DCT

3:26-cv-00636

Vertiv Corp v. Legrand DPC LLC

Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:26-cv-00636, W.D. Tex., Filed 03/05/2026
  • Venue Allegations: Venue is based on allegations that Defendant operates a regular and established place of business within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant's Power Distribution Unit (PDU) products infringe three patents related to the mechanical design of PDU housings, universal power receptacles, and integrated power and environmental monitoring systems.
  • Technical Context: The technology at issue involves power distribution units, which are fundamental components for managing power within the high-density server racks used in modern data centers.
  • Key Procedural History: The complaint alleges that Plaintiff sent a letter to Defendant on or around October 15, 2025, inviting Defendant to license the Asserted Patents. This allegation may be used to support claims of pre-suit knowledge and willful infringement.

Case Timeline

Date Event
2004-12-29 U.S. Patent No. 7,522,036 Priority Date
2009-04-21 U.S. Patent No. 7,522,036 Issued
2013-05-22 U.S. Patent No. 9,728,918 Priority Date
2017-08-08 U.S. Patent No. 9,728,918 Issued
2017-11-02 U.S. Patent No. 10,541,501 Priority Date
2020-01-21 U.S. Patent No. 10,541,501 Issued
2022-07-01 Server Technology, Inc. merges with Defendant
2025-10-15 Plaintiff sends license offer letter to Defendant
2026-03-05 Complaint Filed

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

U.S. Patent No. 9,728,918 - "Distribution Strip"

The Invention Explained

  • Problem Addressed: The patent's background section describes the difficulty of routing thick and often rigid power feed cables from a PDU within the confined space of a server cabinet ʼ918 Patent, col. 1:28-44 Conventional designs where the cable exits straight from the end-face require extra cabinet height or highly flexible cables, which are not always available ʼ918 Patent, col. 1:36-44
  • The Patented Solution: The invention is a distribution strip with a first end face that is angled relative to its side faces, forming an inner angle greater than 105 degrees ʼ918 Patent, col. 2:54-57 This oblique angle allows the feed cable to exit the PDU housing in a predefined direction, facilitating easier routing without requiring complex rotational mechanisms or excess space ʼ918 Patent, col. 2:61-65 The design may also include a tapered depression where the cable passes through, further increasing the degrees of freedom for laying the cable ʼ918 Patent, col. 3:32-44
  • Technical Importance: This design offers greater flexibility for cable management in dense data center environments, where space is at a premium and efficient component layout is critical ʼ918 Patent, col. 2:46-53

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶37
  • Claim 1 requires, among other elements:
    • A distribution strip with a housing defining an inner chamber.
    • A feed cable provided on a first end face.
    • The first end face forms an inner angle of greater than 105° with a side face.
    • A tapered depression is formed in the first end face containing a passage opening for the feed cable.
    • A flexible sealing sleeve surrounds the feed cable in the passage opening.
  • The complaint reserves the right to assert additional claims Compl. ¶38

U.S. Patent No. 10,541,501 - "Apparatus For Providing Power For Multiple Types of Plugs Via A Single Receptacle"

The Invention Explained

  • Problem Addressed: The patent identifies the challenge of designing PDUs for data centers that can accommodate various equipment with different power plug standards (e.g., C14 and C20 plugs) while also maximizing the number of available outlets in a limited space ʼ501 Patent, col. 1:35-47
  • The Patented Solution: The invention provides a single, universal power receptacle designed to accept multiple types of plugs, specifically both C14 and C20 plugs ʼ501 Patent, abstract This is achieved through a unique configuration of the internal electrical terminals that can connect with the different pin sizes and orientations of both plug types ʼ501 Patent, col. 3:35-43 Certain embodiments also include a flange at the base of the receptacle housing that interacts with the shroud of the inserted plug to create a more secure physical connection ʼ501 Patent, col. 5:22-26
  • Technical Importance: This technology increases the density and versatility of PDUs, allowing a single PDU model to support a wider range of server and network equipment, which simplifies data center design and inventory management ʼ501 Patent, col. 4:11-16

Key Claims at a Glance

  • The complaint asserts independent claims 1, 7, and 14 Compl. ¶51
  • Claim 1 requires a receptacle assembly where the electrical terminals are configured to connect with both a C14 and a C20 plug, and the receptacle housing includes a "flange at a base" to provide a "more secure fit."
  • Claim 7 requires a receptacle assembly with terminals configured to connect with both a C14 and a C20 plug, but does not recite the "flange" limitation.
  • Claim 14 requires a multiple receptacle assembly with a plurality of receptacles, each having the features of claim 1, including the "flange at a base."
  • The complaint reserves the right to assert additional claims Compl. ¶52

U.S. Patent No. 7,522,036 - "Integrated Power And Environmental Monitoring Electrical Distribution System"

Technology Synopsis

  • The patent addresses the need for a unified system to monitor both power consumption and environmental conditions (e.g., temperature, humidity, airflow) in a data center ʼ036 Patent, col. 1:46-54 The patented solution is an integrated PDU that contains both power and environmental monitoring systems, which are connected to a network and share a "common interface," such as a series of web pages, for displaying data and configuring alarms from both systems ʼ036 Patent, abstract ʼ036 Patent, col. 2:1-5

Asserted Claims

  • The complaint asserts independent claims 1, 9, and 17 Compl. ¶67

Accused Features

  • The complaint alleges that Defendant's ServerTech PDU product lines, when used in combination with its Server Technology Environmental Sensors, provide an integrated system for monitoring both power and environmental characteristics through a shared, network-accessible interface Compl. ¶5 Compl. ¶66

III. The Accused Instrumentality

Product Identification

  • The Server Technology lines of ServerTech PRO1, PRO2, PRO3x, and PRO4X Power Distribution Units ("PDUs"), which may be used alone or in combination with Server Technology Environmental Sensors Compl. ¶5

Functionality and Market Context

  • The accused products are PDUs designed to distribute electrical power to equipment within server racks Compl. ¶31 The complaint alleges that when these PDUs are used with the accused environmental sensors, they provide an integrated system for monitoring both power consumption and environmental conditions Compl. ¶5 The complaint positions the Defendant as a direct competitor in the data center infrastructure market, alleging that the patented technology is necessary for Defendant to compete with Plaintiff's own product lines Compl. ¶¶32-33

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'918 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A distribution strip for distributing electrical energy for device and/or server cabinets, comprising: an upper, a lower and two lateral elongated side faces and a first and a second end face, which define an inner chamber; The accused ServerTech PRO 4X PDUs are distribution strips with a housing that defines an inner chamber. ¶36; ¶39 col. 3:6-9
a feed cable provided on the first end face for supplying electrical energy and a plurality of connecting means provided on the upper side face... The accused PDUs have a power input cable on an end face and multiple power outlets on a side face. ¶36; ¶39 col. 3:1-5
wherein the first end face forms, with a side face, an inner angle of greater than 105°; The housing of the accused PDUs allegedly has an end face that is angled at greater than 105° relative to a side face. ¶37; ¶39 col. 2:55-57
wherein a depression is formed in the first end face, and a passage opening into the inner chamber is formed for the feed cable in a bottom region of the depression; and wherein the depression is tapered; The angled end face of the accused PDUs allegedly includes a tapered depression where the feed cable passes through. ¶37; ¶39 col. 3:32-41
wherein the passage opening is larger than the feed cable; and wherein a flexible sealing sleeve that surrounds the feed cable is provided...for providing movability of the feed cable... The accused PDUs allegedly include a passage opening for the feed cable that is larger than the cable and contains a flexible sealing sleeve to allow for movement. ¶37; ¶39 col. 4:4-10

'501 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A receptacle assembly, comprising: a receptacle, the receptacle including at least three electrical terminals contained within a receptacle housing... The accused PDUs allegedly contain receptacle assemblies with at least three electrical terminals within a housing. ¶50; ¶53 col. 3:32-35
...wherein the at least three electrical terminals of the receptacle are configured to connect with one plug of multiple types of plugs, the multiple types of plugs including a C14 plug and a C20 plug... The receptacles in the accused PDUs are allegedly configured to accept both C14 and C20 power plugs. ¶51; ¶53 col. 3:35-43
...the receptacle housing including a flange at a base of the receptacle housing to provide a more secure fit between the receptacle housing and one plug of multiple types of plugs... The receptacle housing in the accused PDUs allegedly includes a flange at its base that provides a secure fit for the inserted plugs. ¶51; ¶53 col. 5:22-26

Identified Points of Contention

  • Scope Questions: For the '918 Patent, a central issue may be whether the physical structure of the accused PDUs meets the specific geometric limitations of claim 1, such as the "inner angle of greater than 105°" and the "tapered" depression. For the '501 Patent, a key question for claims 1 and 14 will be whether the accused receptacles include a structure that meets the definition of a "flange at a base" that functions to "provide a more secure fit."
  • Technical Questions: For the '036 Patent, a primary question will be whether the combination of Defendant's PDU and its separate environmental sensors constitutes an integrated "power and environmental monitoring system" where the two subsystems "share the common interface" as required by the claims, or if they operate as distinct systems that can be used together.

V. Key Claim Terms for Construction

The Term: "an inner angle of greater than 105°" ('918 Patent, Claim 1)

  • Context and Importance: This geometric limitation is a core element distinguishing the claimed invention from conventional PDUs with perpendicular (90°) end faces. The infringement analysis for the '918 Patent will depend heavily on how this angle is measured and whether the accused product's structure meets this specific threshold.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Parties may argue the term should be interpreted functionally, in light of the stated purpose to create "a distribution strip which offers a relatively great degree of freedom in the laying of the feed cable" ('918 Patent, col. 2:46-49).
    • Evidence for a Narrower Interpretation: The specification provides a preferred range, stating the angle is "preferably 110° to 120°" ('918 Patent, col. 2:57). A defendant may argue that this context suggests the term should be construed narrowly around this preferred embodiment.

The Term: "flange at a base of the receptacle housing" ('501 Patent, Claims 1 and 14)

  • Context and Importance: This term appears in two of the three asserted independent claims of the '501 Patent. Its construction is critical because it will define the scope of infringement for a key structural feature alleged to provide a "more secure fit" for multiple plug types.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the flange "may include a projecting rim or collar that may surround a receptacle 100 at the base of the receptacle housing" ('501 Patent, col. 5:22-24), suggesting a potentially broad range of structures could qualify.
    • Evidence for a Narrower Interpretation: The specification also describes a specific interaction where the flange creates a "tension fit" with the shroud of a C20 plug and provides a resting surface for the shroud of a C14 plug ('501 Patent, col. 5:35-52). A defendant may argue the term should be limited to structures that perform this specific, detailed function.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement for all three patents, based on Defendant allegedly encouraging or instructing its customers on how to use the accused products in an infringing manner Compl. ¶42 Compl. ¶58 Compl. ¶74 For the '036 Patent, the complaint also alleges contributory infringement, stating that Defendant sells a system knowing it is "specially made or adapted for practicing the invention" and is not a staple article of commerce Compl. ¶75
  • Willful Infringement: The complaint alleges willful infringement for all three patents Compl. ¶47 Compl. ¶63 Compl. ¶80 The asserted basis is Defendant's alleged actual notice of the patents, purportedly from both its general practice of monitoring competitors and, more specifically, from a license offer letter sent by Plaintiff on or around October 15, 2025 Compl. ¶¶28-29

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

  • A core issue will be one of structural correspondence: Do the accused ServerTech PDUs, upon physical inspection and measurement, actually incorporate the precise geometric and structural features required by the claims of the '918 and '501 patents? This includes the end-face angle (>105°), the tapered depression, and the receptacle flange that provides a secure fit for multiple plug types.
  • A key question for the '036 patent will be one of system integration: Does the accused combination of a PDU and separate environmental sensors function as a single, integrated system where the two monitoring components "share the common interface" in the manner claimed, or do they remain functionally distinct products that can be optionally used together?
  • A central question for damages will be willfulness: Did Defendant's alleged continuation of infringing activities after receiving a specific, pre-suit license offer from Plaintiff constitute the kind of egregious conduct necessary to support a finding of willful infringement and a potential award of enhanced damages?