Creekview IP LLC v. Legrand North America LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Creekview IP, LLC (Texas)
  • Defendant: Legrand North America, LLC (California)
  • Plaintiff’s Counsel: Insight, PLC
• Case Identification: 2:22-cv-07909, C.D. Cal., 10/31/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Central District of California because Defendant is incorporated in the state and has committed the alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s wall-mounted wireless chargers infringe a patent related to methods and systems for wirelessly transferring power, specifically involving device authentication prior to charging.
• Technical Context: The technology at issue resides in the field of wireless power transfer, particularly systems that manage charging for multiple devices by first identifying and authorizing a device before initiating power transmission.
• Key Procedural History: The patent-in-suit is a continuation of an earlier application that issued as U.S. Patent No. 8,686,685 and claims priority to a 2009 provisional application, establishing an early priority date for the claimed subject matter.

Case Timeline

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

U.S. Patent No. 9,608,472 - METHOD AND APPARATUS FOR WIRELESSLY TRANSFERRING POWER AND COMMUNICATING WITH ONE OR MORE SLAVE DEVICES

The Invention Explained

• Problem Addressed: The patent describes the limitations of prior wireless power technologies. It notes that induction charging requires very close proximity and that existing wireless communication standards (e.g., 60 GHz-based) did not contemplate the need to first charge a device before being able to communicate with it, instead assuming the device already possessed a power source (’472 Patent, col. 1:25-44; col. 3:7-11).
• The Patented Solution: The invention discloses a system comprising a "master" device (e.g., a charger) and one or more "slave" devices (e.g., phones, sensors). The master authenticates a slave device by receiving an identification and comparing it to a list of authorized devices before transmitting power via radio frequency (RF) or induction. This allows the master to selectively power up, charge, and communicate with authorized slave devices in a controlled manner (’472 Patent, Abstract; col. 4:1-9; Fig. 5).
• Technical Importance: The claimed solution integrates an authentication step into the wireless charging process, which could provide enhanced security and power management in environments with multiple chargeable devices (’472 Patent, col. 12:5-9).

Key Claims at a Glance

• The complaint specifically asserts independent method claim 19.
• The essential elements of Claim 19, which describes a method performed by a slave device, are:
  • transmitting a slave device identification to the master device for determining authorization to wirelessly receive energy from the master device;
  • wirelessly receiving, in response to transmitting the slave device identification to the master device, energy from the master device; and
  • generating power from the wireless energy received from the master device for use by a set of electronic circuitry of the slave device.
• The complaint generally alleges infringement of "one or more claims," potentially reserving the right to assert other claims (’472 Patent, col. 36:19-34; Compl. ¶14).

III. The Accused Instrumentality

Product Identification

The Legrand Radiant Wireless Charger (the "Accused Product") (Compl. ¶11).

Functionality and Market Context

The Accused Product is described as a wall-mounted, 5W Qi-enabled wireless charger that also includes a USB Type-A connection (Compl. ¶11-12). The complaint includes a product image showing a standard wall outlet plate with one traditional receptacle and one wireless charging pad (Compl. ¶11). The infringement theory is based on the product’s operation under the Qi wireless charging standard. The complaint alleges that, per the Qi standard, a power receiver (a device to be charged) sends an identification to the power transmitter (the Accused Product) for verification, and after successful verification, the Accused Product transfers power (Compl. ¶18, col. 5:1-4).

IV. Analysis of Infringement Allegations

’472 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: Claim 19 is a method claim directed to the actions of a slave device (e.g., a smartphone). The defendant, Legrand, manufactures the master device (the charger). A question for the court will be whether Legrand's alleged internal testing constitutes direct infringement of this slave-side method claim (Compl. ¶17). Further, the induced infringement claim depends on showing that end-users of the charger directly infringe the full method claim.
• Technical Questions: A central technical question is whether the "identification and verification" handshake protocol of the Qi standard, as allegedly practiced by the Accused Product, performs the function of "determining authorization" as required by the claim. The complaint does not detail the specifics of the Qi handshake, raising the question of what evidence will be presented to show it is functionally equivalent to the patent's described process of checking an ID against a stored, authorized list.

V. Key Claim Terms for Construction

• The Term: "determining authorization"
• Context and Importance: This term is central to the dispute. Its construction will likely determine whether the functionality of the accused Qi-standard charger falls within the scope of the claim. Practitioners may focus on this term because the infringement case appears to hinge on equating the Qi standard's communication protocol with the patent's specific "authorization" process.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification notes that the "master's selection and power scheduling of slaves is dependent on the priorities of slaves' functions and data," which could be argued to support a broader interpretation of "authorization" as any form of intelligent decision-making before charging (’472 Patent, col. 4:6-9).
  • Evidence for a Narrower Interpretation: The specification repeatedly describes the authorization process as a security check, where a slave's identification is compared against a pre-stored "authorized list" in a database to permit charging (’472 Patent, col. 12:15-26). It further states that a "slave prevents non-authorized masters" from charging it, suggesting a specific security function rather than a generic compatibility check (’472 Patent, col. 12:56-60).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides the Accused Product along with "instruction manuals" and "downloadable instructional guides" that encourage and enable customers to use the product with Qi-compatible devices in a manner that directly infringes method claim 19 (Compl. ¶¶23-24).
• Willful Infringement: The complaint alleges knowledge of the ’472 Patent "since at least the filing of this complaint" (Compl. ¶22). This forms the basis for a claim of post-suit willful infringement, for which Plaintiff seeks enhanced damages (Compl., Prayer for Relief ¶B).

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

• A core issue will be one of definitional scope: can the term "determining authorization," which the patent specification links to checking a device ID against a stored "authorized list" for security purposes, be construed to cover the standard technical handshake and compatibility verification protocol of the accused Qi-enabled charger?
• A second key issue will be one of infringement liability: since the asserted claim is a method performed by a slave device (e.g., a phone), and the defendant manufactures the master device (the charger), the case will turn on whether Plaintiff can prove that either the Defendant's own testing or its customers' subsequent use constitutes a complete performance of all steps of the claimed method within the United States.