Minotaur Systems LLC v. Chargepoint Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Minotaur Systems LLC (Delaware)
  • Defendant: Chargepoint, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01239, D. Del., 01/27/2026
• Venue Allegations: Plaintiff alleges venue is proper because Defendant is incorporated in Delaware, has an established place of business in the district, and has committed acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems and methods for monitoring electric vehicle energy consumption by determining the amount of energy supplied to a vehicle's battery and associating that data with the specific geographic location of the charging event.
• Technical Context: The technology addresses the need for verifiable energy consumption data for electric vehicles, which is significant for administering governmental incentive programs and ensuring accurate, differentiated billing in the growing electric vehicle market.
• Key Procedural History: This filing is a First Amended Complaint. The complaint alleges that Defendant gained actual knowledge of the patent and its alleged infringement upon service of the original complaint on October 8, 2025, a fact that may form the basis for a willfulness claim regarding any post-notice conduct.

Case Timeline

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

U.S. Patent No. 8,417,402 - "MONITORING OF POWER CHARGING IN VEHICLE"

• Patent Identification: U.S. Patent No. 8,417,402, "MONITORING OF POWER CHARGING IN VEHICLE," issued April 9, 2013 (’402 Patent).

The Invention Explained

• Problem Addressed: The patent’s background section describes the difficulty in differentiating between electricity used for charging an electric vehicle and electricity used for other purposes, particularly for vehicles charged at home. This ambiguity created obstacles for incentive programs designed to credit users for vehicle-specific energy consumption, as there was no reliable way to verify where and for what purpose the energy was used Compl. ¶11 ’402 Patent, col. 1:15-31
• The Patented Solution: The invention proposes an in-vehicle "energy meter unit" that solves this problem by integrating energy measurement with location determination ’402 Patent, Abstract This unit measures the amount of energy supplied to the vehicle's battery during a charging session and simultaneously uses a GPS module to determine the vehicle’s location. By associating the energy data with the location data, the system creates a verifiable record of the charging event that can be transmitted to a central server for processing (Compl. ¶13; ’402 Patent, col. 2:1-17, Fig. 2).
• Technical Importance: This approach provided a technical mechanism to create auditable records of electric vehicle charging, enabling energy suppliers and government agencies to reliably verify claims for incentive programs and facilitate accurate billing Compl. ¶16

Key Claims at a Glance

• The complaint asserts at least independent method claim 7 and dependent claim 10 (’402 Patent, col. 4:8-27; Compl. ¶14, ¶17).
• The essential elements of independent claim 7 are:
  • determining a current location of the vehicle;
  • determining an amount of energy supplied to a battery on the vehicle at the current location;
  • associating the amount of energy supplied with the current location.
• The complaint states that Defendant infringes "at least the exemplary claims," suggesting it reserves the right to assert other claims Compl. ¶22

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" identified in charts incorporated by reference as "Exhibit 2" (Compl. ¶22, ¶27). As this exhibit was not provided with the complaint, the specific names and models of the accused instrumentalities are not identified in the pleading itself.

Functionality and Market Context

The complaint alleges that the accused products "practice the technology claimed by the '402 Patent" Compl. ¶27 This suggests the products are related to Chargepoint's network of electric vehicle charging stations and associated software or services that monitor and record charging session data, including location and energy delivered. The complaint does not provide sufficient detail for a more granular analysis of the accused functionality.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts in an "Exhibit 2" that detail its infringement allegations Compl. ¶27 The narrative theory alleges that Defendant’s products and services perform the method of tracking electric vehicle charging claimed in the ’402 Patent. This infringement is alleged to occur when the accused systems determine the location of a charging event, measure the energy delivered to a vehicle, and associate those two pieces of data (Compl. ¶17, ¶27). The complaint asserts infringement occurs through Defendant's own making, using, and selling of the products, as well as through internal testing by its employees (Compl. ¶22, ¶23).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the complaint and patent, the infringement analysis raises several questions:
  • Scope Questions: A primary question may be whether the claimed method requires the "determining" and "associating" steps to be performed by a single, integrated unit located within the vehicle, as depicted in the patent's preferred embodiment ’402 Patent, Fig. 1-2, or if the claims can read on a distributed system where a stationary charging station performs these functions.
  • Technical Questions: What evidence does the complaint provide that the accused Chargepoint system performs an affirmative "associating" step that links energy and location data, as required by the claim, beyond simply time-stamping two separate data points in a log?

V. Key Claim Terms for Construction

• The Term: "determining a current location of the vehicle" (from claim 7)

• Context and Importance: The definition of this term is critical because it dictates where the location-finding action must occur. Practitioners may focus on this term because the patent's specification heavily describes an on-board GPS unit, while the accused instrumentality may involve a stationary charging station determining its own fixed location and associating it with a temporarily connected vehicle.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the component or subsystem that must perform the "determining" act, leaving open the possibility that the location could be determined by an external system (e.g., the charger) and imputed to the vehicle.
  • Evidence for a Narrower Interpretation: The specification's only detailed embodiment describes an "energy meter unit 14" inside the vehicle containing a "GPS unit 38 which is capable of communicating with GPS satellites 26, thereby determining the location of the vehicle 12" (’402 Patent, col. 2:1-4, Fig. 2). This may support an argument that the invention is limited to a system where the vehicle itself ascertains its own location.

• The Term: "associating" (from claim 7)

• Context and Importance: This term defines the inventive nexus between the energy measurement and the location data. The dispute may center on whether "associating" requires a specific, active processing step or if it can be satisfied by the routine logging of data points in a single record.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is general and could be interpreted to mean creating any link between the two data points, such as storing them in corresponding fields of a database entry for a given charging session.
  • Evidence for a Narrower Interpretation: Claim 1, an apparatus claim, recites a "processor receiving the current location and measure of energy ... and associating" the two ’402 Patent, col. 3:51-55 This language suggests an active computational step. Furthermore, the specification explains this association is used to "validate a claim" from an energy source, implying a more robust and purposeful linkage than passive data storage ’402 Patent, col. 3:12-15

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products and provides "product literature and website materials" that instruct customers and end users to operate them in a manner that directly infringes the ’402 Patent Compl. ¶25-¶26
• Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after gaining "actual knowledge" of the ’402 Patent. The complaint specifically pleads that this knowledge was established upon service of the original complaint on October 8, 2025 Compl. ¶24 Plaintiff also requests that the case be declared exceptional under 35 U.S.C. § 285 Compl. Prayer ¶E.i

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

• A core issue will be one of architectural scope: can the method claims of the ’402 Patent, which are described in the specification via an in-vehicle device, be construed to cover a distributed network architecture where a stationary charging station and a central server perform the key steps of determining location and associating data?
• A key evidentiary question will be one of technical operation: does the accused Chargepoint system perform an affirmative, programmatic "associating" step as required by the claims, or does it merely collect and store location and energy data in a common record, raising the question of whether this constitutes a legal "association"?