The asserted patents in the "Non-Dongling" Dongle Gear Investigation

Canon has asserted nine recently obtained patents against 42 respondents in a patent infringement complaint filed with the ITC at the beginning of March 2018.

Utility patents have two types of claims which are known as either "Independent" or "Dependent" claims. If a respondent can prove an independent claim is not infringed, then none of its dependent claims can be infringed. Likewise with invalidity, if a respondent is able to prove an independent claim is invalid, then all its dependent claims will also be invalid.

The nine patents asserted against the respondents in the ITC complaint have a total of 193 claims, of which twenty-eight are independent claims. It is the independent claims where the respondents must focus their efforts to prove non-infringement or invalidity.

In its complaint, Canon has identified nine different versions of aftermarket dongle gears and labeled then A - I. The chart below contains a summary of which independent claims are asserted against which aftermarket gear designs. The nine aftermarket designs are then ranked left to right according to the number of independent claims they are accused of infringing. For example, design B is alleged to infringe 11 of the 28 independent claims, whereas design D is alleged to infringe 16 of the 28 independent claims.

The nine aftermarket versions fall into two groups - group A, including designs B, F, G, H, & I, are all alleged to infringe the same 11 of 28 independent claims and group B, including designs E, A, C, & D, all alleged to infringe 15 or 16 of the 28 independent claims.




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