DCT

2:19-cv-09485

Pilot Inc v. Gooloo Technology LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:19-cv-09485, C.D. Cal., 11/04/2019
  • Venue Allegations: Venue is alleged to be proper based on Defendants having committed acts of infringement in the district, regularly providing goods, and conducting business within the Central District of California, including through online retailers.
  • Core Dispute: Plaintiff alleges that Defendant’s portable automobile jump starters infringe a patent related to intelligent, microcontroller-based safety systems for battery charging.
  • Technical Context: The technology concerns safety features in portable lithium-ion battery jump starters, which use electronic controls to verify a proper connection to a vehicle's battery before delivering a high-current charge.
  • Key Procedural History: The asserted patent, a continuation of the application for U.S. Patent No. 9,525,297, has been subject to post-grant proceedings that are highly relevant to the viability of this case. An Inter Partes Review (IPR) certificate issued on October 1, 2024, indicates that all claims asserted in the complaint (Claims 7-11 and 17-20) have been cancelled. The IPR found only Claim 3 to be patentable. However, a separate terminal disclaimer was filed on May 22, 2024, disclaiming this same Claim 3. These post-filing events raise the question of whether any valid and enforceable claims asserted in the complaint remain.

Case Timeline

Date Event
2014-04-28 Earliest Priority Date ('653' Patent, via CN App. 201420212173U)
2014-09-01 Plaintiff's "LIGHTNING Power Jump Starter" first delivered to customer
2016-12-20 Issue Date of related U.S. Patent 9,525,297
2018-08-14 Issue Date of U.S. Patent 10,046,653
2019-11-04 Complaint Filing Date
2021-04-07 IPR filed against '653 Patent (IPR2021-00777)
2021-07-17 IPR filed against '653 Patent (IPR2021-01232)
2024-05-22 Terminal disclaimer of Claim 3 of the '653 Patent filed
2024-10-01 IPR Certificate issued, cancelling claims 1, 4-9, 11-18, and 20

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 10,046,653 - Automobile Charger, Issued August 14, 2018

The Invention Explained

  • Problem Addressed: The patent's background describes common problems with conventional automobile chargers, including the inability to automatically detect whether a load (e.g., a car battery) is connected, whether the connection is made with reverse polarity, or whether the battery is in a suitable state to receive a charge ('653 Patent, col. 1:15-28). These issues create a risk of damage to the charger, the vehicle, or present a danger to the user ('653 Patent, col. 2:30-33).
  • The Patented Solution: The invention is an "intelligent" automobile charger that uses a microcontroller to manage a system of distinct functional modules, including a battery voltage detector, a load detector, and an automobile start control module ('653 Patent, FIG. 1). This system architecture allows the device to assess the state of its own power source and the connection to the external load before activating switching circuitry to transfer power, thereby preventing dangerous or improper operation ('653 Patent, col. 1:47-57). The complaint highlights a block diagram from the patent illustrating this modular system (Compl. p. 5).
  • Technical Importance: This technology provided a safety control layer for the emerging market of compact, high-power lithium-ion jump starters, aiming to prevent common user errors and enhance product safety (Compl. ¶¶10-11, 15).

Key Claims at a Glance

  • The complaint asserts independent claims 7 (a device) and 17 (a method) ('653 Patent, col. 7:29-42, col. 8:6-18).
  • Independent Claim 7 (device) requires:
    • A "battery level detector" to detect the level of a first battery (the jump starter's internal battery).
    • A "load detector" to detect a "type of connection of a load".
    • A "microcontroller" to generate an output signal based on the inputs from the battery and load detectors.
    • "Switching circuitry" to selectively connect the first battery to the load based on the microcontroller's output signal.
  • Independent Claim 17 (method) requires parallel steps for detecting level, detecting connection type, generating a signal, and selectively connecting a power source to a load.
  • The complaint also asserts dependent claims 8-11 and 18-20 and alleges infringement both literally and under the doctrine of equivalents (Compl. ¶¶51, 56).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Accused Gooloo Jump Starters," specifically listing models GP80, GP37 Plus, GP1500, GP2000, and GP4000 (Compl. ¶26, Table 1).

Functionality and Market Context

  • The accused products are portable lithium-ion jump starters sold with what Gooloo markets as "Intelligent" or "Smart" jumper clamps (Compl. ¶25). The complaint alleges these clamps incorporate the patented safety technology to prevent unintended discharge by checking for conditions such as reverse connection and short circuits before allowing power to flow (Compl. ¶¶24-25). The functionality is communicated to the user via audio-visual indicators (e.g., lights and buzzers) on the clamp, as shown in a chart from the GP80 Owner's Manual included in the complaint (Compl. ¶39, p. 14). The complaint alleges these products were designed using the teachings of Plaintiff's patents after Gooloo observed Plaintiff's own commercial products (Compl. ¶21).

IV. Analysis of Infringement Allegations

Claim Chart Summary: '653 Patent Infringement Allegations

Claim Element (from Independent Claim 7) Alleged Infringing Functionality Complaint Citation Patent Citation
a battery level detector to detect a level of a first battery; The GP80 housing includes a power button and LED indicators which light up to show the electrical power level of the internal lithium battery. ¶34 col. 7:31-32
a load detector to detect a type of connection of a load; The "Smart" jumper clamps feature audio-visual indicators (e.g., a green light for a proper connection, a red light and buzz for a reverse polarity connection) to detect and report the status of the connection to the vehicle's battery. ¶¶35, 38-40 col. 7:33-34
a microcontroller to generate an output signal based on the level of the first battery and the type of connection of the load; An internal microcontroller on the GP80's circuit board receives information from the battery and load detectors and generates a corresponding output signal to control the flow of power. A photograph of the GP80 circuit board identifies the alleged microcontroller (Compl. p. 17). ¶46 col. 7:35-39
and switching circuitry to selectively connect the first battery to the load based on the output signal. The GP80 uses a relay as its switching circuitry, which is controlled by the microcontroller's signal to either allow or prevent the passage of power from the jump starter to the vehicle battery. The same circuit board photograph points to the alleged switching circuitry (Compl. p. 17). ¶¶17, 49 col. 7:40-42

Identified Points of Contention

  • Scope Questions: A central question may be the proper construction of the phrase "type of connection of a load". The patent specification focuses on detecting the presence of a connection and its polarity ('653 Patent, col. 4:15-24). The complaint points to the accused products' marketing, which lists a wider array of safety protections like "over current, short circuit, overload, over-voltage and over-charge" (Compl. ¶25). The dispute may turn on whether "type of connection" is limited to polarity and presence, or if it can be construed to cover these other electrical fault conditions.
  • Technical Questions: The complaint alleges that the microcontroller performs specific logical operations, such as causing the switching circuitry to connect power only when the load is properly connected and the battery level is above a threshold (Compl. ¶49). A key evidentiary question is whether the accused products' circuitry, upon inspection, actually performs the specific, multi-conditional logic required by the asserted claims (e.g., Claim 11).

V. Key Claim Terms for Construction

The Term: "load detector"

  • Context and Importance: This term defines a core functional block of the invention. Its construction will determine what sensing capabilities a device must possess to infringe. Practitioners may focus on this term because its definition is directly linked to the scope of the safety features covered by the patent.
  • Intrinsic Evidence for a Broader Interpretation: The patent states that the "load detector" "detects whether the load module is correctly connected" ('653 Patent, col. 3:16-19), which could be argued to be a broad, functional definition encompassing any means of verifying a proper connection.
  • Intrinsic Evidence for a Narrower Interpretation: Dependent claim 10 further defines a "proper connection" as a "polarity match" and an "improper connection" as a "polarity reversal" or "disconnection" ('653 Patent, col. 7:49-57). This language may be used to argue that the scope of "load detector" in the independent claim is limited to detecting only these specific conditions.

The Term: "type of connection"

  • Context and Importance: The meaning of this phrase dictates the range of inputs the "load detector" must sense and the microcontroller must act upon. Its construction is critical to determining if there is a technical mismatch between the claims and the accused products' full suite of safety features.
  • Intrinsic Evidence for a Broader Interpretation: Plaintiff may argue that conditions like a short circuit or reverse polarity are simply different "types" of connections, and the term should be given its plain and ordinary meaning to cover the various connection states identified by the accused products (Compl. ¶¶39-40).
  • Intrinsic Evidence for a Narrower Interpretation: The specification's primary example of an improper connection is "reversed polarity" ('653 Patent, col. 2:30-33). This focus, along with the specific language in dependent claims, could support an argument that the term is limited to the physical and polar state of the connection, not other electrical properties like current or voltage levels.

VI. Other Allegations

Indirect Infringement

  • The complaint does not contain specific allegations of indirect infringement (inducement or contributory infringement).

Willful Infringement

  • The complaint alleges that Gooloo had pre-suit knowledge of Plaintiff's patents by observing Plaintiff's commercial products on the market and "utilized the teachings of the '653 patent" to design the accused products (Compl. ¶21). It further alleges that infringement became willful and intentional at least upon service of the complaint (Compl. ¶63), forming a basis for seeking enhanced damages and attorneys' fees (Compl. ¶64).

VII. Analyst’s Conclusion: Key Questions for the Case

  1. Claim Viability: The primary and likely dispositive issue is the post-filing invalidation of the asserted intellectual property. The IPR certificate cancelling all asserted claims (7-11 and 17-20) and the subsequent disclaimer of the only surviving claim (Claim 3) raises the fundamental question of whether a viable cause of action remains.
  2. Definitional Scope: Should the case proceed on any remaining or reinstated claims, a core issue will be one of definitional scope: can the term "type of connection", which is described in the patent primarily in the context of polarity and physical connection, be construed broadly enough to read on the full suite of advanced safety features (e.g., over-current, high-temperature) advertised in the accused products?
  3. Functional Operation: A key evidentiary question will be one of functional proof: does the accused "Smart" clamp's microcontroller and switching relay operate according to the specific, multi-part logic recited in the asserted claims? For example, does it make decisions based on a combination of both the internal battery level and the external connection status, as required by claims like Claim 11, or does its internal logic operate differently?