DCT
1:17-cv-01526
Uniloc USA Inc v. Motorola Mobility LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc USA, Inc. (Texas) and Uniloc Luxembourg, S.A. (Luxembourg)
- Defendant: Motorola Mobility, LLC (Delaware)
- Plaintiff’s Counsel: O'KELLY ERNST & JOYCE, LLC; Prince Lobel Tye LLP
- Case Identification: 1:17-cv-01526, D. Del., 10/27/2017
- Venue Allegations: Venue is alleged to be proper based on Defendant offering its products and services to customers within the District of Delaware.
- Core Dispute: Plaintiff alleges that a wide range of Defendant’s smartphones infringe a patent related to temperature-adaptive battery charging systems.
- Technical Context: The technology concerns methods for managing battery charging currents in response to ambient and internal temperatures to prevent overheating, a critical function in modern, high-density portable electronics.
- Key Procedural History: The provided patent documents indicate that after this complaint was filed, an Inter Partes Review (IPR) proceeding was initiated against the patent-in-suit (IPR2018-00523). The IPR concluded with the cancellation of numerous claims, including the two independent claims (1 and 16) upon which the complaint's infringement allegations are primarily based. The patentability of several dependent claims asserted in the complaint (5, 6, and 21) was confirmed, but their viability is dependent on the now-cancelled independent claims.
Case Timeline
| Date | Event |
|---|---|
| 2001-11-12 | U.S. Patent No. 6,661,203 Priority Date |
| 2003-12-09 | U.S. Patent No. 6,661,203 Issue Date |
| 2017-10-27 | Complaint Filing Date |
| 2018-01-23 | IPR2018-00523 Filed |
| 2021-10-22 | IPR Certificate Issued |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,661,203 - "BATTERY CHARGING AND DISCHARGING SYSTEM OPTIMIZED FOR HIGH TEMPERATURE ENVIRONMENTS"
- Issued: December 9, 2003
The Invention Explained
- Problem Addressed: The patent describes a dilemma in designing battery-powered devices: charging and discharging generates internal heat, and when combined with a high-temperature operating environment, can push a battery beyond its safe thermal limits, compromising its lifespan and reliability (’203 Patent, col. 2:13-24, 2:39-47).
- The Patented Solution: The invention proposes an apparatus and method that actively monitors a battery's temperature and dynamically adjusts the charging current. As the temperature rises toward a critical threshold, the system reduces the current to limit self-heating, thereby extending the safe operating range without having to permanently use slow charging speeds or add costly cooling hardware (’203 Patent, Abstract; col. 4:35-46). The system uses a controller coupled to a temperature sensor to set the charging current, potentially using a look-up table that correlates specific temperatures with permissible current levels (’203 Patent, col. 3:6-13).
- Technical Importance: This approach allows a system to balance the need for rapid charging with the physical constraints of battery chemistry, enabling devices to operate more reliably in thermally challenging environments (’203 Patent, col. 4:41-46).
Key Claims at a Glance
- The complaint asserts independent claims 1 (apparatus) and 16 (method).
- Independent Claim 1 (Apparatus):
- A charging circuit for providing a charging current to the battery;
- A temperature sensor positioned to sense a temperature of said battery; and
- A controller coupled to the sensor and charging circuit, operable to control the charging current in accordance with the temperature and set the current to zero when the temperature is higher than a first predetermined threshold.
- Independent Claim 16 (Method):
- Sensing a temperature related to the battery;
- Setting a charging current in accordance with the sensed temperature, including setting the current to zero when the temperature is higher than a first predetermined threshold; and
- Charging the battery at the set current.
- The complaint reserves the right to assert dependent claims 3-6, and 18-21 (Compl. ¶12).
III. The Accused Instrumentality
Product Identification
The accused instrumentalities are numerous lines of Motorola smartphones, including Moto G, Moto X, Droid, and Moto Z series devices (Compl. ¶10).
Functionality and Market Context
The complaint alleges that the accused devices are rechargeable smartphones that include an apparatus for charging a lithium-ion battery (Compl. ¶10, ¶11). This apparatus allegedly contains a temperature sensor to monitor the battery's temperature and a controller coupled to the sensor and charging circuit. The controller is alleged to have the ability to control the charging current based on the sensed temperature, including reducing or setting the current to zero when the battery reaches a "predetermined threshold" (Compl. ¶11). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
'203 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| An apparatus for charging a battery comprising a charging circuit for providing a charging current to the battery; | The accused devices provide an apparatus for charging a lithium ion battery. | ¶11 | col. 7:36-38 |
| a temperature sensor positioned to sense a temperature of said battery; and | The apparatus contains a temperature sensor that is positioned to sense the temperature of the battery. | ¶11 | col. 7:39-40 |
| a controller coupled to said temperature sensor and said charging circuit and operable to control said charging circuit in accordance with said temperature, said controller operable to set said charging current to zero when said temperature is higher than a first predetermined threshold value. | The apparatus contains a controller coupled to the temperature sensor and charging circuit, which has the ability to control the charging current based on temperature and "reduce or set the charging current to zero when the battery reaches a predetermined threshold." | ¶11 | col. 7:41-45 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused devices' charging logic meets the specific limitation of setting the "charging current to zero when said temperature is higher than a first predetermined threshold." The complaint alleges the controller can "reduce or set" the current to zero, which introduces ambiguity as to whether the "set to zero" function is tied specifically to a temperature threshold as required by the claim, or occurs for other reasons (e.g., the battery reaching full capacity).
- Technical Questions: What evidence exists that the accused products' general thermal management—a common feature in modern smartphones—performs the specific functions recited in the claims? The court may need to determine if the accused controller executes the claimed two-step logic (control in accordance with temperature AND set to zero above a threshold), or if it employs a different, non-infringing algorithm such as continuous current throttling.
V. Key Claim Terms for Construction
The Term: "controller"
- Context and Importance: The definition of "controller" is central to the invention, as it is the component that executes the patented logic. The dispute may turn on whether the term is construed broadly to cover any generic processor performing thermal management or is limited to the more specific architecture described in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests a broad scope, stating the host controller "may be any of a variety of processors, microprocessors, controllers, microcontrollers, or other programmable devices" (’203 Patent, col. 6:50-55).
- Evidence for a Narrower Interpretation: A party could argue for a narrower definition based on the illustrative embodiment, which describes a "host controller 6" that communicates via an "SMBus 4" and utilizes a "look up table" to determine current levels (’203 Patent, FIG. 1; col. 6:10-14, 6:61-64).
The Term: "positioned to sense a temperature of said battery"
- Context and Importance: The location and capability of the temperature sensor are critical for the invention to function as intended. Practitioners may focus on this term because infringement could depend on whether a sensor located on a motherboard near the battery, rather than physically on or in the battery pack itself, falls within the claim's scope.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general and does not specify a precise location, only that it senses the battery's temperature.
- Evidence for a Narrower Interpretation: The specification describes an embodiment where a "thermistor 18 is located within the battery 2 at a position enabling it to sense the temperature immediately adjacent to the battery cells 24" (’203 Patent, col. 6:19-23). This could support an argument that the sensor must be integrated with or in very close proximity to the battery cells.
VI. Other Allegations
Indirect Infringement
The complaint alleges active inducement, stating that Motorola instructs customers on infringing use through "training videos, demonstrations, brochures, installation and/or user guides" available on its websites (Compl. ¶14). It also pleads contributory infringement, alleging Motorola provides a component that is a material part of the invention and knows it to be especially adapted for infringement (Compl. ¶15).
Willful Infringement
The complaint alleges that Motorola will be on notice of the ’203 Patent "at the latest, the service of this complaint," which appears to form the basis for a claim of post-filing willful infringement (Compl. ¶16).
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold procedural question will be the impact of the subsequent IPR. Given the post-filing cancellation of the asserted independent claims 1 and 16, the court's primary task will be to determine if Plaintiff can maintain a viable infringement action based on the surviving dependent claims (5, 6, and 21), which now lack a valid antecedent claim.
- Assuming the case can proceed, a core issue will be one of definitional scope and operational mapping: can the general thermal management features in a modern smartphone be mapped onto the specific, multi-step logic of the surviving claims? This will require determining if the accused devices implement the claimed "first predetermined threshold" for setting current to zero, as well as the "second predetermined threshold" for applying a maximum current, as required by surviving dependent claims 5 and 21.
- A key evidentiary question will be one of technical proof: what evidence can be produced from the accused devices to show that their controllers execute the precise algorithm claimed, rather than a functionally similar but structurally different method of thermal throttling? The outcome may depend on whether the alleged infringement is based on the specific logic disclosed in the patent or a more general functional result.