DCT
2:22-cv-02219
Shenzhen Gooloo E Commerce Co Ltd v. Pilot Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Shenzhen Gooloo E-Commerce Co., Ltd. (China) and Hulkman LLC (California)
- Defendant: Pilot, Inc. (California)
- Plaintiff’s Counsel: Perkins Coie LLP
- Case Identification: 2:22-cv-02219, C.D. Cal., 06/27/2022
- Venue Allegations: Venue is alleged to be proper as Defendant Pilot, Inc. resides in the Central District of California, is subject to personal jurisdiction, and a substantial portion of the events giving rise to the claims occurred in the district.
- Core Dispute: Plaintiffs, sellers of portable jump starters, seek a declaratory judgment that their products do not infringe and that Defendant's patent is invalid, while also alleging tortious interference and unfair competition related to Defendant's patent enforcement activities on the Amazon marketplace.
- Technical Context: The technology concerns portable, lithium-battery-based automobile jump starters, which use microcontroller-based "smart" circuits to manage safety features and power delivery.
- Key Procedural History: The complaint alleges a history of aggressive litigation and enforcement by Defendant Pilot, including prior lawsuits and complaints filed via Amazon's Utility Patent Neutral Evaluation (UPNE) process. Notably, the complaint states that two Inter Partes Review (IPR) petitions challenging the validity of the patent-in-suit were filed at the U.S. Patent and Trademark Office (USPTO) and that the Patent Trial and Appeal Board (PTAB) instituted trials in both cases, finding a "reasonable likelihood" that various claims were invalid. The provided patent documentation also includes an IPR certificate, issued October 1, 2024 (after the complaint was filed), which confirms the cancellation of claims 1, 4-9, 11-18, and 20. The patentee also filed a disclaimer for claim 3 on May 22, 2024.
Case Timeline
| Date | Event |
|---|---|
| 2014-04-28 | U.S. Patent 10,046,653 Priority Date |
| 2018-08-14 | U.S. Patent 10,046,653 Issued |
| 2021-04-07 | NOCO Company files IPR Petition (IPR2021-00777) against '653 Patent |
| 2021-07-17 | Shenzhen Chic Electrics files IPR Petition (IPR2021-01232) |
| 2021-10-05 | PTAB institutes trial in IPR2021-00777 |
| 2022-01-14 | PTAB institutes trial in IPR2021-01232 |
| 2022-06-27 | Complaint for Declaratory Judgment Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,046,653 - "AUTOMOBILE CHARGER"
- Patent Identification: U.S. Patent No. 10,046,653, "AUTOMOBILE CHARGER", issued August 14, 2018.
The Invention Explained
- Problem Addressed: The patent background identifies a need for portable automobile chargers that can automatically and safely manage the charging process. Key problems with existing chargers include the inability to automatically detect load connection, reverse polarity, or other unsafe conditions, making them less mature and user-friendly (’653 Patent, col. 1:12-29).
- The Patented Solution: The invention is a "novel automobile charger" that uses a microcontroller to intelligently control the power delivery. The system architecture involves a main power source (a first battery), a power converter, a microcontroller, and several detection modules (battery level, load detection) (’653 Patent, col. 2:32-51). The microcontroller receives data from the various sensors—such as the internal battery's charge level and whether the clamps are properly connected to a car battery—and uses this data to decide whether to activate an electronic switch that connects the internal battery to the car battery (’653 Patent, col. 2:5-18). This centralized control is intended to make the jump-starting process "safe, quick, mature and propagable" (’653 Patent, col. 1:28-29).
- Technical Importance: The invention represents a shift from simple power packs to "smart" jump starters that use logic to prevent common user errors like connecting clamps to the wrong terminals, which could otherwise damage the vehicle's electronics or the charger itself (’653 Patent, col. 2:30-36).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement and invalidity of claims 1-20 (Compl. ¶¶ 11, 104; Prayer for Relief ¶B). The analysis focuses on the independent claims.
- Independent Claim 1: An automobile charger apparatus defined by a specific set of electrical connections between a first battery, a power converter, a microcontroller, a battery level detector, a switching circuit, and a load detector.
- Independent Claim 7: A charging device comprising a battery level detector, a load detector, a microcontroller that generates a signal based on input from both detectors, and switching circuitry that connects a power source to a load based on that signal.
- Independent Claim 17: A method of charging comprising the steps of detecting a power source level, detecting a load connection type, generating a signal based on both detections, and selectively connecting the power source to the load based on the signal.
III. The Accused Instrumentality
Product Identification
- Plaintiffs’ "Redesigned Products" and "Hulkman Products," specifically the Gooloo GP2000 and GP4000 models and the Hulkman Alpha 85, Alpha 85S, and Alpha 100 model jump starters (Compl. ¶¶ 111, Prayer for Relief ¶A).
Functionality and Market Context
- These are hand-held, lithium-battery-powered devices designed to jump-start vehicles (Compl. ¶¶ 3-4). The complaint alleges these products were specifically redesigned by their manufacturer, Carku, to avoid infringement of Defendant's patents (Compl. ¶¶ 65, 71).
- The complaint alleges the key technical difference in the accused products is that their "load detector" (referred to as the Reverse Connection Detection Circuit) is not connected to the microcontroller (MCU), and therefore the MCU does not receive signals from it or base its decisions on the load connection status (Compl. ¶111).
- Plaintiffs are described as significant online retailers of jump starters, primarily through the Amazon Marketplace, with Hulkman identified as the "Number 2" seller in the category at one point (Compl. ¶¶ 12-13, 78).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The table below summarizes Plaintiffs' allegations for why their products do not meet the limitations of the asserted claims.
’653 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality (as per Plaintiffs) | Complaint Citation | Patent Citation |
|---|---|---|---|
| three additional leads of the microcontroller connected with a third lead of the battery level detector, a second lead of the switching circuit and a first lead of a load detector, respectively | The "load detector" (Reverse Connection Detection Circuit) in the accused products is not connected to or coupled with the microcontroller (MCU) and sends no signals to it. | ¶111 | col. 6:11-15 |
| a second pole of the first battery connected with... a first lead of a microcontroller, a first lead of a switching circuit and a second lead of the battery level detector | The ON/OFF switch is connected between the positive poles of the device battery and the external load, which allegedly does not satisfy this claimed connection structure. | ¶111 | col. 6:6-10 |
’653 Patent Infringement Allegations
| Claim Element (from Independent Claim 7) | Alleged Non-Infringing Functionality (as per Plaintiffs) | Complaint Citation | Patent Citation |
|---|---|---|---|
| a microcontroller to generate an output signal based on the level of the first battery and the type of connection of the load | The output signal from the MCU to the switching circuitry is allegedly not based on both the battery level and the load connection type as required. | ¶112 | col. 6:50-54 |
- Identified Points of Contention:
- Technical Questions: A primary factual dispute will concern the actual circuit design of the accused products. What signals, if any, are transmitted between the "load detector" and the microcontroller? Is the output signal that controls the switching circuitry generated based on the logic claimed, or on some other condition (e.g., only battery level, or only a user's manual button press)?
- Scope Questions: The case raises the question of whether the specific circuit topology recited in claim 1 is an essential part of the invention. Plaintiffs’ argument that their different ON/OFF switch connection avoids infringement hinges on a strict reading of the claimed electrical connections.
V. Key Claim Terms for Construction
The Term: "load detector"
Context and Importance: This term is central to the non-infringement argument for claim 1. Plaintiffs allege their "load detector" is not connected to the microcontroller, thereby avoiding a key limitation (Compl. ¶111). The definition and required connectivity of this component will be critical. Practitioners may focus on whether the specification requires the "load detector" to be a distinct module that provides an input to the microcontroller, or if its function can be achieved indirectly.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent claims a "load detector to detect a type of connection of a load" (col. 6:48-49). A party could argue this is a functional definition, and any component performing this function meets the limitation, regardless of its specific integration with the microcontroller.
- Evidence for a Narrower Interpretation: Claim 1 explicitly requires "a first lead of a load detector" to be connected to one of the "three additional leads of the microcontroller" (col. 6:13-15). Figure 1 shows the "load detection module (5)" as a distinct block providing an input to the "microcontroller (2)". This suggests a specific structural relationship where the detector is an input source for the controller, supporting Plaintiffs' narrower view.
The Term: "based on the level of the first battery and the type of connection of the load"
Context and Importance: This phrase from independent claims 7 and 17 is the basis of Plaintiffs' non-infringement defense against those claims (Compl. ¶¶ 112-113). The dispute will turn on whether the microcontroller's output signal must be a logical function of both inputs, or if being based on only one of them, or on a different input entirely, is sufficient to avoid infringement.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that "based on" does not require the inputs to be the sole or simultaneous basis for the signal, allowing for other factors or conditions.
- Evidence for a Narrower Interpretation: The specification describes a system where the microcontroller "collects relevant data to conduct the corresponding control" (’653 Patent, col. 2:60-62). The description of the microcontroller determining "whether the automobile storage battery is connected with the automobile engine through the load detection module" before activating the switch suggests that the load connection data is a necessary prerequisite for the output signal (’653 Patent, col. 4:11-17). This supports an interpretation that the signal must logically depend on both specified inputs.
VI. Other Allegations
- Indirect Infringement: The complaint seeks a declaration of non-infringement of indirect infringement under 35 U.S.C. § 271(b) and (c) but does not provide a specific factual basis for why Plaintiffs would not be liable, other than the general assertion of non-infringement for the underlying products (Compl. ¶115).
- Willful Infringement: This is a declaratory judgment action, so there is no claim for willful infringement against the Plaintiffs. However, the complaint alleges Defendant Pilot acted in "bad faith" with "subjective intent to both punish Gooloo" by knowingly filing baseless infringement complaints with Amazon (Compl. ¶103). These allegations support Plaintiffs' separate counts for tortious interference and unfair competition, rather than a patent-specific willfulness claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- Question of Validity: A threshold issue, significantly influenced by external proceedings, is the validity of the '653 patent's claims. Given that the PTAB instituted two IPRs based on a "reasonable likelihood of success" for invalidity arguments and that an IPR certificate has since cancelled most asserted claims, the enforceability of any remaining claims is a central question.
- Question of Circuit Architecture: The core technical dispute for infringement will be an evidentiary one: does the circuit architecture of the accused Gooloo and Hulkman products match the specific connectivity recited in the patent's claims? Specifically, is there a functional and electrical connection between the "load detector" and the "microcontroller" as claimed?
- Question of Signal Logic: For any surviving method or device claims, a key question will be one of functional operation: does the accused products' microcontroller generate its output signal "based on" the combination of battery level and load connection type, as required by claim 7, or does it operate on a different logic that falls outside the claim scope?