DCT
2:25-cv-00507
Yakar Tech LLC v. Zagg Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Yakar Technologies, LLC (Texas)
- Defendant: Zagg Inc. (Delaware / Utah)
- Plaintiff’s Counsel: Ramey LLP
- Case Identification: 2:25-cv-00507, D. Utah, 06/24/2025
- Venue Allegations: Venue is based on Defendant Zagg Inc. having a principal place of business in Midvale, Utah, which is within the District of Utah.
- Core Dispute: Plaintiff alleges that Defendant’s phone accessories infringe two patents related to magnetic mounts for electronic devices that include a secondary, physical support leg.
- Technical Context: The technology concerns mounts for securing mobile electronic devices, such as smartphones and tablets, that combine magnetic attraction with a foldable mechanical leg for enhanced stability.
- Key Procedural History: The complaint states that Plaintiff is a non-practicing entity and has previously entered into settlement licenses with other entities. Plaintiff argues these licenses did not authorize the production of patented articles and therefore did not trigger patent marking requirements under 35 U.S.C. § 287.
Case Timeline
| Date | Event |
|---|---|
| 2014-07-23 | Priority Date for '309 and '058 Patents |
| 2017-12-19 | '058 Patent Issued |
| 2021-06-15 | '309 Patent Issued |
| 2025-06-24 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,034,309 - “Heavy Duty Magnet Mount” (issued June 15, 2021)
The Invention Explained
- Problem Addressed: The patent describes a problem with existing mounts for electronic devices, noting that as devices become larger and heavier, simple magnetic mounts may not be strong enough to hold them securely, particularly in a moving vehicle. (’309 Patent, col. 1:31-40). It also notes that placing a required ferromagnetic plate on the exterior of a device is often considered "distracting or unsightly" by users. (’309 Patent, col. 1:44-46).
- The Patented Solution: The invention combines a standard magnetic mount with at least one foldable, extendible leg that provides additional physical support. The leg is designed to move from a stored position, where it is flush with the mount’s face, to a support position, where it is substantially perpendicular to the face to hold the device. (’309 Patent, col. 2:2-7). This dual-support system is intended to work with a ferromagnetic element that is positioned inside a device’s case or cover, hiding it from view. (’309 Patent, col. 5:1-17, FIG. 16).
- Technical Importance: This design seeks to provide a more reliable mounting solution for heavy electronic devices by supplementing magnetic force with direct physical support, while also improving aesthetics by concealing the metal plate. (’309 Patent, col. 1:31-49).
Key Claims at a Glance
- The complaint asserts independent Claim 1 and dependent claims 2-9. (Compl. ¶17).
- Independent Claim 1 requires:
- A ferromagnetic element shaped and configured to be positionable inside a cover of the electronic device;
- A mount body comprising a magnet, a face plate, and at least one leg, with the magnet secured in the face plate;
- The at least one leg is movable from a stored position to a support position and is configured to directly support the device;
- The at least one leg is adjustably extendible from the mount body; and
- The at least one leg is extendible in a direction coplanar with the face plate and is foldable to a support position that is substantially normal to the face plate.
U.S. Patent No. 9,845,058 - “Heavy Duty Magnet Mount” (issued Dec. 19, 2017)
The Invention Explained
- Problem Addressed: The '058 Patent, which is the parent of the ’309 Patent, addresses the same technical problems of insufficient support from magnet-only mounts for heavy devices and the "unsightly" nature of externally placed ferromagnetic plates. (’058 Patent, col. 1:31-49).
- The Patented Solution: The invention is a mount for an electronic device that includes both a magnet and at least one movable leg to provide physical support. (’058 Patent, Abstract). The claims describe specific configurations of this leg, including as a pair of rotatable extensions or as a single extendible and foldable unit that moves from a stored position coplanar with the mount face to a support position perpendicular to it. (’058 Patent, col. 2:22-27, col. 6:33-49).
- Technical Importance: The technology aimed to improve the reliability of magnetic mounts by adding a configurable mechanical support structure. (’058 Patent, col. 1:31-40).
Key Claims at a Glance
- The complaint asserts independent Claims 1 and 5, and dependent claims 2-4 and 6-10. (Compl. ¶26).
- Independent Claim 1 requires:
- A ferromagnetic element securable to an electronic device;
- A mount body with a magnet, a face plate, and at least one movable leg;
- The leg further comprises a pair of leg extensions that are rotatably mounted to it to form a support for the device.
- Independent Claim 5 requires:
- A mount body comprising a housing, a magnet positioned in an opening of the housing's face, and at least one movable leg;
- The leg comprises an "extendible, foldable leg extension" that can extend "substantially coplanar" to the mount face and fold to a support position "substantially perpendicular" to the mount face.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the accused products as "Zagg's Phone Accessories as provided at https://www.Zagg.com/ and related methods of use," referenced in non-provided Exhibits B, C, E, and F. (Compl. ¶15).
Functionality and Market Context
- The complaint describes the accused products as "mounting devices" for electronic items like cell phones. (Compl. ¶¶17, 19). It alleges that Defendant provides instructions for use on its website and in product manuals. (Compl. ¶¶19-20). The complaint does not provide further technical detail on the specific structure or operation of the accused products or their market position. No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references preliminary claim charts in Exhibits B, C, E, and F, which were not provided. The analysis below is based on the narrative allegations. (Compl. ¶¶18, 27).
'309 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a ferromagnetic element shaped and configured to be positionable inside a cover of the electronic device | The complaint alleges infringement by the Accused Instrumentalities but does not provide specific facts regarding this element. | ¶17 | col. 5:11-17 |
| a mount body... comprising a magnet, a face plate, and at least one leg... configured to directly support the device | The complaint alleges that Zagg’s "mounting devices" possess the features of the claimed invention. | ¶17 | col. 6:11-18 |
| ...the at least one leg is adjustably extendible from the mount body | The complaint does not provide specific detail on the operation of the leg feature of the Accused Instrumentalities. | ¶17 | col. 6:19-21 |
| ...the at least one leg is extendible... coplanar with the face plate, and is foldable... substantially normal to the face plate | The complaint does not provide specific detail on the movement or orientation of the leg feature of the Accused Instrumentalities. | ¶17 | col. 6:22-27 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the accused system requires a ferromagnetic element to be "positionable inside a cover" as specified by the claim, or if it functions differently.
- Technical Questions: What evidence does the complaint provide that the accused mount's support structure, if any, is an "adjustably extendible" leg that moves from a "coplanar" to a "substantially normal" position, as opposed to a different type of stand or support mechanism?
'058 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a ferromagnetic element securable to the electronic device | The complaint alleges infringement but does not provide details on the accused ferromagnetic element. | ¶26 | col. 2:51-52 |
| a mount body... comprising a magnet, a face plate, and at least one leg... | The complaint alleges that Zagg’s "mounting devices" contain the claimed components. | ¶26 | col. 2:53-56 |
| ...the at least one leg further comprises a pair of leg extensions rotatably mounted to the leg... | The complaint does not provide specific detail on whether the accused products contain a leg with rotatable extensions. | ¶26 | col. 3:30-34 |
| Claim Element (from Independent Claim 5) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a mount body... comprising: a housing... a magnet... and at least one leg movable between a stored position and a support position | The complaint alleges Zagg's products are "mounting devices" that infringe but does not detail their internal construction. | ¶26 | col. 6:33-40 |
| ...the at least one leg comprises an extendible, foldable leg extension... extendible substantially coplanar to the mount face... and... foldable... substantially perpendicular... | The complaint does not provide specific facts about the structure or movement of any support feature on the accused products. | ¶26 | col. 6:41-49 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis will turn on whether any support feature on the accused products meets the specific structural definitions of Claim 1 ("a pair of leg extensions rotatably mounted to the leg") or Claim 5 ("an extendible, foldable leg extension").
- Technical Questions: What is the precise mechanical operation of the accused products' support features, and does it align with the claimed functionality of extending "coplanar" with the face and folding to a "perpendicular" support position?
V. Key Claim Terms for Construction
'309 Patent
- The Term: "positionable inside a cover of the electronic device" (Claim 1)
- Context and Importance: This term appears to define the location of the ferromagnetic element relative to the device and its protective case. Its construction is critical because infringement may depend on whether the accused system is designed for use with a metal plate placed inside a separate case, as opposed to being attached directly to the device's housing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification's background discusses attaching a plate to an "external part of the electronic device," which a case might then conceal. (’309 Patent, col. 1:20-22). This could suggest the limitation covers any configuration where a case is present over the plate.
- Evidence for a Narrower Interpretation: The claim language "positionable inside a cover" and the explicit depiction in Figure 16 of a "ferromagnetic plate placement inside a cover" suggest the term requires placement within the case structure itself, not merely being covered by it. (’309 Patent, FIG. 16; col. 2:62-63).
'058 Patent
- The Term: "at least one leg" (Claims 1 and 5)
- Context and Importance: Practitioners may focus on this term because the addition of a physical "leg" to a magnetic mount is presented as a core inventive concept. The specific structure and function of this "leg" (e.g., having "rotatable extensions" in Claim 1 or being "extendible" and "foldable" in Claim 5) will be central to the infringement analysis.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the leg’s general purpose as providing "further support" for "large devices or heavy devices," which might be argued to encompass a wide range of secondary physical support structures. (’058 Patent, col. 3:9-10, col. 5:35-39).
- Evidence for a Narrower Interpretation: The claims provide significant structural detail, such as the leg being "extendible substantially coplanar to the mount face" and "foldable... substantially perpendicular to the mount face." (’058 Patent, col. 6:43-49). The detailed drawings (e.g., FIGS. 4, 17, 19) show a specific mechanical implementation, which could support a narrower construction limited to designs that operate in this precise manner.
VI. Other Allegations
- Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Zagg encourages infringement through its website and product instruction manuals. (Compl. ¶¶19, 28). The contributory infringement claim is based on the allegation that the accused products are not staple commercial goods and have no substantial non-infringing use. (Compl. ¶¶20, 29).
- Willful Infringement: The complaint asserts that Defendant has known of the patents "from at least the filing date of the lawsuit," establishing a basis for post-suit willfulness. (Compl. ¶¶19, 28). It also seeks a declaration of willfulness and enhanced damages should discovery reveal pre-suit knowledge. (Compl. Prayer for Relief ¶e).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "at least one leg", as detailed in the patent specifications with specific coplanar and perpendicular movements, be construed to read on the accused products' support mechanisms? The outcome will depend on whether Zagg’s products embody the specific mechanical structures and motions required by the claims.
- A key evidentiary question will be one of infringement-in-fact: as the complaint lacks specific factual allegations mapping product features to claim elements, a central issue will be what evidence Plaintiff can marshall to prove that the accused "mounting devices" meet every limitation of the asserted claims, particularly the novel "leg" features and the placement of the ferromagnetic element.
- A significant procedural question will concern damages limitation: Plaintiff, a self-identified non-practicing entity, has argued that its prior settlement licenses did not trigger the patent marking requirements of 35 U.S.C. § 287. The court's ruling on this issue will be critical in determining whether Plaintiff can recover pre-suit damages if infringement is found.