Mobile Motherboard Inc. v. AIOEXPC, et al., No. 24 C 8703 (N.D. Ill. Sept. 4, 2025) (Shah, J.).
Judge Shah granted defendants’ Fed. R. Civ. P. 12(c) motion for judgment on the pleadings in this patent infringement case involving a two-piece computer system patent. The Court found that plaintiff Mobile Motherboard’s own claim charts revealed fatal inconsistencies that prevented its infringement claims.
Mobile Motherboard’s patent covered a computer system with two separate components, among other elements not relevant to this analysis: (1) a computer box with internal circuitry and communication ports, and (2) a separate, portable motherboard that connects externally to the computer box. When connected, the two components were required to create a complete computer system.
Mobile Motherboard’s fatal flaw arose from its claim charts. While alleging that defendants’ computer sticks infringed when plugged into a monitor, the claim charts actually identified the computer sticks themselves as fulfilling both the “computer box” limitations and the “motherboard” limitations. This meant the motherboard was internal to the computer stick housing—directly contradicting the patent’s requirement for an “external” motherboard.
The Court noted that the prosecution history supported this reading. During prosecution, Mobile Motherboard had specifically distinguished its invention from prior art by emphasizing that a motherboard “is not a complete computer system” and required more than just connection to a keyboard and display to function as a regular PC.
This case illustrates the importance of consistency between infringement theories and claim charts. As the Court observed, while plaintiffs need not prove infringement at the pleading stage, a complaint can contain “too much rather than too little, to the point that [a plaintiff can] essentially plead[] itself out of court.”