Boracho IP Holdings LLC v. Schneider Electric USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Boracho IP Holdings LLC (Texas)
  • Defendant: Schneider Electric USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamatios Stamoulis; Rabicoff Law LLC
• Case Identification: 1:19-cv-01823, D. Del., 09/27/2019
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the district, and has allegedly committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s "Conext XW+ Multi-Unit Power System" infringes a patent related to power charging devices that manage and combine multiple, independent energy sources.
• Technical Context: The technology addresses the challenge of creating a unified charging system from multiple, disparate power sources, such as wind and solar, whose electrical output can vary significantly and unpredictably.
• Key Procedural History: The complaint does not mention any prior litigation or administrative proceedings involving the patent-in-suit. A Certificate of Correction was issued for the patent on October 28, 2003, which may be relevant to claim scope as it corrected language in the issued claims.

Case Timeline

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

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 difficulty of efficiently charging a device from a plurality of different power sources (e.g., wind, solar) where each source has a different, independently varying generating capacity and output. This situation typically requires separate, complex charging functions for each source, resulting in low utility and complicated system management (’251 Patent, col. 1:42-52).
• The Patented Solution: The invention proposes a system where each individual power source is connected to its own "output changing means" (e.g., a DC/DC controller). This component takes the variable output from its source and converts it to a uniform, desired voltage. A central "charging means" determines this desired voltage and provides it as a reference signal back to each of the output changing means. This allows the system to receive uniform voltages from all sources, which can then be efficiently combined to charge a battery or power a load (’251 Patent, Abstract; col. 2:1-12). The charging means monitors the battery's charge state and adjusts the desired voltage accordingly to prevent overcurrent and ensure steady charging (’251 Patent, col. 4:45-56).
• Technical Importance: This architecture provides a method for aggregating power from intermittent, non-correlated sources, a key challenge in developing effective renewable and hybrid energy systems (’251 Patent, col. 1:5-12).

Key Claims at a Glance

• The complaint asserts infringement of at least independent claim 1 (’251 Patent, Compl. ¶11).
• The essential elements of independent claim 1 are:
  • A power charging device using multiple energy sources...each having a different generating capacity and each output value thereof varying independently, the device comprising:
  • 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 does not explicitly reserve the right to assert other claims, but refers to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

Schneider's Conext XW+ Multi-Unit Power System (referred to as the "Exemplary Schneider Products") (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality. It identifies the product by name and states that it infringes, incorporating by reference "claim charts of Exhibit 2" that were not filed with the public complaint (Compl. ¶¶17-18). Without these charts or other technical descriptions in the complaint, the specific features and operations of the Conext XW+ system that are alleged to infringe cannot be determined from the filing.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an Exhibit 2, which was not provided with the filed document (Compl. ¶17). Therefore, a claim chart summary cannot be constructed. The complaint’s narrative theory is that the "Exemplary Schneider Products practice the technology claimed by the '251 Patent" and "satisfy all elements of the Exemplary '251 Patent Claims" (Compl. ¶17). However, the complaint does not contain specific factual allegations mapping any feature of the accused products to any specific claim element.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: A central dispute may concern whether the accused Conext XW+ system embodies the specific architecture of the claims. For example, a question for the court could be whether the system's power conversion units qualify as the claimed "output changing means" that are individually controlled by a feedback signal from a central "charging means."
• Technical Questions: Given the lack of detail, a primary technical question is whether the accused system actually functions as claimed. What evidence will be presented to demonstrate that the Schneider product uses a central "charging means" to output a "desired output value" that in turn controls multiple, separate power converters to normalize their outputs before aggregation, as the patent specification describes? (’251 Patent, col. 4:25-31, col. 5:32-38).

V. Key Claim Terms for Construction

• 1. The Term: "output changing means" (from Claim 1)

  • Context and Importance: This term is the core functional unit for normalizing power from each individual source. The finding of infringement will hinge on whether the components in the accused Schneider system meet the definition of this term. As it uses "means," it is a candidate for construction under 35 U.S.C. § 112(f) (means-plus-function).
  • Intrinsic Evidence for a Broader Interpretation: The claim itself provides a purely functional definition: a means "which changes the variable output value to a desired output value" (’251 Patent, col. 8:10-12). This could support an interpretation covering any structure that performs this function.
  • Intrinsic Evidence for a Narrower Interpretation: The specification discloses a specific structure for this means: a DC/DC controller that itself comprises a rectifier and an inverter (’251 Patent, col. 2:13-17; col. 3:60-64; Fig. 3). A court construing this as a means-plus-function term would limit its scope to the disclosed DC/DC controller structure and its equivalents.

• 2. The Term: "charging means" (from Claim 1)

  • Context and Importance: This term defines the control unit of the patented system. The relationship between the "charging means" and the "output changing means" is fundamental to the invention. This term is also a candidate for means-plus-function treatment.
  • Intrinsic Evidence for a Broader Interpretation: The claim defines its functions as "outputs the desired output value to the output changing means" and "supplies the power from the plurality of connected power sources" (’251 Patent, col. 8:13-16). This functional language could support a broad reading.
  • Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific structure for the "charging means," which includes a "maximum-current detector" and a "voltage feedback unit," where the detector itself contains a phase-locked loop (PLL) circuit (’251 Patent, col. 4:25-31; col. 4:57-65; Fig. 5). An interpretation under § 112(f) would likely limit the term to this disclosed PLL-based control circuit and its equivalents.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement based on Defendant selling the accused products and distributing "product literature and website materials" that instruct customers on an infringing use (Compl. ¶¶14-15). It also makes a conclusory allegation of contributory infringement (Compl. ¶16).
• Willful Infringement: The complaint alleges that the filing of the lawsuit provides Defendant with "actual knowledge" of infringement and that any continued infringement is therefore willful (Compl. ¶¶13-14). No specific facts supporting pre-suit knowledge are alleged.

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

• A core issue will be one of claim construction, specifically whether the terms "output changing means" and "charging means" are governed by means-plus-function principles. The resolution of this issue will define the scope of the claims, determining whether they are limited to the specific PLL-based circuit architecture disclosed in the patent or can cover a broader range of power-management systems.
• A second key question will be evidentiary. Given the complaint's lack of technical detail, the case will depend on what discovery reveals about the actual operation of the accused Conext XW+ system. The plaintiff will bear the burden of proving a direct correspondence between the system’s architecture and the specific, interactive functions required by the asserted claims.