Koji IP LLC v. Renesas Electronics America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Koji IP LLC (Texas)
  • Defendant: Renesas Electronics Corp (California)
  • Plaintiff’s Counsel: Ramey LLP
• Case Identification: 5:24-cv-03089, N.D. Cal., 05/22/2024
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established place of business within the Northern District of California and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products and services related to wireless power charging infringe a patent directed to smart wireless power transfer between devices.
• Technical Context: The technology relates to systems that intelligently manage wireless power transfer, a key feature in the market for consumer electronics, IoT devices, and other portable battery-powered products.
• Key Procedural History: Plaintiff identifies itself as a non-practicing entity. The complaint alleges Defendant's knowledge of the patent-in-suit as of the filing date of the lawsuit, while reserving the right to prove pre-suit knowledge through discovery.

Case Timeline

Date	Event
2016-12-19	U.S. Patent 10,790,703 Priority Date
2020-09-29	U.S. Patent 10,790,703 Issued
2024-05-22	Complaint Filed

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"), titled "Smart wireless power transfer between devices", issued on September 29, 2020. (Compl. ¶7).

The Invention Explained

• Problem Addressed: The patent seeks to provide "solutions for wirelessly powering and charging powered devices in a smart manner," improving upon existing systems that may transfer power inefficiently or without regard to device authorization or status. (’703 Patent, col. 2:37-41).
• The Patented Solution: The invention describes a system comprising a "powering device" and a "powered device" that first establish a "close-range wireless communication" link to discover and authenticate one another. (’703 Patent, Abstract). Based on this communication and other conditions (e.g., battery levels), the system conditionally activates or deactivates the wireless power transfer functionality, thereby enabling intelligent control over the charging process. (’703 Patent, col. 7:12-20, Fig. 13).
• Technical Importance: This approach allows for more sophisticated power management than simple proximity-based charging, enabling features like authorization, status monitoring, and conditional power delivery to conserve energy and manage multiple devices. (’703 Patent, col. 2:50-65).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-4. (Compl. ¶9).
• The essential elements of independent claim 1 include:
  • A wireless power transfer system comprising a battery power source, wireless communication circuitry, and wireless powering circuitry.
  • The wireless powering circuitry includes a transmitter that emits electromagnetic waves to form a "radiative powering region."
  • The wireless powering circuitry is activated when a "close-range wireless communication is established."
  • The range of the communication circuitry is "substantially narrower" than the range of the radiative powering region.
  • Activation occurs in response to a message issued by the powered device when its battery level is below a threshold.
  • When the system is battery-powered, activation is allowed only if a "level of drop" in the battery level of the powering device's battery source over a "given time period" is below a threshold.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, methods, or services by name. It broadly refers to "systems, products, and services" maintained, operated, and administered by the Defendant. (Compl. ¶9).

Functionality and Market Context

The complaint alleges that the accused instrumentalities provide "wireless power charging" functionality. (Compl. ¶8, ¶11). The complaint does not provide sufficient detail for analysis of the specific technical operation or market context of any accused product.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" to support its infringement allegations but does not attach the exhibit. (Compl. ¶10). The infringement theory is therefore based on the general assertion that Defendant's unspecified products practice the "novel and improved methods and systems for wireless power charging" claimed in the ’703 Patent. (Compl. ¶8-9). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Pleading Sufficiency: A primary issue for the court may be whether the complaint's failure to identify any specific accused product or provide factual allegations mapping product features to claim elements meets the plausibility standard for patent infringement pleadings established by Ashcroft v. Iqbal and Bell Atlantic Corp. v. Twombly.
  • Scope Questions: Claim 1 is directed to a system with a "radiative powering region" formed by "electromagnetic waves." (’703 Patent, col. 46:17-20). This raises the question of whether the claim scope covers non-radiative technologies, such as inductive or resonant coupling, which are also discussed in the patent's specification but are not explicitly recited in the claim. (’703 Patent, col. 6:49-56).
  • Technical Questions: Claim 1 requires a specific, two-part conditional logic for activation: a low-battery message from the powered device, followed by a check of the powering device's battery "level of drop" over time. (’703 Patent, col. 46:30-42). What evidence the Plaintiff can produce that any accused product performs this specific drain-rate calculation, as opposed to a simpler battery voltage check, will be a central technical question.

V. Key Claim Terms for Construction

• The Term: "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 recites a highly specific functional requirement for the powering device. The viability of the infringement claim depends on whether the accused products perform this precise calculation. Practitioners may focus on this term because it appears to be a significant departure from a simple check of battery status.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue this term should be construed broadly to cover any form of power management logic that accounts for the rate of battery drain, not just one specific algorithm.
    • Evidence for a Narrower Interpretation: The plain language suggests a specific calculation of a rate of change (a "level of drop" over a "time period"). This is supported by embodiments in the specification, such as Figure 41, which explicitly depicts a decision block based on this condition, suggesting a narrow construction tied to this described function. (’703 Patent, col. 42:15-21, Fig. 41).

• The Term: "a range of the close-range wireless communication substantially narrower than a range of the radiative powering region"

  • Context and Importance: This term defines the spatial relationship between the control channel (communication) and the power-delivery channel. Proving infringement requires showing that an accused system is designed with this specific architecture.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party could argue that "substantially narrower" is a qualitative term of degree that does not require a specific numerical ratio, allowing it to cover a variety of system designs where the communication range is simply less than the power range.
    • Evidence for a Narrower Interpretation: A party could argue the term requires a functionally significant difference in range, necessary to implement the patent's "smart" charging concept where authorization and control are established before a device enters the main powering field. (’703 Patent, col. 2:37-41).

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement by "actively encourage[ing] or instruct[ing] others (e.g., its customers...)" on how to use its products for wireless power charging. (Compl. ¶11). It also alleges contributory infringement by asserting that there are "no substantial non-infringing uses" for the accused products. (Compl. ¶12). These allegations are not supported by specific factual assertions in the complaint.
• Willful Infringement: The willfulness claim is based on alleged knowledge of the ’703 Patent "from at least the filing date of the lawsuit," establishing a basis for potential post-filing willfulness. (Compl. ¶11). The Plaintiff also explicitly reserves the right to amend its complaint to allege pre-suit knowledge if such evidence is revealed during discovery. (Compl. ¶11, fn. 1).

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

• A threshold procedural question will be one of pleading sufficiency: Can the complaint survive a motion to dismiss given its failure to identify any accused product or provide factual allegations detailing how an accused product meets the specific limitations of the asserted claims?
• A key evidentiary question will be one of functional specificity: Does any accused product perform the specific, two-part conditional activation logic required by Claim 1, which involves not only a signal from the device to be charged but also a distinct analysis of the charging device's own battery drain-rate over time?
• A central claim construction issue will be one of technological scope: Can the term "radiative powering region," which is explicitly recited in the asserted independent claim, be construed to cover the near-field inductive or resonant charging technologies common in the marketplace, or is it limited to far-field technologies, potentially creating a mismatch with the functionality of the accused products?