IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`SENKO ADVANCED COMPONENTS,
`INC.,
`
`Plaintiff,
`
`vs.
`US CONEC, LTD.,
`
`Defendant.
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`______________________________________ )
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`Civil Action No. ____________
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`
`
`COMPLAINT
`
`Plaintiff Senko Advanced Components, Inc. ("Senko" or "Plaintiff") makes this
`
`Complaint, including a demand for a jury trial, against Defendant US Conec, Ltd. ("US Conec"
`
`or "Defendant") and alleges as follows:
`
`NATURE OF THE ACTION
`
`1.
`
`This action seeks past and ongoing money damages and permanent injunctive
`
`relief for the Defendant's acts of making, using, selling, offering for sale, and/or importing its
`
`accused MDC and MMC fiber optic connector and adapter products that infringe Senko's rights
`
`in seven issued U.S. patents.
`
`THE PARTIES
`
`2.
`
`Plaintiff Senko is incorporated under the laws of the State of Massachusetts, and
`
`its principal place of business is located at 2 Cabot Road, Suite 103, Hudson, Massachusetts
`
`01749.
`
`US Conec EX1020
`IPR2024-00116
`U.S. Patent No. 11,307,369
`
`

`

`3.
`
`Upon information and belief, Defendant US Conec, Ltd. is a corporation
`
`organized and existing under the laws of the State of Delaware, and its principal place of
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`business is located at 1138 25th St SE, Hickory, North Carolina 28602.
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`JURISDICTION AND VENUE
`
`4.
`
`This action arises under the United States patent laws, 35 U.S.C. § 101, et seq.,
`
`including 35 U.S.C. § 271, et seq. This Court has subject matter jurisdiction under 28 U.S.C. §
`
`1331 and § 1338(a).
`
`5.
`
`This Court has personal jurisdiction over US Conec because, upon information
`
`and belief, US Conec is incorporated under the laws of the State of Delaware and therefore
`
`resides in Delaware. On information and belief, Defendant also regularly conducts business in
`
`this judicial district related to the products at issue in this action. On information and belief,
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`Defendant uses, offers for sale and/or sells its products at issue in this action within this District
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`or otherwise places such products within the stream of commerce with the expectation that they
`
`would be used in this District.
`
`6.
`
`Venue is proper in this judicial district pursuant to 28 U.S.C. § 1400(b) because
`
`US Conec is, upon information and belief, incorporated under the laws of the State of Delaware
`
`and is legally deemed to reside in Delaware.
`
`INTRODUCTION
`
`7.
`
`The parties are competitors in the markets for various types of passive fiber optic
`
`connection components. Traditional customers for the parties' competing products are vendors
`
`who provide fiber optic equipment and solutions to data centers, communication network
`
`providers, and other owners of fiber optic networks. Fiber optic communications require a high
`
`degree of accuracy at each connection point for robust, consistent, and high-speed transmission
`
`of data.
`
`2
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`

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`8.
`
`As demand for bandwidth has increased, networks increasingly use fiber optic
`
`systems instead of traditional copper-electrical systems because of fiber's capacity for higher
`
`speed and reduced maintenance. For example, networks rely on fiber optic components to
`
`connect the switches and servers that underlie high-speed computer and communication systems.
`
`In some fiber optic facilities, for example data centers, millions of connection components of the
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`type sold by the parties are used to connect the optical fibers.
`
`9.
`
`Fiber optic cables hold one or more fibers that run between two points in a data
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`center or communication network. It is challenging to directly connect (e.g., fuse) one optical
`
`fiber to another, so cables are terminated with standard connectors that are configured to plug
`
`into corresponding adapters to make optical connections.
`
`10. Most optical connectors in use today retain the ends of fibers in high-precision
`
`ferrules. The ferrules, in turn, are mounted in a housing or plug frame that attaches to the cable.
`
`Optical connector housings include precise alignment and retention features that correspond to
`
`complementary features of the adapter. Since optical fibers are often less than the diameter of a
`
`human hair, these alignment and retention features have very strict tolerances to ensure the fibers
`
`line up in the adapter. For ease of use, fiber optic connectors can be equipped with extraction
`
`mechanisms that enable them to be disconnected from the adapter after initial mating.
`
`11.
`
`Two types of ferrules are common: cylindrical single-fiber ferrules and
`
`rectangular multi-fiber ferrules. The industry frequently calls multi-fiber ferrules "MT" ferrules.
`
`Various fiber optic connectors have been developed around both types of ferrules.
`
`12.
`
`For many years, fiber optic networks have employed "small form factor" ("SFF")
`
`single-fiber ferrule connectors and adapters. In the United States, the most common type of SFF
`
`single-fiber ferrule connector is an LC Connector, which comprises a 1.25 mm-diameter ferrule
`
`3
`
`

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`in a square connector housing with an integrated upper latch hook for securing the connector to a
`
`mating adapter. Two individual LC connectors are frequently assembled together in a side-by-
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`side configuration to make an LC duplex connector.
`
`13.
`
`The most common multi-fiber ferrule connector in the United States is called an
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`MPO connector. In an MPO connector, there is a single MT ferrule that carries a plurality of
`
`optical fibers. This MPO connector has a rectangular housing and a spring-loaded sleeve and
`
`latching mechanism.
`
`14.
`
`Conventional LC and MPO connector and adapter components have met the
`
`industry's needs for many years. But within a fiber optic network installment, space can be at a
`
`premium. Optoelectronic transceivers have also advanced, creating a need for smaller fiber optic
`
`connection components that can accommodate more fiber connections in the same transceiver
`
`footprint.
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`15.
`
`To meet the industry’s desire for density, Senko has spent years developing a new
`
`generation of connectors and adapters with smaller footprints than the conventional components
`
`described above. These efforts have yielded three all-new connection systems, which the
`
`industry now calls "VSFF," i.e., very small form factor. Senko offers two "duplex" VSFF
`
`connector platforms that utilize two 1.25-mm single-fiber ferrules in each plug and one "multi-
`
`fiber" VSFF connector platform that utilizes an MT ferrule in a plug.
`
`16.
`
`Senko's first VSFF product was a duplex connector platform called "CS". The CS
`
`platform includes duplex connectors and corresponding adapters. The CS connector has a 40%
`
`smaller size than the conventional duplex LC connector.
`
`17.
`
`After the CS connector, Senko released another VSFF duplex connector platform,
`
`called "SN". The SN connectors and adapters allow for even greater density than CS. Compared
`
`4
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`

`

`with conventional LC components, the SN components allow for about three-times the fiber
`
`connection density.
`
`18. Most recently, Senko has begun marketing its SN-MT platform, which includes a
`
`connector and corresponding adapters. The SN-MT connector has a similar mating interface to
`
`the SN connector but uses a multi-fiber ferrule instead of two single-fiber ferrules. The SN-MT
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`connector allows for about 2.7-times as many multi-fiber ferrules to be connected in a given
`
`footprint than the conventional MPO connector.
`
`19.
`
`Shown below is a chart with representative samples of Senko's CS, SN, and SN-
`
`MT connectors and their corresponding adapters:
`
`Product platform
`
`Connector
`
`Adapter
`
`
`
`CS
`
`
`
`SN
`
`
`
`SN-MT
`
`
`
`5
`
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`
`
`
`
`
`
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`
`
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`

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`20.
`
`To achieve these improvements in fiber optic connection density while still
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`meeting industry expectations for accuracy, robustness, and ease of use, Senko made significant
`
`research and development investments. Its research and development led to important
`
`innovations that underlie Senko's three VSFF product platforms. For example, Senko developed
`
`new low-profile push-pull latch interfaces that enable simple, accessible insertion and extraction
`
`of a VSFF connector within a small footprint. Senko also developed new ways to integrate the
`
`high-precision alignment features of connectors and adapters to save space. Additionally, Senko
`
`innovated new ways of enabling connector polarity reversal within the limited size available for
`
`VSFF connectors. Recognizing the importance of these innovations to the next generation of
`
`fiber optic network equipment, Senko consistently sought patent protection for its VSFF
`
`inventions. Seven of the resulting patents are the subject of this lawsuit.
`
`21.
`
`In addition to the VSFF products described above, Senko has numerous other
`
`products that relate to different fiber optic connectivity solutions. Senko understands and values
`
`intellectual property rights that are intended to protect its products and innovation. Senko has
`
`over 200 U.S. patents that cover various features and improvements in the field of fiber optic
`
`connectivity. Over 70 of Senko's patents pertain to VSFF interconnect systems.
`
`22.
`
`US Conec is also marketing two VSFF product lines in direct competition with
`
`Senko's patented VSFF products and in violation of the asserted patents. US Conec's products in
`
`these two product lines are referred to herein as the "Infringing Products."1
`
`1 A list of specific "Infringing Products" currently known to Senko is provided below. See infra
`¶ 69. Senko reserves the right to revise, amend, or supplement the list of Infringing Products as
`the case progresses.
`
`6
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`

`

`23.
`
`The first US Conec VSFF product line is called MDC, which, upon information
`
`and belief, includes a VSFF duplex connector and various mating adapters. The MDC connector
`
`marketed by US Conec has a similar size to Senko's SN connector.
`
`24.
`
`The second US Conec VSFF product line is called MMC, which, upon
`
`information and belief, includes a multi-fiber connector and various mating adapters. The MMC
`
`connector marketed by US Conec has a similar size to Senko's SN-MT connector.
`
`25.
`
`Below is a chart depicting representative Infringing Products that, based on
`
`information and belief, US Conec is selling or offering for sale, in direct competition with
`
`Senko's patented VSFF products:
`
`Product Platform
`
`Connector
`
`Adapter
`
`MDC
`
`MMC
`
`26.
`
`None of US Conec's VSFF products is cross-compatible with any of Senko's
`
`VSFF products. For example, it is not possible to make a direct optical connection between an
`
`SN connector and an MDC connector or an SN-MT connector and an MMC connector.
`
`7
`
`

`

`Likewise, it is not possible to properly mate an SN connector to an MDC adapter, or vice versa,
`
`or to properly mate an SN-MT connector to an MMC adapter, or vice versa.
`
`27.
`
`The above-described Senko and US Conec fiber optic connectivity products are
`
`generally not sold at retail to consumers. They are instead sold most often in bulk quantities to
`
`suppliers that specify these components in bids to supply equipment to a fiber optic network
`
`installation. Together with a lack of cross-compatibility between the parties' respective connector
`
`and adapters, this often leads to the "single-winner" bidding aspect of the competition for sales
`
`between companies such as Senko and US Conec.
`
`28.
`
`These market factors generally mean that for every bid in which a given network
`
`installation chooses to buy US Conec's infringing connectors and adapters, Senko is shut out
`
`completely from making that sale–and often future sales–to that end customer and its vendors.
`
`29.
`
`On information and belief, US Conec has successfully offered its Infringing
`
`Products in direct competition with Senko as part of bidding on at least two recent large-scale
`
`fiber optic network projects. When US Conec's Infringing Products are chosen for such
`
`installations over Senko's patented products, Senko is effectively shut out from being a supplier.
`
`30.
`
`If US Conec is allowed to continue marketing and promoting its infringing MDC
`
`and MMC connector and adapter products, then Senko will continue to suffer irreparable harm,
`
`including loss of sales, market share, profit, and goodwill. This impacts both Senko's sale of the
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`CS, SN, and SN-MT product platforms and also its potential participation in more lucrative sales
`
`of entire data center installations and communication networks. In short, Senko's VSFF
`
`innovation, its current market success, and its accompanying patent rights are deeply threatened
`
`by US Conec's infringement.
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`8
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`

`

`31.
`
`To eliminate further infringement and to recover appropriate legal and equitable
`
`remedies for past and ongoing infringement, Senko brings this action for patent infringement.
`
`THE SENKO ASSERTED PATENTS
`
`32.
`
`Senko has over 200 issued U.S. patents and is actively seeking additional
`
`protection for its innovative products and product features relating to fiber optic connectivity
`
`solutions. While Senko put US Conec on notice of infringement of several additional patents and
`
`claims before bringing this suit, the claims in this Complaint are for infringement of U.S. Patent
`
`Nos. 11,307,369; 11,333,836; 11,340,413; 11,415,760; 10,191,230; 11,181,701; and 11,061,190
`
`(collectively, the "Asserted Patents"). Senko does not waive, and expressly reserves, all rights
`
`and claims for relief against US Conec and others with regard to its patent rights beyond those
`
`set forth in this Complaint.
`
`THE '369 PATENT
`
`33.
`
`U.S. Patent No. 11,307,369 (the "'369 Patent") is entitled "ULTRA - SMALL
`
`FORM FACTOR OPTICAL CONNECTORS USED AS PART OF A RECONFIGURABLE
`
`OUTER HOUSING." The '369 Patent was duly and legally issued on April 19, 2022, by the
`
`United States Patent and Trademark Office. A copy of the '369 Patent is attached to this
`
`Complaint as Exhibit A and incorporated herein by reference.
`
`34.
`
`Senko is the owner and assignee of the '369 Patent and possesses all rights of
`
`recovery under the '369 Patent.
`
`35.
`
`36.
`
`37.
`
`The '369 Patent has not expired and is in full force and effect.
`
`The '369 Patent claims are valid and enforceable.
`
`The '369 Patent relates generally to certain claimed latching and unlatching
`
`features in a very small form fiber optic connector.
`
`9
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`

`

`THE '836 PATENT
`
`38.
`
`U.S. Patent No. 11,333,836 (the "'836 Patent") is entitled "ADAPTER FOR
`
`OPTICAL CONNECTORS." The '836 Patent was duly and legally issued on May 17, 2022, by
`
`the United States Patent and Trademark Office. A copy of the '836 Patent is attached to this
`
`Complaint as Exhibit B and incorporated herein by reference.
`
`39.
`
`Senko is the owner and assignee of the '836 Patent and possesses all rights of
`
`recovery under the '836 Patent.
`
`40.
`
`41.
`
`42.
`
`The '836 Patent has not expired and is in full force and effect.
`
`The '836 Patent claims are valid and enforceable.
`
`The '836 Patent relates generally to a partition-free adapter for aligning and
`
`latching with multiple VSFF connectors.
`
`THE '413 PATENT
`
`43.
`
`U.S. Patent No. 11,340,413 (the "'413 Patent") is entitled "ULTRA - SMALL
`
`FORM FACTOR OPTICAL CONNECTORS USED AS PART OF A RECONFIGURABLE
`
`OUTER HOUSING." The '413 Patent was duly and legally issued on May 24, 2022, by the
`
`United States Patent and Trademark Office. A copy of the '413 Patent is attached to this
`
`Complaint as Exhibit C and incorporated herein by reference.
`
`44.
`
`Senko is the owner and assignee of the '413 Patent and possesses all rights of
`
`recovery under the '413 Patent.
`
`45.
`
`46.
`
`47.
`
`The '413 Patent has not expired and is in full force and effect.
`
`The '413 Patent claims are valid and enforceable.
`
`The '413 Patent relates to a multi-fiber VSFF optical connector with a polarity key
`
`that is integrated with a pullback extraction mechanism.
`
`10
`
`

`

`THE '760 PATENT
`
`48.
`
`U.S. Patent No. 11,415,760 (the "'760 Patent") is entitled "NARROW WIDTH
`
`ADAPTERS AND CONNECTORS WITH PULL TAB RELEASE." The '760 Patent was duly
`
`and legally issued on August 16, 2022, by the United States Patent and Trademark Office. A
`
`copy of the '760 Patent is attached to this Complaint as Exhibit D and incorporated herein by
`
`reference.
`
`49.
`
`Senko is the owner and assignee of the '760 Patent and possesses all rights of
`
`recovery under the '760 Patent.
`
`50.
`
`51.
`
`52.
`
`The '760 Patent has not expired and is in full force and effect.
`
`The '760 Patent claims are valid and enforceable.
`
`The '760 Patent relates generally to a multi-fiber VSFF connector with a low-
`
`profile sliding interface between the connector housing and pullback remote release mechanism.
`
`THE '230 PATENT
`
`53.
`
`U.S. Patent No. 10,191,230 (the "'230 Patent") is entitled "OPTICAL
`
`CONNECTORS WITH REVERSIBLE POLARITY." The '230 Patent was duly and legally
`
`issued on January 29, 2019, by the United States Patent and Trademark Office. A copy of the
`
`'230 Patent is attached to this Complaint as Exhibit E and incorporated herein by reference.
`
`54.
`
`The '230 Patent was the subject of Ex Parte Reexamination Request No.
`
`90/014,456, on February 19, 2020. The Ex Parte Reexamination resulted in issuance of Ex Parte
`
`Reexamination Certificate No. 10,191,230 C1 (the "'230 Reexamination Certificate") on
`
`November 16, 2020. The '230 Reexamination Certificate is attached to this Complaint as Exhibit
`
`F. The '230 Reexamination Certificate amends claims 1, 9, 15, 19, and 23 of the '230 Patent and
`
`adds new claims 26-34.
`
`11
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`

`

`55.
`
`Senko is the owner and assignee of the '230 Patent and '230 Reexamination
`
`Certificate and possesses all rights of recovery under the '230 Patent and '230 Reexamination
`
`Certificate.
`
`56.
`
`The '230 Patent, as amended by the '230 Reexamination Certificate, has not
`
`expired and is in full force and effect.
`
`57.
`
`The '230 Patent claims, as amended by the '230 Reexamination Certificate, are
`
`valid and enforceable.
`
`58.
`
`The '230 Patent and the '230 Reexamination Certificate generally relate to duplex
`
`VSFF connectors with upper and lower couplings that facilitate polarity reversal.
`
`THE '701 PATENT
`
`59.
`
`U.S. Patent No. 11,181,701 (the "'701 Patent") is entitled "OPTICAL
`
`CONNECTORS WITH REVERSIBLE POLARITY AND METHOD OF USE." The '701 Patent
`
`was duly and legally issued on November 23, 2021, by the United States Patent and Trademark
`
`Office. A copy of the '701 Patent is attached to this Complaint as Exhibit G and incorporated
`
`herein by reference.
`
`60.
`
`Senko is the owner and assignee of the '701 Patent and possesses all rights of
`
`recovery under the '701 Patent.
`
`61.
`
`62.
`
`63.
`
`The '701 Patent has not expired and is in full force and effect.
`
`The '701 Patent claims are valid and enforceable.
`
`The '701 Patent generally relates to duplex VSFF connectors with removable latch
`
`elements that facilitate polarity reversal.
`
`12
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`

`

`THE '190 PATENT
`
`64.
`
`U.S. Patent No. 11,061,190 (the "'190 Patent") is entitled "SMALL FORM
`
`FACTOR FIBER OPTIC CONNECTOR WITH MULTI – PURPOSE BOOT ASSEMBLY."
`
`The '190 Patent was duly and legally issued on July 13, 2021, by the United States Patent and
`
`Trademark Office. A copy of the '190 Patent is attached to this Complaint as Exhibit H.
`
`65.
`
`Senko is the owner and assignee of the '190 Patent and possesses all rights of
`
`recovery under the '190 Patent.
`
`66.
`
`67.
`
`68.
`
`The '190 Patent has not expired and is in full force and effect.
`
`The '190 Patent claims are valid and enforceable.
`
`The '190 Patent generally relates to a duplex VSFF connector with a rotatable
`
`boot that can both (i) rotate to reverse the polarity of the connector and (ii) be pulled back to
`
`release the connector from an adapter.
`
`DEFENDANT'S ACCUSED PRODUCTS
`
`69.
`
`US Conec's infringement of Senko's patent rights by making, using, offering for
`
`sale, selling and/or importing connector and adapter products in both the MDC and MMC
`
`platforms has been and is continuous and ongoing. The currently known US Conec connector
`
`and adapter Infringing Products include:
`
`• MDC UPC Connector
`
`• MDC APC Connector
`
`• MMC Connector
`
`• MMC Adapter
`
`• MDC 2-Port Adapter Aligned Key MDC/MDC
`
`• MDC 3-Port Adapter MDC/MDC Jr.
`
`13
`
`

`

`• MDC 4-Port Adapter MDC/MDC Jr.
`
`• MDC 4-Port Adapter Aligned Key MDC/MDC
`
`• MDC 4-Port Adapter Opposed Key – MDC/MDC
`
`DEFENDANT'S KNOWLEDGE OF SENKO'S PATENT RIGHTS
`
`70.
`
`Senko complies with the marking requirements of 35 U.S.C. § 287 at least
`
`through the websites and other materials related to its products under the Asserted Patents.
`
`Senko's marking includes a virtual patent marking page, located at
`
`https://www.senko.com/corporate/#patents, which associates its CS and SN product platforms
`
`with some of the Asserted Patents, among others.
`
`71.
`
`At least as of January 26, 2022, US Conec has known that Senko is a competing
`
`manufacturer of fiber optic connectors and adapters, and at least as of that same date US Conec
`
`has known about Senko's products and its corresponding patents as well.
`
`72.
`
`Beginning in early 2022, Senko sent multiple letters to US Conec to provide
`
`notice of Senko's Asserted Patents, among several other Senko patents. Senko sent the first
`
`notice letter on January 26, 2022, which notified US Conec of the '230 patent, the '836 patent
`
`(which at the time was an allowed patent application), and the '369 patent (which at the time was
`
`an allowed patent application), among others. Defendant thus had knowledge of certain of the
`
`Asserted Patents at least as of January 26, 2022, the date of Senko's first notice letter.
`
`73.
`
`Throughout 2022, Senko gave further actual pre-suit notice of its claims of
`
`infringement to US Conec on all other Asserted Patents as well.
`
`74.
`
`Despite having been made aware before this action was commenced of its
`
`infringing sales and marketing of MDC and MMC connectors and adapters, US Conec continues
`
`to sell and offer for sale the Infringing Products.
`
`14
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`

`

`75.
`
`On information and belief, US Conec has not made any attempt to redesign,
`
`modify, or withdraw any of its Infringing Products in response to Senko's notices and demands.
`
`76.
`
`Defendant knows and at all relevant times has known of its infringement of the
`
`Asserted Patents, or at the very least has been willfully blind to its infringement of the Asserted
`
`Patents.
`
`77.
`
`Upon information and belief, such infringement has been, and will continue to be,
`
`willful, and upon further belief, Defendant lacks any reasonable invalidity or non-infringement
`
`defense making this case exceptional and entitling Senko to increased damages and reasonable
`
`attorneys' fees pursuant to 35 U.S.C. §§ 284 and 285.
`
`CLAIMS FOR RELIEF
`
`Senko's averments of infringement against US Conec that follow in Counts One –
`
`78.
`
`Seven and as further illustrated in the corresponding infringement charts are exemplary of, and
`
`without prejudice to Senko's ultimate infringement contentions. The Claim Charts attached and
`
`incorporated by reference in this Complaint as Exhibits I-O have individual claim elements of a
`
`representative claim mapped to an Accused Product and shall be considered a separate averment
`
`within the meaning of the Federal Rules of Civil Procedure, for which an element-by-element
`
`response is expected in conformity with Rule 8(b) of the Federal Rules of Civil Procedure. In
`
`providing these averments, Senko does not convey or imply any particular claim constructions or
`
`purport to describe the precise scope of the claims. Senko's claim constructions, as necessary,
`
`regarding any particularized meaning of the claim terms for the Asserted Patents' claims will be
`
`provided in accordance with the Court's scheduling order and any applicable local rules or
`
`standards.
`
`
`
`
`
`15
`
`

`

`COUNT ONE
`(INFRINGEMENT OF U.S. PATENT NO. 11,307,369)
`
`Senko repeats, re-alleges, and incorporates by reference the averments of
`
`
`79.
`
`paragraphs 1-78 of this Complaint as though fully set forth herein.
`
`80.
`
`Defendant US Conec, without license or authorization to do so, has directly
`
`infringed one or more claims of the '369 Patent, currently infringes, and will continue to infringe,
`
`literally or under the doctrine of equivalents, one or more claims the '369 Patent by making,
`
`using, offering for sale and/or selling its MDC and MMC fiber optic connectivity products
`
`within this District and elsewhere in the United States, and/or importing into the United States its
`
`MDC and MMC fiber optic connectivity products, in violation of 35 U.S.C. § 271(a).
`
`81.
`
`Defendant's accused fiber optic connectivity products directly infringe the '369
`
`Patent. For example, US Conec's Accused Products infringe at least claims 1-20 and 22-39 of
`
`the '369 Patent. By way of further illustrative infringement, Senko provides an exemplary claim
`
`chart for claim 23 of the '369 patent. See Exhibit I (claim chart), attached and incorporated by
`
`reference.
`
`82.
`
`Defendant's past and continuing infringement of the '369 Patent by its sales and
`
`offers for sale of the Accused Products are causing economic harm to Senko, for which Senko is
`
`entitled to damages for past infringement up to and including the date of judgment in an amount
`
`to be determined by the Court but in no event less than a reasonable royalty.
`
`83.
`
`Defendant's infringement of Senko's rights in the 369 Patent has caused, is
`
`causing, and will continue to cause irreparable harm to Senko for which there is no adequate
`
`remedy at law, and such irreparable harm will continue unless US Conec is enjoined by this
`
`Court.
`
`16
`
`

`

`COUNT TWO
`(INFRINGEMENT OF U.S. PATENT NO. 11,333,836)
`
`Senko repeats, re-alleges, and incorporates by reference the averments of
`
`84.
`
`paragraphs 1-78 of this Complaint as though fully set forth herein.
`
`85.
`
`Defendant US Conec, without license or authorization to do so, has infringed one
`
`or more claims of the '836 Patent, currently infringes, and will continue to infringe, literally or
`
`under the doctrine of equivalents, one or more claims the '836 Patent by making, using, offering
`
`for sale and/or selling its fiber optic adapter products within this District and elsewhere in the
`
`United States and/or importing into the United States its fiber optic adapter products, in violation
`
`of 35 U.S.C. § 271(a).
`
`86.
`
`Defendant's accused fiber optic adapter products directly infringe the '836 Patent.
`
`For example, US Conec's Accused Products infringe at least claims 3-5 of the '836 Patent. By
`
`way of further illustrative infringement, Senko provides an exemplary claim chart for claim 3 of
`
`the '836 patent. See Exhibit J (claim chart), attached and incorporated by reference.
`
`87.
`
`Defendant's past and continuing infringement of the '836 Patent by its sales and
`
`offers for sale of the Accused Products are causing economic harm to Senko, for which Senko is
`
`entitled to damages for past infringement up to and including the date of judgment in an amount
`
`to be determined by the Court but in no event less than a reasonable royalty.
`
`88.
`
`Defendant's infringement of Senko's rights in the '836 Patent has caused, is
`
`causing, and will continue to cause irreparable harm to Senko for which there is no adequate
`
`remedy at law, and such irreparable harm will continue unless US Conec is enjoined by this
`
`Court.
`
`17
`
`

`

`COUNT THREE
`(INFRINGEMENT OF U.S. PATENT NO. 11,340,413)
`
`89.
`
`Senko repeats, re-alleges, and incorporates by reference the averments of
`
`paragraphs 1-78 of this Complaint as though fully set forth herein.
`
`90.
`
`Defendant US Conec, without license or authorization to do so, has infringed one
`
`or more claims of the '413 Patent, currently infringes, and will continue to infringe, literally or
`
`under the doctrine of equivalents, one or more claims the '413 Patent by making, using, offering
`
`for sale and/or selling its fiber optic adapter and connector products within this District and
`
`elsewhere in the United States and/or importing into the United States its fiber optic adapter and
`
`connector products, in violation of 35 U.S.C. § 271(a).
`
`91.
`
`Defendant's accused fiber optic connectivity products, both adapters and
`
`connectors, directly and indirectly infringe the '413 Patent. For example, US Conec's Accused
`
`Products infringe at least claims 1-8, 10, 13-18, and 20-28 of the '413 Patent. By way of further
`
`illustrative infringement, Senko provides an exemplary claim chart for claim 1 of the '413 patent.
`
`See Exhibit K (claim chart), attached and incorporated herein by reference.
`
`92.
`
`Defendant's past and continuing infringement of the '413 Patent by its sales and
`
`offers for sale of the Accused Products are causing economic harm to Senko, for which Senko is
`
`entitled to damages for past infringement up to and including the date of judgment in an amount
`
`to be determined by the Court but in no event less than a reasonable royalty.
`
`93.
`
`Defendant's infringement of Senko's rights in the '413 Patent has caused, is
`
`causing, and will continue to cause irreparable harm to Senko for which there is no adequate
`
`remedy at law, and such irreparable harm will continue unless US Conec is enjoined by this
`
`Court.
`
`18
`
`

`

`COUNT FOUR
`(INFRINGEMENT OF U.S. PATENT NO. 11,415,760)
`
`94.
`
`Senko repeats, re-alleges, and incorporates by reference the averments of
`
`paragraphs 1-78 of this Complaint as though fully set forth herein.
`
`95.
`
`Defendant US Conec, without license or authorization to do so, has infringed one
`
`or more claims of the '760 Patent, currently infringes, and will continue to infringe, literally or
`
`under the doctrine of equivalents, one or more claims the '760 Patent by making, using, offering
`
`for sale and/or selling its fiber optic adapter and connector products within this District and
`
`elsewhere in the United States and/or importing into the United States its fiber optic adapter and
`
`connector products, in violation of 35 U.S.C. § 271(a).
`
`96.
`
`Defendant's accused fiber optic connectivity products directly infringe the '760
`
`Patent. For example, US Conec's Accused Products infringe at least claims 1-4, 12, 13, and 15-
`
`17 of the '760 Patent. By way of further illustrative infringement, Senko provides an exemplary
`
`claim chart for claim 1 of the '760 patent. See Exhibit L (claim chart), attached and incorporated
`
`herein by reference.
`
`97.
`
`Defendant's past and continuing infringement of the '760 Patent by its sales and
`
`offers for sale of the Accused Products are causing economic harm to Senko, for which Senko is
`
`entitled to damages for past infringement up to and including the date of judgment in an amount
`
`to be determined by the Court but in no event less than a reasonable royalty.
`
`98.
`
`Defendant's infringement of Senko's rights in the '760 Patent has caused, is
`
`causing, and will continue to cause irreparable harm to Senko for which there is no adequate
`
`remedy at law, and such irreparable harm will continue unless US Conec is enjoined by this
`
`Court.
`
`19
`
`

`

`COUNT FIVE
`(INFRINGEMENT OF U.S. PATENT NO. 10,191,230)
`
`99.
`
`Senko repeats, re-alleges, and incorporates by reference the averments of
`
`paragraphs 1-78 of this Complaint as though fully set forth herein.
`
`100. Defendant US Conec, without license or authorization to do so, has infringed one
`
`or more claims of the '230 Patent, currently infringes, and will continue to infringe, literally or
`
`under the doctrine of equivalents, one or more claims the '230 Patent by making, using, offering
`
`for sale and/or selling its fiber optic connectivity products with polarity change features within
`
`this District and elsewhere in the United States and/or importing into the United States its fiber
`
`optic connectivity products with polarity change features, in violation of 35 U.S.C. § 271(a).
`
`101. Defendant's accused fiber optic connectivity products with polarity change
`
`features directly infringe the '230 Patent. For example, US Conec's Accused Products infringe at
`
`least claims 1, 6, 9, 11, and 26-34 of the '230 Patent. By way of further illustrative infringement,
`
`Senko provides an exemplary claim chart for claim 1 of the '230 patent, as amended by the '230
`
`Reexamination Certificate. See Exhibit M (claim chart), attached and incorporated herein by
`
`reference.
`
`102. Defendant's past and continuing infringement of the '230 Patent by its sales and
`
`offers for sale of the Accused Products are causing economic harm to Senko, for which Senko is
`
`entitled to damages for past infringement up to and including the date of judgment in an amount
`
`to