Celebration IP LLC v. Semiconductor Components Industries LLC

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Celebration IP LLC (Texas)
  • Defendant: Semiconductor Components Industries, LLC (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA
• Case Identification: 1:20-cv-00878, D. Del., 06/29/2020
• Venue Allegations: Venue is alleged to be proper because Defendant has committed acts of patent infringement and has an established place of business in the District of Delaware.
• Core Dispute: Plaintiff alleges that Defendant’s semiconductor products infringe a patent related to circuits that prevent the over-discharge of batteries.
• Technical Context: The technology concerns battery protection circuits, a critical component in portable electronic devices that rely on rechargeable batteries like lithium-ion cells.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

Date	Event
2000-02-29	U.S. Patent No. 6,346,795 Priority Date
2002-02-12	U.S. Patent No. 6,346,795 Issued
2020-06-29	Complaint Filed

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

• Patent Identification: U.S. Patent No. 6,346,795, "Discharge control circuit of batteries", issued February 12, 2002.

The Invention Explained

• Problem Addressed: The patent describes a problem in conventional battery protection circuits where, after a discharge is cut off due to low voltage, the battery's cell voltage can instantaneously recover. This recovery can cause the protection circuit to immediately re-enable discharge, leading to repeated on-off cycling that can cause malfunctions in the electronic device and fail to "securely prevent the over-discharge of the battery" (’795 Patent, col. 3:49-65, col. 4:1-4).
• The Patented Solution: The invention proposes a discharge control circuit that includes a "switch holding circuit." After a low-voltage condition triggers a "discharge stop signal" to cut off the battery, this holding circuit ensures the stop signal is continuously supplied for a "predetermined time," regardless of any immediate recovery in the cell's voltage (’795 Patent, Abstract; col. 4:15-20). This prevents the circuit from immediately re-enabling discharge, thus providing a more stable and secure cutoff. Figure 4 illustrates this concept with a block diagram showing a control circuit (30) containing a switch holding circuit (M) that controls the discharge switch (4) (’795 Patent, Fig. 4).
• Technical Importance: The described solution provides a more robust method for protecting rechargeable batteries, particularly lithium-ion types, which are sensitive to over-discharging and were becoming ubiquitous in portable electronics at the time of the invention.

Key Claims at a Glance

• The complaint asserts one or more claims of the ’795 Patent without specifying them (Compl. ¶11). Independent claim 1 is representative of the core invention.
• Independent Claim 1:
  • A discharge control circuit for controlling discharge of a battery including at least one cell comprising:
  • a discharge control switch connected to the battery for cutting off a discharge current of the battery in response to a discharge stop signal; and
  • a control circuit connected to the battery and the discharge control switch for generating the discharge stop signal that deactivates the discharge control switch when a voltage of at least one cell reaches a lower limit,
  • wherein the control circuit includes a switch holding circuit for continuously supplying the discharge stop signal to the discharge control switch for a predetermined time after the discharge stop signal is generated.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly detailed in claim charts referenced as Exhibit 2 (Compl. ¶¶11, 17). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context beyond the general allegation that they "practice the technology claimed by the '795 Patent" (Compl. ¶17). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts attached as Exhibit 2, but this exhibit is not included in the provided filing (Compl. ¶18). The infringement theory must be inferred from the general allegations. The complaint asserts that the "Exemplary Defendant Products" satisfy all elements of the "Exemplary '795 Patent Claims" (Compl. ¶17). Due to the absence of the claim charts, a tabular analysis cannot be performed.

Identified Points of Contention

• Technical Questions: A central question will be whether the accused products, once identified, contain circuitry that performs the function of the claimed "switch holding circuit." The analysis will depend on whether the accused circuits, after cutting off discharge, maintain that cutoff for a "predetermined time" even if the cell voltage recovers, or if they operate on a different principle.
• Scope Questions: The dispute may turn on the scope of the term "switch holding circuit." Plaintiff may argue that this term covers a range of circuit implementations that achieve the holding function, while Defendant may argue for a narrower construction limited to the specific embodiments disclosed in the patent, such as the hysteresis buffer (Fig. 5) or latch circuit configurations (Fig. 7).

V. Key Claim Terms for Construction

The Term: "switch holding circuit"

• Context and Importance: This term appears in the independent claim's "wherein" clause and describes the core inventive concept. Its construction will be dispositive for infringement, as it distinguishes the invention from prior art that might simply react to instantaneous voltage levels. Practitioners may focus on this term because it is functional in nature and its scope will determine whether a variety of modern battery protection architectures fall within the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is functional, defining the circuit by what it does: "continuously supplying the discharge stop signal...for a predetermined time" (’795 Patent, col. 10:38-41). This could support an interpretation that covers any circuit structure that achieves this result.
  • Evidence for a Narrower Interpretation: A defendant may argue the term is limited to the structures disclosed in the specification for performing this function. The specification describes specific embodiments, including a "hysteresis buffer" (col. 5:42-49, Fig. 5, element 16) and "latch circuits" (col. 7:58-61, Fig. 7, elements 18, 19), which could be used to argue for a narrower scope under 35 U.S.C. § 112.

The Term: "predetermined time"

• Context and Importance: This term quantifies the duration of the holding action. The infringement analysis will require evidence that an accused device holds the cutoff state for a specific, designed duration, rather than for a variable time dependent on other factors.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not assign a specific numerical value to this time, suggesting it can be designed by a person of skill in the art. The time is functionally defined as being long enough to prevent undesirable cycling (’795 Patent, col. 7:50-57).
  • Evidence for a Narrower Interpretation: The specification explains how this time is set by the interaction of specific circuit components, such as "the voltage difference between the thresholds Vth1, Vth2, the currents of the current sources 11, 12, and the capacitance of the capacitor 5" (’795 Patent, col. 7:50-55). This suggests the "predetermined time" is not arbitrary but is a direct result of specific structural component values.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products to customers for use in end-user products and distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes" (’795 Patent, Compl. ¶¶14-15). The complaint also alleges contributory infringement, asserting the accused products "are not a staple article of commerce suitable for substantial noninfringing use" (Compl. ¶16).
• Willful Infringement: The complaint does not use the word "willful" but lays a foundation for post-suit willfulness by stating, "The service of this Complaint upon Defendant constitutes actual knowledge of infringement as alleged here" (Compl. ¶13).

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

• A core issue will be one of technical implementation: Once the accused products are identified, the central question will be whether their battery protection mechanisms include a distinct "switch holding circuit" that forces a discharge cutoff for a "predetermined time," or if they use an alternative method to prevent undesirable discharge cycling that is technically distinct from the claimed invention.
• A key evidentiary question will be one of inducement: Plaintiff will need to produce evidence, such as the alleged "product literature and website materials," demonstrating that Defendant specifically instructed or encouraged its customers to incorporate the accused products in a way that directly infringes the method claimed in the ’795 Patent.
• Finally, the case may present a significant claim construction dispute over whether the functional term "switch holding circuit" should be interpreted broadly to cover any means of achieving the holding function, or narrowly limited to the specific hysteresis buffer and latch circuit embodiments detailed in the patent specification.