Koji IP LLC v. Renesas Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Koji IP, LLC (Texas)
  • Defendant: Renesas Electronics America, Inc. (California)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 3:23-cv-05752, N.D. Cal., 11/08/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business in the Northern District of California and has committed the alleged acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s systems, products, and services for wireless power charging infringe a patent related to smart wireless power transfer between devices.
• Technical Context: The technology concerns intelligent wireless power systems that use a secondary, close-range communication channel to discover and authorize devices before activating power transfer, aiming to improve efficiency and control.
• Key Procedural History: The complaint notes that Plaintiff owns the patent-in-suit by assignment. No other significant procedural events, such as prior litigation or post-grant proceedings, are mentioned.

Case Timeline

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

U.S. Patent No. 10,790,703 - "Smart wireless power transfer between devices"

• Patent Identification: U.S. Patent No. 10,790,703 (“the ’703 Patent”), "Smart wireless power transfer between devices," issued September 29, 2020.

The Invention Explained

• Problem Addressed: The patent seeks to improve upon existing wireless charging systems by providing solutions for powering and charging devices in a "smart manner," moving beyond simple continuous power transmission to create more efficient and controlled charging environments (’703 Patent, col. 1:37-41).
• The Patented Solution: The invention describes a system with a "powering device" and a "powered device" that first establish a "close-range wireless communication" to discover and authorize each other. Only after this communication is successful is the main wireless power transfer circuitry activated (’703 Patent, Abstract). This conditional activation is managed by a processor and can be based on various factors, including the battery levels of the devices and a database of authorized identifiers, preventing the system from broadcasting power unnecessarily (’703 Patent, col. 2:50-65; Fig. 4).
• Technical Importance: This approach conserves energy and enhances security by ensuring that power is only transferred to known, authorized devices that actually require a charge, a key consideration for deploying wireless power in public or multi-device environments (’703 Patent, col. 2:19-24).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-4 (Compl. ¶28).
• Independent claim 1 of the ’703 Patent recites the following essential elements for a wireless power transfer system:
  • A battery power source for the system.
  • Wireless communication circuitry for establishing a "close-range wireless communication" using a message.
  • Wireless powering circuitry with a transmitter that emits electromagnetic waves to form a "radiative powering region."
  • A requirement that the range of the close-range communication is "substantially narrower" than the range of the radiative powering region.
  • A condition that the powered device issues the message when its battery level is below a predetermined threshold.
  • The powering circuitry is activated in response to receiving that message.
  • A further condition that when the system is battery-powered, it makes a determination "whether a level of drop in a battery level of the battery power source in a given time period is below a threshold," and only allows activation if the drop is below that threshold.

III. The Accused Instrumentality

Product Identification

• The complaint accuses unspecified "systems, products, and services" that are maintained, operated, and administered by Defendant for "wireless power charging" (Compl. ¶9, ¶11). No specific product names, model numbers, or service offerings are identified.

Functionality and Market Context

• The complaint alleges that Defendant’s products and services perform infringing methods but does not provide specific details about their technical operation (Compl. ¶9, ¶13). The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe claims 1-4 of the ’703 Patent either literally or under the doctrine of equivalents (Compl. ¶9). It states that support for these allegations is contained in an attached Exhibit B, which was not filed with the public complaint (Compl. ¶10). The narrative infringement theory is that by making and selling its wireless charging products, Defendant has "put the inventions claimed by the ’703 Patent into service" (Compl. ¶9).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Specificity Question: A threshold issue for the court will be the identification of the specific accused instrumentalities. The complaint’s failure to name any "systems, products, and services" raises the question of whether it meets federal pleading standards for providing adequate notice to the defendant.
  • Technical Question: A central evidentiary question will be whether Plaintiff can show that Defendant's products, once identified, perform the specific two-part conditional activation required by Claim 1: first, activation in response to a message from a low-battery device, and second, the self-monitoring function where the powering device checks its own "level of drop" in battery over time before enabling power transfer.
  • Scope Question: The infringement analysis will question whether the "radiative powering region" in the claims reads on the technology used by Renesas, and whether the range of its control communication is "substantially narrower" than its power transfer field, a key structural limitation.

V. Key Claim Terms for Construction

• The Term: "a determination is made whether a level of drop in a battery level of the battery power source in a given time period is below a threshold"

  • Context and Importance: This term, located in the final clause of claim 1, describes a specific "smart" power-saving feature for the powering device itself. Proving infringement requires showing that an accused device performs this exact function, not just a generic power-saving mode. Practitioners may focus on this term because its specificity could create a high bar for the plaintiff to prove infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue this language should be read more generally to cover any system where the powering device assesses its own battery condition to decide whether to enable power transfer, consistent with the patent's overall goal of "smart" charging.
    • Evidence for a Narrower Interpretation: The patent specification provides a detailed flowchart for this exact process, explicitly showing a decision block for "Level of Drop in Battery Level of Battery Power Source in Given Time Period Being Below Threshold ?" (’703 Patent, Fig. 41). This figure and its description strongly suggest the term requires a specific calculation of a rate of change in battery level, not just a check against a static battery percentage, supporting a narrower and more complex technical meaning.

• The Term: "substantially narrower"

  • Context and Importance: This term of degree defines the required relationship between the communication range and the power transfer range. It is critical to the claim's architecture, as it ensures that a device is close enough for a dedicated communication link before the broader power field is activated.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide a specific numerical ratio. This may support an interpretation where any functional difference in range that achieves the goal of targeted communication prior to powering is sufficient.
    • Evidence for a Narrower Interpretation: The specification repeatedly contrasts "close-range wireless communication" like NFC or Bluetooth with a wider "powering region" (’703 Patent, col. 2:50-59, col. 8:27-38). This context suggests that the difference in range must be significant enough to reflect the distinct technological categories described, not merely a minor or incidental variance.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. For inducement, it alleges Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its products for wireless charging in an infringing manner (Compl. ¶11). For contributory infringement, it makes a conclusory allegation that there are "no substantial non-infringing uses" for the accused products (Compl. ¶12).
• Willful Infringement: The complaint alleges that Defendant has had knowledge of the ’703 Patent "from at least the filing date of the lawsuit" (Compl. ¶11, fn. 1; ¶12, fn. 2). This allegation forms a basis for potential post-filing willfulness and enhanced damages. The Plaintiff explicitly reserves the right to amend the complaint to allege pre-suit knowledge if such facts are revealed during discovery (Compl. ¶11, fn. 1).

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

• A threshold procedural question will be one of specificity: will the court require the Plaintiff to amend its complaint to identify the specific Renesas "systems, products, and services" that are accused of infringement before the case can proceed meaningfully?
• A core claim construction issue will be one of definitional scope: how will the court construe the highly specific limitation requiring the powering device to calculate its own "level of drop" in battery over a "given time period," a term that appears to define a very particular algorithm?
• The key evidentiary question will be one of functional proof: assuming specific products are identified, what evidence can Plaintiff provide to show that those products actually perform the complex, multi-step conditional logic recited in claim 1, particularly the "substantially narrower" range relationship and the "level of drop" calculation?