Scramoge Technology LTD. v. Apple Inc.

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Scramoge Technology Ltd. (Ireland)
  • Defendant: Apple Inc. (California)
  • Plaintiff’s Counsel: BC LAW GROUP, Group
• Case Identification: 6:21-cv-01071, W.D. Tex., 11/09/2022
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple is registered to do business in Texas, has transacted business in the district, and has regular and established places of business at several physical addresses listed in Austin, Texas.
• Core Dispute: Plaintiff alleges that certain of Defendant's wireless charging products, including the MagSafe and Apple Watch accessory lines, infringe three U.S. patents related to wireless power supply and transfer technology.
• Technical Context: The patents address technologies for managing and improving the efficiency of wireless power transfer, a ubiquitous feature in the modern consumer electronics market for smartphones, wearables, and other portable devices.
• Key Procedural History: This action is a Second Amended Complaint. Subsequent to its filing, two of the three asserted patents were the subject of Inter Partes Review (IPR) proceedings before the Patent Trial and Appeal Board. IPR proceedings for U.S. Patent Nos. 9,490,652 and 10,193,392 resulted in the cancellation of all asserted claims in this litigation. The complaint was filed while these IPRs were pending but before the final certificates of cancellation were issued.

Case Timeline

Date	Event
2008-11-14	’537 Patent Priority Date
2010-11-02	’537 Patent Issue Date
2013-07-24	’652 Patent Priority Date
2014-01-08	’392 Patent Priority Date
2016-11-08	’652 Patent Issue Date
2019-01-29	’392 Patent Issue Date
2021-10-14	Original Complaint Filing Date (approx.)
2022-02-02	IPR Filed for ’392 Patent (IPR2022-00529)
2022-02-03	IPR Filed for ’652 Patent (IPR2022-00532)
2022-11-09	Second Amended Complaint Filing Date
2023-11-13	IPR Certificate Issued for ’652 Patent (Claims 1-5, 7 cancelled)
2023-12-01	IPR Certificate Issued for ’392 Patent (Claims 1-8 cancelled)

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

U.S. Patent No. 9,490,652 - "Wireless charger equipped with auxiliary power supply and auxiliary power device," Issued November 8, 2016

The Invention Explained

• Problem Addressed: The patent describes the inconvenience of conventional wireless chargers, which must be connected to a commercial power supply via a dedicated cable, thus limiting their portability and utility. (ʼ652 Patent, col. 1:36-54).
• The Patented Solution: The invention is a wireless charger that incorporates an "auxiliary power unit"—essentially an internal, rechargeable battery. This unit is designed to charge its internal battery from an external source, power the wireless transmission unit while charging, or power the wireless transmission unit from the battery alone when disconnected from external power. The solution explicitly includes a "boost converter" to step up the battery's voltage to a level sufficient for wireless power transmission. (ʼ652 Patent, Abstract; col. 2:13-38).
• Technical Importance: This design merges the functionality of a portable battery pack with a wireless charger, enhancing user convenience by enabling device charging without constant connection to a wall outlet. (ʼ652 Patent, col. 2:1-12).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶10).
• Essential elements of claim 1 include:
  • a power input unit connected to an external power supply;
  • a wireless power transmission unit;
  • an auxiliary power unit capable of (i) charging a battery from the power input, (ii) simultaneously charging the battery and powering the transmission unit, and (iii) powering the transmission unit from the battery when the external supply is stopped;
  • wherein the auxiliary power unit comprises the battery, a charge/discharge module, and a boost converter that boosts voltage from the module.
• The complaint reserves the right to assert other claims from the patent. (Compl. ¶9).

U.S. Patent No. 7,825,537 - "Inductive power transfer system and method," Issued November 2, 2010

The Invention Explained

• Problem Addressed: The patent notes that traditional inductive power systems suffer from poor efficiency, which designers attempt to solve through careful, static tuning of the primary and secondary coils, increasing design cost and complexity. (ʼ537 Patent, col. 1:32-47).
• The Patented Solution: The invention proposes a dynamic system that actively optimizes power transfer. A control circuit in the base unit monitors a parameter (e.g., a voltage at a specific node) that is "indicative of an efficiency of power transfer." Based on this feedback, the control circuit automatically adjusts a characteristic of the time-varying current (such as its frequency or duty cycle) to "maximize an efficiency of power transfer," specifically by inducing a self-resonant oscillation in the target device's secondary coil. (ʼ537 Patent, Abstract; col. 4:11-34).
• Technical Importance: This method allows for a more robust and flexible system that can maintain high efficiency across different operating conditions and component variations, moving beyond static electrical matching. (ʼ537 Patent, col. 4:35-51).

Key Claims at a Glance

• The complaint asserts independent claim 1. (Compl. ¶16).
• Essential elements of claim 1, a method, include:
  • positioning a secondary inductive element (target) near a first inductive element (base);
  • applying a time-varying electric current to the first inductive element;
  • monitoring at least one parameter indicative of an efficiency of power transfer;
  • automatically adjusting at least one characteristic of the current in response to the parameter to maximize transfer efficiency.
• The complaint reserves the right to assert other claims from the patent. (Compl. ¶15).

U.S. Patent No. 10,193,392 - "Wireless power transfer device and wireless power transfer system," Issued January 29, 2019

• Technology Synopsis: This patent addresses the technical problem of spurious harmonic waves generated by a power transmitter, which can cause electromagnetic interference and reduce efficiency. (ʼ392 Patent, col. 1:50-58). The proposed solution uses a full-bridge inverter controlled by a pulse width modulation (PWM) signal with a duty ratio specifically selected (e.g., between 26% and 44%) to minimize the ratio of the maximum harmonic magnitude to the fundamental frequency magnitude, thereby improving the signal quality. (ʼ392 Patent, Abstract; col. 17:42-51).
• Asserted Claims: Independent claim 1. (Compl. ¶25).
• Accused Features: The complaint accuses the Apple Watch Magnetic Charging Cable and other wireless chargers for the Apple Watch of infringement. (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

• The complaint names several of Apple's wireless charging products, including the MagSafe Battery Pack, MagSafe Charger, MagSafe Duo Charger, Apple Watch Magnetic Charging Dock, Apple Watch Magnetic Fast Charger to USB-C Cable, and Apple Watches sold with wireless chargers. (Compl. ¶9, 15, 24).

Functionality and Market Context

• The accused products provide wireless charging for Apple's flagship mobile devices, including iPhones and Apple Watches. The complaint highlights specific functionality through screenshots. For the MagSafe Duo Charger, the complaint shows an image of the device charging an iPhone and an Apple Watch simultaneously. (Compl. p. 6). For the MagSafe Battery Pack, the complaint provides product information stating it "makes on-the-go charging easy" and "automatically charges, so there's no need to turn it on or off." (Compl. p. 8). The complaint also cites Apple's technical documentation stating that the "system intelligently adapts to conditions to optimize charging" and "will dynamically optimize power delivered." (Compl. p. 7). These products are integral accessories within Apple's popular and commercially significant device ecosystem.

IV. Analysis of Infringement Allegations

The complaint references, but does not attach, claim chart exhibits. The infringement theories are summarized below based on the complaint's narrative allegations.

’652 Patent Infringement Allegations

The complaint alleges that the MagSafe Battery Pack directly infringes claim 1 of the ’652 Patent. (Compl. ¶9). The infringement theory aligns the product's function with the claim elements: the Battery Pack is a "wireless charger" ('wireless power transmission unit') with an internal battery ('auxiliary power unit'). It uses a Lightning port as a "power input unit" to charge its internal battery from an external source. It can simultaneously charge its own battery and an iPhone, and it can charge an iPhone using only its battery power when unplugged, thus appearing to meet the functional requirements of the claim. A screenshot of the product description notes that a user can "charge both the MagSafe Battery Pack and your iPhone even faster" with a higher-wattage adapter, which supports the simultaneous charging allegation. (Compl. p. 8). The presence of a "boost converter" as claimed would need to be confirmed through technical analysis of the product's circuitry.

’537 Patent Infringement Allegations

The complaint alleges that a range of Apple products, including MagSafe and Apple Watch chargers, infringe claim 1 of the ’537 Patent by practicing the claimed method. (Compl. ¶15, 17). The core of the allegation is that these products monitor operating conditions and dynamically adjust power delivery to maximize efficiency. The complaint provides a screenshot of an Apple support document for the MagSafe Duo Charger which states, "The system intelligently adapts to conditions to optimize charging iPhone 12 at up to 14W of peak power delivery" and "MagSafe will dynamically optimize power delivered to the iPhone." (Compl. p. 7). Plaintiff appears to map the phrase "adapts to conditions" to the claimed step of "monitoring at least one parameter indicative of an efficiency" and "dynamically optimize power" to the step of "automatically adjusting" a current characteristic to "maximize" efficiency.

Identified Points of Contention

• Evidentiary Questions (’652 Patent): A central factual question is whether the MagSafe Battery Pack contains circuitry that performs the function of the claimed "boost converter."
• Technical Questions (’537 Patent): The infringement analysis may focus on whether the parameters Apple's system monitors (e.g., "temperature and system activity") are "indicative of an efficiency of power transfer" as required by the claim. A potential dispute is whether Apple's system performs the specific function taught in the patent—achieving self-resonance—or a different function, such as thermal management, that is outside the scope of the claims.

V. Key Claim Terms for Construction

’652 Patent

• The Term: "boost converter"
• Context and Importance: This is a specific circuit element required by claim 1. Infringement of the '652 patent depends on whether the accused MagSafe Battery Pack contains a circuit that meets this definition and "boosts the voltage of the electrical power output from the charge/discharge module."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification does not appear to provide a special definition, stating only that the boost converter "boosts the voltage... and provides the boosted voltage to the wireless power transmission unit." (ʼ652 Patent, col. 2:33-38). A party could argue for the plain and ordinary meaning of the term as understood in electrical engineering: a DC-to-DC converter that increases voltage.
  • Evidence for a Narrower Interpretation: A party could argue the term should be limited to the specific context of providing a sufficient voltage for wireless charging from a lower-voltage battery source, potentially excluding other forms of voltage regulation that might be present in the device.

’537 Patent

• The Term: "parameter indicative of an efficiency of power transfer"
• Context and Importance: This term defines the input to the claimed feedback control system. The viability of the infringement claim hinges on whether the data Apple's system monitors (allegedly "temperature and system activity") falls within the scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party might argue that any parameter used in a feedback loop to "optimize" power delivery is, by its nature, "indicative of" efficiency, as inefficient transfer often manifests as heat (temperature) or altered system performance.
  • Evidence for a Narrower Interpretation: The specification describes monitoring the voltage at an internal node (Vnode) to infer the input impedance of the primary coil, which directly relates to the electrical efficiency of the inductive coupling and the achievement of self-resonance. (ʼ537 Patent, col. 5:20-34). A party could argue the term is limited to such direct electrical measurements of coupling efficiency, not general system-level parameters like thermal status.

VI. Other Allegations

• Indirect Infringement: For the ’537 patent, the complaint alleges both induced and contributory infringement. The inducement allegation is based on Apple's user manuals and online instructions, which allegedly instruct users to operate the products in an infringing manner. (Compl. ¶17). The contributory infringement allegation claims the accused products are a material part of the invention, are not staple articles of commerce, and have no substantial non-infringing use. (Compl. ¶18).
• Willful Infringement: The complaint alleges knowledge of the ’537 patent as of the filing of the original complaint and seeks a finding of an exceptional case, suggesting a claim for post-suit willfulness. (Compl. ¶17, p. 12, ¶e).

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

• Impact of IPR Estoppel: The most significant issue in the case is the cancellation of all asserted claims of the '652 and '392 patents via Inter Partes Review. As the IPR certificates were issued after this complaint was filed, a threshold question is whether Plaintiff can maintain its causes of action on these two patents, given that the asserted claims are now cancelled and unenforceable.
• Functional Equivalence (’537 Patent): A central technical question will be whether Apple’s "dynamic optimization" based on "temperature and system activity" is functionally equivalent to the '537 patent’s method of maximizing efficiency by inducing self-resonance. The case may turn on evidence showing whether Apple's system performs the specific electrical function taught in the patent or a distinct, non-infringing function related to thermal safety or battery health.
• Definitional Scope (’537 Patent): The dispute will likely require construction of the claim term "a parameter indicative of an efficiency of power transfer." The key legal question is whether this term can be broadly construed to encompass thermal and general system data, or if the patent's specification limits it to direct electrical measurements of the inductive coupling's resonance state.