DCT

2:25-cv-07964

CyboEnergy Inc v. Deye Ess Technology

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-07964, C.D. Cal., 08/22/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants have a regular and established place of business in the Central District of California and have committed acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant’s SUN Series Microinverters infringe patents related to smart, scalable, and user-interface technologies for solar power inverters.
  • Technical Context: The technology concerns solar power inverters, which convert direct current (DC) from solar panels into alternating current (AC) suitable for use in the electrical grid, with a focus on modular, multi-input systems.
  • Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the patents-in-suit, or relevant licensing history.

Case Timeline

Date Event
2009-07-16 U.S. Patent No. 8,786,133 Priority Date
2011-06-30 U.S. Patent No. 9,331,488 Priority Date
2014-07-22 U.S. Patent No. 8,786,133 Issues
2016-05-03 U.S. Patent No. 9,331,488 Issues
2025-08-22 Complaint Filed

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

U.S. Patent No. 8,786,133 - “Smart and Scalable Power Inverters” (Issued Jul. 22, 2014)

The Invention Explained

  • Problem Addressed: The patent’s background section describes shortcomings of traditional solar power systems that use a single, large, centralized inverter, including that the failure of the inverter shuts down the entire system, power production is dictated by the weakest solar panel, and installation is costly and labor-intensive due to complex DC wiring requirements (’133 Patent, col. 1:36-57).
  • The Patented Solution: The invention proposes a decentralized system using multiple "smart and scalable" inverters that can be connected in a "daisy chain" configuration (’133 Patent, col. 3:27-43). Each inverter connects to one or more DC power sources (e.g., a solar panel), and the AC output of one inverter connects to the AC input of the next, adding their power in parallel onto the AC powerline, as illustrated in Figure 3 (’133 Patent, Fig. 3). This architecture is designed to simplify wiring, improve scalability, and increase system resilience against single-point failures (’133 Patent, col. 1:58-63; col. 3:58-61).
  • Technical Importance: This modular approach offered a method to improve the efficiency, flexibility, and fault tolerance of solar power installations compared to the prevailing centralized inverter architecture (’133 Patent, col. 1:58-63).

Key Claims at a Glance

  • The complaint asserts one or more of claims 1-24 (Compl. ¶16). Independent claim 1 is representative and includes the following essential elements:
    • A system with a plurality of power inverters, each having a DC power input port, an AC power input port, and an AC power output port.
    • The AC output port of each inverter is connected in a daisy chain to the AC power input port of the next inverter.
    • The AC output port of the last inverter is connected to a power service panel.
    • Each inverter includes a DC-DC boost converter, a DC-AC inverter, an internal AC powerline, a load interface circuit, an MFA microcontroller, a powerline modem, a line sensing circuit, and a solid state switch for disconnecting from the grid.

U.S. Patent No. 9,331,488 - “Enclosure and Message System of Smart and Scalable Power Inverters” (Issued May 3, 2016)

The Invention Explained

  • Problem Addressed: As power inverters become more complex with multiple input channels, installers and users require an effective and user-friendly way to monitor the status of the device and troubleshoot potential problems, especially in the harsh outdoor environments where such devices are typically installed (’488 Patent, col. 1:9-14, col. 11:13-20).
  • The Patented Solution: The patent discloses an inverter with an integrated "message system" that uses light-emitting diodes (LEDs) to provide visual feedback on the inverter's operational status (’488 Patent, Abstract). The system is controlled by a microcontroller and uses distinct LEDs to indicate the status of the overall system as well as the status of each individual DC input channel, employing different colors and flashing patterns to convey specific diagnostic information, as detailed in Tables 1 and 2 (’488 Patent, col. 2:3-9; Tables 1-2).
  • Technical Importance: The invention provides a built-in, intuitive diagnostic tool that can help solar installers identify and resolve issues during installation and operation without needing external monitoring equipment (’488 Patent, col. 11:15-20).

Key Claims at a Glance

  • The complaint asserts one or more of claims 1-17 (Compl. ¶24). Independent claim 1 is representative and includes the following essential elements:
    • A multiple channel power inverter with at least two DC power input channels and an AC power output port.
    • Internal components including a DC-DC boost converter for each channel, a DC power combiner, and a DC-AC inverter.
    • A message system connected to a digital microcontroller.
    • The message system is arranged to indicate the status of the power inverter and the status of each input channel.

III. The Accused Instrumentality

Product Identification

The accused products are the SUN600G3, SUN800G3, SUN1000G3, SUN1300G3, SUN1600G3, and SUN2000G3 microinverters, collectively referred to as the "SUN Series Microinverters" (Compl. ¶12).

Functionality and Market Context

The complaint identifies the accused products as "solar inverters" and "microinverters" that Defendants manufacture, offer for sale, and sell (Compl. ¶12, ¶16, ¶24). The complaint does not provide sufficient detail for analysis of the specific technical architecture, wiring methods, user interface, or diagnostic features of the SUN Series Microinverters. It also makes no specific allegations regarding the products' market position or commercial success (Compl. ¶12).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendants’ SUN Series Microinverters infringe claims of the ’133 and ’488 patents, either literally or under the doctrine of equivalents (Compl. ¶16, ¶24). It states that claim charts supporting these allegations are attached as Exhibits B and D; however, these exhibits were not included with the complaint as filed (Compl. ¶18, ¶25). The complaint’s narrative theory asserts that Defendants make, use, sell, and offer for sale power inverters that practice the patented inventions (Compl. ¶16, ¶24). No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions (’133 Patent): The analysis may raise the question of whether the connection method used by the accused SUN Series Microinverters constitutes the claimed "daisy chain" where the AC output of one inverter connects to the AC input of the next. The court may need to determine if this requires a specific port-to-port physical connection or if connection to a common trunk cable could meet this limitation.
  • Technical Questions (’133 Patent): What evidence does the complaint provide that the accused products contain each of the internally recited components, such as the specific "MFA microcontroller" required by Claim 1?
  • Scope Questions (’488 Patent): A central question may be whether the indicator lights on the accused products, if any, function as a "message system" that indicates status for both the overall system and for each individual input channel as required by Claim 1 of the ’488 Patent.
  • Technical Questions (’488 Patent): Does the complaint provide evidence that the accused products' indicator lights are driven by a microcontroller to display different colors or patterns corresponding to specific operational states, or are they simple power indicators?

V. Key Claim Terms for Construction

  • ’133 Patent:

    • The Term: "connected in a daisy chain to the AC power input port of the next inverter"
    • Context and Importance: This term is central to the scalability and simplified wiring architecture claimed by the patent. Its construction will determine whether the accused products' method of interconnecting multiple inverters falls within the scope of the claims. Practitioners may focus on this term because the distinction between a true input-to-output daisy chain and other parallel connection methods (e.g., tapping into a trunk line) is a critical technical difference in inverter system design.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that this method "greatly simplifies the wiring job," suggesting the functional result of simplification is key (’133 Patent, col. 3:58-61).
      • Evidence for a Narrower Interpretation: Figure 3 depicts a direct connection from the "AC power output port" (55, 52) of one inverter to the "AC power input port" (51) of the subsequent inverter, which could support an interpretation requiring distinct, physically separate input and output ports for the connection (’133 Patent, Fig. 3).

  • ’488 Patent:

    • The Term: "message system... arranged to indicate the status of the power inverter and the status of each input channel"
    • Context and Importance: This term defines the core user-interface and diagnostic feature of the invention. The infringement analysis will depend on whether the accused products provide this dual level of status indication (system-level and channel-level).
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The language of Claim 1 itself does not specify how the status is indicated, only that it is indicated for both the inverter and each channel (’488 Patent, col. 12:2-4).
      • Evidence for a Narrower Interpretation: The detailed description and associated tables provide a highly specific implementation where different colors (green, red) and patterns (solid, flashing) correspond to a wide range of distinct system and channel statuses (e.g., "Working," "Power Grid Error," "Defective Channel") (’488 Patent, Tables 1 & 2, col. 5:29-67). This could support a narrower construction requiring a system capable of conveying complex diagnostic information, not just simple on/off status.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. The inducement claim is based on Defendants allegedly instructing customers on how to use the accused products through "product manuals, brochures, videos, demonstrations, and website materials" (Compl. ¶19, ¶26). The contributory infringement claim is based on the allegation that the accused products have no substantial non-infringing uses (Compl. ¶20, ¶28).

Willful Infringement

The complaint alleges Defendants have known of the ’133 patent "from at least the filing date of lawsuit" and reserves the right to plead an earlier date of knowledge upon discovery (Compl. ¶17 & n.1). The prayer for relief requests a finding that infringement was willful and deliberate (Prayer for Relief, ¶e).

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

  • A key evidentiary question will be one of architectural equivalence: do the accused microinverters implement the specific input-to-output "daisy chain" AC connection architecture required by the ’133 patent, or do they utilize a different parallel wiring method that may fall outside the claim’s scope?
  • A core issue will be one of functional scope: does the user interface on the accused products constitute a "message system" capable of providing distinct status indications for both the overall inverter and for each of its individual input channels, as recited in the ’488 patent?
  • A foundational question for the litigation, stemming from the complaint's lack of specificity, will be what evidence Plaintiff can present to demonstrate that the accused inverters contain the numerous and specific internal hardware and software components recited in the asserted independent claims.