Celebration IP LLC v. Universal Power Group Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Celebration IP LLC (Texas)
  • Defendant: Universal Power Group, Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA
• Case Identification: 1:22-cv-00694, D. Del., 05/27/2022
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant is incorporated in Delaware and has allegedly committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to discharge control circuits for batteries.
• Technical Context: The technology at issue involves protective circuitry designed to prevent the over-discharge of batteries, particularly those used in portable electronic devices, thereby extending battery life and ensuring safe operation.
• Key Procedural History: The complaint does not reference any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 6,346,795 - "Discharge control circuit of batteries"

The Invention Explained

• Problem Addressed: The patent addresses a problem in conventional battery protection circuits where, after a discharge current is cut off due to low voltage, the battery's cell voltage can "instantaneously rise" back above the low-voltage threshold. This rebound can trick the circuit into re-enabling the discharge, leading to repeated on-off cycles that fail to "securely prevent the over-discharge of the battery" (’795 Patent, col. 3:49-65).
• The Patented Solution: The invention proposes a control circuit that includes a "switch holding circuit" designed to solve this problem. When a low cell voltage triggers a "discharge stop signal," this holding circuit continues to supply the stop signal to the main discharge switch for a "predetermined time," regardless of whether the cell voltage recovers in the interim ('795 Patent, col. 4:16-20). This ensures the discharge remains cut off long enough to prevent the problematic cycling described in the background ('795 Patent, Fig. 5; col. 6:58-7:4).
• Technical Importance: This approach provides a more robust method for preventing battery over-discharge by making the protection circuit immune to transient voltage rebounds common in battery systems under load.

Key Claims at a Glance

• The complaint does not identify specific asserted claims, instead referring to "exemplary claims" identified in an unattached exhibit (Compl. ¶11). Independent claim 1 is representative of the patent's core teachings.
• 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 specific products by name, model number, or function. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an unattached exhibit (Compl. ¶¶11, 13).

Functionality and Market Context

The complaint does not provide any description of the accused products' functionality, features, or market context. It alleges in a conclusory manner that the "Exemplary Defendant Products practice the technology claimed by the '795 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint does not provide a narrative infringement theory or any specific factual allegations mapping claim elements to accused product features. It states that "Exhibit 2 includes charts comparing the Exemplary '795 Patent Claims to the Exemplary Defendant Products," but this exhibit was not provided with the complaint (Compl. ¶13). The allegations are limited to the conclusory statement that the accused products "satisfy all elements of the Exemplary '795 Patent Claims" (Compl. ¶13).

No probative visual evidence provided in complaint.

Due to the absence of factual allegations regarding infringement, it is not possible to identify specific points of technical or legal contention from the complaint.

V. Key Claim Terms for Construction

Based on an analysis of representative independent claim 1, the following terms may be central to the dispute.

• The Term: "switch holding circuit"

• Context and Importance: This term appears to name the novel component of the invention. Its construction will be critical to determining the scope of the claim, as the dispute will likely center on whether any component within the accused products meets this limitation both structurally and functionally.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself describes the circuit functionally as one "for continuously supplying the discharge stop signal...for a predetermined time" ('795 Patent, col. 10:38-42). A party might argue that any combination of components that achieves this function qualifies.
  • Evidence for a Narrower Interpretation: The specification describes specific embodiments, such as the one in Figure 5 including a hysteresis buffer (16) and a transistor (Tr3) combination, that perform this holding function ('795 Patent, col. 6:46-7:4). A party could argue the term should be limited to these or structurally similar implementations.

• The Term: "continuously supplying"

• Context and Importance: This adverb modifies the action of the "switch holding circuit." Practitioners may focus on this term because the degree of continuity required (e.g., whether momentary interruptions are permissible) could be a point of non-infringement.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent's objective is to prevent the discharge from restarting due to transient voltage rebound ('795 Patent, col. 3:49-54). A party could argue that "continuously" should be interpreted in light of this purpose, meaning any supply sufficient to prevent such a restart meets the limitation.
  • Evidence for a Narrower Interpretation: A party could argue for a plain meaning, suggesting the signal must be supplied without any interruption for the entire "predetermined time." The timing diagrams, such as Figure 6, show a flat, uninterrupted high-level signal for the duration Td, which may support a stricter interpretation ('795 Patent, Fig. 6).

VI. Other Allegations

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement. However, in the prayer for relief, it requests that the case be declared "exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees (Compl. ¶E.i). The complaint does not allege any facts regarding pre-suit knowledge of the patent or the alleged infringement.

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

Given the limited factual detail provided, the initial phase of this case may focus on pleading sufficiency. If the case proceeds to the merits, the central questions will likely be:

• A primary procedural question will be one of pleading sufficiency: Does the complaint, which identifies neither the accused products nor the asserted claims and offers only conclusory allegations of infringement, meet the plausibility standard required to survive a motion to dismiss?
• A core technical question will be one of structural and functional correspondence: Assuming specific products are identified, do they contain a "switch holding circuit" that operates as claimed by maintaining a discharge stop signal for a predetermined duration even after the initial low-voltage condition has resolved?
• A key issue of definitional scope will be whether the specific circuitry in an accused product performs the function of "continuously supplying" the stop signal in a manner consistent with the patent's teachings, or if its operation is technically distinct from the method disclosed.