DCT
3:26-cv-00636
Vertiv Corp v. Legrand DPC LLC
Key Events
Amended Complaint
Table of Contents
complaint Intelligence
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vertiv Corp (Ohio)
- Defendant: Legrand DPC, LLC, and Legrand North America, LLC (Delaware)
- Plaintiff's Counsel: Scott Douglass & McConnico LLP; Benesch Friedlander Coplan & Aronoff LLP
- Case Identification: 3:26-cv-00636, W.D. Tex., 06/01/2026
- Venue Allegations: Venue is alleged based on Defendants having a regular and established place of business within the Western District of Texas and having committed acts of infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant's Power Distribution Unit (PDU) products, sold under the ServerTech and Raritan brands, infringe three patents related to PDU design and integrated monitoring capabilities.
- Technical Context: The technology relates to high-density power distribution and monitoring for equipment in data center racks, a critical component of modern digital infrastructure for cloud computing and artificial intelligence.
- 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, which may serve as evidence of pre-suit notice for the purpose of establishing willful infringement. The complaint also notes that the accused ServerTech and Raritan brands were acquired by Defendant through mergers around June and July of 2022.
Case Timeline
| Date | Event |
|---|---|
| 2004-12-29 | '036 Patent Priority Date |
| 2009-04-21 | '036 Patent Issue Date |
| 2014-04-11 | '918 Patent Priority Date |
| 2017-08-08 | '918 Patent Issue Date |
| 2017-11-02 | '501 Patent Priority Date |
| 2020-01-21 | '501 Patent Issue Date |
| 2022-06-30 | Raritan, Inc. merges with Legrand DPC, LLC |
| 2022-07-01 | Server Technology, Inc. merges with Legrand DPC, LLC |
| 2025-10-15 | Plaintiff sends letter to Defendant inviting license discussions |
| 2026-06-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,728,918 - "Distribution Strip"
- Patent Identification: U.S. Patent No. 9,728,918, "Distribution Strip," issued August 8, 2017 Compl. ¶32
The Invention Explained
- Problem Addressed: The patent's background section describes the difficulty of routing thick, rigid power feed cables from conventional, cuboid-shaped power distribution strips (PDUs) within the confined space of a server cabinet ʼ918 Patent, background, col. 1:35-44
- The Patented Solution: The invention is a distribution strip where the end face, from which the power cable exits, is angled at greater than 105 degrees relative to a side face ʼ918 Patent, col. 2:55-58 This oblique angle, combined with a tapered depression at the cable exit point, allows the feed cable to be routed more easily and with a smaller bend radius, saving space and increasing installation flexibility ʼ918 Patent, abstract ʼ918 Patent, col. 3:26-34
- Technical Importance: This design allows a single PDU model to be used in various server cabinet configurations, simplifying inventory and installation for data center operators ʼ918 Patent, col. 2:46-54
Key Claims at a Glance
- The complaint asserts at least independent claim 1 Compl. ¶49
- The essential elements of independent claim 1 are:
- A distribution strip with an upper, lower, two side faces, and two end faces defining an inner chamber.
- A feed cable on the first end face and multiple connecting means on the upper side 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, with a passage opening for the feed cable.
- The passage opening is larger than the feed cable.
- A flexible sealing sleeve is provided in the passage opening to allow for movability of the feed cable.
- The complaint reserves the right to assert additional claims Compl. ¶50
U.S. Patent No. 10,541,501 - "Apparatus For Providing Power For Multiple Types of Plugs Via A Single Receptacle"
- Patent Identification: U.S. Patent No. 10,541,501, "Apparatus For Providing Power For Multiple Types of Plugs Via A Single Receptacle," issued January 21, 2020 Compl. ¶33
The Invention Explained
- Problem Addressed: The patent's background notes that data center PDUs often need different types of receptacles (e.g., C13 and C19) to accommodate different equipment plugs (e.g., C14 and C20), which reduces outlet density and flexibility ʼ501 Patent, background, col. 1:36-46
- The Patented Solution: The patent discloses a universal receptacle designed to accept multiple plug types-specifically, both a C14 plug and a C20 plug-within a single housing ʼ501 Patent, abstract This is achieved through a specific configuration of electrical terminals and a "flange at the base of the receptacle housing" that helps create a secure fit for both of the differently sized plugs ʼ501 Patent, col. 5:21-33
- Technical Importance: This innovation increases the effective outlet density on a PDU and provides data center managers with greater flexibility, as any outlet can connect to multiple equipment types ʼ501 Patent, col. 4:1-15
Key Claims at a Glance
- The complaint asserts at least independent claims 1, 7, and 14 Compl. ¶63
- The essential elements of independent claim 1 include:
- A receptacle assembly with a receptacle containing at least three electrical terminals in a housing.
- The terminals are configured to connect with either a C14 plug or a C20 plug.
- The receptacle housing includes a flange at its base to provide a "more secure fit" for both the C14 and C20 plug types.
- Independent claim 7 is a similar receptacle assembly claim, without the "flange" limitation recited in claim 1 Compl. ¶66
- Independent claim 14 is for a "multiple receptacle assembly" comprising a casing and a plurality of the receptacles described in claim 1 Compl. ¶67
- The complaint reserves the right to assert additional claims Compl. ¶64
U.S. Patent No. 7,522,036 - "Integrated Power And Environmental Monitoring Electrical Distribution System"
- Patent Identification: U.S. Patent No. 7,522,036, "Integrated Power And Environmental Monitoring Electrical Distribution System," issued April 21, 2009 Compl. ¶34
- Technology Synopsis: The patent describes an integrated system for data centers that combines a power distribution unit (PDU) with both a power monitoring system (for metrics like voltage and current) and an environmental monitoring system (for metrics like temperature and humidity). A key aspect is that both monitoring systems "share" a "common interface" accessible via a network connector, providing a unified view of disparate data types ʼ036 Patent, abstract ʼ036 Patent, col. 2:1-5
- Asserted Claims: The complaint asserts at least independent claims 1 (system), 9 (system), and 17 (method) Compl. ¶79
- Accused Features: The accused ServerTech and Raritan PDU products are alleged to infringe by integrating power distribution with power and environmental monitoring functions that are accessible through a common network interface Compl. ¶78
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are various lines of Power Distribution Units (PDUs) and associated environmental sensors sold under the "Server Technology" and "Raritan" brands Compl. ¶¶5-6 Specific product lines named include the ServerTech PRO4X, PRO3x, PRO2, and PRO1 PDUs, as well as the Raritan PX3 and PX4 Rack PDUs Compl. ¶5 Compl. ¶6 The complaint includes a logo for "Server Technology A brand of legrand," which visually links the accused brand to the Defendant Compl. ¶17
Functionality and Market Context
- These products are intelligent PDUs designed for use in data center racks to distribute, monitor, and manage electrical power for servers and other IT equipment Compl. ¶¶2-3 The complaint alleges that these products compete directly with Plaintiff's own PDU products and generate "significant revenue" for the Defendants Compl. ¶45
IV. Analysis of Infringement Allegations
'918 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 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 products are distribution strips with a housing that forms an inner chamber. | ¶49 | col. 2:2-4 |
| 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 products have a feed cable on one end and power outlets on the face of the strip. | ¶49 | col. 2:5-9 |
| wherein the first end face forms, with a side face, an inner angle of greater than 105°; | The accused products allegedly have a first end face that is angled relative to a side face at more than 105 degrees. | ¶49 | col. 2:9-11 |
| 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; | The accused products allegedly feature a depression on the first end face where the feed cable passes into the inner chamber. | ¶49 | col. 3:26-30 |
| wherein the depression is tapered; | The depression in the accused products is allegedly tapered in shape. | ¶49 | col. 3:40-41 |
| wherein the passage opening is larger than the feed cable; | The passage opening in the accused products is allegedly larger than the feed cable. | ¶49 | col. 4:9-11 |
| wherein a flexible sealing sleeve that surrounds the feed cable is provided...for providing movability of the feed cable... | The accused products allegedly include a flexible sleeve around the feed cable to allow for movement. | ¶49 | col. 4:5-8 |
- Identified Points of Contention:
- Scope Questions: A primary question will be geometric and structural: do the accused products physically embody an end face with an "inner angle of greater than 105°" and a "tapered" depression as claimed? Infringement will depend on precise physical measurements of the accused products.
- Technical Questions: A factual question for the court will be whether the accused products contain a "flexible sealing sleeve" and, if so, whether its function is to provide "movability" for the cable, as required by the claim, or for some other purpose such as dust sealing alone.
'501 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a receptacle, the receptacle including at least three electrical terminals contained within a receptacle housing... | The accused products allegedly contain receptacle assemblies with electrical terminals inside a housing. | ¶63 | col. 3:34-36 |
| ...the at least three electrical terminals... 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 terminals in the accused products' receptacles are allegedly designed to connect with both C14 and C20 type plugs. | ¶63 | col. 3:36-43 |
| ...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 multiple types of plugs including the C14 plug and the C20 plug. | The housing of the accused receptacles allegedly includes a flange at its base that provides a secure fit for both C14 and C20 plugs. | ¶63 | col. 5:21-26 |
- Identified Points of Contention:
- Scope Questions: The core of the dispute will likely concern the term "flange." A question for the court is what structure on the accused receptacle qualifies as a "flange" and whether that structure performs the claimed function of providing "a more secure fit" for both C14 and C20 plugs.
- Technical Questions: A key technical question will be how the accused product achieves a "secure fit" for two plugs of different dimensions (the C20 plug being larger than the C14). The analysis will likely focus on whether the accused mechanism operates in the manner described in the '501 Patent specification.
V. Key Claim Terms for Construction
For the '918 Patent
- The Term: "inner angle of greater than 105°"
- Context and Importance: This term is a precise, dispositive limitation for claim 1. Infringement hinges on whether the physical geometry of the accused product meets this specific angular threshold.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party may argue the term should be given its plain and ordinary meaning, as a simple geometric measurement between the two specified faces of the PDU housing ʼ918 Patent, col. 2:9-11
- Evidence for a Narrower Interpretation: A party could argue that the context of the specification, which describes a preferred range of "110° to 120°" ʼ918 Patent, col. 2:57-58 and the purpose of facilitating cable exit ʼ918 Patent, col. 2:60-65, implies the angle must be substantial enough to provide a clear functional advantage over the prior art.
For the '501 Patent
- The Term: "a flange at a base of the receptacle housing to provide a more secure fit"
- Context and Importance: This limitation is critical as it links a specific structure ("flange") to a function ("provide a more secure fit") that is central to the universal receptacle's operation. The definition of this term will determine whether the accused product's stabilizing features fall within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the flange as a "projecting rim or collar" ʼ501 Patent, col. 5:22-23, suggesting any such structure at the base that contributes to stability could be considered the claimed flange.
- Evidence for a Narrower Interpretation: The specification provides specific examples of how the flange creates a secure fit, such as by forming a "tension fit" with a C20 plug's shroud and providing a "contact and rest upon" surface for a C14 plug's shroud ʼ501 Patent, col. 6:35-52 A party may argue the term requires this specific dual-mode functionality, not just general stabilization.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement for all three patents, stating that Defendants "encourage or instruct others, including Defendants' customers, on how to use" the accused products in an infringing manner Compl. ¶54 Compl. ¶70 Compl. ¶86 For the '036 Patent, the complaint also alleges contributory infringement, asserting the accused system is "specially made or adapted for practicing the invention" and is not a staple article of commerce Compl. ¶87
- Willful Infringement: The complaint alleges willful infringement for all three patents Compl. ¶59 Compl. ¶75 Compl. ¶92 The allegations are based on two forms of knowledge. First, it alleges Defendants had notice from the patents' issue dates due to their practice of monitoring competitor patents Compl. ¶¶38-39 Second, it alleges Defendants received specific, actual notice via a letter sent on October 15, 2025, that identified the patents and infringement allegations Compl. ¶40
VII. Analyst's Conclusion: Key Questions for the Case
- A question of physical fact: The dispute over the '918 and '501 patents will likely center on factual, structural comparisons. For the '918 Patent, does the accused PDU's housing meet the specific "greater than 105°" angular limitation? For the '501 Patent, does the accused universal receptacle possess a "flange" that provides the claimed "more secure fit" for two different plug types? Resolution will likely depend on expert analysis of the physical products.
- A question of system integration: For the '036 Patent, the case will likely turn on the interpretation of "common interface." A key issue will be whether the software and hardware architecture of the accused PDUs constitutes a "shared" interface for both power and environmental monitoring systems in the manner required by the claims, or if the systems are sufficiently distinct in their operation.
- A question of intent and damages: The allegation of a pre-suit licensing letter provides a strong basis for the willfulness claim. A central question for the case will be whether Defendant's continued sales after receiving explicit notice of infringement constitute the kind of "willful, wanton, and deliberate" conduct that would justify an award of enhanced damages under 35 U.S.C. § 284.
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