DCT

3:18-cv-02916

Uniloc USA Inc v. LG Electronics USA Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Uniloc USA, Inc. v. LG Electronics U.S.A., Inc., 4:17-cv-00828, N.D. Tex., 02/05/2018
  • Venue Allegations: Venue is premised on Defendant LG Electronics U.S.A., Inc. having a place of business within the Northern District of Texas.
  • Core Dispute: Plaintiff alleges that a wide range of Defendant's electronic devices, including smartphones and tablets, infringe a patent related to temperature-adaptive battery charging systems.
  • Technical Context: The technology at issue addresses the degradation of rechargeable batteries in portable electronics by dynamically adjusting charging and discharging currents in response to the battery's operating temperature.
  • Key Procedural History: This Amended Complaint was filed to supersede an original complaint and moot a pending motion to dismiss. Subsequent to the filing of this complaint, an Inter Partes Review (IPR2018-00523) was concluded on October 22, 2021. The IPR resulted in the cancellation of several asserted claims, including independent claims 1 and 16, while confirming the patentability of asserted dependent claims 5, 6, 20, and 21. This development significantly alters the scope of the dispute from what is pleaded in the complaint.

Case Timeline

Date Event
2001-11-12 ’203 Patent Priority Date (Filing)
2003-12-09 ’203 Patent Issue Date
2018-02-05 Amended Complaint Filing Date
2021-10-22 IPR Certificate Issued for '203 Patent

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

U.S. Patent No. 6,661,203 - "BATTERY CHARGING AND DISCHARGING SYSTEM OPTIMIZED FOR HIGH TEMPERATURE ENVIRONMENTS"

  • Patent Identification: U.S. Patent No. 6,661,203, "BATTERY CHARGING AND DISCHARGING SYSTEM OPTIMIZED FOR HIGH TEMPERATURE ENVIRONMENTS," issued December 9, 2003.

The Invention Explained

  • Problem Addressed: The patent's background describes a dilemma faced by designers of devices with rechargeable batteries. When a battery operates near its maximum temperature, maintaining normal charge and discharge currents can compromise its life and reliability. Conversely, a conservative approach of always using low currents results in unacceptably long charge and discharge times. ( ’203 Patent, col. 2:38-50).
  • The Patented Solution: The invention proposes a system that actively monitors a battery's temperature and adjusts the charge or discharge current accordingly. A controller, coupled to a temperature sensor, reduces the current as the temperature rises toward unsafe levels, thereby limiting internal heat generation. ( ’203 Patent, Abstract; col. 4:62-67). This allows the system to use higher, faster currents when conditions are cool and safer, lower currents when conditions are hot, thus optimizing both performance and longevity. ( ’203 Patent, col. 5:41-45).
  • Technical Importance: This adaptive approach allows designers to extract maximum performance from a battery without exceeding its safe operational constraints, a critical factor for portable electronic devices that generate their own heat and may be used in warm environments. ( ’203 Patent, col. 5:35-45).

Key Claims at a Glance

  • The complaint asserts independent claims 1 (apparatus) and 16 (method).
  • Independent Claim 1 (Apparatus):
    • A charging circuit for providing a charging current to the battery;
    • A temperature sensor positioned to sense the battery's temperature; and
    • A controller, coupled to the sensor and circuit, that controls the charging current "in accordance with said temperature," and is operable to set the charging current to zero when the temperature is higher than a "first predetermined threshold value."
  • Independent Claim 16 (Method):
    • Sensing a temperature related to the battery;
    • Setting a charging current "in accordance with said sensed temperature," including setting the current to zero if the temperature exceeds a "first predetermined threshold value"; and
    • Charging the battery at that set current.
  • The complaint also asserts dependent claims 2, 4-7, 16-17, and 19-22, though it reserves the right to assert others. (Compl. ¶13).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies a broad array of "Accused Infringing Devices," including dozens of models of LG cellular telephones, tablets, and smartwatches, such as the LG V30, G Pad series, and Watch Sport. (Compl. ¶12).
  • Functionality and Market Context: The complaint alleges that these devices and their associated software infringe the ’203 Patent but does not provide specific technical details on how their battery management systems operate. (Compl. ¶13). It states that a chart attached as Exhibit 1 identifies where each claim element is found, but this exhibit was not included with the provided complaint document. (Compl. ¶13). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references an infringement chart in "Exhibit 1" to detail how the Accused Infringing Devices meet each claim limitation, but this exhibit was not provided. (Compl. ¶13). The narrative allegations state that the devices, by being made, used, or sold, directly infringe the asserted claims. (Compl. ¶13). In the absence of the claim chart, a detailed element-by-element analysis is not possible based on the complaint alone.

  • Identified Points of Contention:
    • Scope Questions: Given the subsequent cancellation of independent claims 1 and 16 in the IPR, the central question for the case is whether Plaintiff can prove infringement of the surviving dependent claims (e.g., claims 5, 6, 20, 21). This raises the question of whether LG’s devices implement the more specific limitations of those claims, such as setting the charging current to a "maximum value" below a certain temperature threshold (claim 5) and whether that value corresponds to the "battery's maximum specified charging current" (claim 6).
    • Technical Questions: A primary technical question will be what evidence demonstrates that the accused devices' software or hardware performs the claimed functions. For example, what evidence shows that the devices set charging current "in accordance with said temperature" in the manner claimed, rather than through a different, non-infringing thermal management technique?

V. Key Claim Terms for Construction

  • The Term: "controller"

  • Context and Importance: This term appears in independent claim 1 and is fundamental to the apparatus. Its construction will determine whether the claim can read on devices that use a general-purpose processor running software for thermal management, or if it is limited to a more specific, dedicated hardware controller.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification suggests a broad scope, stating the host controller "may be any of a variety of processors, microprocessors, controllers, microcontrollers, or other programmable devices as are presently understood, or later become available." ( ’203 Patent, col. 6:49-54).
    • Evidence for a Narrower Interpretation: A party seeking a narrower construction might argue that the "controller" must be a distinct component as depicted in Figure 1 ("controller 16" and "host controller 6"), separate from the main computing functions of the device.

  • The Term: "in accordance with said temperature"

  • Context and Importance: This phrase from claims 1 and 16 defines the required relationship between temperature and current. The dispute will likely center on how direct and specific this relationship must be to infringe.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The general language of the claim could be argued to cover any system where current is reduced as temperature rises.
    • Evidence for a Narrower Interpretation: The specification provides a specific example of this relationship in a look-up table (Table 1), which shows a stepped, non-linear function. ( ’203 Patent, col. 6:5-14). An argument could be made that the term requires a similar, predetermined functional relationship rather than a simple on/off switch at a single temperature threshold.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges active inducement, stating that LG instructs customers to infringe through "training videos, demonstrations, brochures, and installation and user guides." (Compl. ¶14). It also alleges contributory infringement, arguing that the software in the accused devices is a material part of the invention, especially made for use in an infringing manner, and not a staple article of commerce. (Compl. ¶¶15-16).
  • Willful Infringement: The complaint alleges post-suit willfulness, asserting that upon receiving notice via the complaint, LG's continued infringement will be knowing and intentional. (Compl. ¶17). No facts supporting pre-suit knowledge are alleged.

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

  • A foundational issue is the impact of the IPR proceeding: With the asserted independent claims cancelled, the case's viability hinges on whether Plaintiff can successfully prove infringement of the remaining asserted dependent claims (5, 6, 20, 21). This shifts the focus to the specific, narrower limitations recited in those claims.
  • A key evidentiary question will be one of technical implementation: Can Plaintiff produce evidence demonstrating that the accused LG devices perform the specific functions recited in the surviving dependent claims, such as setting a "maximum value" for charging current below a temperature threshold (claim 5) that is explicitly defined as the "battery's maximum specified charging current" (claim 6)? The case will turn on the proof of these detailed operational characteristics.