DCT
2:19-cv-07355
Voltstar Tech Inc v. Superior Communications Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Voltstar Technologies, Inc. (Illinois)
- Defendant: Superior Communications, Inc. (California) and AT&T Mobility, LLC (Delaware)
- Plaintiff’s Counsel: Sriplaw PLLC
- Case Identification: 2:19-cv-07355, C.D. Cal., 08/23/2019
- Venue Allegations: Venue is alleged as proper based on Defendant Superior Communications having its principal place of business within the district and Defendant AT&T Mobility regularly conducting business in the district.
- Core Dispute: Plaintiff alleges that Defendants’ Qi-standard wireless charging pads infringe two patents related to energy-saving power adapters that reduce or eliminate "phantom" power consumption.
- Technical Context: The technology addresses methods for automatically cutting power to chargers when the connected electronic device is off or fully charged, thereby preventing wasteful standby power draw.
- Key Procedural History: The complaint alleges that Plaintiff notified Defendant Superior of its infringement of the asserted patents on or about April 8, 2019, approximately four months prior to filing the suit. The U.S. Patent and Trademark Office issued an inter partes reexamination certificate for the ’648 Patent on December 1, 2015, which cancelled several original claims, including two asserted in this complaint, and amended others.
Case Timeline
| Date | Event |
|---|---|
| 2008-05-27 | Earliest Priority Date ('834 and '648 Patents) |
| 2011-03-22 | Issue Date: U.S. Patent No. 7,910,834 |
| 2011-06-14 | Issue Date: U.S. Patent No. 7,960,648 |
| 2015-12-01 | Reexamination Certificate Issued ('648 Patent) |
| 2019-04-08 | Plaintiff Notifies Defendant of Alleged Infringement |
| 2019-08-23 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,910,834 - "Energy Saving Cable Assemblies," issued March 22, 2011
The Invention Explained
- Problem Addressed: The patent describes the problem of "phantom load," where power adapters and chargers continuously draw power from an outlet, even when the host electronic device is disconnected or turned off (’834 Patent, col. 2:5-10).
- The Patented Solution: The invention is a power device or charger with internal circuitry that automatically cuts its own power when it detects that the current being drawn by the connected electronic device falls below a certain threshold, such as when a battery is fully charged (’834 Patent, Abstract). A key feature is an "initial startup period" during which the circuitry ignores low current draw, which prevents the charger from shutting off prematurely at the beginning of a charging cycle when current can be low (’834 Patent, col. 10:26-34).
- Technical Importance: The technology provides an automated solution to reduce energy waste from phantom loads without requiring the user to manually unplug the charger.
Key Claims at a Glance
- The complaint asserts independent claim 28 and dependent claims 30 and 31 (Compl. ¶26).
- Independent Claim 28 recites the core elements of:
- A power device with an input and an output.
- Circuitry operable to automatically de-power a portion of the device when current to the electronic device falls below a threshold level.
- The circuitry "initially ignores current to the electrical device below the threshold level for an initial startup period."
U.S. Patent No. 7,960,648 - "Energy Saving Cable Assemblies," issued June 14, 2011
The Invention Explained
- Problem Addressed: Like its related '834 patent, the '648 patent targets the problem of phantom power draw from chargers, particularly those for devices like laptops that can provide an electrical signal (e.g., via a USB port) indicating their operational status (’648 Patent, col. 1:19-25, col. 2:4-10).
- The Patented Solution: The patent describes a "smart" cable assembly with switch circuitry that controls the flow of AC power to the charger's converter (’648 Patent, col. 3:25-40). The system can automatically shut off power in response to a "reduced power state" of the connected device, such as when a laptop is turned off or when current draw diminishes (’648 Patent, col. 13:50-56). The patent discloses using "pulse monitoring circuitry" to monitor pulses from a transformer winding as one way to determine the power state (’648 Patent, cl. 9).
- Technical Importance: This invention automates power saving by linking the charger’s on/off state directly to the operational state or power needs of the host electronic device.
Key Claims at a Glance
- The complaint asserts claims 28, 30, and 31 (Compl. ¶46). However, an inter partes reexamination certificate issued in 2015 cancelled claims 28 and 30, and amended claim 31 (’648 Reexam. Cert., col. 2:14-16, 20-24).
- The original independent claim was claim 26 (now cancelled). The asserted claim 31, as amended by reexamination, depends from cancelled claim 26 but is patentable as amended. It recites:
- A system including an electrical device and a cable assembly.
- The assembly has an input, a converter, and switch circuitry for controlling an on/off state.
- The switch circuitry automatically disconnects input power in response to a "reduced power state" of the device.
- The reexamination added a limitation requiring "pulse monitoring circuitry operable to monitor the frequency of pulses and drive the switch circuitry based thereon." (’648 Reexam. Cert., col. 2:20-24).
III. The Accused Instrumentality
Product Identification
- "Superior Qi wireless charging pads" distributed by Superior and AT&T (Compl. ¶17).
Functionality and Market Context
- The complaint alleges these wireless charging pads incorporate "automatic depowering of the charging device" for use with electronic devices like cellular phones (Compl. ¶18). The core of the accused functionality is attributed to an internal microcontroller chip, identified as a "CVSMICRO CV90325 1831" (Compl. ¶19). An image of the accused product's internal circuit board shows this microcontroller in proximity to the wireless charging coil (Compl. p. 5). The complaint alleges this chip executes the infringing power-control logic, specifically by measuring the frequency of pulses from a transformer to determine load and control the on/off state (Compl. ¶42).
IV. Analysis of Infringement Allegations
’834 Patent Infringement Allegations
| Claim Element (from Independent Claim 28) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| circuitry operable to automatically de-power at least a portion of the power device when current to the electrical device falls below a threshold level | The accused chargers feature "automatic depowering" which is allegedly performed by the CVSMICRO CV90325 microcontroller chip. | ¶18, ¶19 | col. 10:15-20 |
| wherein the circuitry initially ignores current to the electrical device below the threshold level for an initial startup period, while the power device is coupled with the electrical device | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 10:26-34 |
’648 Patent Infringement Allegations
| Claim Element (from Independent Claim 26, Basis for Asserted Claims) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| switch circuitry for controlling an on and an off state for the system | The accused product’s microcontroller chip allegedly controls the power state of the charger. The complaint shows an image of the internal circuit board with the identified microcontroller. | ¶19, ¶42, p. 5 | col. 7:4-16 |
| wherein the switch circuitry automatically disconnects the input electrical power to switch the system to the off state in response to a reduced power state of the electrical device | The system allegedly de-powers by measuring "the frequency of the pulses originating from a transformer winding in the power device to determine the power or load being drawn." | ¶42 | col. 13:50-56 |
- Identified Points of Contention:
- Factual Sufficiency: A primary question is whether the complaint provides sufficient factual support for its allegations under the Iqbal/Twombly pleading standard. For the '834 patent, the complaint makes no factual allegation that maps to the "initial startup period" limitation. For the '648 patent, it conclusorily alleges that the microcontroller performs a specific function (measuring pulse frequency) without providing supporting evidence from testing or reverse engineering.
- Assertion of Cancelled Claims: A significant procedural issue arises from the assertion of claims 28 and 30 of the '648 patent, which were cancelled during reexamination years before the complaint was filed. The court will need to address the propriety of asserting claims that no longer legally exist.
- Technical Questions: A key technical dispute will be whether the accused microcontroller actually performs the function alleged in the complaint—specifically, measuring pulse frequency to detect a reduced power state. This is a highly specific technical allegation that will require expert evidence to prove or disprove.
V. Key Claim Terms for Construction
Term: "initially ignores current ... for an initial startup period" (’834 Patent, cl. 28)
- Context and Importance: This limitation is a specific, affirmative functional step required by the claim. Infringement will depend on whether the accused device performs this function. Practitioners may focus on this term because the complaint provides no factual allegations to support its presence in the accused devices, suggesting it may be a primary point of non-infringement.
- Evidence for a Broader Interpretation: The term "startup period" is not explicitly defined, which could support an argument that it applies to any initial power-on phase.
- Evidence for a Narrower Interpretation: The specification provides a specific example for this feature: "It is not uncommon for batteries, at the beginning of a charge cycle, to draw a low amperage current" (’834 Patent, col. 10:28-30). This could be used to argue the term is limited to the context of overcoming an initial low-current state in battery charging, rather than a more general power-on sequence.
Term: "reduced power state" (’648 Patent, cl. 26)
- Context and Importance: This term defines the trigger for the automatic shut-off feature. Its scope—whether it means "off," "disconnected," or merely "standby"—is central to the infringement analysis.
- Evidence for a Broader Interpretation: The plain language is general and could be argued to encompass any state of operation that is less than full power draw.
- Evidence for a Narrower Interpretation: The specification describes embodiments where the trigger is a specific signal, such as a laptop’s USB port powering down when the computer is turned off (’648 Patent, col. 11:45-54). This may support an argument that "reduced power state" requires more than just a drop in current; it may require a specific signal or a complete cessation of power draw indicative of the device being off or disconnected.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant Superior induces infringement of both patents by "instructing and encouraging its customers, purchasers, users and developers to distribute" and use the accused products through unspecified "guidelines and instructions" and advertising (Compl. ¶¶36, 47).
- Willful Infringement: The complaint alleges that Defendants had pre-suit knowledge of infringement based on a notice letter sent on or about April 8, 2019 (Compl. ¶¶23, 32). It alleges that Defendants’ continued infringement after this notice was "blatant and egregious," forming the basis for a willfulness claim and a request for treble damages (Compl. ¶33; Prayer for Relief ¶5).
VII. Analyst’s Conclusion: Key Questions for the Case
Procedural Validity: A threshold question is one of claim validity: can the infringement suit for the ’648 patent proceed based on the assertion of claims 28 and 30, which were cancelled by a reexamination certificate issued four years prior to the complaint? This raises immediate questions about the diligence underlying the complaint's preparation.
Factual Plausibility: A core evidentiary issue will be one of operational fact: does the complaint provide plausible factual allegations that the accused chargers’ microcontroller performs the specific, complex functions required by the asserted claims? In particular, the court will need to assess whether the conclusory allegation of "measuring the frequency of pulses" (’648 patent) and the complete absence of facts regarding an "initial startup period" (’834 patent) satisfy modern pleading standards.
Claim Scope: The case may turn on a question of definitional scope: what constitutes a "reduced power state" under the ’648 patent? The resolution will likely depend on whether the term is construed broadly to mean any drop in current, or narrowly to require a specific signal or state (e.g., device fully off) as suggested by embodiments in the patent specification.