DCT
5:17-cv-01712
Pilot Inc v. Winplus North America Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Pilot, Inc. (California)
- Defendant: Winplus North America, Inc. (California)
- Plaintiff’s Counsel: Fernald Law Group LLP; Bradford, Ltd.
- Case Identification: 5:17-cv-01712, C.D. Cal., 08/23/2017
- Venue Allegations: Venue is alleged to be proper in the Central District of California because the Defendant, a California corporation, resides in the district and has its principal place of business there.
- Core Dispute: Plaintiff alleges that Defendant’s portable automobile jump starter infringes a patent related to safety circuitry designed to prevent dangerous, unintended electrical discharges.
- Technical Context: The technology addresses safety concerns in portable, lithium-ion-based car battery jump starters, a common automotive accessory.
- Key Procedural History: The complaint notes the asserted patent claims priority from a Chinese application filed in April 2014. It also describes Plaintiff's commercialization of the patented technology in its "LIGHTNING" brand jump starter, which it began selling in September 2014, potentially to support arguments of commercial success.
Case Timeline
| Date | Event |
|---|---|
| 2014-04-28 | Priority date of '297 Patent (based on Chinese application filing) |
| 2014-09-01 | Plaintiff begins commercial sales of its "LIGHTNING" product |
| 2016-12-20 | U.S. Patent 9,525,297 issues |
| 2016-12-31 | Alleged start date of Defendant's infringement (on or before) |
| 2017-08-23 | Complaint filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,525,297 - "Automobile Charger"
- Patent Identification: U.S. Patent No. 9525297, "Automobile Charger", issued December 20, 2016.
The Invention Explained
- Problem Addressed: The patent's background describes the risks associated with portable automobile chargers, which lacked the ability to automatically detect whether they were properly connected to a vehicle's battery, whether the polarity was reversed, or whether the battery was in a suitable state for charging. This created a risk of damage to the vehicle or an unsafe electrical discharge. (’297 Patent, col. 2:13-28; Compl. ¶7).
- The Patented Solution: The invention is an electrical circuit architecture for a portable charger that uses a microcontroller to coordinate several functional modules, including a DC-to-DC converter, a battery voltage detector, and a load detector. This system acts as a safety gatekeeper, preventing the charger from supplying power unless the microcontroller confirms that a proper connection to a car battery has been established, thereby preventing unintended discharge. (’297 Patent, Abstract; col. 4:5-13, FIG. 1).
- Technical Importance: The patented design provides a comprehensive safety mechanism that can automatically detect various connection states to protect both the charger and the vehicle, which is particularly important for devices intended for storage and emergency use by consumers. (’297 Patent, col. 2:48-56).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1. (Compl. ¶20).
- The essential elements of independent Claim 1 are:
- A novel automobile charger which comprises a direct current power supply comprising:
- A positive pole of the direct current voltage connected simultaneously with a first lead of a DC to DC module, a first lead of a battery voltage detection module, and a first lead of a load module.
- A negative pole of the direct current power supply connected simultaneously with a second lead of the DC to DC module, a first lead of a microcontroller, a first lead of an automobile start control module, and a second lead of the battery voltage detection module.
- A third lead of the DC to DC module connected with a second lead of the microcontroller.
- Three additional leads of the microcontroller connected respectively with a third lead of the battery voltage detection module, a second lead of the automobile start control module, and a first lead of a load detection module.
- A second lead of the load detection module connected simultaneously with a third lead of the automobile start control module and a second lead of the load module.
- The load module includes an automobile storage battery and an automobile engine located on one end of an automobile.
III. The Accused Instrumentality
Product Identification
The "Winplus Car Jump Start and Portable Power Bank." (Compl. ¶17).
Functionality and Market Context
- The accused product is a portable device for jump-starting automobile batteries. The complaint alleges that to prevent unintended discharge, the product incorporates a "safety switch on the jumper cables" that contains a printed circuit board (PCB) with the "same electrical configuration" as that claimed in the ’297 Patent. (Compl. ¶¶18-19). The complaint provides an annotated photograph of the front of the accused product's circuit board, identifying specific electronic components and mapping them to various claim limitations. (Compl. p. 8, FIG. 1). A second photograph shows the back of the circuit board, identifying additional components relevant to the "automobile start control module." (Compl. p. 8, FIG. 2).
- The complaint alleges the product is sold through major retailers, including Walmart, Target, Sam's Club, Costco, and Amazon. (Compl. ¶¶17, 28).
IV. Analysis of Infringement Allegations
Claim Chart Summary
The complaint alleges infringement of Claim 1 of the ’297 Patent, supported by an inspection of the accused product’s PCB. The core allegations are summarized below.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a positive pole of the direct current voltage connected with a first lead of a DC to DC module, a first lead of a battery voltage detection module, and a first lead of a load module simultaneously, | The accused PCB's direct current voltage is allegedly connected to the DC to DC module (U2.3), a voltage division circuit (R4, R6, R7, C2, C5), and the load module (CON1.1). | ¶31(b); p. 8 | col. 3:39-42 |
| a negative pole of the direct current power supply connected with a second lead of the DC to DC module, a first lead [of a] microcontroller, a first lead of an automobile start control module and a second lead of the battery voltage detection module simultaneously; | The accused PCB's power supply negative pole is allegedly connected to the DC to DC module (U2.2), the auto start control module (Q1.2), and the battery voltage detection module (C5.1). The complaint does not explicitly identify the connection to the microcontroller's first lead in this element. | ¶31(c); p. 8 | col. 3:42-46 |
| a third lead of the DC to DC module connected with a second lead of the microcontroller, | The third lead of the DC to DC module (U2.1) is allegedly connected to the second lead of a "probable microcontroller (U1.2)." | ¶31(f); p. 8 | col. 3:47-49 |
| three additional leads of the microcontroller connected with a third lead of the battery voltage detection module, a second lead of the automobile start control module and a first lead of a load detection module respectively, | Additional leads of the microcontroller (U1.9-14) are allegedly connected to leads of the battery voltage detection module, the car start control module, and the load detection module. | ¶31(f); p. 8 | col. 3:49-53 |
| wherein a second lead of the load detection module is connected with a third lead of the automobile start control module and a second lead of the load module simultaneously; | Leads from the accused load detection module allegedly connect to the automobile start control module and the load module through the microcontroller. | ¶31(h); p. 8 | col. 3:53-56 |
| the load module including an automobile storage battery and an automobile engine is located on one end of an automobile. | The load module is alleged to consist of the car battery and engine to which the device is connected. | ¶31(i); p. 8 | col. 3:56-59 |
Identified Points of Contention
- Scope Questions: Claim 1 is defined by a specific set of interconnections between functional "modules." The complaint identifies collections of discrete electronic components (e.g., resistors R4, R6, R7 and capacitors C2, C5) as constituting a single "battery voltage detection module." (Compl. p. 8). A central dispute may be whether such a grouping of standard components meets the claim requirement for a distinct "module," or if the term requires a more integrated or structurally defined unit.
- Technical Questions: The complaint identifies component U1 as a "probable microcontroller." (Compl. p. 8). A key evidentiary question will be whether this component in the accused device actually performs the intelligent control functions described in the patent—such as collecting data from other modules and making decisions to supply or withhold power—as required to meet the claim limitations.
V. Key Claim Terms for Construction
The Term: "module" (e.g., "battery voltage detection module", "load detection module")
Context and Importance: The claims are structured around the interconnection of various "modules." The definition of "module" is critical to infringement, as the complaint alleges that collections of discrete circuit components satisfy this limitation. Practitioners may focus on this term because its construction will determine whether the accused product's architecture can be mapped onto the claim's structure.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent specification describes the modules by their function (e.g., "The battery voltage detection module conducts the measurement of the batter voltage"). (’297 Patent, col. 4:62-63). The block diagram in Figure 1 also abstractly depicts the modules as simple boxes, which may support an argument that any set of components performing the recited function constitutes a "module." (’297 Patent, FIG. 1).
- Evidence for a Narrower Interpretation: Dependent claim 2 defines the "DC to DC module" by listing very specific components (a diode, resistor, capacitor, and a "HT7530 voltage stabilizing tube"). (’297 Patent, col. 5:27-45). This may support an argument that a "module" is intended to be a more specific and defined structural unit, not just a label for any components that achieve a given function.
The Term: "lead"
Context and Importance: The claim is a web of connections between the "leads" of the various modules. How "lead" is defined—whether as a physical pin on an integrated package or a more general electrical node—is essential for determining if the required connections exist in the accused device's circuit.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's summary uses the phrase "one end or lead," suggesting the terms are interchangeable and may support a broader definition as a general point of electrical connection. (’297 Patent, col. 3:5-7).
- Evidence for a Narrower Interpretation: The detailed embodiment describes connections to specific, named I/O points on components, such as "an IN port of the HT7530 voltage stabilizing tube." (’297 Patent, col. 5:31-33). This could support a narrower construction where "lead" refers to a formal, designated terminal on a component.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides an "instruction manual, videos, packaging and other promotional materials" that instruct end-users to connect and use the accused jump starter with their automobile engines, thereby causing them to perform the infringing use. (Compl. ¶¶29, 36).
- Willful Infringement: The complaint bases its willfulness allegation on post-suit conduct, asserting that any infringement continuing after Defendant receives the complaint will be "deliberate, willful, and intentional." (Compl. ¶37).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "module", as used in Claim 1, be construed to cover a diffuse collection of discrete resistors and capacitors on a circuit board, or does the patent require a more structurally distinct and identifiable unit? The resolution of this question will be fundamental to the infringement analysis.
- A key evidentiary question will be one of functional mapping: does the accused product's "probable microcontroller (U1)" and associated circuitry actually perform the specific, intelligent control logic recited in the patent—namely, detecting multiple conditions and selectively enabling power flow based on those conditions—or is there a fundamental mismatch in technical operation?