DCT

1:25-cv-00066

CogniPower LLC v. Fantasia Trading LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-00066, D. Del., 01/16/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant AnkerDirect is a Delaware corporation, and Defendant Anker Innovations is a foreign company that conducts business in the district, at least through AnkerDirect.
  • Core Dispute: Plaintiff alleges that certain of Defendant's Anker-branded power adapters and chargers, which incorporate specific controller chips, infringe two reissue patents related to switched-mode power converters that use a demand-pulse-based feedback system for regulation across a galvanic isolation barrier.
  • Technical Context: The technology concerns the design of switched-mode power supplies, which are fundamental components for efficiently converting AC power to DC power in a vast range of modern electronics.
  • Key Procedural History: The complaint notes a prior, pending lawsuit ("Anker Case I") filed in 2019, where CogniPower asserts the same patents against different Anker products. Public records associated with the patents-in-suit indicate that the asserted claims in both patents (Claim 1 of the ’031 Patent and Claim 18 of the ’713 Patent) were challenged in inter partes review (IPR) proceedings and were subsequently found patentable by the Patent Trial and Appeal Board in June 2024. The complaint also alleges that Defendants were put on notice of infringement for the currently accused products via draft infringement contentions served in September 2024.

Case Timeline

Date Event
2012-07-03 Priority Date for ’031 and ’713 Patents
2018-09-04 ’031 Patent Issue Date
2019-11-05 ’713 Patent Issue Date
2019-12-18 "Anker Case I" Complaint Filed
2020-10-16 IPR Proceedings Initiated for ’031 and ’713 Patents
2024-06-12 IPR Certificate Issued for ’031 Patent (Claim 1 Found Patentable)
2024-06-13 IPR Certificate Issued for ’713 Patent (Claim 18 Found Patentable)
2024-09-04 Plaintiff Served Draft Infringement Contentions on Defendant
2025-01-16 Complaint Filing Date

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

U.S. Reissue Patent No. RE47,031 - Power converter with demand pulse isolation

Issued Sep. 4, 2018

The Invention Explained

  • Problem Addressed: The patent describes the technical challenge of reliably communicating feedback information from the secondary (low-voltage output) side of a power converter to the primary (high-voltage input) side across a galvanic isolation barrier, noting the difficulty of processing traditional analog feedback signals (’031 Patent, col. 1:57-col. 2:3).
  • The Patented Solution: The invention proposes a system where the secondary side, upon detecting a need for more power (e.g., a drop in output voltage), generates a digital "demand pulse." This pulse is transmitted across the isolation barrier to trigger the primary-side commutating switch, initiating an energy-bearing cycle. This replaces complex analog signal processing with a more direct, digital trigger mechanism (’031 Patent, Abstract; col. 4:1-9). A key feature is that the secondary-side demand pulse generator is powered by energy captured from forward pulses of the converter's transformer, allowing it to function even during output short-circuits (’031 Patent, col. 5:35-42).
  • Technical Importance: This design approach simplifies the circuitry required for feedback in isolated switched-mode power converters, which are ubiquitous in devices like plug-in power adapters, potentially enhancing robustness and lowering manufacturing costs (’031 Patent, col. 1:36-40).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 1 (Compl. ¶26).
  • Essential elements of independent claim 1 include:
    • An apparatus for switched-mode power conversion with an input port, a switch, and galvanic isolation circuitry comprising a transformer.
    • A "demand pulse generator" connected to the secondary winding, configured to generate demand pulses to adjust the switch's commutation frequency.
    • A capacitor and a second rectifier connected to the secondary winding.
    • The second rectifier is distinct from a first rectifier and is poled to charge the capacitor during "forward pulses" of the apparatus.
    • The demand pulse generator is powered by the energy stored in this capacitor.

U.S. Reissue Patent No. RE47,713 - Power converter with demand pulse isolation

Issued Nov. 5, 2019

The Invention Explained

  • Problem Addressed: The patent addresses the same problem as the ’031 Patent: creating a reliable feedback mechanism across a galvanic isolation barrier in a switched-mode power converter (’713 Patent, col. 2:4-11).
  • The Patented Solution: The invention is claimed as an "article of manufacture" embodying a flyback converter with a specific division of control logic. The secondary side includes a "demand pulse generator" that determines when to turn on the primary-side switch and sends a corresponding demand pulse. Crucially, the "determination of when to turn off the primary-side switch is originated on the primary side and not on the secondary side" (’713 Patent, cl. 18). This partitions the control loop, with the secondary side requesting power and the primary side independently controlling the duration of the power delivery cycle.
  • Technical Importance: This architectural division of control responsibility provides a clear and robust method for regulating power output in a flyback converter while maintaining strict isolation, as the complex and variable timing of the 'off' cycle is managed entirely on the primary side (’713 Patent, cl. 18).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 18 (Compl. ¶29).
  • Essential elements of independent claim 18 include:
    • A flyback converter with galvanically isolated primary and secondary sides.
    • A primary-side switch.
    • A secondary-side "demand pulse generator" that determines when to turn on the primary switch and generates corresponding demand pulses.
    • Coupled conductors to convey the demand pulses from the secondary to the primary side.
    • A control scheme where the primary-side switch is turned on in response to the demand pulse, but the determination of when to turn the switch off "is originated on the primary side."
    • A secondary-side capacitor and rectifier poled to charge the capacitor during forward power converter pulses, with the demand pulses being generated using energy from this capacitor.

III. The Accused Instrumentality

Product Identification

The Accused Instrumentalities are Anker power adapters and chargers that "comprise or otherwise implement power conversion, management and regulation using demand pulse regulation technology" (Compl. ¶21). The complaint alleges these products are configured with controller chips from the "Power Integrations InnoSwitch family of chips, including InnoSwitch, InnoSwitch3, InnoSwitch4, and subsequent generations" (Compl. ¶23).

Functionality and Market Context

The relevant functionality is that of a switched-mode power converter used for charging electronic devices (Compl. ¶21). The complaint alleges that the internal functionality of the accused products and their controller chips is not publicly available or determinable from simple inspection, and that its infringement allegations rely on "publicly reported identification of the features and components" (Compl. ¶24).

IV. Analysis of Infringement Allegations

The complaint references appendices with exemplary claim charts that were not provided with the filed document; therefore, this analysis summarizes the narrative infringement theory.

  • RE47,031 Patent: The complaint alleges that the Accused Instrumentalities, by incorporating the InnoSwitch family of chips, directly infringe at least claim 1 (Compl. ¶26, ¶35). The core theory is that these products are switched-mode power converters that utilize a demand pulse regulation technology functionally equivalent to that recited in the claims (Compl. ¶21, ¶23). The complaint asserts that all accused products are "materially the same with respect to infringement of this patent" (Compl. ¶26).

  • RE47,713 Patent: The complaint alleges that the Accused Instrumentalities are flyback converters that directly infringe at least claim 18 (Compl. ¶29, ¶35). The infringement theory posits that the InnoSwitch chips implement the specific control architecture of claim 18, wherein the secondary side signals a "turn on" command and the primary side independently determines when to "turn off" the main switch (Compl. ¶23, ¶29). The complaint asserts that all accused products are "materially the same with respect to infringement of this patent" (Compl. ¶29).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Questions: The complaint relies on "information and belief" and "publicly reported" data for the internal functionality of the accused InnoSwitch chips (Compl. ¶22, ¶24). A primary point of contention will be whether discovery confirms that the chips operate in a manner that maps to the specific limitations of the asserted claims.
    • Scope Questions (’031 Patent): The analysis may turn on whether the accused devices practice the specific power-delivery mechanism of claim 1, which requires the "demand pulse generator" to be powered by a capacitor charged during "forward pulses" of the apparatus. The precise electrical behavior during startup and load conditions will be critical.
    • Technical Questions (’713 Patent): A central dispute for the ’713 Patent will likely involve the "locus of control" limitation in claim 18. The question will be whether the primary-side circuitry in the InnoSwitch chips originates the turn-off determination (e.g., based on primary-side current sensing or a timer independent of the secondary side), or if it merely executes a turn-off sequence that is functionally dependent on the timing or nature of the demand pulse received from the secondary side.

V. Key Claim Terms for Construction

  • The Term: "demand pulse generator" (’031 Patent, cl. 1; ’713 Patent, cl. 18)

    • Context and Importance: This term is central to the claimed invention. Its construction will determine whether the signaling architecture within the accused InnoSwitch chips falls within the scope of the patents. Practitioners may focus on this term because its scope dictates whether a specific hardware block or a more functional description of signaling logic meets the limitation.
    • Intrinsic Evidence for a Broader Interpretation: The specification describes the generator functionally as indicating "the need for another energy-bearing cycle" (’031 Patent, col. 4:62-64). The claims do not recite a specific circuit, which may support a construction covering any component that generates a signal to trigger a power cycle in response to output demand.
    • Intrinsic Evidence for a Narrower Interpretation: The detailed description discloses specific embodiments, such as a "triggering blocking oscillator" or logic gates combined with a fast oscillator, that perform this function (’031 Patent, col. 5:22-26, col. 6:13-16, Fig. 4). A party may argue the term should be construed as limited to these or structurally equivalent circuits.

  • The Term: "the determination of when to turn off the primary-side switch is originated on the primary side and not on the secondary side" (’713 Patent, cl. 18)

    • Context and Importance: This limitation defines the unique control architecture claimed in the ’713 Patent and is a likely focal point of the infringement dispute. The case may hinge on whether the accused products' "turn off" mechanism is truly independent of secondary-side control.
    • Intrinsic Evidence for a Broader Interpretation: The claim language is functional. Any primary-side-based mechanism, such as one sensing primary-side current or using a primary-side timer, could be argued to "originate" the determination, regardless of the specific implementation.
    • Intrinsic Evidence for a Narrower Interpretation: The specification describes an embodiment where the turn-off determination is made by a primary-side comparator (217d) that senses current through a primary-side resistor (209d) to reset a flip-flop (220d) (’713 Patent, col. 7:15-22). A defendant could argue that "originated on the primary side" requires the determination to be based on sensing a condition on the primary side, rather than a pre-set timing operation that is merely located there.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product manuals and other technical information" that encourage and instruct customers and other third parties on the infringing use of the Accused Instrumentalities (Compl. ¶38, ¶41).
  • Willful Infringement: Willfulness is alleged based on pre-suit knowledge of the patents. The complaint cites the filing of "Anker Case I" in December 2019 as providing actual notice, and further alleges that draft infringement contentions for the current products were served in September 2024, after which Defendant allegedly continued its infringing conduct (Compl. ¶31, ¶32, ¶44).

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

  • A central issue will be one of evidentiary proof: The complaint is premised on "information and belief" regarding the internal workings of third-party controller chips. A key question is whether discovery will confirm that the accused InnoSwitch chips operate in a manner that reads on the specific, nuanced limitations of the asserted claims, or if there is a functional or structural mismatch.
  • A key legal and technical question for the ’713 Patent will be one of locus of control: Can the "turn off" determination in the accused products be considered "originated on the primary side" if its timing is inherently linked to or derived from the "turn on" demand pulse from the secondary side? The construction and application of this claim language will be critical.
  • A key procedural question will be the impact of related proceedings: How will the existence of a prior, pending case on the same patents and the successful IPR outcomes for the asserted claims affect this litigation? The confirmed patentability of the claims may narrow the case to focus intensely on infringement and damages, potentially increasing pressure for an early resolution.