Battery Conservation Innovations LLC v. Targus US LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Battery Conservation Innovations, LLC (Texas)
  • Defendant: Targus US, LLC (Delaware)
  • Plaintiff’s Counsel: SML AVVOCATI P.C.
• Case Identification: 8:22-cv-02231, C.D. Cal., 12/12/2022
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed a resident of the Central District of California, where it has a regular and established place of business and where acts of infringement are allegedly occurring.
• Core Dispute: Plaintiff alleges that Defendant’s computer mice infringe a patent related to battery conservation technology that uses motion sensing to automatically power down a device.
• Technical Context: The technology addresses the common problem of battery drain in portable electronic devices by automatically entering a power-saving state when left inactive.
• Key Procedural History: The patent-in-suit, U.S. Patent No. 9,239,158, is subject to a terminal disclaimer, which ties its expiration date to that of a parent patent, U.S. Patent No. 8,610,372.

Case Timeline

Date	Event
2011-12-27	Priority Date for U.S. Patent No. 9,239,158
2016-01-19	U.S. Patent No. 9,239,158 Issued
2022-12-12	Complaint Filed

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

U.S. Patent No. 9,239,158 - "Battery-Conserving Flashlight and Method Thereof," issued January 19, 2016

The Invention Explained

• Problem Addressed: The patent's background describes how battery-powered devices, such as flashlights, are frequently left on inadvertently after use, which "drains the battery, often resulting in a 'dead' or unusable flashlight upon the next attempted use" (ʼ158 Patent, col. 1:31-34). This wastes energy and requires more frequent battery replacement.
• The Patented Solution: The invention integrates a motion sensor with a controller inside a battery-powered device ('158 Patent, col. 4:20-22). If the controller detects that the device has been motionless for a "predetermined period of time," it automatically "decouples the at least one battery from the illumination source to conserve energy" ('158 Patent, Abstract). The system can also provide a visual or audible alert to the user before shutting down, and the user can prevent the shutdown by simply moving the device ('158 Patent, col. 5:10-15). The core components are illustrated in the block diagram of Figure 2, which shows a motion sensor (226) and a battery (220) providing input to a controller (224) that operates a switch (222) to power an illumination source (108).
• Technical Importance: This technology provides an automated solution to extend the usable life of batteries in portable devices, reducing waste and improving user convenience ('158 Patent, col. 1:36-39).

Key Claims at a Glance

• The complaint asserts "one or more claims, including at least Claim 15" (Compl. ¶15).
• Independent Claim 15 recites the following essential elements for a "battery-conserving electronic device":
  • a body including an opening for accessing an interior of the body;
  • at least one battery disposed in the body and configured for powering the device;
  • a controller disposed in the body configured to determine if the body is in motion;
  • wherein if the body is not in motion for a first predetermined period of time, the controller decouples the at least one battery from the electronic device to conserve energy; and
  • a visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator.
• The complaint reserves the right to assert additional claims (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as a "Computer Mouse" and "any similar products" manufactured and sold by Defendant Targus (Compl. ¶15). No specific product models are named.

Functionality and Market Context

• The complaint alleges the accused product is a computer mouse powered by a replaceable battery (Compl. ¶16). Its relevant functionality includes "motion sensing capabilities" that allow it to "automatically switch to sleep mode when no movement is detected" (Compl. ¶16-17). The complaint alleges infringement through direct use, including internal testing by Defendant's employees, and through inducement of end-users via "product literature and website materials" (Compl. ¶16, ¶18). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" to detail its infringement allegations but does not include the exhibit in the filing (Compl. ¶15, ¶20). The narrative allegations in the complaint form the basis for the following analysis. The complaint does not provide sufficient detail for a full element-by-element analysis in a claim chart format.

The core of the infringement theory is that the "sleep mode" of the accused Targus mouse performs the function claimed in the ’158 Patent (Compl. ¶17). Plaintiff alleges that the mouse's body, battery, motion sensing capabilities, and controller map to the corresponding elements of claim 15. The automatic switching to "sleep mode" after a period of inactivity is alleged to constitute the claimed "decoupl[ing]" of the battery to conserve energy (Compl. ¶17, ¶15). The complaint broadly asserts that the accused products "satisfy all elements of the Exemplary '158 Patent Claims" but does not specify which feature of the mouse constitutes the claimed "visual indicator" (Compl. ¶13).

• Identified Points of Contention:
  • Scope Questions: The patent is titled and primarily describes a "flashlight." A potential issue is whether the claims, when read in light of the specification, can be interpreted to cover unrelated electronic devices like a computer mouse.
  • Technical Questions: A central technical question is whether the accused mouse's "sleep mode" is technically equivalent to the claimed function of "decoupl[ing] the at least one battery from the electronic device." The analysis may depend on whether the sleep mode constitutes a sufficient electrical disconnection or merely a low-power state. A second question is what evidence exists that the accused mouse has a "visual indicator" that is activated by the controller in response to a lack of motion, as the claim requires.

V. Key Claim Terms for Construction

1. The Term: "decouples the at least one battery from the electronic device" (’158 Patent, col. 7:21-23)

   • Context and Importance: This term is central to the infringement analysis, as it defines the core power-saving action. The dispute will likely focus on whether the accused product's "sleep mode" (Compl. ¶17) meets this definition.
   • Intrinsic Evidence for a Broader Interpretation: A party could argue the term's meaning is functional, focusing on the stated purpose to "conserve energy" (’158 Patent, col. 7:23-24). From this perspective, any state that effectively ceases primary power consumption, such as a software-controlled sleep mode, could be considered "decoupling."
   • Intrinsic Evidence for a Narrower Interpretation: A party could argue for a more structural definition based on the patent's diagrams and description. Figure 2 shows the controller (224) operating a physical "switch 222" that connects or disconnects the battery (220) from the load (108) (’158 Patent, col. 4:5-17). This could support an interpretation requiring a more complete electrical disconnection, rather than just a low-power hibernation state.

2. The Term: "a visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator" (’158 Patent, col. 7:26-28)

   • Context and Importance: This is a required element of claim 15. Infringement hinges on identifying a corresponding feature in the accused mouse that performs this specific function. The complaint does not identify such a feature.
   • Intrinsic Evidence for a Broader Interpretation: The specification describes the indicator as an "alert to the user" (’158 Patent, col. 4:55-56) and notes it can be an LED (’158 Patent, col. 4:48). This could support arguing that any LED on the mouse that activates or changes state in connection with inactivity qualifies.
   • Intrinsic Evidence for a Narrower Interpretation: The method described in the patent specifies that the controller activates the indicator after a period of inactivity and before deactivating the device, to serve as a warning (ʼ158 Patent, col. 5:50-60; Fig. 3, step 312). This functional context suggests that a general "power on" light or a low-battery warning light, which are not tied to signaling an impending motion-based shutdown, may not meet the claim limitation.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant distributes "product literature and website materials" that instruct end-users to operate the accused mouse in a manner that infringes the ’158 Patent (Compl. ¶18). Contributory infringement is also pleaded (Compl. ¶19).
• Willful Infringement: The willfulness allegation appears to be based on post-suit conduct. The complaint alleges that "Defendant has knowledge of its infringement... at least as of the service of the present complaint" and that it "actively, knowingly, and intentionally continued to induce infringement" after being served (Compl. ¶13, ¶19).

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

1. A core issue will be one of claim construction: does the term "decouples the at least one battery," as used in a patent focused on a flashlight with a physical switch, read on the software-based "sleep mode" of a modern computer mouse? The outcome will depend on whether the court adopts a functional (conserve energy) or a more structural (electrical disconnection) interpretation.

2. A second key issue will be evidentiary: can the plaintiff demonstrate that the accused mouse contains a "visual indicator" that is activated by the controller after a period of non-motion to warn of an impending shutdown, as the claim requires? The absence of this specific allegation in the complaint suggests it may be a point of significant factual dispute.

3. The case may also raise a question of patent scope: to what extent can claims from a patent whose specification is almost entirely dedicated to the embodiment of a "flashlight" be asserted against a technologically distinct product category like a computer mouse?