DCT

3:24-cv-08891

CyboEnergy Inc v. Duracell Power Center LLC

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I. Executive Summary and Procedural Information

Case Timeline

Date Event
2011-06-30 U.S. Patent No. 9,331,488 Priority Date
2013-03-07 U.S. Patent No. 9,331,489 Priority Date
2016-05-03 U.S. Patent No. 9,331,488 Issued
2016-05-03 U.S. Patent No. 9,331,489 Issued
2024-12-10 Complaint Filed

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

U.S. Patent No. 9,331,488 - "Enclosure and Message System of Smart and Scalable Power Inverters", Issued May 3, 2016

The Invention Explained

  • Problem Addressed: The patent describes the need for an effective and user-friendly way for installers to understand the operational status of complex, multi-channel solar inverters, which must operate reliably in harsh environments. A clear diagnostic system can help installers troubleshoot problems during installation, thereby reducing costs (’488 Patent, col. 11:7-21).
  • The Patented Solution: The invention is a power inverter incorporating a "message system" that uses a combination of a main system status LED and individual LEDs for each DC input channel. A microcontroller is programmed to control the color (e.g., green, red) and pattern (e.g., solid, flashing) of these LEDs to visually communicate specific diagnostic information, such as normal operation, warnings, or different types of errors (’488 Patent, Abstract; col. 4:11-23; FIG. 4).
  • Technical Importance: This technology provides a built-in visual diagnostic interface on the inverter itself, which may reduce the time and equipment needed for on-site installation, commissioning, and maintenance (’488 Patent, col. 11:12-21).

Key Claims at a Glance

  • The complaint asserts independent claim 16 (Compl. ¶18).
  • The essential elements of independent claim 16 are:
    • A method for indicating status, comprising:
    • monitoring the status of a power inverter having multiple DC input channels and monitoring each of the input channels; and
    • actuating LEDs (light-emitting diodes) based on the monitoring,
    • wherein a system status LED is controlled and arranged to indicate that a) the inverter is working; b) the inverter is working but has warnings; c) the inverter has errors; d) the AC grid has errors; and e) the inverter is off.
  • The complaint reserves the right to assert additional claims (Compl. ¶23).

U.S. Patent No. 9,331,489 - "Maximizing Power Production at Low Sunlight by Solar Power Mini-Inverters", Issued May 3, 2016

The Invention Explained

  • Problem Addressed: Solar inverters require a minimum level of DC power from solar panels to operate their own internal electronics. In low-light conditions such as sunrise, sunset, or heavy cloud cover, the power from the panels can fall below this threshold, forcing the inverter to shut down and cease power production entirely, which results in lost energy generation (’489 Patent, col. 3:50-col. 4:24).
  • The Patented Solution: The patent discloses a multi-channel inverter that can operate in a "low power mode." When the microcontroller detects low overall input power, it can dedicate one of the inverter's input channels solely to powering its internal electronics. This allows the remaining channels to continue inverting whatever power they can generate from the low sunlight, thereby enabling the inverter to operate and produce power in conditions that would otherwise force a complete shutdown (’489 Patent, Abstract; col. 5:27-53).
  • Technical Importance: This method aims to extend the daily operating window for a solar power system, increasing the total energy harvested, especially in environments prone to shading or variable sunlight (’489 Patent, col. 1:53-64).

Key Claims at a Glance

  • The complaint asserts independent claim 14 and dependent claims 15 and 16 (Compl. ¶28).
  • The essential elements of independent claim 14 are:
    • An m-channel solar power inverter, comprising:
    • at least two DC input channels;
    • a digital microcontroller constructed to run the power inverter in normal or low power mode based on calculated DC input power;
    • a DC power supply configured to take DC power from a dedicated input channel and its connected solar panel when the digital microcontroller detects that calculated input power is below a pre-determined value.
  • The complaint reserves the right to assert additional claims (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

The complaint identifies "Duracell PC's solar power inverters" as the Accused Instrumentalities (Compl. ¶16).

Functionality and Market Context

The complaint alleges that the Accused Products are solar power inverters used to convert DC power from solar panels into AC power (Compl. ¶18, ¶28). The products are allegedly marketed and sold to businesses and individuals throughout the United States (Compl. ¶21, ¶31). The complaint references a product brochure for technical details but does not provide the brochure itself as an exhibit (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits (Exhibits B and D) that were not attached to the pleading itself. Therefore, the infringement allegations are summarized below based on the complaint's narrative.

  • ’488 Patent Infringement Allegations: The complaint alleges that the Accused Products directly infringe at least claim 16 of the ’488 patent (Compl. ¶18). The infringement theory, as suggested by the reference to an exemplary claim chart, is that the Accused Products practice the patented method by monitoring their own system and input channel status and using on-board LEDs to communicate that status to users (Compl. ¶23).
  • ’489 Patent Infringement Allegations: The complaint alleges the Accused Products directly infringe at least claims 14, 15, and 16 of the ’489 patent (Compl. ¶28). The infringement theory appears to be that the Accused Products are multi-channel inverters that include a low-power operational mode where, upon detecting insufficient input power, one input channel is dedicated to powering the inverter's internal electronics while other channels continue to generate AC power, thereby meeting the limitations of claim 14 (Compl. ¶33).

No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope and Technical Questions (’488 Patent): A central issue may be whether the LED indication system on the Accused Products performs the specific functions required by the claim. The case raises the question of whether the accused system monitors and indicates the five distinct status conditions recited in claim 16 (working, working with warnings, errors, grid errors, off), or if it provides a more generalized status indication that does not map to the claim elements.
  • Technical Questions (’489 Patent): The infringement analysis will likely focus on the actual operational behavior of the Accused Products in low-light conditions. What evidence does the complaint provide that the accused inverters employ the specific architecture of dedicating one input channel to power internal electronics, as required by claim 14, rather than using an alternative method such as drawing small amounts of power from all channels or relying on internal energy storage?

V. Key Claim Terms for Construction

’488 Patent

The Term: "actuating LEDs... based on the monitoring" (Claim 16)

  • Context and Importance: This term is critical because it links the inverter's internal state-awareness to its external visual output. Practitioners may focus on this term because the strength of the infringement case depends on showing that the accused device's LED behavior is a direct, causal result of monitoring the specific statuses claimed, rather than a generic or unrelated indicator.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function in general terms, such as using an LED driver "to turn a specific LED to certain color and pattern to indicate the system status" (’488 Patent, col. 5:11-13).
    • Evidence for a Narrower Interpretation: The specification includes detailed tables (Table 1 and Table 2) that provide a specific, multi-level diagnostic code, linking precise LED colors and patterns (e.g., "solid green," "flashing red") to specific system conditions ("Inverter output AC voltage approaching limits," "Defective Channel") (’488 Patent, col. 5-6). A party could argue the claims should be read in light of this highly detailed disclosure.

’489 Patent

The Term: "one input channel... dedicated to supply DC power" (Claim 14)

  • Context and Importance: This phrase captures the core of the patented solution. Infringement will hinge on whether the Accused Products, in low-power mode, actually isolate and use a single, distinct input channel for the purpose of powering internal electronics.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes the concept as to "take power from one solar panel to supply DC power to its internal electronic circuits" (’489 Patent, Abstract), which could be argued to encompass any method of using a single panel's power for this purpose.
    • Evidence for a Narrower Interpretation: Figure 3 and the accompanying description illustrate a specific architecture where a channel's DC-DC boost converter is controlled to "stop[] pulling power... for AC power generation," and the power from that channel's solar panel is instead routed to the internal DC power supply (’489 Patent, col. 5:31-41; FIG. 3). An opposing party may argue that "dedicated" requires this specific functional and architectural separation.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for both patents. The inducement allegations are based on Defendant allegedly encouraging and instructing customers on the use of the Accused Products through materials like websites and instruction manuals (Compl. ¶24, ¶34). The contributory infringement allegations assert that the products are not staple commercial goods and that their only reasonable use is an infringing one (Compl. ¶25, ¶35).

Willful Infringement

Willfulness is alleged based on Defendant’s knowledge of the patents and the alleged infringement from at least the filing date of the lawsuit. Plaintiff seeks a finding of willfulness and treble damages (Compl. ¶24, ¶34; Prayer for Relief ¶e).

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

  • A core issue will be one of operational equivalence: Do the accused inverters, when operating in low-light conditions, actually implement the specific method of dedicating a single input channel to power internal electronics as claimed in the ’489 patent, or do they manage low power through a technically distinct, non-infringing mechanism?
  • A second key question will be one of diagnostic mapping: Does the accused products' LED status system perform the specific, multi-part diagnostic method of claim 16 of the ’488 patent by signaling distinct categories of system, channel, and grid status, or is there a fundamental mismatch between the claimed method and the accused system's functionality?