DCT
1:17-cv-01034
Somaltus LLC v. Maxim Integrated Products Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Somaltus LLC (Texas)
- Defendant: Maxim Integrated Products, Inc. (Delaware)
- Plaintiff’s Counsel: STAMOULIS & WEINBLATT LLC
- Case Identification: 1:17-cv-01034, D. Del., 07/26/2017
- Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant, a Delaware corporation, is "deemed to reside in this District."
- Core Dispute: Plaintiff alleges that Defendant’s battery charger integrated circuit infringes a patent related to an integrated battery service system.
- Technical Context: The technology concerns systems and methods for intelligently managing the charging of rechargeable batteries, a core function in countless electronic devices.
- Key Procedural History: The patent-in-suit is a divisional of a prior application that issued as U.S. Patent No. 7,089,127. The complaint asserts compliance with the patent marking statute, 35 U.S.C. § 287.
Case Timeline
| Date | Event |
|---|---|
| 2002-06-13 | ’386 Patent Priority Date |
| 2010-02-02 | ’386 Patent Issue Date |
| 2017-07-26 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,657,386 - “Integrated Battery Service System”
- Patent Identification: U.S. Patent No. 7,657,386, "Integrated Battery Service System," issued February 2, 2010 (’386 Patent).
The Invention Explained
- Problem Addressed: The patent describes conventional battery testers as being limited, single-function devices. It notes that if a service process is interrupted, the user must start over, reducing productivity, and that testing can be subject to noise interference from other components coupled to the battery, such as a car stereo or fan (’386 Patent, col. 1:21-44).
- The Patented Solution: The invention is an "integrated battery service system" that performs multiple services, such as testing and charging for both a battery and its associated components (e.g., alternators, starters) (’386 Patent, col. 2:56-62). To control battery charging, the system implements a method that compares the battery's current output level to a target level and adjusts the charge by controlling the on/off period of an AC power source connected to a transformer, as depicted in the control circuit of Figure 1C (’386 Patent, col. 7:47-54; Fig. 1C). This allows for maintaining a variable, adjustable charge level (’386 Patent, col. 7:31-42).
- Technical Importance: The invention aims to consolidate multiple diagnostic and service functions into a single, more efficient tool for technicians, with features like the ability to resume aborted tests to improve productivity (’386 Patent, col. 2:45-49).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 8 (’Compl. ¶12).
- The essential elements of Claim 8, a method claim, are:
- detecting a current battery output level of the battery;
- accessing a target charge level;
- comparing the current battery output level and the target charge level; and
- altering the charge signal by adjusting an on/off period of an AC power source to a transformer coupled to the battery.
- The complaint reserves the right to assert other claims (’Compl. ¶12).
III. The Accused Instrumentality
Product Identification
- The accused instrumentality is the "Max77301 JEITA-Compliant, Li+ Charger with Smart Power Selector" integrated circuit and similar devices (the "Product") (Compl. ¶13).
Functionality and Market Context
- The complaint alleges the Product is a power generation system component used in battery charging devices (Compl. ¶12-13). Its functionality is described as controlling "the charging sequence for single-cell Li+ batteries from battery detection, prequalification, fast charge, top-off, and charge termination" (Compl. ¶14). To achieve this, the Product allegedly detects the battery's voltage level, accesses a target charge level (a "set point or full" level), and compares the two to determine how to control the charge (Compl. ¶15-17). The complaint does not provide further detail on the Product's market positioning.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
’386 Patent Infringement Allegations
| Claim Element (from Independent Claim 8) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| detecting a current battery output level of the battery; | The Product detects the current battery output level, which the complaint alleges is a battery voltage, to determine the charging status. | ¶15 | col. 8:19-21 |
| accessing a target charge level; | The Product accesses a target charge level, described as a "set point or full" level, to determine when to change charging modes or stop charging. | ¶16 | col. 8:17-19 |
| comparing the current battery output level and the target charge level; | The Product compares the current battery output level to the target level to decide whether to stop charging or switch modes. | ¶17 | col. 8:19-21 |
| altering the charge signal by adjusting an on/off period of an AC power source to a transformer coupled to the battery. | The Product alters the charge signal by "adjusting an on/off period" by, for example, turning an AC power source on or off to the battery. | ¶18 | col. 8:8-13 |
Identified Points of Contention:
- Scope Questions: Claim 8 is a method claim. A primary question is whether the Defendant, by selling a component (an integrated circuit), can be said to directly perform all the steps of the claimed method. The complaint does not specify whether the accused Product performs the method itself or is merely a component within a larger system that does.
- Technical Questions: A key technical question is whether the accused Product’s internal charging control mechanism operates by "adjusting an on/off period of an AC power source to a transformer" as required by the claim. The complaint alleges this functionality but does not explain how an integrated circuit, which typically operates on DC power, would directly control an AC power source in the manner described by the patent (’386 Patent, Fig. 1C).
V. Key Claim Terms for Construction
The Term: "adjusting an on/off period of an AC power source to a transformer"
Context and Importance: This limitation defines the core mechanism of action for controlling the charge and is central to the infringement analysis. The dispute will likely focus on whether the accused integrated circuit's operation falls within the scope of this language, particularly given the patent’s focus on a system that appears to be powered directly from an AC line.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might argue the term is functional and should cover any technique that periodically gates power originating from an AC source, regardless of intermediate conversion steps. The claim language does not specify how the adjustment is made, only that it occurs.
- Evidence for a Narrower Interpretation: A defendant may argue the term is limited by the specification’s detailed disclosure, which describes a specific circuit for controlling the AC line input using an AC zero-cross detector and a PWM controller to drive a power transformer (’386 Patent, col. 7:47-54, Fig. 1C). This could be used to argue that the claim does not read on devices, such as many modern chargers, that operate from an intermediate DC power supply (e.g., a USB adapter).
The Term: "current battery output level"
Context and Importance: The complaint alleges this term is met by detecting "battery voltage" (Compl. ¶15). The construction of "output level" will determine what battery parameter must be measured.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: "Output level" could be argued to be a broad term encompassing any relevant battery state indicator, including voltage, current, or a calculated state of charge. The patent's background discusses testing general "battery conditions" (’386 Patent, col. 1:23).
- Evidence for a Narrower Interpretation: The specific embodiment describing the variable charging function explicitly refers to comparing "battery voltage" to a "target battery voltage" to control the charging process (’386 Patent, col. 8:19-21). This suggests "output level" in the context of this claim may be construed more narrowly as battery voltage.
VI. Other Allegations
The complaint does not contain allegations of indirect or willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technical and legal scope: Does the accused integrated circuit, a component that likely operates on DC power, perform the steps of a method claim requiring the "adjusting [of] an on/off period of an AC power source"? This raises a fundamental question of whether there is a mismatch between the technology described in the patent (an AC-powered automotive service system) and the technology of the accused product (a modern Li+ charger IC).
- A key threshold question will be one of direct liability: Can the sale of a component (the Maxim chip) constitute direct infringement of a method claim? The case may turn on what entity—Maxim, its customers who integrate the chip, or end-users—performs all the recited steps of comparing levels and altering a charge signal.