Swissdigital USA Co Ltd v. Dongguan Digao Trading Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Swissdigital USA Co., Ltd. (Delaware)
  • Defendant: Dongguan Digao Trading Co., Ltd. and Dongguanshi Digao Innovation Technology Co., Ltd. (China)
  • Plaintiff's Counsel: Keyhani LLC; Naman Howell Smith & Lee, PLLC
• Case Identification: 1:26-cv-475, W.D. Tex., 02/27/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendants are not residents of the United States and may be sued in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant's backpacks and bags equipped with external USB charging ports infringe four U.S. patents related to integrated charging systems for luggage and wearables.
• Technical Context: The technology involves integrating a pass-through USB port and internal cabling into soft goods like backpacks, allowing users to connect an internal power bank to charge external devices without opening the bag.
• Key Procedural History: The complaint notes that Plaintiff has previously litigated against competitors including Wenger S.A. and Samsonite International S.A. Notably, it states that the court in the Wenger case conducted a claim construction hearing and issued an opinion concerning U.S. Patent Nos. 10,574,071 and 10,931,138, two of the patents-in-suit in the present case.

Case Timeline

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

U.S. Patent No. 10,574,071 - "Bag or Luggage with USB Charging Connector"

• Patent Identification: U.S. Patent No. 10,574,071, titled "Bag or Luggage with USB Charging Connector," issued on February 25, 2020 (the '071 Patent).

The Invention Explained

• Problem Addressed: The patent addresses the inconvenience for travelers and others who need to charge portable electronic devices on the go Compl. ¶11 It notes that conventional methods require opening the bag or luggage to access a portable power source, which is cumbersome Compl. ¶11 '071 Patent, col. 1:26-29
• The Patented Solution: The invention is a bag or piece of luggage with an integrated charging system Compl. ¶11 It provides an internal space for a power storage device (like a power bank) and features a USB extension cable that runs to a "power cable outlet" on the bag's exterior '071 Patent, col. 1:40-54 A male USB connector remains inside the bag to connect to the power bank, while a female USB connector is positioned at the external outlet, allowing a user to plug in a device for charging without accessing the bag's interior '071 Patent, abstract The external female connector is protected by a "water proof sheath" '071 Patent, col. 5:64-67
• Technical Importance: This solution provides a more convenient and accessible method for on-the-go charging by externalizing the connection port while keeping the bulkier power source secured inside the bag Compl. ¶11

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶26
• The essential elements of claim 1 include:
  • A bag or luggage body with an internal space for a power storage device and an external power cable outlet.
  • A USB extension cable with a male connector and a female connector.
  • The male connector is located inside the bag body for connection to the power storage device.
  • The female connector is retained outside and adjacent to the power cable outlet.
  • A "water proof sheath" covers three sides of the female connector, protecting it and holding it in a flat position.
  • The sheath does not cover the "operative end" of the female connector, which remains exposed and fixedly attached for easy access.

U.S. Patent No. 10,931,137 - "Sheath for USB Charger"

• Patent Identification: U.S. Patent No. 10,931,137, titled "Sheath for USB Charger," issued on February 23, 2021 (the '137 Patent).

The Invention Explained

• Problem Addressed: Similar to the '071 Patent, this patent addresses the need for convenient charging of personal devices, but broadens the application beyond bags to include activewear and other wearable items Compl. ¶12 '137 Patent, col. 1:30-40
• The Patented Solution: The invention focuses on the structure of the "sheath" that houses the female end of a USB cable Compl. ¶12 The claimed sheath has specific geometric features: a left side, top side, and right side; a "first tapered closed end"; a "second open end"; and a surrounding bottom portion for attachment '137 Patent, claim 1 This structure is designed to be mounted at a "power cable outlet" on a body (e.g., a backpack strap), receive the female USB connector, and hold it in a stable, flat position with the operative end uncovered for easy access '137 Patent, abstract '137 Patent, col. 5:22-29
• Technical Importance: The patent claims a specific physical housing for an external charging port, intended to provide a secure, weather-resistant, and user-friendly integration on various types of personal articles Compl. ¶12

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶26
• The essential elements of claim 1 include:
  • A sheath with a left, top, and right side, a first tapered closed end, a second open end, and a surrounding bottom portion.
  • The sheath extends above the outer surface of a "body" which has an inner surface, outer surface, and a power cable outlet.
  • The sheath is located at the power cable outlet and receives a female USB cable end.
  • The operative end of the female USB cable is "removably retained" in the second open end, while the cord end is retained in the first tapered closed end.
  • This configuration provides the female end in a "flat position" with the operative end "uncovered and above the outer surface of the body."
  • The surrounding bottom portion is attached to the inner surface of the body.

U.S. Patent No. 10,931,138 - "Sheath for USB Charger"

• Patent Identification: U.S. Patent No. 10,931,138, titled "Sheath for USB Charger," issued on February 23, 2021 (the '138 Patent) Compl. ¶13
• Technology Synopsis: This patent describes a sheath for convenient charging that is characterized by having a "raised portion" that extends above the outer surface of a body Compl. ¶84 The raised portion contains a USB opening to receive the female end of a USB cable Compl. ¶84
• Asserted Claims: The complaint asserts independent claim 23 Compl. ¶26
• Accused Features: The complaint alleges that the "raised external USB port" of the Accused Deego Backpacks infringes this patent Compl. ¶84

U.S. Patent No. 11,601,009 - "Sheath for Convenient Charging"

• Patent Identification: U.S. Patent No. 11,601,009, titled "Sheath for Convenient Charging," issued on March 7, 2023 (the '009 Patent) Compl. ¶14
• Technology Synopsis: This patent is similar to the '138 Patent but further specifies that the sheath is a "separate piece that attaches to a body" Compl. ¶102 When attached, its raised portion extends above the body's outer surface to present the charging port Compl. ¶102
• Asserted Claims: The complaint asserts independent claim 29 Compl. ¶26
• Accused Features: The complaint alleges that the sheath in the Accused Deego Backpacks is a separate piece sewn between the inner and outer fabric of the bag, thereby infringing this patent Compl. ¶102

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are the "Accused Deego Backpacks," which include, but are not limited to, the Matien Mlassic Travel Laptop Backpack, the Yorepek Travel Backpack, the Taygeer Travel Backpack, and the Matein NTE Laptop Backpack Compl. ¶19

Functionality and Market Context

• The relevant feature of the accused backpacks is an "External USB Port with built-in charging cable" Compl. ¶31 This feature is marketed as providing "a more convenient and easier way to charge your phone" and allowing users to "charge your devices without opening up the bag" Compl. ¶31 An image in the complaint from a product listing shows the external port and an internal cable for connecting to a power bank. Compl. p. 10
• The complaint alleges that Defendants' products are "top-selling backpacks on www.amazon.com" and that Defendants conduct business in over 100 countries Compl. ¶19 A graphic from Defendants' website included in the complaint identifies certain accused products as "Amazon #1/2/4/6 TOP SELLING". Compl. p. 7

IV. Analysis of Infringement Allegations

'071 Patent Infringement Allegations

'137 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The dispute may turn on the construction of structural terms. For the '071 Patent, the meaning of "water proof sheath" could be a point of contention. For the '137 Patent, the specific definitions of "first tapered closed end" and how the operative and cord ends are "retained" will likely be critical.
  • Technical Questions: A key factual question will be whether the accused products' sheaths meet the precise structural and relational limitations of the claims. For example, does the accused sheath's structure cause the cord end to be "retained in the first tapered closed end" in the manner required by claim 1 of the '137 Patent, or is there a functional or structural difference?

V. Key Claim Terms for Construction

'071 Patent, Claim 1

• The Term: "water proof sheath"
• Context and Importance: This term is central to the claimed protection for the external connector. The scope of "water proof" will determine what level of protection an accused product must provide to infringe. Practitioners may focus on this term because its construction could distinguish the claimed invention from a simple cosmetic cover.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not define "water proof" with a specific standard (e.g., an IP rating). It describes the sheath as being for "water proofing" generally, which may support a construction covering any feature that provides some resistance to water '071 Patent, col. 2:51-54
  • Evidence for a Narrower Interpretation: The specification describes the sheath as being "wrapped on the outer surface of the female connector" '071 Patent, col. 3:23-25 This, combined with the term "sheath," may suggest a more form-fitting or complete covering on the required three sides, rather than a simple hood or flap that offers minimal protection.

'137 Patent, Claim 1

• The Term: "first tapered closed end"
• Context and Importance: This term defines a key structural feature of the claimed sheath, which is allegedly responsible for retaining the "cord end" of the female USB cable. The definition of this term is critical because it distinguishes the claimed sheath from a simple open-ended sleeve or pocket.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the "sheath tapers down from the four sides to the first tapered closed end" and that this "serves the purpose to accommodate the cord end... such that it is retained" '137 Patent, col. 5:25-30 This could support a functional definition where any structure that narrows to retain the cord end meets the limitation.
  • Evidence for a Narrower Interpretation: Figure 12 of the patent shows a distinct and significant taper (1208) relative to the open end (1210). A defendant may argue that the term requires a specific degree or type of taper as depicted in the embodiments, not just any slight narrowing.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The basis for inducement includes Defendants' marketing materials, website instructions, and technical support which allegedly encourage customers to use the backpacks in an infringing manner Compl. ¶31 Compl. ¶37 The complaint also points to Defendants' active recruitment of distributors and operation of an "Affiliate Program" as acts of inducement Compl. ¶¶29-30
• Willful Infringement: The complaint alleges willful infringement based on Defendants' alleged knowledge of the patents-in-suit Compl. ¶44 This knowledge is allegedly based on Defendants' market research, the public nature of Plaintiff's litigation against competitors involving the same patents, and the similarity of the accused products to Plaintiff's own patented and marked products Compl. ¶33

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

• A core issue will be one of claim construction and structural correspondence: can the specific geometric and relational limitations recited in the patent claims-such as "water proof sheath" ('071 Patent) and "first tapered closed end" that "retains" a cord end ('137 Patent)-be read to cover the precise physical structures used in the accused backpacks? The outcome may depend heavily on the interpretation given to these terms, potentially informed by the prior claim construction in the Wenger litigation.
• A key evidentiary question will be one of knowledge and intent: what evidence can Plaintiff produce to demonstrate that Defendants, as foreign entities, had the requisite pre-suit knowledge of the specific patents-in-suit to support the claims for willful and induced infringement, beyond general assertions of market awareness?
• A final question will be the distinction between the asserted patents: with four patents in the same family asserted, the case will likely require a careful analysis of the asserted claims to determine if the accused products practice the distinct features of each patent-for example, the "raised portion" of the '138 Patent versus the "separate piece" construction of the '009 Patent.