Koji IP LLC v. Guru Wireless Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Koji IP, LLC (Texas)
  • Defendant: Guru Wireless, Inc. (Delaware)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 2:24-cv-03713, C.D. Cal., 05/03/2024
• Venue Allegations: Venue is alleged to be proper based on Defendant having a regular and established place of business in the district and committing the alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s wireless power charging systems, products, and services infringe a patent related to smart wireless power transfer between devices.
• Technical Context: The technology concerns systems that intelligently manage wireless power transfer by using a separate, close-range communication channel to discover and authorize devices before activating the power transfer itself.
• Key Procedural History: The complaint states that Plaintiff is a non-practicing entity. It alleges willful infringement based on Defendant’s knowledge of the patent from at least the date the lawsuit was filed, while reserving the right to amend to allege pre-suit knowledge if revealed in discovery.

Case Timeline

Date	Event
2016-12-19	’703 Patent Priority Date
2020-09-29	’703 Patent Issue Date
2024-05-03	Complaint Filing Date

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

U.S. Patent No. 10,790,703 - "Smart wireless power transfer between devices"

• Patent Identification: U.S. Patent No. 10,790,703, "Smart wireless power transfer between devices," issued September 29, 2020. (Compl. ¶7; ’703 Patent, cover).

The Invention Explained

• Problem Addressed: The patent seeks to provide "solutions for wirelessly powering and charging powered devices in a smart manner," moving beyond simple, continuous power transmission to incorporate more efficiency and control. (’703 Patent, col. 2:37-41).
• The Patented Solution: The invention describes a system comprising a "powering device" and a "powered device" that use "close-range wireless communication" to first discover and authenticate each other. (’703 Patent, Abstract). Power transfer is then conditionally activated based on this discovery and other factors, such as the battery status of one or both devices. This intelligent handshaking, managed by components like a processor (101) and a database of authorized devices (122), allows the system to avoid wasting energy on unauthorized or fully charged devices. (’703 Patent, Fig. 4; col. 12:7-39).
• Technical Importance: This approach enables more sophisticated, secure, and energy-efficient wireless power ecosystems, particularly in environments with multiple charging sources and devices. (’703 Patent, col. 2:32-37).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-4. (Compl. ¶9).
• The essential elements of independent claim 1 include:
  • A wireless power transfer system comprising a battery power source, wireless communication circuitry, and wireless powering circuitry.
  • The wireless communication circuitry establishes a "close-range wireless communication" to exchange a message from the powered device.
  • The wireless powering circuitry includes a transmitter that emits electromagnetic waves to form a "radiative powering region."
  • A key architectural feature is that the transmission power of the communication circuitry is controlled to make its range "substantially narrower" than the range of the radiative powering region.
  • A first condition for activation is that the message is issued by the powered device when its battery is below a predetermined threshold.
  • A second condition for activation, when the system is battery-powered, is a determination that the "level of drop" in the battery level of the powering device's battery source over a given time is below a threshold.
  • The powering circuitry is activated only in response to receipt of the message and satisfaction of the conditions.
• The complaint asserts infringement of claims 1-4, indicating that the limitations of the dependent claims are also at issue. (Compl. ¶9).

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products or services by name. It broadly refers to Defendant’s "systems, products, and services" related to "wireless power charging." (Compl. ¶¶9, 11).

Functionality and Market Context

• The complaint alleges that the Defendant "maintains, operates, and administers" the accused instrumentalities, which "perform infringing methods or processes." (Compl. ¶¶3, 9). The complaint does not provide specific details about the functionality or operation of the accused products, stating that support for the infringement allegations is contained in an attached exhibit that was not included with the filed document. (Compl. ¶10).

IV. Analysis of Infringement Allegations

The complaint references a claim-chart exhibit (Exhibit B) that is not provided with the filing. (Compl. ¶10). As such, a detailed, element-by-element analysis of the infringement allegations is not possible from the face of the complaint. The general theory of infringement is that the Defendant’s unnamed wireless charging systems, products, and services practice the methods and systems claimed in U.S. Patent No. 10,790,703. (Compl. ¶9).

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central question may be whether the accused system employs two distinct regions for communication and power transfer. The analysis will likely focus on whether the accused system utilizes a "close-range wireless communication" whose range is "substantially narrower" than its "radiative powering region," as strictly required by claim 1.
• Technical Questions: The infringement analysis will likely require significant technical evidence regarding the conditional logic of the accused system. A key question is whether the accused powering device performs the specific two-part activation sequence recited in claim 1, which requires not only a low-battery message from the powered device but also a separate determination on the powering device itself regarding its own rate of battery drain.

V. Key Claim Terms for Construction

The Term: "close-range wireless communication"

• Context and Importance: This term is foundational to the "smart" aspect of the invention, distinguishing the control channel from the power channel. Its construction will be critical for determining if the architecture of the accused system, particularly its control protocol (e.g., Bluetooth, NFC), falls within the scope of the claims.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses a wide variety of technologies that can implement this communication, including "WLAN or Wi-Fi," "Bluetooth and ZigBee," "RFID," "NFC," "ultrasonic communication," and "IR communication," suggesting the term is not limited to a single technology. (’703 Patent, col. 7:27-38).
  • Evidence for a Narrower Interpretation: The claims and specification repeatedly require that the range of this communication be "substantially narrower" than the power region. (’703 Patent, col. 46:27-31). A defendant may argue that this creates a functional, not just technological, limit, potentially excluding systems where control and power signals have similar ranges or are deeply integrated.

The Term: "a determination is made whether a level of drop in a battery level of the battery power source in a given time period is below a threshold"

• Context and Importance: This limitation defines a very specific power-saving function on the powering device, not the device being charged. Practitioners may focus on this term because infringement will hinge on whether the accused transmitter performs this exact calculation, which goes beyond a simple check of its own static battery level.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff might argue this language should be construed to cover any power-saving mode on a battery-powered transmitter that considers its own power-delivery capability before activating.
  • Evidence for a Narrower Interpretation: The claim language recites a specific algorithm: calculating a "level of drop" (a rate) within a "given time period" and comparing it to a "threshold." The specification provides detailed flowcharts illustrating this precise logic, such as determining if a decline is "Steep" or "Moderate," which could be used to argue that a general low-battery mode is insufficient to meet this limitation. (’703 Patent, Fig. 41; col. 41:17-29).

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, asserting that Defendant "actively encouraged or instructed" its customers on how to use its products in an infringing manner. (Compl. ¶11). It also alleges contributory infringement, claiming the accused products have "no substantial non-infringing uses." (Compl. ¶12).
• Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the ’703 Patent from "at least the filing date of the lawsuit," providing a basis for post-filing willfulness. (Compl. ¶¶11, 12). The prayer for relief requests a finding of willful infringement and treble damages. (Compl. p.6, ¶e).

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

• A core issue will be one of architectural correspondence: does the accused system’s design separate communication and power transfer into two distinct zones, where the control channel has a "substantially narrower" range than the "radiative powering region" as mandated by the claim language?
• A key evidentiary question will be one of functional proof: can the Plaintiff demonstrate, through discovery, that the accused powering device performs the specific, multi-step conditional activation logic of claim 1, particularly the sophisticated power-saving calculation based on the rate of its own battery drain, not merely its static charge level?
• Given the lack of specificity in the complaint, a threshold question will be one of pleading sufficiency: while likely to survive a motion to dismiss under current standards, the complaint’s reliance on a missing exhibit and its failure to identify any specific products will place significant pressure on early discovery to substantiate its infringement theory.