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: 1:23-cv-01674, D. Colo., 06/30/2023
• Venue Allegations: Plaintiff alleges venue is proper in the District of Colorado because Defendant maintains a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified 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 systems for managing wireless power, using a separate, close-range communication channel to discover and authorize devices before activating a wider power transfer field.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit. The patent is noted as having been acquired by the Plaintiff through assignment.

Case Timeline

Date	Event
2016-12-19	U.S. Patent No. 10,790,703 Priority Date
2020-09-29	U.S. Patent No. 10,790,703 Issue Date
2023-06-30	Complaint Filing Date

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, "Smart wireless power transfer between devices," issued September 29, 2020 (the "'703 Patent").

The Invention Explained

• Problem Addressed: The patent seeks to provide "solutions for wirelessly powering and charging powered devices in a smart manner," moving beyond simple power coupling to add a layer of intelligent control. (’703 Patent, col. 1:36-41).
• The Patented Solution: The invention describes a system comprising a "powering device" and a "powered device" that first establish a "close-range wireless communication" to discover and authorize each other. (’703 Patent, Abstract). Only after this successful communication handshake does the powering device activate its "powering circuitry" to transmit energy over a potentially wider area, thus conserving power and preventing unauthorized charging. (’703 Patent, col. 2:50-65). This process is illustrated in various flowcharts, such as FIG. 16, which shows a discovery step (S1040) preceding the start of powering (S1041).
• Technical Importance: This approach improves energy efficiency by ensuring power-transmitting fields are not active when no authorized recipient is present and adds a layer of security by managing which devices can draw power. (’703 Patent, col. 2:19-23).

Key Claims at a Glance

• The complaint asserts claims 1-4. (Compl. ¶9, ¶11). Independent claim 1 is the focus.
• Essential elements of independent claim 1 include:
  • A wireless power transfer system with a battery power source, wireless communication circuitry, and wireless powering circuitry.
  • The communication circuitry establishes a "close-range wireless communication" with a powered device.
  • The powering circuitry emits electromagnetic waves to form a "radiative powering region" to charge the powered device.
  • The range of the close-range communication is "substantially narrower" than the range of the radiative powering region.
  • A "message is issued by the powered device when a battery level of the battery is below a predetermined threshold."
  • The powering circuitry is activated in response to receiving this message.
  • When battery-powered, activation is allowed only when a "level of drop in a battery level of the battery power source in a given time period is below a threshold."
• The complaint also asserts dependent claims 2-4, which further refine the conditions for allowing power transfer based on metrics like average battery consumption, processor utilization, and the number of active applications. (’703 Patent, col. 47:1-48:22).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any of Defendant's accused instrumentalities by name. It refers generally to "systems, products, and services that infringes one or more of claims 1-4 of the '703 patent." (Compl. ¶9).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality. It makes only a general reference to "wireless power charging" (Compl. ¶11) and alleges that Defendant "maintains, operates, and administers" the infringing products. (Compl. ¶9). No allegations regarding the products' specific operation or market position are provided.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in "Exhibit B" but this exhibit was not provided with the filing. (Compl. ¶10). The infringement theory is therefore based on the narrative allegations in the complaint body.

The complaint alleges that Defendant's unspecified products infringe claims 1-4 of the ’703 Patent "literally or under the doctrine of equivalents." (Compl. ¶9). It asserts that "Defendant put the inventions claimed by the '703 Patent into service (i.e., used them)" and that these actions caused the "claimed-invention embodiments as a whole to perform." (Compl. ¶9). The complaint does not provide any specific facts mapping features of any accused product to the limitations of the asserted claims.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Evidentiary Questions: The primary issue is evidentiary. What specific Renesas products are accused? What evidence does the complaint provide that these products contain a communication system and a separate power transfer system with the claimed "substantially narrower" range relationship? What evidence shows that these products automatically issue a message based on a battery level falling "below a predetermined threshold"?
• Scope Questions: A central question for the court will be whether Renesas’s accused technology, once identified, performs the specific, multi-step conditional logic required by claim 1, particularly the final limitation requiring a check on the "level of drop in a battery level" before allowing power transfer when the system itself is battery-powered.

V. Key Claim Terms for Construction

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 is the central architectural limitation of claim 1, defining the two-tiered nature of the system. The outcome of the infringement analysis will depend on whether an accused product uses two distinct operational zones with this specific relative relationship. Practitioners may focus on this term because it requires a factual comparison between two different wireless fields, which could be a point of significant technical dispute.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is functional, defining the relationship by what the ranges are, not by a specific protocol. This may support an interpretation that covers any system with two distinct ranges, regardless of the specific technology used.
  • Evidence for a Narrower Interpretation: The specification provides specific examples of "close-range wireless communication," such as RFID, NFC, and Bluetooth, and "radiative powering" using radio or microwaves. (’703 Patent, col. 7:32-38; col. 8:23-29). A party could argue the term should be construed in light of these examples, potentially limiting its scope to systems where the communication and power transfer technologies are of these distinct types.

The Term: "the message is issued by the powered device when a battery level of the battery is below a predetermined threshold"

• Context and Importance: This term defines the specific trigger for initiating wireless charging. Infringement requires that an accused device autonomously sends a request based on this condition. The dispute may turn on whether the accused device's logic for requesting a charge matches this specific requirement, as opposed to a user-initiated request or a different automated trigger.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim uses the general term "predetermined threshold," which could be interpreted to mean any set-point, whether fixed or user-configurable, that triggers a "low battery" communication.
  • Evidence for a Narrower Interpretation: The patent’s flowcharts, such as in FIG. 13 (S2010) and FIG. 15 (S2030), depict a discrete, programmed step of checking the battery level against a threshold to decide whether to activate the power reception circuitry. This could support a narrower construction requiring a specific, non-user-driven, programmatic check as part of an automated power management sequence.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement. (Compl. ¶11-12). It alleges inducement by asserting Defendant "actively encouraged or instructed others (e.g., its customers...)" to use its products in an infringing manner. (Compl. ¶11). For contributory infringement, it makes a similar allegation and adds the conclusory statement that there are "no substantial noninfringing uses." (Compl. ¶12).

Willful Infringement

The complaint alleges that Defendant has known of the ’703 patent "from at least the filing date of the lawsuit" and asks the court to declare the infringement willful and award treble damages. (Compl. ¶11, ¶V.e). No allegations of pre-suit knowledge are made, though Plaintiff reserves the right to amend if such knowledge is discovered. (Compl. ¶11, n.1).

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

• A threshold question will be one of evidentiary sufficiency: Can the Plaintiff, through discovery, identify a specific Renesas product and present factual evidence that it implements the core architecture of claim 1, namely the dual-range communication and power system and the autonomous, battery-level-triggered messaging protocol?
• The case will likely turn on a question of functional and technical scope: Does the operational logic of any accused Renesas product meet the specific, multi-part conditional requirements of claim 1, particularly the requirement to check the "level of drop" in the power source's own battery before enabling power transfer?
• A central claim construction dispute will likely address the definitional relationship between the communication and power transfer fields: What technical proof is required to demonstrate that the range of one is "substantially narrower" than the other, and does this require distinct communication and power transfer technologies as suggested by the specification's examples?