Battery Conservation Innovations LLC v. Scribe Labs Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Battery Conservation Innovations, LLC (Texas)
  • Defendant: Scribe Labs Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:19-cv-00851, D. Del., 05/06/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is a Delaware corporation and is therefore deemed to be a resident of the district.
• Core Dispute: Plaintiff alleges that Defendant’s RunScribe wearable running sensors infringe a patent related to methods for conserving battery power in electronic devices by detecting periods of motionlessness.
• Technical Context: The technology at issue involves using motion sensors to automatically place a battery-powered electronic device into a low-power state to extend battery life.
• Key Procedural History: The patent-in-suit is a continuation of a prior U.S. patent application, a fact that may be relevant to the patent’s prosecution history and claim scope. The complaint does not mention any other prior litigation or administrative proceedings.

Case Timeline

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

U.S. Patent No. 9,239,158 - "Battery-Conserving Flashlight And Method Thereof,"

• Patent Identification: U.S. Patent No. 9,239,158, "Battery-Conserving Flashlight And Method Thereof," issued January 19, 2016.

The Invention Explained

• Problem Addressed: The patent's background section identifies a common problem with battery-powered devices like flashlights: they are often accidentally left on after use, which drains the battery unnecessarily ('158 Patent, col. 1:26-34). This results in a "dead" device when it is next needed, requiring battery replacement and creating waste ('158 Patent, col. 1:35-40).
• The Patented Solution: The invention solves this problem by incorporating a controller and a motion sensor into the device ('158 Patent, Fig. 2). The controller is configured to detect if the device has been motionless for a predetermined period of time. If it has, the controller automatically "decouples" the battery from the device's main power-consuming components (e.g., the illumination source) to conserve energy ('158 Patent, Abstract; col. 4:18-24). The user can stop the deactivation by simply shaking or moving the device ('158 Patent, col. 5:10-14).
• Technical Importance: This automated power-saving approach sought to provide a more intelligent and user-friendly alternative to manual on/off switches, extending the useful life of batteries in portable electronics ('158 Patent, col. 1:38-40).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 15 (Compl. ¶14).
• The essential elements of independent Claim 15 are:
  • A body including an opening for accessing an interior of the body;
  • At least one battery disposed in the body and configured for powering the device;
  • A controller disposed in the body configured to determine if the body is in motion, wherein if the body is not in motion for a first predetermined period of time, the controller decouples the at least one battery from the electronic device to conserve energy in the at least one battery; and
  • A visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The accused products are the "RunScribe foot pad, and any similar products" (Compl. ¶16).

Functionality and Market Context

• The RunScribe is a small, lightweight "9-axis motion sensor" that is worn on a runner's shoe to capture detailed data about their gait and performance (Compl. ¶17).
• The complaint alleges that the product incorporates a battery-saving feature that mirrors the patented invention. Specifically, it alleges the "runScribe is designed to sleep when it is not active" and that it "turns itself off and on at a certain cadence" (Compl. ¶17, ¶20). The complaint includes a diagram from a user manual showing how to install the device's battery. This diagram illustrates the product's body having an opening for accessing its interior (Compl. ¶18).

IV. Analysis of Infringement Allegations

Claim Chart Summary

Identified Points of Contention

• Scope Questions: A central question will be whether the term "electronic device" in Claim 15, which originates from a patent titled and focused on a "flashlight," can be construed to read on a wearable running sensor. The complaint focuses on Claim 15, which recites a general "electronic device," rather than Claim 1, which is limited to a "flashlight."
• Technical Questions: The infringement analysis may turn on whether the accused product's "sleep" mode constitutes "decoupl[ing] the at least one battery from the electronic device" as required by the claim. The complaint alleges the device "turns itself off," but the court will need to determine if this software-based low-power state is technically equivalent to the "decoupling" described in the patent, which is illustrated with a physical switch disconnecting the power source ('158 Patent, Fig. 2). A screenshot provided in the complaint shows various LED indicator states for the accused product, including "Motion Detected" and "Recording," which is presented as evidence that the controller activates the visual indicator based on motion status (Compl. ¶21).

V. Key Claim Terms for Construction

• The Term: "electronic device"

• Context and Importance: This term's construction is critical. The patent-in-suit is titled and primarily describes a "flashlight." The accused product is a wearable athletic sensor. The viability of the plaintiff's case hinges on whether "electronic device," as used in Claim 15, is broad enough to cover the accused product.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly states that the invention's principles can be applied beyond flashlights, listing "a radio, portable media player, mobile phone, laptop computer, tablet, etc." as other examples ('158 Patent, col. 6:20-22). This language may support an argument that the term should be given a broad, plain-and-ordinary meaning.
  • Evidence for a Narrower Interpretation: The patent’s title, abstract, summary, and detailed description consistently refer to a "flashlight" embodiment ('158 Patent, Title; Abstract; col. 2:43-44). A party could argue that the entire disclosure frames the invention in the context of a flashlight, and the term "electronic device" should be limited to that context or to the specific list of alternative devices provided.

• The Term: "decouples the at least one battery from the electronic device"

• Context and Importance: The infringement allegation rests on the accused product's "sleep mode" meeting this limitation. Practitioners may focus on this term because modern electronics often use software-controlled low-power states rather than physically disconnecting a battery. The dispute will likely be whether a "sleep mode" is the same as "decoupling."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language is not explicitly limited to a physical switch. An argument could be made that any action that effectively stops the primary power draw for the purpose of conservation, such as a deep sleep state, meets the functional requirement of "decoupling."
  • Evidence for a Narrower Interpretation: The specification describes the controller operating a physical "switch 222" that "couples or decoupled the at least one battery to the illumination source 108" ('158 Patent, col. 4:12-15). This could be used to argue that "decouples" requires a hardware-level disconnection of the battery from the primary load, not merely a software-based sleep state where the controller and other components may still draw power.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Defendant induces infringement through its "customers' actions" (Compl. ¶24). The factual basis appears to be that Defendant sells a product with an automatic, built-in battery-conservation feature, thereby causing its customers to infringe by using the product as intended.
• Willful Infringement: The complaint alleges that Defendant has knowledge of its infringement "at least as of the service of the present complaint" (Compl. ¶13). This appears to be a standard allegation to support a claim for post-filing willfulness, rather than an allegation of pre-suit knowledge.

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

• A core issue will be one of definitional scope: can the term "electronic device," as used in a claim from a patent heavily focused on a "flashlight" embodiment, be construed broadly enough to cover a specialized, wearable athletic sensor?
• A second key issue will be one of technical and functional equivalence: does the accused product’s software-controlled "sleep" mode perform the same function in the same way as the claimed act of "decoupl[ing] the at least one battery from the electronic device," a function the patent specification illustrates with a physical switch?