DCT

6:23-cv-02194

NOCO Co v. Deltona Transformer Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:23-cv-02194, M.D. Fla., 11/13/2023
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants reside in the district, have committed acts of infringement in the district, and maintain a regular and established place of business there.
  • Core Dispute: Plaintiff alleges that Defendant’s Battery Tender® brand of portable vehicle jump starters infringes three patents related to safety features and USB-based charging technology.
  • Technical Context: The technology concerns portable, lithium-ion battery jump starters, which have become a popular consumer electronics category offering a more compact and safer alternative to traditional jumper cables.
  • Key Procedural History: The complaint does not allege any prior litigation, licensing history, or post-grant proceedings involving the parties and the patents-in-suit.

Case Timeline

Date Event
2014-07-03 Priority Date for ’023, ’243, and ’203 Patents
2022-09-20 U.S. Patent No. 11,447,023 Issues
2023-02-21 U.S. Patent No. 11,584,243 Issues
2023-06-06 U.S. Patent No. 11,667,203 Issues
2023-11-13 Complaint Filed

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

U.S. Patent No. 11,447,023 - "Portable Vehicle Battery Jump Start Apparatus with Safety Protection and Jumper Cable Device Thereof," Issued September 20, 2022

The Invention Explained

  • Problem Addressed: The patent’s background section describes the safety risks associated with traditional jumper cables, such as sparking and short circuits caused by incorrect polarity connections (e.g., connecting a positive clamp to a negative terminal) (’023 Patent, col. 1:16-24). The complaint adds that recharging prior-art jump starters often required non-standard or proprietary chargers (Compl. ¶17).
  • The Patented Solution: The invention is a handheld jump starter that incorporates safety logic and convenient charging. It uses sensors to detect both the presence of a vehicle battery and whether the clamps are connected with the correct polarity. A microcontroller processes these sensor inputs and only then actuates a power switch (a field-effect transistor, or FET) to deliver jump-starting current (’023 Patent, Abstract; col. 4:8-45, FIG. 1). To address the charging problem, the device includes a USB input circuit with a DC/DC converter, allowing the internal high-capacity lithium-ion battery to be recharged from a standard, low-voltage USB source (’023 Patent, col. 5:14-24).
  • Technical Importance: This approach combines intelligent safety controls that prevent common user errors with the now-ubiquitous convenience of USB charging, enabling a safer and more user-friendly product (Compl. ¶¶14-17).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 39, 47, 52, and 54 (Compl. ¶64). Claim 1 is representative and includes the following essential elements:
    • A power supply.
    • Positive and negative battery terminal connectors.
    • A power switch configured to turn on power from the power supply to the connectors.
    • A control system or circuit that controls the power switch, configured to detect correct polarity connection prior to turning on the power switch.
    • A USB input circuit connected to the power supply, which includes a DC/DC converter configured to increase power voltage from a USB power source.
    • A USB input connector for connecting to the USB power source.

U.S. Patent No. 11,584,243 - "Jump Starting Device with USB," Issued February 21, 2023

The Invention Explained

  • Problem Addressed: Like the ’023 Patent, this patent addresses the historical danger and inconvenience of jump-starting a vehicle, particularly the problem that jump starters powerful enough for a car battery often required specialized, high-power chargers rather than standardized inputs (’243 Patent, col. 1:10-24; Compl. ¶17).
  • The Patented Solution: The patent describes a jump starting device that integrates a USB charge circuit specifically designed to overcome the voltage mismatch between a standard USB source (typically 5V) and the higher-voltage internal power supply needed for jump starting. The core of the solution is a "DC-DC converter configured to upconvert voltage from the USB input connector to the power supply," allowing the device's powerful lithium-ion battery to be recharged using a common USB cable (’243 Patent, Abstract; col. 4:51-64).
  • Technical Importance: This invention provided a technical pathway for making powerful automotive tools compatible with the low-voltage charging ecosystem of consumer electronics, increasing convenience and eliminating the need for proprietary chargers (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 57 (Compl. ¶70). Claim 1 includes the following essential elements:
    • A power supply.
    • Positive and negative battery connectors.
    • A power switch or circuit to deliver power from the supply to the connectors to boost a battery.
    • A USB input connector.
    • A USB charge circuit connecting the USB connector to the power supply, which includes a DC-DC converter configured to upconvert voltage from the USB input.

Multi-Patent Capsule

  • U.S. Patent No. 11,667,203, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection," Issued June 6, 2023
    • Technology Synopsis: This patent focuses on a specific safety architecture. It claims a jump starter where the power switch is controlled by signals from two separate sensors: a "vehicle battery isolation sensor" to detect that a battery is physically connected, and a "reverse polarity sensor" to detect that it is connected correctly. Power is only supplied to the vehicle battery when both sensors indicate a safe condition, providing a dual-check safety mechanism (’203 Patent, Abstract; Compl. ¶54).
    • Asserted Claims: Independent claim 1 (Compl. ¶76).
    • Accused Features: The complaint alleges the accused products comprise the claimed separate sensors for battery isolation and reverse polarity, which control a power switch to connect the internal power supply to a vehicle battery only when conditions are met (Compl. ¶¶61-62).

III. The Accused Instrumentality

Product Identification

  • The accused products are the "Accused Battery Tender® jump starters," which include the Battery Tender® 800 AMP Jump Starter, 1000 AMP Jump Starter, 1500 AMP Jump Starter, 2000 AMP Jump Starter, 2000 AMP Power Station, 600 AMP Jump Starter, and 800 AMP Jump Starter And Tire Inflator (Compl. ¶24).

Functionality and Market Context

  • The accused products are described as portable, lithium-ion powered devices for boosting or charging depleted 12-volt vehicle batteries (Compl. ¶¶33, 35, 41). They feature red and black "smart alligator clips" for connecting to battery terminals (Compl. ¶36). The complaint highlights images of the various accused jump starter models. A representative image shows four of the accused devices with their corresponding red and black jumper cables (Compl. ¶33, p. 11). The complaint alleges these devices include safety features such as "reverse polarity protection" that "ensures you're connecting to the correct terminal before the jump starter kicks in" (Compl. ¶¶39-40). The devices are recharged via standard USB ports, such as "Micro USB" or "Type - C USB" (Compl. ¶40). An image in the complaint shows close-ups of the USB ports on three of the accused products (Compl. ¶40, p. 14).
  • The complaint alleges the products are sold via Defendants' website and the Amazon marketplace, positioning them as direct competitors to Plaintiff's NOCO BOOST® products (Compl. ¶¶22, 26, 28, 66).

IV. Analysis of Infringement Allegations

11,447,023 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a power supply The accused jump starters comprise an internal "lithium ion" battery cell or "lithium battery pack." ¶35 col. 4:8-16
a positive polarity battery terminal connector... [and] a negative polarity battery terminal connector The accused jump starters include red (positive) and black (negative) "smart alligator clips." ¶36 col. 4:45-51
a power switch or circuit configured to turn on power from the power supply The accused jump starters comprise an internal power relay or switch that turns on power to the alligator clips. ¶38 col. 4:40-45
a control system or circuit... configured to detect whether the... connectors have a correct polarity connection... prior to turning on the power switch or circuit The accused jump starters have a "reverse polarity protection" feature that prevents power from being sent "unless the alligator clips are connected correctly." ¶39 col. 4:26-34
a USB input circuit connected to the power supply, the USB input circuit comprising a DC/DC converter... configured for... increas[ing] power voltage The accused jump starters are charged via a 5-volt USB input, and this voltage is increased by a DC/DC converter to charge the internal multi-cell Lithium-ion battery pack. ¶¶40-41 col. 5:14-24
a USB input connector connected to the USB input circuit The accused jump starters include a "Micro USB Input port" or "Type - C USB, (IN) port" for charging the internal battery. ¶40 col. 7:20-24
  • Identified Points of Contention:
    • Technical Questions: A primary factual question will be whether the accused products' "reverse polarity protection" feature operates in the specific manner required by the claim—namely, detecting polarity before the main power switch is activated. The marketing language cited ("before the jump starter kicks in") suggests this, but discovery will be needed to confirm the actual circuit operation (Compl. ¶40). Similarly, the complaint asserts the presence of a DC/DC converter that increases voltage, which will need to be proven with technical evidence beyond product descriptions (Compl. ¶41).
    • Scope Questions: The case may raise the question of whether a general marketing description of a safety feature (e.g., "reverse polarity protection") is sufficient at the pleading stage to allege infringement of a specific, multi-step functional claim limitation regarding a "control system or circuit."

11,584,243 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a power supply The accused jump starters comprise an internal power supply, such as a lithium-ion battery. ¶48 col. 3:19-27
a positive battery connector for electrically connecting... [and] a negative battery connector The accused jump starters comprise positive and negative connectors (alligator clips) for connecting to a vehicle battery. ¶49 col. 3:52-58
a power switch or switch circuit... configured to switch power on from the power supply to boost or charge the depleted or discharged battery The accused jump starters comprise a power switch or circuit to turn on power from the internal supply to the connectors. ¶50 col. 3:47-51
a USB input connector The accused jump starters comprise a USB input connector for charging. ¶51 col. 4:51-54
a USB charge circuit... comprising a DC-DC converter configured to upconvert voltage from the USB input connector The accused jump starters comprise a USB charge circuit with a DC-DC converter that upconverts voltage from the USB input to the power supply. ¶52 col. 4:51-64
  • Identified Points of Contention:
    • Technical Questions: The central technical question is whether the accused products’ charging circuitry in fact contains a "DC-DC converter" that performs the function of "upconvert[ing] voltage" from the USB input. The complaint makes this allegation, citing user manuals, but this will likely be a key area for expert discovery and reverse engineering (Compl. ¶52).
    • Scope Questions: Does the term "upconvert" imply a specific type of boost converter, or can it be read more broadly to cover other power conversion topologies, such as a buck-boost converter, that may be used in the accused products? The construction of this term may be dispositive.

V. Key Claim Terms for Construction

For the ’023 Patent:

  • The Term: "a control system or circuit... configured to detect whether the... connectors have a correct polarity connection... prior to turning on the power switch or circuit" (Claim 1)
  • Context and Importance: This term defines the core safety logic of the invention. The infringement analysis will depend on whether the accused "reverse polarity protection" meets both the "detect" and temporal "prior to turning on" limitations. Practitioners may focus on this term because the sequence of operations—detection before power delivery—is critical to the patent's safety value proposition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes this function being performed by a "programmable microcontroller unit (MCU) 1" that receives inputs from sensors and provides control outputs, suggesting the term could cover a wide range of hardware and software implementations (’023 Patent, col. 4:17-25, 5:46-64).
    • Evidence for a Narrower Interpretation: The detailed description and figures disclose a specific embodiment using an "optically coupled isolator phototransistor (4N27)" as the reverse battery sensor (’023 Patent, col. 5:26-35, FIG. 2A). A defendant may argue that the term should be limited to such an optical isolation circuit or a direct equivalent.

For the ’243 Patent:

  • The Term: "a DC-DC converter configured to upconvert voltage" (Claim 1)
  • Context and Importance: This term is the technical heart of the USB charging invention. Infringement hinges on proving that the accused devices use a converter that boosts, or "upconverts," the ~5V from a USB source to the higher voltage required by the internal battery pack.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states that the "5V potential provided from standard USB chargers is up-converted to the 12.4 VDC voltage required for charging the internal lithium battery pack using a DC-DC converter 49" (’243 Patent, col. 4:56-61). This provides a clear functional definition without limiting the specific converter topology.
    • Evidence for a Narrower Interpretation: While the specification does not detail a specific converter type, a defendant could argue that the term "upconvert" has a specific meaning in the art that excludes certain types of converters (e.g., those that can also step down voltage) or that the context of the invention limits the term to a simple boost converter architecture.

VI. Other Allegations

  • Indirect Infringement: While the complaint does not contain a separate count for indirect infringement, it alleges facts that may be used to support such a claim. Specifically, it alleges that Defendants provide users with instruction manuals that include "step-by-step instructions" on how to use the accused jump starters, such as "Connect the RED positive clip to the positive post on the battery, then the BLACK negative clip to the negative post on the battery" (Compl. ¶¶34, 37).
  • Willful Infringement: The complaint alleges willful infringement for all three asserted patents. The basis for willfulness is alleged pre-suit knowledge, founded "upon information and belief" that Defendants compete with NOCO, that NOCO's patent portfolio is "public knowledge," and that Defendants have "actually known about the ['023, '243, and '203] Patent[s] and its infringement thereof since prior to this lawsuit" (Compl. ¶¶66, 72, 78).

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

This dispute between competitors in the portable jump starter market will likely focus on the precise technical operation of the accused products compared to the specific requirements of the patent claims. The central questions for the court appear to be:

  • A core question will be one of technical proof: Can Plaintiff produce evidence, likely through discovery and expert analysis, that the internal circuitry of the Accused Battery Tender® products matches the claims? Specifically, do they employ a DC-DC converter that "upconverts" voltage from a USB source, and does their safety mechanism operate by detecting polarity before enabling power flow, as distinct from merely warning a user or cutting power after a fault is detected?
  • A key legal issue will be one of claim construction: How will the court define the scope of functional limitations, such as the '203 patent's requirement for two separate sensors for battery presence and polarity that both provide signals to control the power switch? The outcome of these definitional disputes will determine whether the accused products' safety architecture falls within the bounds of the patents.