Electronic Edison Transmission Tech LLC v. Monster Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Electronic Edison Transmission Technologies, LLC (Texas)
  • Defendant: Monster, Inc. (Delaware)
  • Plaintiff’s Counsel: Stamoulis & Weinblatt LLC
• Case Identification: 1:20-cv-00175, D. Del., 02/04/2020
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated in Delaware and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that certain of Defendant's products infringe a patent related to systems and methods for wirelessly transferring power between mobile electronic devices.
• Technical Context: The technology concerns device-to-device wireless power sharing, enabling a device with a higher battery level (e.g., a laptop) to recharge a device with a lower battery level (e.g., a mobile phone) without a physical power outlet.
• Key Procedural History: The complaint does not mention any prior litigation, IPR proceedings, or licensing history related to the patent-in-suit. The asserted patent claims priority to a 2011 provisional application.

Case Timeline

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

U.S. Patent No. 9,448,603 - "Transferring power to a mobile device," issued September 20, 2016

The Invention Explained

• Problem Addressed: The patent addresses the common scenario where a user's mobile device has a low battery, but no conventional power source (e.g., an electrical outlet) is available, while another of the user's mobile devices has a substantial remaining battery charge (’603 Patent, col. 1:23-31).
• The Patented Solution: The invention provides a system where a "donor" mobile device (e.g., a laptop) can wirelessly transfer power to a "receptor" mobile device (e.g., a mobile phone) (’603 Patent, col. 4:49-54). The process is managed by software applications on both devices, which can configure power transfer thresholds to control when the charging starts and stops (’603 Patent, col. 7:46-59). The patent describes that this wireless transfer can be accomplished through various technologies, including inductive coupling (using coils), capacitive coupling, or electromagnetic radiation like radio frequency waves (’603 Patent, col. 4:5-14).
• Technical Importance: The described technology provides a method for on-the-go power sharing between personal electronic devices, extending the operational life of a critical device by using the stored energy of another.

Key Claims at a Glance

• The complaint asserts "exemplary claims" without specifying particular claim numbers (Compl. ¶11). Independent claims 1, 6, and 8 are the three independent method claims of the patent.
• Independent Claim 1 recites a method with the essential elements of:
  • Configuring a donor wireless power transfer mechanism (WPTM) on a donor mobile device via a transmit application.
  • Configuring a receptor WPTM on a receptor mobile device via a receive application.
  • Transferring power between the devices using the WPTMs.
  • Receiving and converting the power into electric current at the receptor device.
  • The donor WPTM includes a primary coil, and the receptor WPTM includes a secondary coil and a capacitor, where a magnetic field from the primary coil generates current in the secondary coil, and the capacitor stores charge to increase the receptor's battery life upon discharge.
• The complaint does not explicitly reserve the right to assert dependent claims, but refers generally to infringement of "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Monster Products" (Compl. ¶11).

Functionality and Market Context

The complaint does not name specific products or describe their functionality. It states that the accused products are identified in charts included as "Exhibit 2" to the complaint; this exhibit was not publicly filed with the complaint (Compl. ¶17-18). Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality's specific features or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused "Exemplary Monster Products" practice the technology claimed by the ’603 Patent but incorporates claim charts by reference in an unprovided "Exhibit 2" (Compl. ¶17). As such, a detailed claim chart analysis based on the complaint is not possible.

The narrative allegations state that the Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products (Compl. ¶11). The complaint does not contain specific factual allegations mapping features of any particular Monster product to the elements of the asserted patent claims.

No probative visual evidence provided in complaint.

Identified Points of Contention

Given the reliance on an unprovided exhibit, any points of contention are speculative. However, based on the technology, future disputes may revolve around:

• Scope Questions: Whether the components in the accused products meet the specific structural requirements of the claims, such as the "primary coil" and "secondary coil" of claim 1, or the "primary conductor" and "secondary conductor" of claim 6.
• Technical Questions: A likely point of dispute will be whether any capacitor in an accused device functions to "store[] electric charge that increases battery life when the capacitor is discharged" as required by claim 1, or if it serves a different purpose within the device's standard power circuitry (’603 Patent, col. 12:56-59). The evidence showing that the accused products implement software for configuring the power transfer, as recited in the claims, will also be a key factual question.

V. Key Claim Terms for Construction

• The Term: "a capacitor storing electric charge that increases battery life when the capacitor is discharged" (from Claim 1).
• Context and Importance: This term recites a specific structure (capacitor) with a specific function (storing charge to increase battery life). The infringement analysis for claim 1 will depend on whether a component in the accused device meets both the structural and functional aspects of this limitation. Practitioners may focus on this term because modern electronics contain many capacitors, and the dispute will likely be whether any of them perform this specific claimed function, rather than a more general power-smoothing or filtering function.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification suggests the capacitor's role is part of the power reception and conversion process, stating that the receptor WPTM "converts the received power to electric current" and that this power transfer is capable of "potentially increasing the battery life of the receptor device" (’603 Patent, col. 9:1-5). This could support an interpretation where any capacitor involved in the wireless power receiving circuit meets the limitation.
  • Evidence for a Narrower Interpretation: The patent also describes a "charge storage device" as potentially being "one or more capacitors that can store charge for a significant amount of time" (’603 Patent, col. 5:12-14). This could support a narrower construction requiring a capacitor that functions as a distinct, temporary power reservoir, rather than just a standard component in a power management integrated circuit (PMIC). The claim's specific language linking the capacitor's discharge to an "increase" in battery life may be argued to require more than simple power passthrough.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" the ’603 Patent (Compl. ¶14). It further alleges contributory infringement, claiming the accused products are "not a staple article of commerce suitable for substantial noninfringing use" (Compl. ¶16).
• Willful Infringement: The complaint alleges that its service upon the Defendant "constitutes actual knowledge" and that Defendant's continued infringement is despite this knowledge (Compl. ¶13-14). While not using the word "willful," these allegations lay a foundation for post-filing willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 (Compl. Prayer ¶D.i).

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

• A central issue will be one of technical evidence: as the complaint lacks specific product details, the case will turn on what discovery reveals about the internal architecture and software functionality of the accused "Exemplary Monster Products" and whether they align with the patent's claims.
• A key legal question will be one of claim construction: the viability of the infringement case will likely depend on the court's interpretation of functional limitations, such as whether a standard capacitor within a power management circuit can be considered a "capacitor storing electric charge that increases battery life when the capacitor is discharged" as specifically required by claim 1.
• The viability of the indirect infringement claims will depend on the specificity of Defendant's user-facing instructions. The court will have to determine whether materials like user manuals actively instruct customers to perform the steps of the patented method, thereby showing the requisite intent for inducement.