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: Digao International Ltd. (Hong Kong)
  • Plaintiff's Counsel: Keyhani LLC; Naman Howell Smith & Lee, PLLC
• Case Identification: 1:26-cv-00475, W.D. Tex., 07/02/2026
• Venue Allegations: Venue is alleged to be proper on the basis that the Defendant is not a resident of the United States.
• Core Dispute: Plaintiff alleges that Defendant's backpacks and bags featuring integrated USB charging ports infringe four U.S. patents related to systems for convenient on-the-go charging of electronic devices.
• Technical Context: The technology involves embedding a USB port on the exterior of a bag, connected by an internal cable to a user-supplied power bank, allowing devices to be charged without opening the bag.
• Key Procedural History: The complaint notes that Plaintiff has previously litigated some of the patents-in-suit against competitors, including a case against Wenger S.A. in the same court (W.D. Tex.) where a claim construction opinion was issued for the '071 and '138 patents.

Case Timeline

Date	Event
2014-11-18	Earliest Priority Date for all Patents-in-Suit
2016-01-01	Defendant's related entity "Dongguan Digao Trading Co., Ltd." was founded
2020-02-25	U.S. Patent No. 10,574,071 Issued
2021-02-23	U.S. Patent No. 10,931,137 Issued
2021-02-23	U.S. Patent No. 10,931,138 Issued
2023-01-01	Defendant begins sponsorship of Corpus Christi Football Club
2023-03-07	U.S. Patent No. 11,601,009 Issued
2026-07-02	First Amended Complaint Filed

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

U.S. Patent No. 10,574,071 - "Bag or Luggage with USB Charging Connector" (issued Feb. 25, 2020)

The Invention Explained

• Problem Addressed: The patent's background describes the inconvenience of charging portable electronic devices while traveling, which often requires a user to open their bag to access a portable power source (Complainant alleges this at Compl. ¶9; '071 Patent, col. 1:21-30).
• The Patented Solution: The invention is a bag or piece of luggage that integrates a complete charging system. It includes an internal space for a power storage device, a USB extension cable running from that internal space to the bag's exterior, and a power cable outlet on the outside surface. The external female USB connector is protected by a "water proof sheath" that covers three of its sides, leaving the operative end exposed for easy access '071 Patent, col. 1:40-54 '071 Patent, col. 6:5-11
• Technical Importance: This configuration allows a user to charge a device conveniently without opening their bag, while providing environmental protection for the external connection port '071 Patent, col. 2:26-32

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶34
• The essential elements of Claim 1 include:
  • A bag or luggage body with an internal placing space for a power storage device and an external power cable outlet.
  • A USB extension cable with a male connector (for the internal power source) and a female connector (for the external port).
  • The female connector is retained outside, adjacent to the power cable outlet.
  • A "water proof sheath" that covers three sides of the female connector, provides it in a flat position, and is positioned above and covers the power cable outlet.
  • The sheath does not cover the "operative end" of the female connector, which is "exposed and fixedly attached" to the bag's exterior.

U.S. Patent No. 10,931,137 - "Sheath for USB Charger" (issued Feb. 23, 2021)

The Invention Explained

• Problem Addressed: The patent addresses the need for a convenient charging solution that can be incorporated into not just bags but also a wider array of items, including clothing and other wearables '137 Patent, col. 1:30-40
• The Patented Solution: The invention focuses on a specific "sheath" component designed to be integrated into a "body" (such as a bag or jacket). The sheath receives and holds a female USB cable, positioning the connector's operative end in a flat, uncovered position above the body's outer surface for easy access. The claim specifies that the operative end is "removably retained," suggesting the cable can be detached from the sheath '137 Patent, col. 1:41-59 '137 Patent, abstract '137 Patent, col. 6:65-67
• Technical Importance: This invention modularizes the charging port, creating a discrete component (the sheath) that can be integrated by manufacturers into a diverse range of soft goods to add charging functionality '137 Patent, col. 1:30-40

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 Compl. ¶52
• The essential elements of Claim 1 include:
  • A sheath with a specific geometry (left, top, right sides; tapered closed end; open end; surrounding bottom portion).
  • The sheath extends above the outer surface of a body that has an inner surface, outer surface, and a power cable outlet.
  • The sheath receives a female end of a USB cable.
  • The operative end of the USB cable is "removably retained" in the sheath's open end, held in a flat position, and is uncovered.
  • The sheath's surrounding bottom portion is attached to the inner surface of the body.
  • The sheath has at least one "ventilation opening" on its top side.

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

• Patent Identification: U.S. Patent No. 10,931,138, "Sheath for USB Charger," issued Feb. 23, 2021 Compl. ¶11
• Technology Synopsis: The patent describes a sheath for integrating a USB charging port into various items. The sheath is designed to hold the female end of a USB cable in a flat, externally accessible position for convenient charging, while the cord passes through an opening in the item's body to an internal power source. The claims detail the specific path of the cord and the attachment of the sheath's bottom portion to the body '138 Patent, abstract
• Asserted Claims: At least claim 6 Compl. ¶71
• Accused Features: The complaint accuses the integrated USB charging port system in the Accused Deego Backpacks, specifically the sheath component that houses the external USB port and its method of attachment to the backpack Compl. ¶¶82-88

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

• Patent Identification: U.S. Patent No. 11,601,009, "Sheath for Convenient Charging," issued Mar. 7, 2023 Compl. ¶12
• Technology Synopsis: The patent discloses a sheath as a separate component that attaches to a body (e.g., a bag) to create an external charging port. It claims a structure where the sheath holds a female cable connector externally for easy access, with the cord passing through a port in the body to connect to an internal power source. The claims emphasize that the sheath is a "separate" piece from the body '009 Patent, abstract '009 Patent, claim 1
• Asserted Claims: At least claim 6 Compl. ¶90
• Accused Features: The complaint alleges that the "external USB port" in the accused backpacks is a separate sheath piece attached to the bag body, thereby infringing this patent Compl. ¶103

III. The Accused Instrumentality

• Product Identification: The "Accused Deego Backpacks," which include models sold under the brands "Matein," "Yorepek," "Taygeer," and "Mancro" Compl. ¶14 Compl. ¶18
• Functionality and Market Context: The accused products are backpacks featuring an "External USB Port with built-in charging cable" Compl. ¶30 This feature allows a user to charge an electronic device by plugging it into the external port, which is connected via an internal cable to a power bank stored inside the backpack Compl. ¶¶46-48 The complaint includes a marketing image from Defendant's sales materials that shows the backpack and describes how the "USB Port Outside & Charging Cable Inside" allows users to charge devices "without opening up the bag" Compl. p. 10 The complaint alleges these are "top-selling backpacks" and that Defendant's North American sales constitute 45% of its worldwide business Compl. ¶18 Compl. ¶19

IV. Analysis of Infringement Allegations

10,574,071 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a bag or luggage body having a placing space for placing a power storage device inside the bag or luggage body and a power cable outlet on the outer surface of the bag or luggage body;	The accused backpacks have an internal space for a power bank and a power cable outlet on the exterior.	¶46	col. 5:51-54
a USB extension cable having a male connector and a female connector having four sides and an operative end,	The accused backpacks include a USB extension cable with both male and female connectors.	¶47	col. 5:55-57
wherein the male connector of the USB extension cable is inside the bag or luggage body and is used to connect to the power storage device in the placing space;	The male connector of the cable is inside the backpack and connects to the user's power bank.	¶48	col. 6:1-4
wherein the female connector is retained outside and adjacent to the power cable outlet with one side of the four sides of the female connector in communication with the bag or luggage body, and the other three sides of the female connector are covered by a water proof sheath...	The external female connector is housed in a "water proof sheath" that covers three of its sides.	¶49	col. 6:5-11
wherein the sheath does not cover the operative end of the female connector which is exposed and fixedly attached above the exterior of the bag...	The operative end of the female connector is exposed, uncovered by the sheath, and fixedly attached to the exterior of the bag.	¶50	col. 6:12-19

10,931,137 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a sheath having a left side, top side and right side, a first tapered closed end, a second open end and a surrounding bottom portion...	The accused backpacks include a sheath with the specified geometry for housing the USB port.	¶64	col. 6:51-55
wherein at least a portion of the sheath extends above an outer surface of a body, wherein the body has an inner surface, an outer surface and a power cable outlet...	A portion of the accused sheath extends above the bag's outer surface, and the bag has an inner/outer surface and a cable outlet.	¶65	col. 6:56-60
wherein the sheath is at the power cable outlet and the sheath receives a female end of a USB cable having four sides, an operative end and a cord end,	The accused sheath is at the power cable outlet and receives the female end of a USB cable.	¶66	col. 6:61-64
wherein the operative end of the female end of the USB cable is removably retained in the second open end of the sheath... to provide the female end of the UBS cable in a flat position with the operative end... being uncovered and above the outer surface of the body,	The operative end of the USB cable is uncovered, held in a flat position, and removably retained.	¶67	col. 6:65-col. 7:2
wherein the surrounding bottom portion is attached to the inner surface of the body,	The bottom portion of the sheath is attached to the inner surface of the backpack body.	¶68	col. 7:3-4
wherein the sheath has at least one ventilation opening on the top side.	The sheath on the accused backpacks has ventilation openings on its top side.	¶69	col. 7:5-6

Identified Points of Contention

• Scope Questions: A potential dispute for the '071 Patent is whether the housing for the external port on the accused backpacks constitutes a "water proof sheath" that "covers" three sides of the connector, as required by the claim. For the '137 Patent, a question is whether the USB cable is truly "removably retained," or if it is permanently affixed in a way that falls outside the claim's scope.
• Technical Questions: The infringement allegation for the '137 Patent hinges on the presence of specific features like "ventilation opening[s]" Compl. ¶69 A factual question will be whether the accused products have structures that are specifically designed for ventilation, or if the Plaintiff is interpreting general material properties (like the weave of a fabric) as meeting this limitation.

V. Key Claim Terms for Construction

• The Term: "water proof sheath" '071 Patent, claim 1

  • Context and Importance: The definition of this term is critical for the '071 Patent infringement analysis. Practitioners may focus on this term because the Defendant may argue that the accused product's plastic port housing is not a "sheath" and does not meet the "water proof" standard implied by the patent.
  • Intrinsic Evidence for a Broader Interpretation: The specification describes a "sheath (3) wrapped on the outer surface of the female connector (2-2) for water proofing," which may suggest any protective covering intended to resist moisture could qualify '071 Patent, col. 5:9-11
  • Intrinsic Evidence for a Narrower Interpretation: The specification also states that the "charging interface is featured with waterproof and dust-proof functions, resulting in reliable performance," which could imply a higher standard of protection than a simple plastic bezel might offer '071 Patent, col. 2:30-32

• The Term: "removably retained" '137 Patent, claim 1

  • Context and Importance: This term is central to the infringement theory for the '137 Patent. Its construction will determine whether a permanently or semi-permanently installed cable can infringe.
  • Intrinsic Evidence for a Broader Interpretation: The complaint alleges that the Defendant's own website provides instructions on "How to Remove USB Port Built in the Backpack to wash the body of the bag," which directly supports an interpretation that "removably" includes removal for maintenance, even if it is not instantaneous Compl. ¶30
  • Intrinsic Evidence for a Narrower Interpretation: The term itself may suggest a user-friendly, tool-less removal process. The patent specification does not provide a specific definition or embodiment of the removal mechanism, leaving the term open to interpretation based on its plain and ordinary meaning.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement allegations are based on Defendant's marketing materials, online instructions that teach customers how to use the allegedly infringing feature, and its affiliate programs that encourage third parties to promote the products (Compl. ¶28; Compl. ¶29; Compl. ¶30). The contributory infringement allegations assert that the accused backpacks are not suitable for substantial non-infringing use Compl. ¶39 Compl. ¶57
• Willful Infringement: The complaint alleges willful infringement, asserting that Defendant had pre-suit knowledge of the patents-in-suit. The basis for this allegation includes Defendant's alleged market research, the similarity of its products to Plaintiff's patented and marked products, and, notably, the public nature of Plaintiff's prior patent litigations against Defendant's competitors involving the same technology and patents Compl. ¶31 Compl. ¶32 Compl. ¶43

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

• A core issue will be one of claim construction, particularly how the court defines "water proof sheath" ('071 patent) and "removably retained" ('137 patent). The court's previous claim construction ruling in a related case may heavily influence, if not control, the outcome of this dispute.
• A key evidentiary question will be one of technical and factual correspondence: do the physical structures of the accused backpacks-specifically the material and construction of the external port housing and the method of securing the internal cable-factually align with the specific limitations recited in the asserted claims, such as the "ventilation opening" requirement?
• The viability of the willfulness claim will be a central focus, turning on what evidence emerges regarding Defendant's pre-suit knowledge. The Plaintiff's reliance on prior, publicized lawsuits against Defendant's direct competitors raises a significant question of whether Defendant proceeded with a high degree of culpability or willful blindness to Plaintiff's patent rights.