DCT
2:17-cv-08590
TII Trading Inc v. Guangdong Bestek E Commerce Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: TII Trading Inc. (California)
- Defendant: Guangdong Bestek E-Commerce Co., Ltd. (China); Bestek Global LLC (Delaware)
- Plaintiff’s Counsel: Karish & Bjorgum, P.C.
- Case Identification: 2:17-cv-08590, C.D. Cal., 11/28/2017
- Venue Allegations: Venue is alleged to be proper based on Defendants conducting business or having their principal place of business in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its "Key Power" brand voltage converters do not infringe Defendant's patent related to smart matching step-down circuits for power conversion devices.
- Technical Context: The technology concerns circuits within travel power converters that step-down voltage (e.g., from a 220V European standard to a 110V U.S. standard) and stabilize the output.
- Key Procedural History: This declaratory judgment action was filed in response to multiple patent infringement complaints that Defendant Bestek allegedly filed with Amazon.com against Plaintiff TII Trading between June and September 2017, which resulted in the temporary removal of Plaintiff's products from the e-commerce platform.
Case Timeline
| Date | Event |
|---|---|
| 2014-09-30 | '020 Patent Priority Date |
| 2017-01-XX | Plaintiff begins selling products on Amazon.com |
| 2017-05-16 | U.S. Patent No. 9,654,020 issues |
| 2017-06-13 | Defendant files first infringement complaint with Amazon |
| 2017-06-14 | Defendant files second infringement complaint with Amazon |
| 2017-07-16 | Defendant files third infringement complaint with Amazon |
| 2017-09-26 | Defendant files fourth infringement complaint with Amazon |
| 2017-11-28 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,654,020 - Smart Matching Step-Down Circuits and Travel-Use Power Conversion Devices
- Patent Identification: U.S. Patent No. 9,654,020, "Smart Matching Step-Down Circuits and Travel-Use Power Conversion Devices," issued May 16, 2017.
The Invention Explained
- Problem Addressed: The patent describes the inconvenience of conventional power converters that can only convert between two fixed voltages, limiting their adaptability for travelers encountering different power standards (’020 Patent, col. 1:12-29).
- The Patented Solution: The invention is a "smart matching step-down circuit" that can accept a wide range of input AC voltages (e.g., 90V to 265V) and produce a stable, low-voltage AC output (e.g., 110V) (’020 Patent, col. 3:15-19, col. 3:32-35). It achieves this using a specific circuit topology that includes a high-voltage DC conversion stage followed by a full-bridge DC/AC converter, with a control system that uses feedback from the final AC output to stabilize the voltage (’020 Patent, col. 8:51-col. 9:36).
- Technical Importance: The described solution provides a power converter that can automatically adapt to various international power grids, making it more convenient for travel use (’020 Patent, col. 3:35-39).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 9 as being at issue (Compl. ¶29).
- Essential elements of independent claim 1 include:
- A rectifier filter circuit to convert an input AC to a first DC.
- A high voltage BUCK control step-down circuit to produce a second DC.
- A full-bridge DC/AC converter circuit to convert the second DC to a second AC.
- An AC output end that connects to the output of the full-bridge DC/AC converter.
- An output voltage detection circuit that connects to the AC output end to sample voltages of the second AC.
- A conversion controller that uses the sampled voltage to control the full-bridge DC/AC converter to stabilize the second AC.
- The complaint does not explicitly reserve the right to assert dependent claims, but seeks a declaration of non-infringement of "any claim" of the patent (Compl. ¶41).
III. The Accused Instrumentality
Product Identification
The "Key Power 2001 W Step Down 220V to 110V Voltage Converter & International Travel Adapter," sold under the brand name "Key Power" (Compl. ¶18).
Functionality and Market Context
- The accused product is an electronic power converter sold on Amazon.com that allows electrical equipment to be used with different international voltage standards (Compl. ¶¶18-19).
- The complaint alleges a specific technical operation: the product's control circuit for the final DC/AC conversion stage bases its control on voltage detected from the DC end of the converter circuit, not the AC output end (Compl. ¶33).
- The complaint alleges that Defendants' actions of filing infringement notices with Amazon caused Plaintiff's product listings to be taken down, indicating a competitive relationship in the online marketplace for such devices (Compl. ¶¶24, 44).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. Its core theory is that the accused Key Power Converter has a fundamentally different circuit architecture than that required by the claims of the ’020 Patent. The complaint provides a block diagram of the accused product to illustrate this alleged difference (Compl. p. 7). This diagram shows a "Current & Voltage Detection Circuit" (block 4) providing feedback to the "PWM control conversion circuit" (block 10), which in turn controls the "DC-AC Full bridge Inverter circuit" (block 5). The complaint argues this shows detection occurs at the DC stage, not the AC output.
’020 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (Plaintiff's Position) | Complaint Citation | Patent Citation |
|---|---|---|---|
| an output voltage detection circuit connects to the AC output end to sample voltages of the second AC from the AC output end so as to generate a first sampling voltage; | The accused Key Power Converters do not have an output voltage detection circuit connected to the AC output end. Instead, they control the DC/AC converter based on voltage detected from the DC end of that converter circuit. | ¶¶32-34 | col. 9:26-31 |
| a conversion controller connecting to the output voltage detection circuit and the full-bridge DC/AC converter circuit, the conversion controller is configured to controlling a duty cycle ratio of outputted waveform... in accordance with the first sampling voltage | Because the accused converter lacks the claimed "output voltage detection circuit" connected to the AC output, it consequently lacks a "conversion controller" that is connected to and controlled by such a circuit as required by the claim. | ¶32 | col. 9:31-36 |
Identified Points of Contention
- Scope Questions: The primary dispute concerns the scope of "connects to the AC output end." Does this phrase require a direct electrical connection for sampling the final AC waveform, or could it be construed more broadly to cover a circuit that detects a proxy for the AC output voltage (e.g., the DC voltage immediately preceding the inverter stage)? The complaint argues for a narrow, literal interpretation that its product does not meet (Compl. ¶¶32-33).
- Technical Questions: What evidence will establish the actual point of voltage detection in the accused Key Power Converter? The complaint provides a high-level block diagram as its main piece of evidence (Compl. p. 7). The court will likely require more detailed schematics or expert analysis to resolve the factual question of where and how voltage is sampled for the control loop in the accused device.
V. Key Claim Terms for Construction
- The Term: "an output voltage detection circuit connects to the AC output end"
- Context and Importance: This term is the lynchpin of the non-infringement argument. The Plaintiff contends its product detects voltage at the DC input of the final inverter, not the AC output, thereby avoiding infringement (Compl. ¶33). The definition of where this connection must be and what it means to "connect" for the purpose of sampling will likely be dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the overall goal as outputting a "stable second AC" (e.g., ’020 Patent, col. 8:68-col. 9:11). A party might argue that any detection circuit that achieves this goal, even if not physically touching the final AC output terminals, falls within the spirit of the invention.
- Evidence for a Narrower Interpretation: Claim 1 explicitly distinguishes between the "full-bridge DC/AC converter circuit" and the subsequent "AC output end." It requires the detection circuit to connect to the latter to sample "the second AC." The patent's block diagram (Fig. 1) also shows the "Output voltage detection circuit" (62) distinctly connected to the "AC output terminal" (70), separate from the "Full-bridge DC/AC converter circuit" (60) (’020 Patent, Fig. 1). This supports an interpretation that the connection must be at the final AC output stage, post-conversion.
VI. Other Allegations
- Indirect Infringement: The Plaintiff seeks a declaration that it does not induce or contribute to infringement (Compl. ¶¶ 6, 39). The complaint does not present facts related to inducement or contributory infringement, as its purpose is to deny all forms of liability.
- Willful Infringement: Willfulness is not alleged by the patentee in this declaratory judgment complaint.
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to turn on a focused technical and claim construction dispute. The central questions for the court will likely be:
- A question of claim construction: Must the "output voltage detection circuit" required by the claims be physically and electrically connected to the final AC output of the converter, or can the claim be construed to cover a circuit that detects voltage at the DC input stage of the final inverter to control the AC output?
- A question of fact: Assuming the claim is construed to require connection at the AC output, does the Plaintiff's accused "Key Power Converter" actually practice this limitation? Resolution will depend on technical evidence, such as circuit schematics and expert testimony, detailing the precise operation of the accused device's control loop.
- A question of commercial conduct: Separately from the patent issue, the court will address whether the Defendant's repeated infringement complaints to Amazon, if found to be baseless, constitute unfair competition or tortious interference under California law.