Boracho IP Holdings LLC v. Sensata Tech Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Boracho IP Holdings LLC (Texas)
  • Defendant: Sensata Technologies, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Associates, LLC; Rabicoff Law LLC
• Case Identification: 1:19-cv-01822, D. Del., 09/27/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s MSH-M Series Inverter/Charger products infringe a patent related to power charging devices that manage and combine power from multiple, independently varying energy sources.
• Technical Context: The technology at issue addresses power management systems for integrating disparate energy sources, such as those found in renewable or off-grid power applications, to enable simplified and efficient battery charging.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events related to the patent-in-suit.

Case Timeline

Date	Event
2001-04-20	’251 Patent Priority Date
2003-06-17	’251 Patent Issue Date
2019-09-27	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 6,580,251, "Power charging device using multiple energy sources," issued June 17, 2003.

The Invention Explained

• Problem Addressed: The patent addresses the challenge of efficiently charging a system using multiple types of power sources (e.g., wind, solar) whose power outputs vary independently and without correlation. Conventional approaches often require separate charging functions for each source, which increases device complexity and reduces utility value (ʼ251 Patent, col. 1:43-52).
• The Patented Solution: The invention proposes a system architecture where individual controllers, one for each power source, receive a single, uniform control signal from a central charging unit. This signal represents a "desired output voltage." Each controller then independently converts its source's variable power to match this desired voltage. This normalization allows the power from all disparate sources to be aggregated and supplied to the charging unit for efficient, unified charging (ʼ251 Patent, Abstract; col. 2:1-12; Fig. 1).
• Technical Importance: This design aims to simplify system management by centralizing control, allowing a single charging function to manage multiple, diverse power inputs simultaneously (ʼ251 Patent, col. 1:53-61).

Key Claims at a Glance

• The complaint asserts independent claim 1 of the ’251 Patent (Compl. ¶11).
• The essential elements of independent claim 1 are:
  • A power charging device using multiple energy sources...comprising a plurality of power sources, each having a different generating capacity and each output value thereof varying independently...
  • "output changing means" which is provided for each of the power sources and which changes the variable output value to a desired output value; and
  • "charging means" which outputs the desired output value to the output changing means and which supplies the power from the plurality of connected power sources.
• The complaint notes that Plaintiff may assert other claims, including dependent claims (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint identifies "at least Sensata's MSH-M Series Inverter/Charger" as an exemplary accused product (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused product's specific functionality. It identifies the product as an "Inverter/Charger" but offers no description of how it operates in a multi-source power system or how its features correspond to the patented technology (Compl. ¶11). The complaint makes no specific allegations regarding the product's commercial importance or market position.

IV. Analysis of Infringement Allegations

The complaint states that "Exhibit 2 includes charts comparing the Exemplary '251 Patent Claims to the Exemplary Sensata Products" (Compl. ¶17). However, this exhibit was not filed with the complaint. The infringement theory is therefore limited to the general allegations in the body of the complaint, which assert that the accused products "practice the technology claimed by the '251 Patent" and "satisfy all elements of the Exemplary '251 Patent Claims" (Compl. ¶17).

No probative visual evidence provided in complaint.

Identified Points of Contention

• The lack of specific factual allegations in the complaint raises foundational questions for the infringement analysis.
  • Scope Questions: The complaint does not specify whether the accused "Inverter/Charger" is alleged to embody the entire claimed device or only a single component (e.g., the "charging means" or the "output changing means") within a larger infringing system. A primary question will be how the single accused product is alleged to meet the claim limitations that require a plurality of components, one for "each of the power sources" (ʼ251 Patent, col. 8:8-9).
  • Technical Questions: A key technical question is what evidence demonstrates that the accused product performs the dual functions of the "charging means": both (1) outputting a "desired output value" to external controllers and (2) supplying power from those sources, as required by claim 1. The complaint provides no facts to support this allegation.

V. Key Claim Terms for Construction

• The Term: "output changing means"

• Context and Importance: This term, recited in means-plus-function format, is central to the invention's architecture of normalizing power from diverse sources. Infringement will depend on whether the accused product contains a structure that performs the claimed function for each power source. Practitioners may focus on this term because its construction will determine whether it is limited to the specific embodiments in the specification or can cover a wider range of functionally equivalent hardware.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is functional, defining the means as that which "changes the variable output value to a desired output value" (ʼ251 Patent, col. 8:10-11). A plaintiff could argue this language covers any component that achieves this result.
  • Evidence for a Narrower Interpretation: The specification describes a specific structure for this means, namely a "DC/DC controller" that itself comprises a rectifier and an inverter (ʼ251 Patent, col. 2:13-18; col. 3:60-67). A defendant could argue the claim scope is limited to this disclosed structure and its equivalents.

• The Term: "charging means"

• Context and Importance: This term defines the control hub of the patented system. The infringement analysis will turn on whether a single accused component performs the two distinct functions recited for this means: (1) outputting the control signal ("desired output value") and (2) supplying the resulting power.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A plaintiff may argue that any integrated unit that generates a control voltage for external power controllers and manages the combined power flow meets the functional requirements of the claim.
  • Evidence for a Narrower Interpretation: The specification discloses a detailed structure for the "charging means", which includes a "maximum-current detector" and a "voltage feedback unit," where the detector itself uses a "phase-locked loop (PLL) circuit" (ʼ251 Patent, col. 4:24-31, col. 4:57-60). A defendant may argue the term should be construed as limited to a device containing these specific sub-components or their structural equivalents.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users to operate them in an infringing manner (Compl. ¶14, ¶15). The complaint also makes a parallel allegation of contributory infringement (Compl. ¶16).

Willful Infringement

• The willfulness allegation appears to be based on post-suit conduct. The complaint asserts that its service provides Defendant with "actual knowledge" of infringement and that any continued infringing activity thereafter is willful (Compl. ¶13, ¶14). No facts suggesting pre-suit knowledge are alleged.

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

1. A central issue will be one of pleading and evidentiary sufficiency: Given the complaint's lack of factual detail and the absence of its referenced claim chart exhibit, a primary question is whether the allegations provide sufficient notice of how the accused MSH-M Series Inverter/Charger is purported to meet the limitations of the asserted claims, particularly the requirements for a multi-source architecture.

2. The case will likely turn on a question of claim construction: The viability of the infringement claim will depend on the scope assigned to the means-plus-function terms "output changing means" and "charging means". The core legal dispute will be whether these terms are interpreted broadly according to their stated functions or are limited to the specific DC/DC controller and PLL-based circuit structures disclosed in the patent's preferred embodiments.