DCT
2:18-cv-02703
Purkeys Fleet Electric Inc v. Ra Phillips Industries Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Purkey's Fleet Electric, Inc. (Arkansas)
- Defendant: R.A. Phillips Industries, Inc. (California)
- Plaintiff’s Counsel: Milord & Associates, P.C.; Gurr & Brande, PLLC
- Case Identification: 2:18-cv-02703, C.D. Cal., 04/03/2018
- Venue Allegations: Venue is alleged to be proper as Defendant maintains its principal place of business in the Central District of California and conducts regular business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s tractor-trailer battery charging systems infringe a patent related to managing power distribution between a vehicle's primary and auxiliary battery systems.
- Technical Context: The technology addresses the need to charge auxiliary batteries for equipment like liftgates on commercial trucks without depleting the main engine-cranking battery.
- Key Procedural History: The complaint alleges that Defendant was a former licensee of the patent-in-suit's subject matter. The license, originally granted by Plaintiff's predecessor-in-interest, allegedly terminated on December 31, 2015. Plaintiff also alleges providing Defendant with specific notice of infringement, including an element-by-element analysis, prior to filing the lawsuit.
Case Timeline
| Date | Event |
|---|---|
| 2008-10-03 | Plaintiff's predecessor allegedly began licensing the patent's subject matter to Defendant |
| 2009-03-13 | '242 Patent Priority Date |
| 2011-08-23 | '242 Patent Issue Date |
| 2015-12-31 | Alleged termination of Defendant's license |
| 2017-09-11 | Plaintiff allegedly gave Defendant written notice of infringement |
| 2017-11-07 | Defendant allegedly responded with a letter asserting non-infringement |
| 2018-01-05 | Plaintiff allegedly provided Defendant with an element-by-element infringement analysis |
| 2018-04-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,004,242 - "SYSTEM AND METHOD FOR MANAGING DISTRIBUTION OF VEHICLE POWER IN A MULTIPLE BATTERY SYSTEM"
- Patent Identification: U.S. Patent No. 8,004,242, "SYSTEM AND METHOD FOR MANAGING DISTRIBUTION OF VEHICLE POWER IN A MULTIPLE BATTERY SYSTEM", issued August 23, 2011.
The Invention Explained
- Problem Addressed: The patent describes a problem in heavy-duty vehicles where auxiliary electrical systems, like power liftgates, have their own batteries that must be charged. Relying solely on the main engine (crank) battery for this charging risks depleting it to a point where the vehicle cannot be started, especially when the engine is off (ʼ242 Patent, col. 1:20-30).
- The Patented Solution: The invention is a battery charge controller that intelligently manages power from multiple sources. It monitors the voltage of both the tractor's crank battery and a separate onboard power source (e.g., a refrigeration "reefer" unit). The controller prioritizes using the crank battery but automatically decouples it if its voltage drops below a preset threshold to preserve starting power. If the crank battery is too low, the controller then checks the secondary power source and uses it for charging if its voltage is sufficient ('242 Patent, Abstract; col. 6:10-25).
- Technical Importance: This approach allows for opportunistic charging of auxiliary equipment without jeopardizing the primary function of the main vehicle battery, a critical reliability concern in the commercial trucking industry ('242 Patent, col. 3:20-30, 45-49).
Key Claims at a Glance
- The complaint asserts infringement of "one or more claims" and its infringement theory closely tracks independent claim 1 (Compl. ¶¶ 29, 33).
- Independent Claim 1 is a means-plus-function claim with the following essential elements:
- means for monitoring a voltage level of said crank battery;
- means for monitoring a voltage level of said onboard electrical power source;
- means for electrically coupling the crank battery to the auxiliary battery for charging when the crank battery voltage exceeds a first threshold, and decoupling it when the voltage falls below that threshold;
- means for electrically coupling the onboard power source to the auxiliary battery for charging when the crank battery voltage is below the first threshold AND the onboard source voltage exceeds a second threshold, and decoupling it when the onboard source voltage falls below that second threshold.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused product is the PERMALOGIC Smart-Charge system (Compl. ¶22).
Functionality and Market Context
- The complaint alleges the Smart-Charge is a liftgate battery charging system that accepts power from up to three inputs: the tractor's crank battery (via a J560 7-way circuit), an onboard power source like a reefer unit, and a third auxiliary input (e.g., solar) (Compl. ¶23).
- It allegedly utilizes a micro-controller to manage these inputs and control a solenoid for connecting power to the liftgate batteries (Compl. ¶¶25-26).
- A product manual attached to the complaint includes a system diagram showing the "Smart-Charge Box" connected to a "STA-CHARGE Battery Charger," a reefer harness, and liftgate batteries (Compl., Ex. 2, p. 24).
- The complaint alleges the product is marketed as a system that "Recognizes and automatically manages the best power source(s) to charge your batteries" and has "built-in low voltage detection to avoid draining power sources" (Compl., Ex. 3, p. 31).
IV. Analysis of Infringement Allegations
- Claim Chart Summary: The complaint provides a narrative infringement theory rather than a formal claim chart. The table below summarizes these allegations against independent claim 1.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| means for monitoring a voltage level of said crank battery; | The Smart-Charge comprises a microcontroller that receives input from the tractor's crank battery. | ¶34 | col. 8:36-40 |
| means for monitoring a voltage level of said onboard electrical power source; | The Smart-Charge's microcontroller receives input from an onboard electrical power source, such as a reefer. | ¶34 | col. 8:36-40 |
| means for electrically coupling said crank battery and said auxiliary battery to charge said auxiliary battery when the voltage level of said crank battery exceeds a first voltage threshold, and for electrically decoupling said crank battery and said auxiliary battery when the voltage level of said crank battery is below said first voltage threshold; | The Smart-Charge electrically couples the crank battery and auxiliary battery via a microcontroller and DC-DC converter. The microcontroller controls a switch in the DC-DC converter to decouple the crank battery from the auxiliary battery when the crank battery voltage is too low. | ¶34 | col. 8:55-65 |
| means for electrically coupling said onboard power source and said auxiliary battery to charge said auxiliary battery when: (i) the voltage level of said crank battery is below said first voltage threshold and (ii) the voltage level of said onboard power source exceeds a second voltage threshold... | The onboard electrical power source (e.g., a reefer) is coupleable to the auxiliary battery via the Smart-Charge's microcontroller and DC-DC converter. Diodes and microcontroller control are used to couple the onboard source when its voltage is greater than the crank battery's voltage. | ¶34 | col. 8:55-65 |
| ...and for electrically decoupling said onboard power source and said auxiliary battery when the voltage level of said onboard power source is below said second voltage threshold. | The onboard electrical power source is decoupled via diodes or the microcontroller when its voltage is lower than the crank battery's or below a threshold. A product manual's functional test description states the system will switch between power sources depending on voltage levels. | ¶34; Ex. 2, p. 29 | col. 8:55-65 |
- Identified Points of Contention:
- Scope Questions: A central question will be whether the combination of a "microcontroller," a "DC-DC converter," and "diodes" in the accused product (Compl. ¶34) is structurally equivalent to the "microprocessor-based control module 55" and "electrical switching devices 56, 58, such as electromagnetic or solid-state relays" disclosed in the patent as the structure corresponding to the "means for... coupling" and "decoupling" functions ('242 Patent, col. 6:1-9).
- Technical Questions: The complaint's product manual attachments provide evidence that the accused system performs logical switching. One diagram describes the function of indicator lights, stating that a "WHITE" light indicates that "BOTH STINGER CORD AND BATTERY CHARGER ARE ACTIVE" when liftgate voltage falls below tractor battery voltage, suggesting a two-source power-sharing function (Compl., Ex. 2, p. 29). A key evidentiary question will be whether this described operation performs the specific, sequential two-threshold logic required by claim 1.
V. Key Claim Terms for Construction
Because Claim 1 is drafted in means-plus-function format, its scope is governed by 35 U.S.C. § 112, ¶ 6 (pre-AIA). The construction of the "means for..." terms will be dispositive.
- The Term: "means for electrically coupling said crank battery and said auxiliary battery" and "means for electrically coupling said onboard power source and said auxiliary battery"
- Context and Importance: These terms define the core of the invention's logic. Their construction will determine what physical structures are covered by the claim. The infringement analysis will turn on whether the accused Smart-Charge system's components (microcontroller, DC-DC converter, solenoid) are the same as or structurally equivalent to the components disclosed in the '242 patent specification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent states that the "switching device comprises a relay (e.g., electromagnetic or solid-state relay, or switching transistors or the like)" ('242 Patent, col. 2:35-37). A party could argue this language supports a broader interpretation covering any form of electronic switch controlled by a processor.
- Evidence for a Narrower Interpretation: The specification explicitly describes the structure as a "microprocessor-based control module 55" that "controls switching devices 56, 58" which are identified as "electromagnetic or solid-state relays (e.g., 80-amp)" ('242 Patent, col. 6:1-6). A party could argue that the scope is limited to this specific configuration of a control module and separate high-amperage relays, and does not read on a system where switching logic is integrated differently, for instance within a DC-DC converter.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), asserting that Defendant instructs customers to use the Smart-Charge in an infringing manner (Compl. ¶46). This allegation is supported by the inclusion of the product's detailed installation manual as an exhibit (Compl., Ex. 2).
- Willful Infringement: The complaint makes detailed allegations to support willfulness. It claims Defendant was aware of the patent's subject matter since at least October 2008 due to a prior license (Compl. ¶38). It further alleges that Plaintiff provided written notice of infringement on September 11, 2017, and followed up with "representative claim charts mapping the claims to the Smart-Charge" on January 5, 2018 (Compl. ¶¶15, 17, 38). The complaint alleges that Defendant continued its infringing activity despite this extensive history and knowledge (Compl. ¶42).
VII. Analyst’s Conclusion: Key Questions for the Case
A central issue will be one of structural equivalence under § 112: can the "microcontroller," "DC-DC converter," and "solenoid" structure alleged to be in the accused Smart-Charge system be proven equivalent to the "microprocessor-based control module" and separate "solid-state relays" disclosed in the '242 patent specification? The outcome of the means-plus-function analysis will likely determine infringement.
A second key question will be evidentiary and functional: can Plaintiff prove that the accused product, in operation, actually performs the specific two-threshold, sequential logic of claim 1—first checking the crank battery against a first threshold, and only if that fails, checking the onboard source against a second threshold? Or does the accused product use a different logic, such as simply selecting the highest voltage source or blending power sources simultaneously?
Given the detailed allegations of a prior license and multiple pre-suit notices, a significant question will be the disposition of the willfulness claim. The dispute may focus on the reasonableness of Defendant's alleged non-infringement position (Compl. ¶16) in light of its long history with the patented technology.