Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 1 of 25 PageID #: 1

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE
SENKO ADVANCED COMPONENTS,
INC.,

)
)
)
Plaintiff,
)
)
vs.
)
)
US CONEC, LTD.,))))
Defendant.
))______________________________________ )Civil Action No. ____________COMPLAINT
Plaintiff Senko Advanced Components, Inc. ("Senko" or "Plaintiff") makes thisComplaint, 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, andits principal place of business is located at 2 Cabot Road, Suite 103, Hudson, Massachusetts
01749.

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 2 of 25 PageID #: 23.

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 ofbusiness is located at 1138 25th St SE, Hickory, North Carolina 28602.
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 inthis judicial district related to the products at issue in this action. On information and belief,
Defendant uses, offers for sale and/or sells its products at issue in this action within this Districtor otherwise places such products within the stream of commerce with the expectation that theywould 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 highdegree of accuracy at each connection point for robust, consistent, and high-speed transmissionof data.
2

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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 toconnect 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 thetype 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

center or communication network. It is challenging to directly connect (e.g., fuse) one opticalfiber 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 tocomplementary features of the adapter. Since optical fibers are often less than the diameter of ahuman 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 andrectangular 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 ferrule3Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 4 of 25 PageID #: 4in a square connector housing with an integrated upper latch hook for securing the connector to amating adapter. Two individual LC connectors are frequently assembled together in a side-byside configuration to make an LC duplex connector.
13.

The most common multi-fiber ferrule connector in the United States is called an

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 andlatching mechanism.
14.

Conventional LC and MPO connector and adapter components have met theindustry's needs for many years. But within a fiber optic network installment, space can be at apremium. Optoelectronic transceivers have also advanced, creating a need for smaller fiber optic
connection components that can accommodate more fiber connections in the same transceiverfootprint.
15.

To meet the industry’s desire for density, Senko has spent years developing a newgeneration of connectors and adapters with smaller footprints than the conventional components
described above. These efforts have yielded three all-new connection systems, which theindustry 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 "multifiber" 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. Compared4

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 5 of 25 PageID #: 5with conventional LC components, the SN components allow for about three-times the fiberconnection density.
18.

Most recently, Senko has begun marketing its SN-MT platform, which includes aconnector 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
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

CS

SN

SN-MT

5

AdapterCase 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 6 of 25 PageID #: 620.

To achieve these improvements in fiber optic connection density while still

meeting industry expectations for accuracy, robustness, and ease of use, Senko made significant
research and development investments. Its research and development led to importantinnovations 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 extractionof a VSFF connector within a small footprint. Senko also developed new ways to integrate thehigh-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 offiber 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 otherproducts 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 inthese 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.
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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

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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 tosuppliers 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 theCS, SN, and SN-MT product platforms and also its potential participation in more lucrative salesof entire data center installations and communication networks. In short, Senko's VSFF
innovation, its current market success, and its accompanying patent rights are deeply threatenedby US Conec's infringement.

8Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 9 of 25 PageID #: 931.

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 andclaims before bringing this suit, the claims in this Complaint are for infringement of U.S. PatentNos. 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 theUnited States Patent and Trademark Office. A copy of the '369 Patent is attached to thisComplaint as Exhibit A and incorporated herein by reference.
34.

Senko is the owner and assignee of the '369 Patent and possesses all rights ofrecovery under the '369 Patent.
35.

The '369 Patent has not expired and is in full force and effect.

36.

The '369 Patent claims are valid and enforceable.

37.

The '369 Patent relates generally to certain claimed latching and unlatching

features in a very small form fiber optic connector.

9Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 10 of 25 PageID #: 10

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 thisComplaint as Exhibit B and incorporated herein by reference.
39.

Senko is the owner and assignee of the '836 Patent and possesses all rights ofrecovery under the '836 Patent.
40.

The '836 Patent has not expired and is in full force and effect.

41.

The '836 Patent claims are valid and enforceable.

42.

The '836 Patent relates generally to a partition-free adapter for aligning andlatching 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 theUnited States Patent and Trademark Office. A copy of the '413 Patent is attached to thisComplaint as Exhibit C and incorporated herein by reference.
44.

Senko is the owner and assignee of the '413 Patent and possesses all rights ofrecovery under the '413 Patent.
45.

The '413 Patent has not expired and is in full force and effect.

46.

The '413 Patent claims are valid and enforceable.

47.

The '413 Patent relates to a multi-fiber VSFF optical connector with a polarity key

that is integrated with a pullback extraction mechanism.

10

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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 byreference.
49.

Senko is the owner and assignee of the '760 Patent and possesses all rights ofrecovery under the '760 Patent.
50.

The '760 Patent has not expired and is in full force and effect.

51.

The '760 Patent claims are valid and enforceable.

52.

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 "OPTICALCONNECTORS WITH REVERSIBLE POLARITY." The '230 Patent was duly and legallyissued 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 andadds new claims 26-34.

11Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 12 of 25 PageID #: 12

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, arevalid 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 "OPTICALCONNECTORS 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 ofrecovery under the '701 Patent.
61.

The '701 Patent has not expired and is in full force and effect.

62.

The '701 Patent claims are valid and enforceable.

63.

The '701 Patent generally relates to duplex VSFF connectors with removable latch

elements that facilitate polarity reversal.

12Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 13 of 25 PageID #: 13

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 andTrademark 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 ofrecovery under the '190 Patent.
66.

The '190 Patent has not expired and is in full force and effect.

67.

The '190 Patent claims are valid and enforceable.

68.

The '190 Patent generally relates to a duplex VSFF connector with a rotatableboot that can both (i) rotate to reverse the polarity of the connector and (ii) be pulled back torelease 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

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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 athttps://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 wasan allowed patent application), among others. Defendant thus had knowledge of certain of theAsserted 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 ofinfringement 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 theAsserted 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
78.

Senko's averments of infringement against US Conec that follow in Counts One –Seven and as further illustrated in the corresponding infringement charts are exemplary of, andwithout prejudice to Senko's ultimate infringement contentions. The Claim Charts attached andincorporated by reference in this Complaint as Exhibits I-O have individual claim elements of arepresentative 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 orstandards.

15

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COUNT ONE(INFRINGEMENT OF U.S. PATENT NO. 11,307,369)
79.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 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 byreference.
82.

Defendant's past and continuing infringement of the '369 Patent by its sales andoffers 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 amountto 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, iscausing, 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 thisCourt.

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COUNT TWO(INFRINGEMENT OF U.S. PATENT NO. 11,333,836)
84.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 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 violationof 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 ofthe '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 andoffers 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 amountto 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, iscausing, 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 thisCourt.

17

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COUNT THREE(INFRINGEMENT OF U.S. PATENT NO. 11,340,413)
89.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 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 andelsewhere in the United States and/or importing into the United States its fiber optic adapter andconnector products, in violation of 35 U.S.C. § 271(a).
91.

Defendant's accused fiber optic connectivity products, both adapters andconnectors, 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 andoffers 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 amountto 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, iscausing, 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 thisCourt.

18

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COUNT FOUR(INFRINGEMENT OF U.S. PATENT NO. 11,415,760)
94.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 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 andelsewhere in the United States and/or importing into the United States its fiber optic adapter andconnector 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 1517 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 andoffers 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 amountto 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, iscausing, 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 thisCourt.

19

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 20 of 25 PageID #: 20

COUNT FIVE
(INFRINGEMENT OF U.S. PATENT NO. 10,191,230)
99.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 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 changefeatures directly infringe the '230 Patent. For example, US Conec's Accused Products infringe atleast 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 byreference.
102.

Defendant's past and continuing infringement of the '230 Patent by its sales andoffers 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 amountto be determined by the Court but in no event less than a reasonable royalty.
103.

Defendant's infringement of Senko's rights in the '230 Patent has caused, iscausing, 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 thisCourt.

20

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 21 of 25 PageID #: 21

COUNT SIX
(INFRINGEMENT OF U.S. PATENT NO. 11,181,701)
104.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 1-78 of this Complaint as though fully set forth here.
105.

Defendant US Conec, without license or authorization to do so, has infringed one

or more claims of the '701 Patent, currently infringes, and will continue to infringe, literally or
under the doctrine of equivalents, one or more claims the '701 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).
106.

Defendant's accused fiber optic connectivity products with polarity changefeatures directly infringe the '701 Patent. For example, US Conec's Accused Products infringe atleast claims 1-53 of the '701 Patent. By way of further illustrative infringement, Senko provides
an exemplary claim chart for claim 1 of the '701 patent. See Exhibit N (claim chart), attached andincorporated by reference.
107.

Defendant's past and continuing infringement of the '701 Patent by its sales andoffers 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 amountto be determined by the Court but in no event less than a reasonable royalty.
108.

Defendant's infringement of Senko's rights in the '701 Patent has caused, iscausing, 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 thisCourt.

21

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 22 of 25 PageID #: 22

COUNT SEVEN(INFRINGEMENT OF U.S. PATENT NO. 11,061,190)
109.

Senko repeats, re-alleges, and incorporates by reference the averments ofparagraphs 1-78 of this Complaint as though fully set forth herein.
110.

Defendant US Conec, without license or authorization to do so, has infringed one

or more claims of the '190 Patent, currently infringes, and will continue to infringe, literally or
under the doctrine of equivalents, one or more claims the '190 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).
111.

Defendant's accused fiber optic connectivity products with polarity changefeatures directly infringe the '190 Patent. For example, US Conec's Accused Products infringe atleast claims 1-3 and 6-20 of the '190 Patent. By way of further illustrative infringement, Senko
provides an exemplary claim chart for claim 1 of the '190 patent. See Exhibit O (claim chart),
attached and incorporated by reference.
112.

Defendant's past and continuing infringement of the '190 Patent by its sales andoffers 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 amountto be determined by the Court but in no event less than a reasonable royalty.
113.

Defendant's infringement of Senko's rights in the '190 Patent has caused, iscausing, 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 thisCourt.

22

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 23 of 25 PageID #: 23

PRAYER FOR RELIEF
WHEREFORE, Senko respectfully requests that the Court find in its favor and against
the Defendant US Conec, and that the Court grant Senko the following relief:a. A judgment in favor of Senko that US Conec has infringed one or more claims of
the following Asserted Patents of Senko: 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;
b. A permanent injunction pursuant to 35 U.S.C. § 283, enjoining US Conec andeach of its officers, directors, agents, servants, affiliates, employees, divisions,branches, subsidiaries, parents, and all others acting in active concert therewith
from continued acts of infringement, including, but not limited to, directly
infringing or inducing the infringement of, or contributing to the infringement of
the Asserted Patents, or such other equitable relief the Court determines iswarranted;
c. An accounting of and an award to Senko of damages adequate to compensate
Senko for US Conec's acts of infringement, including lost profits and/or areasonable royalty, and also including supplemental damages for any post-verdict
infringement up until entry of final judgment with an accounting as needed,
together with pre-judgment and post-judgment interest pursuant to 35 U.S.C. §284;
d. Finding US Conec's infringement to be willful and an award to Senko ofenhanced damages in an amount up to treble the amount of compensatory
damages as justified under 35 U.S.C. § 284 for US Conec's willful infringement;23

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 24 of 25 PageID #: 24

Case 1:23-cv-00083-UNA Document 1 Filed 01/24/23 Page 25 of 25 PageID #: 25

Index of Exhibits to Complaint
EXHIBIT NO.

DESCRIPTIONAUS PATENT NO. 11,307,369

B

US PATENT NO. 11,333,836

C

US PATENT NO. 11,340,413

D

US PATENT NO. 11,415,760

E

US PATENT NO. 10,191,230

F
G

US PATENT EX PARTE REEXAMINATION CERTIFICATE NO.
10,191,230 C1
US PATENT NO. 11,181,701

H

US PATENT NO. 11,061,190

I

CLAIM CHART FOR 369 PATENTJ

CLAIM CHART FOR 836 PATENTK

CLAIM CHART FOR 413 PATENTL

CLAIM CHART FOR 760 PATENTM

CLAIM CHART FOR 230 PATENTN

CLAIM CHART FOR 701 PATENTOCLAIM CHART FOR 190 PATENT

25

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EXHIBIT A

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Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 104 of 415 PageID #: 129

EXHIBIT B

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 105 of 415 PageID #: 130

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 144 of 415 PageID #: 169

EXHIBIT C

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 145 of 415 PageID #: 170

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 227 of 415 PageID #: 252

EXHIBIT D

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 228 of 415 PageID #: 253

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 256 of 415 PageID #: 281

EXHIBIT E

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 257 of 415 PageID #: 282

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 290 of 415 PageID #: 315

EXHIBIT F

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 291 of 415 PageID #: 316

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 294 of 415 PageID #: 319

EXHIBIT G

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 295 of 415 PageID #: 320

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 328 of 415 PageID #: 353

EXHIBIT H

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 329 of 415 PageID #: 354

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 373 of 415 PageID #: 398

EXHIBIT I

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 374 of 415 PageID #: 399
U.S. Patent No. 11,307,369
23. An opticalcomprising:

fiber

MMC

connector

multi-fiber ferrule configured toterminate a plurality of optical fibers;a connector housing having a front end
portion and a rear end portion spaced
apart along a longitudinal axis, theconnector housing comprising a top
portion and a bottom portion spaced
apart alongatransverse axis
perpendicular to the longitudinal axis,
the connector housing being configured
to hold the multi-fiber ferrule such thatthe multi-fiber ferrule is exposed throughthe front end portion for making an
optical connection and the plurality of
optical fibers are spaced apart from one
another in a row extending parallel to thetransverse axis,

1Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 375 of 415 PageID #: 400
U.S. Patent No. 11,307,369

MMC

a depressible latch above the top portionof the connector housing; andan elongate arm connected to theconnector housing above the top portionand configured to be pulled to actuate thedepressible latch;2

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 376 of 415 PageID #: 401
U.S. Patent No. 11,307,369

MMC

whereintheconnector
housingcomprises a guide connecting theelongate arm to the optical fiberconnector.

3

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 377 of 415 PageID #: 402

EXHIBIT J

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 378 of 415 PageID #: 403

U.S. Pat. No. 11,333,836

MMC Adapters

1. An adapter for mating with
optical fiber connectors, the adapter
comprising:1Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 379 of 415 PageID #: 404

U.S. Pat. No. 11,333,836

MMC Adaptersan outer housing having a first end
portion and a second end portion
spaced apart along a longitudinalaxis, the outer housing comprising afirst side wall and a second sidewall spaced apart along a lateral
axis
perpendiculartothelongitudinal axis, the outer housing
having a width extending along thelateral axis from the first side wall
to the second side wall, the outerhousing comprising a upper wall
and a lower wall spaced apart alongatransverse
axis
oriented
perpendicular to the lateral axis andperpendicular to the longitudinalaxis, each of the upper wall and thelower wall having an inner surface,
the outer housing defining aplurality of channels spaced apartalong the width, each of thechannels being configured toreceive an optical fiber connector,
the plurality of channels including
first and second channels; and2

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 380 of 415 PageID #: 405

U.S. Pat. No. 11,333,836

MMC Adaptersa first longitudinal rib formed on the
inner surface of the upper wall at alocation spaced apart along thewidth of the outer housing between
the first side wall and the secondside wall and a second rib formedon the inner surface of the lower
wall at a location spaced apart along
the width of the outer housing
between the first side wall and thesecond side wall, the first andsecond ribs being aligned along thewidth of the outer housing, the firstrib being spaced apart from thesecond rib along the transverse axis
by a transverse gap,

3

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 381 of 415 PageID #: 406

U.S. Pat. No. 11,333,836

MMC Adapterswherein the first longitudinal rib
and the second longitudinal rib arelocated between the first and second
channels.

4Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 382 of 415 PageID #: 407

U.S. Pat. No. 11,333,836

MMC Adapters

2. The adapter as set forth in claim
1, wherein the upper wall comprises
a first latch opening aligned withthe first channel and a second latch
opening aligned with the second
channel, the first rib being spaced
apart between the first latch
opening and the second latch
opening along the width.

3. The adapter as set forth in claim
2, wherein the adapter is configured
to receive a first one of the opticalfiber connectors in the first channel
and a second one of the optical fiberconnectors in the second channelsuch that:5Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 383 of 415 PageID #: 408

U.S. Pat. No. 11,333,836

MMC Adaptersa flexible latch arm of the first
optical fiber connector is latchedwith the first latch opening and afront section of a remote release of
the first optical fiber connector isreceived in the first channel at alocation spaced apart from the firstlatch opening along the longitudinal
axis toward the second end portionof the outer housing; and6Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 384 of 415 PageID #: 409

U.S. Pat. No. 11,333,836

MMC Adaptersa flexible latch arm of the second
optical fiber connector is latchedwith the second latch opening and afront section of a remote release of
the second optical fiber connector isreceived in the first channel at alocation spaced apart from thesecond latch opening along thelongitudinal axis toward the second
end portion of the outer housing.

7

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 385 of 415 PageID #: 410

U.S. Pat. No. 11,333,836

MMC Adapters

8

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 386 of 415 PageID #: 411

EXHIBIT K

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 387 of 415 PageID #: 412

U.S. Patent No. 11,340,413
1. An optical fiber connector comprising:

MMC Connectora housing having a longitudinal axis and afront end portion and a rear end portion spaced
apart along the longitudinal axis, the housing
comprising opposite first and second end
walls spaced apart along a transverse axis
oriented perpendicular to the longitudinalaxis, the housing comprising opposite firstand second side walls spaced apart along alateral axis oriented perpendicular to thelongitudinal axis and the transverse axis;

1Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 388 of 415 PageID #: 413

U.S. Patent No. 11,340,413
an MT ferrule received in the housing andexposed through the front end portion of the
housing for making an optical connection, theMT ferrule configured to receive plurality offibers such that the fibers are spaced apart in a
row that extends parallel to a fiber alignment
axis, the MT ferrule further comprising firstand second guide pin openings spaced apartalong the fiber alignment axis; andMMC Connectora polarity key disposed on the first end wall;2

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 389 of 415 PageID #: 414

U.S. Patent No. 11,340,413
wherein each of the first and second end walls
has a lateral dimension along the lateral axis
and each of the first and second side walls has
a transverse dimension along the transverse
axis, the lateral dimension being less than thetransverse dimension;

MMC Connector

3Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 390 of 415 PageID #: 415

U.S. Patent No. 11,340,413
wherein the optical fiber connector isconfigured to latch with a mating adapter andwherein the optical fiber connector isconfigured to be actuated to unlatch from themating adapter by displacing a first portion of
the optical fiber connector rearward relative toa second portion of the optical fiber connector,
wherein said displacing the first portion of the
optical fiber connector rearward relative to thesecond portion of the optical fiber connector
displaces the polarity key rearward relative to
the MT ferrule.

MMC Connector

4Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 391 of 415 PageID #: 416

EXHIBIT L

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 392 of 415 PageID #: 417

U.S. Patent No. 11,415,760
1. An optical fiber connector configured formating with a receptacle, the optical fiberconnector comprising:

MMC Connector

an MT ferrule configured to hold a plurality of
optical fibers;

1Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 393 of 415 PageID #: 418

U.S. Patent No. 11,415,760
a connector housing having a front end portion
and a rear end portion spaced apart along a
longitudinal axis, the connector housing
configured to hold the MT ferrule such that the
MT ferrule is exposed through the front end
portion for making an optical connection;

MMC Connector

a depressible latching arm connected to theconnector housing for latching with thereceptacle when the optical fiber connector ismated with the receptacle to releasably retain
the optical fiber connector in the receptacle;and2Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 394 of 415 PageID #: 419

U.S. Patent No. 11,415,760
a remote release connected to the connector
housing for movement relative to theconnector housing along the longitudinal axis,
the remote release being configured to bepulled rearward along the longitudinal axis todepress the depressible latching arm forreleasing the optical fiber connector from thereceptacle;

MMC Connector

3Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 395 of 415 PageID #: 420

U.S. Patent No. 11,415,760
wherein the connector housing has a generally
rectangular perimeter including opposite firstand second walls and opposite third and fourthwalls, the depressible latching arm being
located on an exterior of the first wall;

MMC Connector

4Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 396 of 415 PageID #: 421

U.S. Patent No. 11,415,760
wherein the first wall of the connector housing
defines a groove, the remote release being
slidably received in the groove;

MMC Connector

1

wherein the remote release comprises a lower
portion and a narrower portion above thelower portion, the lower portion being wider
than the narrower portion;

Senko refers to black and white line drawings taken from US Conec's own WO 2021/217054 patent application, which drawings are an appropriate proxy forshowing how US Conec's MMC product reads on relevant features of the claim.
15Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 397 of 415 PageID #: 422

U.S. Patent No. 11,415,760
wherein the groove includes an inner portion
and an outer portion, the inner portion being
wider than the outer portion, the inner portionof the groove being configured to slidably
receive the lower portion of the latch releaseand the outer portion of the groove being
configured to slidably receive the narrower
portion of the latch release such that the firstwall releasably retains the latch release in thegroove.

MMC Connector

6Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 398 of 415 PageID #: 423

EXHIBIT M

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 399 of 415 PageID #: 424

U.S. Pat. No. 10,191,230 C1

MDC

1. A reversible polarity fiber optic
connector comprising:at least first and second opticalferrules;1Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 400 of 415 PageID #: 425

U.S. Pat. No. 10,191,230 C1

MDC

a connector housing having alongitudinal axis and comprising an
exterior portion at least partiallysurrounding the first and second
optical ferrules such that the exterior
portionextends360°
circumferentially with respect to thelongitudinal axis about a space inwhich each of the first and second
optical ferrules are received, theexterior portion comprising a firstexterior wall positioned above thefirst and second optical ferrules anda second exterior wall positioned
beneath the first and second opticalferrules;2Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 401 of 415 PageID #: 426

U.S. Pat. No. 10,191,230 C1

MDC

a latch coupling positioned on eachof the first and second exterior wallsof the connector housing;3Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 402 of 415 PageID #: 427

U.S. Pat. No. 10,191,230 C1

MDC

a removable latch for engaging
either of the first and second exteriorwall latch couplings on theconnector housing;4Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 403 of 415 PageID #: 428

U.S. Pat. No. 10,191,230 C1

MDC

wherein positioning the removablelatch on the first exterior wall of theconnector housing yields a fiber
optic connector with a first polarityand positioning the removable latchon the second exterior wall of theconnector housing yields a fiber
optic connector with a second
polarity, the second polarity being
opposite to the first polarity.

5Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 404 of 415 PageID #: 429

EXHIBIT N

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 405 of 415 PageID #: 430

U.S. Pat. No. 11,181,701 B2
1. A fiber
comprising:

optic

MDC

connector

at least first and second opticalferrules;a connector housing having alongitudinal axis and comprising an
exterior portion at least partiallysurrounding the first and second
optical ferrules such that the exterior
portion circumscribes a space inwhich each of the first and second
optical ferrules are received, theexterior portion comprising a firstexterior wall and a second exteriorwall on an opposite side of the spacefrom the first exterior wall;1

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 406 of 415 PageID #: 431

U.S. Pat. No. 11,181,701 B2

MDC

a latch coupling positioned on eachof the first and second exterior wallsof the connector housing;2

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 407 of 415 PageID #: 432

U.S. Pat. No. 11,181,701 B2

MDC

a removable latch for engaging eitherof the first and second exterior walllatch couplings on the connector
housing, whereby the removablelatch couples to the respective latch
coupling;

3

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 408 of 415 PageID #: 433

U.S. Pat. No. 11,181,701 B2

MDC

wherein each latch coupling
comprises a groove extending along
the axis and having an open axial
end; and4

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 409 of 415 PageID #: 434

U.S. Pat. No. 11,181,701 B2

MDC

wherein the removable latch
comprises a protrusion for being
inserted into the open axial end of thegroove by movement relative to the
housing along the axis.

5Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 410 of 415 PageID #: 435

EXHIBIT O

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 411 of 415 PageID #: 436

U.S. Pat. No. 11,061,190

MDC Connector

1. An optical fiber connector
comprising:a front body configured to hold firstand second ferrules;

a back body having a proximal end
portion and a distal end portion
spaced apart along a longitudinalaxis, the proximal end portion of theback body configured to couple tothe front body, the distal end
portion of the back bodycomprising a cylindrical back post
having an outer round surface
extending along the longitudinalaxis, the back body defining a backbody passageway extending fromthe distal end portion through theproximal end portion; and1

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 412 of 415 PageID #: 437

U.S. Pat. No. 11,061,190

MDC Connector

a rotatable boot assembly having a
proximal end portion and a distal
end portion spaced apart along thelongitudinal axis, the rotatable bootassembly comprising a main bodyand a strain relief sleeve extending
longitudinally from the main bodyto the distal end portion of therotatable boot assembly, therotatable boot assembly comprisinga boot passageway extending fromthe distal end portion through themain body, the main bodycomprising an inner round surface
extending along the longitudinalaxis, the inner round surface
defining a proximal end portion of
the boot passageway, the rotatableboot assembly configured to bedisposed on the back body such that(i) the outer round surface of theback post is matingly received in
the inner round surface of the main
body and2

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 413 of 415 PageID #: 438

U.S. Pat. No. 11,061,190

MDC Connector(ii) the cable boot member isslidable along the longitudinal axis
relative to the back body forreleasing the optical fiber connector
from an adapter,the optical fiber connector being
configured to terminate a fiber optic
cable such that a jacket of the cable
is received in the strain relief sleevein the boot passageway, the bootpassageway and the back body
passageway configured to align for
passing first and second fibers fromthe fiber optic cable to the front
body to complete a signal path tothe first and second ferrules within
the front body;3

Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 414 of 415 PageID #: 439

U.S. Pat. No. 11,061,190

MDC Connector

the main body further comprising atleast one boot hook configured forreleasably securing the multipurpose rotatable boot assembly
against rotation relative to the backbody,and the rotatable boot assembly
further comprising an elongate arm
extending longitudinally from themain body in a proximal direction
along the longitudinal axis,

4Case 1:23-cv-00083-UNA Document 1-1 Filed 01/24/23 Page 415 of 415 PageID #: 440

U.S. Pat. No. 11,061,190

MDC Connector

the elongate arm being configured
for selectively setting the opticalfiber connector to each of a firstpolarity and a second polarity.

5Case 1:23-cv-00083-UNA Document 1-2 Filed 01/24/23 Page 1 of 2 PageID #: 441

Case 1:23-cv-00083-UNA Document 1-2 Filed 01/24/23 Page 2 of 2 PageID #: 442