plaintiff Melanie Reah, who then granted an exclusive license to Plaintiff Denmel Holdings, LLC. The complaint notes that Plaintiffs have also granted sublicenses to third parties.

Case Timeline

Date Event
2001-06-22 ’542 Patent Priority Date
2006-01-03 ’542 Patent Issue Date
2009-11-09 Inventor Denis Reah passed away
2010-02-17 Patent assigned to Melanie Reah
2015-02-09 Complaint Filed

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

U.S. Patent No. 6,982,542 - "Accessory for Use with Mobile Telephones," Issued January 3, 2006

The Invention Explained

  • Problem Addressed: The patent addresses the challenge presented when a family or group possesses a "relatively large number of mobile telephones" that require simultaneous charging, which can lead to disorganization and use of multiple power outlets (’542 Patent, col. 5:15-22).
  • The Patented Solution: The invention is a "box-like structure" that provides a neat and effective way to hold and charge multiple devices using a single power supply point (’542 Patent, col. 5:18-22). It achieves this through pairs of dedicated compartments or "holding formations": a first formation to hold the phone and a second, typically behind the first, to house the phone's charger block (’542 Patent, col. 5:46-53; Fig. 3). The charger blocks plug into internal electrical sockets that are wired together and connected to a single external power cord, thereby consolidating the charging process (’542 Patent, col. 6:1-4).
  • Technical Importance: The invention provides a physical organization and power consolidation solution for the proliferation of personal electronic devices.

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶17).
  • Independent Claim 1 includes these essential elements:
    • A support body defining at least two pairs of holding formations.
    • Each pair includes a first formation for removably holding a mobile telephone.
    • Each pair includes a second formation for removably holding a mobile telephone charger that has pins.
    • An electrical connector arrangement on the support body.
    • The arrangement includes a socket for receiving the pins of the mobile telephone charger.
    • The arrangement includes connector means for connecting the socket arrangements to a mains electricity power supply.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are identified as "Charging Stations" or "Infringing Products" manufactured, sold, or imported by the Defendants (Compl. ¶¶14, 17, 23).

Functionality and Market Context

The complaint alleges the accused products are "Charging Stations which have structures to hold multiple mobile telephones, PDAs, or other electronic devices and their respective charging cables" (Compl. ¶15). The complaint references an exhibit containing "Screenshots of Defendants' websites showing infringing Charging Stations" as evidence of the products' infringing nature (Compl. ¶17). The complaint alleges these products are sold in the United States and interfere with the Plaintiffs' and their sublicensees' rights in the U.S. market (Compl. ¶18).

IV. Analysis of Infringement Allegations

The complaint does not provide a detailed element-by-element infringement analysis. The following chart summarizes the infringement theory as inferred from the general allegations.

’542 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An accessory for use with mobile telephones comprising a support body that defines at least two pairs of holding formations... The accused "Charging Stations" are described as having "structures to hold multiple mobile telephones, PDAs, or other electronic devices and their respective charging cables." ¶15 col. 5:6-9
each pair of holding formations including a first formation in which a mobile telephone can be removably held... The accused products allegedly have structures to "hold multiple mobile telephones." ¶15 col. 6:25-27
and a second formation in which a mobile telephone charger having pins can be removably held... The accused products allegedly have structures to hold the "respective charging cables" of the electronic devices. ¶15 col. 6:27-29
and wherein the support body has an electrical connector arrangement located thereon that includes a socket arrangement... The complaint alleges the accused products are "Charging Stations," which suggests they provide electrical power to devices held within, implying an internal electrical connector system. ¶14, ¶15 col. 6:29-31
for the second formation of each pair of holding formations for receiving the pins of the mobile telephone charger... The complaint does not provide sufficient detail for analysis of this element. --- col. 6:31-33
and connector means for connecting the socket arrangements to a mains electricity power supply. The function as a "Charging Station" suggests connection to an external power source. ¶14, ¶15 col. 6:33-35

Identified Points of Contention

  • Structural Questions: A primary question will be whether the accused products' "structures to hold" devices and cables meet the claimed limitation of "pairs of holding formations." The patent specification describes these as distinct first and second compartments, one for the phone and one for the charger block (’542 Patent, col. 5:48-53). The complaint's description may suggest a less structured organizer.
  • Technical Questions: The complaint alleges the accused products hold "charging cables" (Compl. ¶15), whereas Claim 1 requires a formation to hold a "mobile telephone charger having pins" (’542 Patent, col. 6:27-29). This raises the question of whether the accused products are merely cable organizers or if they actually house the entire charger block as depicted in the patent's figures (e.g., Fig. 3, element 46).

V. Key Claim Terms for Construction

The Term: "a mobile telephone charger having pins"

Context and Importance

This term is critical because it defines what is held in the "second formation." The infringement analysis may hinge on whether the accused products, which are alleged to hold "charging cables" (Compl. ¶15), also hold the entire charger block itself, which contains the "pins" that plug into a socket. Practitioners may focus on this term because a device that only manages USB cables, without housing the AC adapter block, may not meet this limitation.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The term is not explicitly defined, which could support an argument for its plain and ordinary meaning, encompassing any part of the charging apparatus with electrical contacts.
  • Evidence for a Narrower Interpretation: The specification consistently shows the entire charger block (46) being placed into the second compartment (24) and its AC prongs ("pins") plugging into an internal socket (26) (’542 Patent, Fig. 3; col. 6:18-24). This consistent depiction may support a narrower construction limited to the AC adapter portion of the charger.

The Term: "pairs of holding formations"

Context and Importance

This term is central to the claimed structure. The case may turn on whether the accused products' "structures" (Compl. ¶15) have the specific paired relationship required by the claim. If the accused products are simply a tray with cable clips, it raises the question of whether this constitutes "pairs" of "formations."

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The claim language itself does not mandate that the formations be fully enclosed compartments, potentially allowing for more open structures like slots or brackets to qualify.
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the formations as "compartments" (e.g., "first compartment 22" and "second compartment 24") separated by a "partition wall" (38), suggesting a more defined and separated structure (’542 Patent, col. 5:48-53; col. 6:59-60).

VI. Other Allegations

Indirect Infringement

The complaint includes a claim for inducement, alleging on "information and belief" that Defendants actively induce others to use the infringing Charging Stations (Compl. ¶29). It further alleges that Defendants are "aware of the '542 patent" and induced infringement with "deliberate disregard" for Plaintiffs' rights (Compl. ¶31). The complaint does not, however, plead specific facts supporting knowledge or intent, such as referencing user manuals or advertising materials that instruct on an infringing use.

Willful Infringement

The complaint does not use the term "willful," but the allegation of inducement in "deliberate disregard for the rights of Plaintiffs" (Compl. ¶31) and the prayer for "punitive or other exemplary damages" (Prayer for Relief, ¶A) lay the groundwork for a willfulness claim. The basis appears to be knowledge of the patent itself, though the complaint does not specify whether this knowledge was pre-suit or post-suit.

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

  1. A core issue will be one of definitional scope: does the claim term "mobile telephone charger having pins," which the patent specification depicts as an AC adapter block, read on the accused products which are alleged in the complaint to hold "charging cables"?
  2. A second central issue will be structural equivalence: do the accused products possess the claimed "pairs of holding formations," which the patent illustrates as distinct, partitioned compartments, or do they employ a more generalized organization structure that falls outside the claim scope?
  3. An underlying evidentiary question will be whether the facts, once developed through discovery, can substantiate the complaint's conclusory allegations of infringement, particularly regarding the internal electrical configuration of the accused "Charging Stations," a topic on which the complaint provides no detail.