DCT
8:25-cv-00335
NOCO Co v. Winplus North America Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: The NOCO Company (Ohio)
- Defendant: Winplus North America, Inc., Winplus NA, LLC, and ADC Solutions Auto LLC (California/Delaware)
- Plaintiff’s Counsel: Jones Day
- Case Identification: 8:25-cv-00335, C.D. Cal., 02/20/2025
- Venue Allegations: Venue is alleged to be proper as Defendants reside in the Central District of California and the accused infringing acts occurred within the district.
- Core Dispute: Plaintiff alleges that Defendant’s portable vehicle jump starters infringe patents related to USB-based recharging circuitry and integrated safety features.
- Technical Context: The technology domain is portable, lithium-ion-based consumer electronics for jump-starting vehicles, a market segment where convenience and safety are significant competitive features.
- Key Procedural History: The complaint notes prior litigation between the parties involving related patents before the U.S. International Trade Commission. Such history, if proven, may be relevant to the complaint's allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-07-03 | Priority Date for ’143 and ’696 Patents |
| 2025-01-07 | U.S. Patent No. 12,187,143 Issued |
| 2025-01-28 | U.S. Patent No. 12,208,696 Issued |
| 2025-02-20 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,187,143, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection" (Issued Jan. 7, 2025)
The Invention Explained
- Problem Addressed: The patent describes the dangers of traditional jump-starting, such as sparks from improper connections, and the inconvenience of recharging prior-art portable jump starters, which often required proprietary high-power chargers. (Compl. ¶¶13, 17; ’143 Patent, col. 1:36-52).
- The Patented Solution: The invention is a handheld, portable jump starter that can be recharged using a low-voltage, standardized USB input. This is achieved through an internal "upconverting" DC-to-DC converter circuit that boosts the lower USB voltage (e.g., 5V) to a higher voltage sufficient to recharge the device's multi-cell lithium battery pack (e.g., 12V). (’143 Patent, Abstract; col. 7:55-67). The system also incorporates control circuitry to prevent over-charging and over-discharging. (’143 Patent, Abstract).
- Technical Importance: This approach enabled powerful vehicle jump starters to be recharged using ubiquitous and convenient USB power sources, removing the need for bulky, non-standard chargers. (Compl. ¶17).
Key Claims at a Glance
- The complaint asserts independent claims 1, 23, and 30. (Compl. ¶¶26, 37, 38).
- Essential elements of Independent Claim 1 include:
- A hand held, portable jump starter device with a housing containing a multi-cell rechargeable battery (at least three cells in series), a USB input port for recharging, and an output port for jump starting.
- A USB charge circuit with a DC-to-DC converter for "upconverting" the input voltage from the USB port to a higher charging voltage.
- A pair of series-connected transistor devices to control current flow into and out of the battery.
- A control circuit to prevent over-charging by turning off the USB charge circuit when voltage exceeds a threshold.
- A battery charge controller to prevent over-discharging.
- The complaint reserves the right to assert additional claims. (Compl. ¶27).
U.S. Patent No. 12,208,696, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection" (Issued Jan. 28, 2025)
The Invention Explained
- Problem Addressed: The patent background describes the safety risks associated with incorrectly connecting high-current jumper cables to a vehicle battery. (’696 Patent, col. 1:30-43).
- The Patented Solution: The invention is an apparatus comprising two main parts: a handheld booster device and a separate jumper cable device. The handheld booster contains the rechargeable battery, a power switch, and a "control circuit" that first detects if it is safe to connect to the vehicle's battery (e.g., checks for correct polarity) and only then connects the battery to the output port via the power switch. (’696 Patent, Abstract; col. 5:2-10). This gatekeeping function is designed to prevent power from flowing until a safe connection is confirmed.
- Technical Importance: The invention integrates intelligent safety logic into the jump starter to preemptively identify and prevent dangerous conditions like short circuits or reverse polarity connections before high current is applied. (Compl. ¶59).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 23. (Compl. ¶¶56, 67).
- Essential elements of Independent Claim 1 include:
- A handheld booster device with a rechargeable battery pack, a control circuit, a power switch, and an output port. The control circuit detects when it is safe to couple to the vehicle's battery and then connects the battery pack to the output port through the power switch.
- A jumper cable device with a plug configured to connect to the output port in a specific orientation.
- The handheld device also includes an input port for external charging and a "charge circuit" with an "upconverter" for converting the input voltage to a higher charging voltage.
- The complaint reserves the right to assert additional claims. (Compl. ¶57).
III. The Accused Instrumentality
- Product Identification: The accused instrumentalities are a range of portable jump starter products sold by Winplus, including those marketed under the "TYPE S" brand such as the "Dynamic Light," "Dynamic D20," and "ProJump" models. (Compl. ¶22).
- Functionality and Market Context: The accused products are described as handheld, lithium-ion-based devices capable of jump-starting vehicles with 12V batteries. (Compl. ¶¶29, 40). They are recharged via micro-USB and/or USB-C input ports and feature advertised "Safe & Smart Jump-Starting Technology," which includes protections such as "Polarity Protection" and "Over-discharge Protection." (Compl. ¶¶30, 36, 59). The complaint provides a teardown image of a TYPE S jump starter to identify its internal "Power Supply." (Compl. p. 10).
IV. Analysis of Infringement Allegations
’143 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A hand held, portable jump starter device, comprising: a housing having a multi-cell rechargeable battery including at least three battery cells connected in series, a USB input port for receiving a charging current from an external source to recharge the multi-cell rechargeable battery, and an output port for providing jump starting current... | The accused products are handheld devices containing an internal lithium-ion battery, advertised for 12V output (implying a multi-cell series configuration), and featuring micro-USB and/or USB-C input ports for recharging. | ¶29 | col. 6:53-60 |
| a USB charge circuit connected to the USB input port, the USB charge circuit including a DC-to-DC converter circuit for upconverting an input voltage on the USB input port to a higher charging voltage... and a pair of series connected transistor devices... | The complaint alleges the products' internal circuitry takes input voltage from the USB ports (e.g., 5V or 9V) and converts it to a higher voltage (e.g., 12V) to charge the internal battery, and includes transistor devices for current control. The complaint presents an image of the accused product's circuit board, highlighting components alleged to perform this function. (Compl. p. 13). | ¶32 | col. 7:55-67 |
| a control circuit for detecting the voltage of the multi-cell rechargeable battery and configured to turn off the USB charge circuit to prevent over charging... if the detected voltage exceeds a threshold value... | The accused products are alleged to have a control circuit that detects when the battery is fully charged (e.g., showing "100%" on an LCD screen) and stops the charging process. | ¶35 | col. 8:1-6 |
| a battery charge controller coupled to the multi-cell rechargeable battery... and configured to prevent over discharging of the multi-cell rechargeable battery. | The accused products are marketed with "Safe & Smart Jump-Starting Technology," which the complaint alleges includes an "Over-discharge Protection" feature that meets this limitation. | ¶36 | col. 8:7-10 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the claim term "USB input port", based on a 2014 priority date, can be construed to literally cover newer standards like USB-C, which are present on some accused products. The complaint preemptively argues for a broad construction or, alternatively, infringement under the doctrine of equivalents. (Compl. ¶31).
- Technical Questions: The complaint alleges the presence of a "DC-to-DC converter circuit for upconverting" based on product functionality and images of internal circuit boards. (Compl. ¶32). A key evidentiary question will be whether discovery confirms that the accused circuitry operates in the specific manner required by the claim.
’696 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus for jump starting a vehicle, comprising: a handheld booster device comprising a rechargeable battery pack, a control circuit, a power switch, and an output port, wherein the control circuit detects when it is safe to couple the handheld booster device to the vehicle's battery and connects the rechargeable battery pack to the output port thru the power switch... | The accused jump starters are alleged to be handheld booster devices with internal batteries and safety features ("Safe & Smart Jump-Starting Technology") that detect for proper connection before a power relay connects the battery to the output port. | ¶59 | col. 5:2-10 |
| a jumper cable device comprising a plug and a pair of cables integrated with the plug, the plug being configured to connect to the output port of the handheld booster device in a specific orientation... | The accused products are used with a detachable jumper cable that has a keyed plug, ensuring it can only be inserted into the device's output port in one orientation. The complaint includes an image from the user manual showing this gray, three-prong plug. (Compl. p. 26). | ¶61 | col. 3:9-14 |
| wherein the handheld booster device further comprises an input port for providing power from an external source to the rechargeable battery pack... | The accused devices include micro-USB and/or USB-C input ports for receiving charging power from external sources. | ¶62 | col. 5:11-14 |
| wherein the handheld booster device further comprises a charge circuit connected to the input port, the charge circuit including an upconverter circuit... for converting the voltage from the input port to a higher voltage for charging the rechargeable battery pack... | As with the ’143 Patent, the complaint alleges the products' internal circuitry upconverts voltage from the USB input to charge the internal battery pack. | ¶63 | col. 5:15-26 |
- Identified Points of Contention:
- Technical Questions: The claim requires a specific sequence of operations: the "control circuit detects when it is safe" and then "connects the... battery pack... thru the power switch". A point of contention may be whether the accused products' integrated safety systems perform this precise two-step logical function, or if their safety mechanism operates in a fundamentally different way.
- Scope Questions: The case may explore whether the functions of the claimed "control circuit" and "power switch" are performed by distinct components in the accused devices, or if they are integrated into a single microcontroller or chipset in a manner that diverges from the structure implied by the patent's claims.
V. Key Claim Terms for Construction
For the ’143 Patent:
- The Term: "USB input port"
- Context and Importance: This term's scope is critical, as some accused products use USB-C ports, a standard that gained prominence after the patent’s priority date. The viability of a literal infringement allegation may depend on whether the term is construed broadly to cover the USB family of standards or is limited to the specific types prevalent in 2014.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Practitioners may argue that the specification does not limit the term to a specific version (e.g., USB-A or micro-USB) but instead describes the function of receiving low-voltage power from a standardized source, a function common to all USB versions. The complaint advocates for this view. (Compl. ¶31).
- Evidence for a Narrower Interpretation: The patent’s specific embodiments and figures may only depict older USB connector types. A defendant could argue that the term should be limited to the physical and electrical standards known to a person of ordinary skill at the time of the invention.
For the ’696 Patent:
- The Term: "the control circuit detects when it is safe to couple... and connects the rechargeable battery pack to the output port thru the power switch"
- Context and Importance: This phrase defines the core safety logic and sequence of operations. Infringement hinges on whether the accused products perform this specific cause-and-effect sequence. Practitioners may focus on this term because it links a detection step to a separate connection step.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification may describe the overall goal of preventing power flow until safety is confirmed, potentially allowing for various hardware or software implementations that achieve this result.
- Evidence for a Narrower Interpretation: The patent's detailed description and figures may disclose a particular arrangement where a sensor circuit ("control circuit") provides a signal to a distinct relay or FET ("power switch"). A defendant might argue the claim requires this discrete architecture, which may differ from the integrated safety ICs used in modern devices.
VI. Other Allegations
- Indirect Infringement: The complaint does not contain a formal count for indirect infringement. However, it alleges facts that could potentially support such a theory, stating that Defendants provide user manuals and marketing that instruct customers on how to use the allegedly infringing features, such as charging via the USB port and connecting the jumper cables. (Compl. ¶¶26, 38, 49).
- Willful Infringement: The complaint explicitly alleges that Winplus’s infringement has been willful. (Compl. ¶¶81, 87). The basis for this allegation is alleged actual knowledge of the patents-in-suit and a history of prior patent litigation between NOCO and Winplus involving related jump starter technologies before the U.S. International Trade Commission. (Compl. ¶¶81, 87).
VII. Analyst’s Conclusion: Key Questions for the Case
This dispute presents several technical and legal questions for the court. The outcome may turn on the resolution of two central issues:
A core issue will be one of definitional scope: Can the term "USB input port," as used in a patent with a 2014 priority date, be construed to encompass the later-adopted USB-C standard, or will infringement for certain products depend on the more fact-intensive doctrine of equivalents?
A key evidentiary question will be one of operational correspondence: Does the accused products' integrated "Safe & Smart" circuitry perform the specific, sequential logic of "detecting safety" and then separately "connecting power" as required by the '696 patent claims, or is there a material difference in the technical method of operation that places it outside the claims' scope?