DCT
6:25-cv-00251
NOCO Co v. Deltona Transformer Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: The NOCO Company (Ohio)
- Defendant: Deltona Transformer Corporation (Florida); Deltran USA, LLC (Florida); Deltran Operations USA, Inc. (Florida)
- Plaintiff’s Counsel: Jones Day
- Case Identification: 6:25-cv-00251, M.D. Fla., 02/17/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendants are Florida corporations that reside in, have committed acts of infringement in, and maintain a regular and established place of business in the Middle District of Florida.
- Core Dispute: Plaintiff alleges that Defendants’ Battery Tender® line of portable jump starters infringes two patents related to safety and charging features for lithium-ion-based vehicle jump starters.
- Technical Context: The technology concerns compact, portable lithium-ion battery packs designed to safely jump-start a vehicle, a consumer electronics category where safety features preventing sparks and battery damage are significant market differentiators.
- Key Procedural History: The complaint notes that the parties have been involved in prior patent litigation over related patents. It alleges the patents-in-suit claim priority to patents asserted in earlier lawsuits and were issued during the pendency of that litigation, which may be relevant to the allegations of willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-07-03 | Earliest Priority Date for ’143 and ’696 Patents |
| 2020-01-09 | Plaintiff files first lawsuit against Defendants over related patents |
| 2023-11-13 | Plaintiff files second lawsuit against Defendants over related patents |
| 2025-01-07 | ’143 Patent Issued |
| 2025-01-28 | ’696 Patent Issued |
| 2025-02-17 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,187,143 - "Portable Vehicle Battery Jump Start Apparatus With Safety Protection"
- Patent Identification: U.S. Patent No. 12,187,143, titled "Portable Vehicle Battery Jump Start Apparatus With Safety Protection", issued on January 7, 2025 (the "’143 Patent"). (Compl. ¶23).
The Invention Explained
- Problem Addressed: The patent addresses the dangers of conventional jump-starting, which can cause sparks, short circuits, and potential injury if jumper cable clamps are connected improperly or touch each other. (’143 Patent, col. 1:36-44).
- The Patented Solution: The invention is a hand-held, portable jump starter containing a multi-cell lithium battery. A key aspect is its charging system, which uses a "USB charge circuit" with a DC-to-DC converter to "upconvert" a low input voltage (e.g., 5V from a standard USB port) to the higher voltage required to charge the internal series-connected battery cells. The system also includes a control circuit to monitor battery voltage and prevent over-charging, and a separate battery charge controller to prevent over-discharging. (’143 Patent, Abstract; col. 6:3-12, Fig. 1).
- Technical Importance: This design allows for a compact, powerful jump starter to be recharged safely and conveniently from common low-voltage sources like USB chargers, while incorporating critical safety protections for the internal lithium-ion battery. (Compl. ¶¶19-20).
Key Claims at a Glance
- The complaint asserts independent claims 1, 23, and 30. (Compl. ¶161).
- Exemplary independent claim 1 includes the following essential elements:
- A hand-held, portable jump starter device;
- A housing containing a multi-cell rechargeable battery (at least three cells in series), a USB input port, and an output port;
- A USB charge circuit connected to the USB input port, which includes a DC-to-DC converter for upconverting the input voltage to a higher charging voltage, and a pair of series-connected transistors to control current flow;
- A control circuit that detects the battery's voltage and can turn off the USB charge circuit to prevent over-charging; and
- A battery charge controller configured to prevent over-discharging of the battery. (Compl. ¶82; ’143 Patent, col. 8:47-9:4).
U.S. Patent No. 12,208,696 - "Portable Vehicle Battery Jump Start Apparatus With Safety Protection"
- Patent Identification: U.S. Patent No. 12,208,696, titled "Portable Vehicle Battery Jump Start Apparatus With Safety Protection", issued on January 28, 2025 (the "’696 Patent"). (Compl. ¶24).
The Invention Explained
- Problem Addressed: Like the ’143 Patent, this invention addresses the safety risks inherent in jump-starting a vehicle, particularly the danger of sparks from live clamps. (’696 Patent, col. 1:36-44).
- The Patented Solution: The invention is a two-part system: a handheld booster device and a jumper cable device. The handheld unit contains the battery and a "control circuit" that first detects if it is "safe to couple" to a vehicle's battery. Only after confirming a safe connection does the control circuit activate a power switch to connect the internal battery to the output port, thereby energizing the jumper clamps. The jumper cable connects to the booster via a plug with a "specific orientation" to ensure correct polarity. (’696 Patent, Abstract; col. 4:40-54).
- Technical Importance: This "smart" switching functionality ensures the high-current jumper clamps remain inert until a proper connection to a vehicle battery is verified, preventing sparks that could occur if the clamps were to touch each other or an incorrect surface. (Compl. ¶19).
Key Claims at a Glance
- The complaint asserts independent claims 1 and 23. (Compl. ¶167).
- Exemplary independent claim 1 includes the following essential elements:
- An apparatus comprising a handheld booster device and a separate jumper cable device;
- The booster device has a rechargeable battery pack, a control circuit, a power switch, an output port, and an input port;
- The control circuit detects when it is safe to connect to a vehicle battery and, in response, connects the battery pack to the output port through the power switch;
- The jumper cable device has a plug configured to connect to the booster's output port in a specific orientation;
- The booster device also includes a charge circuit with an upconverter and transistors for charging its internal battery. (Compl. ¶135; ’696 Patent, col. 8:42-65).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are the "Battery Tender®" brand of portable jump starters, including but not limited to the 600, 800, 1000, 1500, and 2000 AMP models. (Compl. ¶¶1, 48).
Functionality and Market Context
- The complaint describes the accused products as handheld, lithium-ion-powered devices designed to jump-start vehicles. (Compl. ¶102). They feature USB input ports (e.g., Type-C and/or micro-USB) for recharging the internal battery and a dedicated output port, termed a "Smart Alligator Clip Receptacle," for connecting the jumper cables to a vehicle. (Compl. ¶¶86-87, 90). The complaint alleges these products are marketed with safety features such as "spark-proof and reverse polarity protection," which "ensures no charge is sent unless the alligator clips are connected correctly to the battery." (Compl. ¶153). The complaint presents an image of an accused device's internal circuit board, highlighting components alleged to perform the patented functions. (Compl. ¶91).
IV. Analysis of Infringement Allegations
’143 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing having a multi-cell rechargeable battery including at least three battery cells connected in series, a USB input port...and an output port... | The device's external casing, an internal multi-cell lithium battery, a USB-C or micro-USB input port for charging, and a "Smart Alligator Clip Receptacle" for outputting current. The complaint includes a teardown photograph showing the casing and battery. | ¶¶85, 86, 90 | col. 6:3-12 |
| a USB charge circuit...including a DC-to-DC converter circuit for upconverting an input voltage...and a pair of series connected transistor devices... | Internal circuitry, shown in photographs, that allegedly upconverts the 5V input from a USB port to a higher voltage (e.g., 12V) to charge the internal battery, and which includes transistor devices to control current flow. | ¶91 | col. 8:55-65 |
| a control circuit for detecting the voltage...and configured to turn off the USB charge circuit to prevent over charging... | A control circuit that monitors the battery voltage during charging and stops the process if the voltage exceeds a predefined threshold. | ¶94 | col. 9:1-4 |
| a battery charge controller...configured to prevent over discharging of the multi-cell rechargeable battery. | A battery charge controller, shown in a photograph of the circuit board, that is coupled to the battery and transistors to prevent the battery from being overly depleted. | ¶95 | col. 8:43-46 |
’696 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a handheld booster device comprising a rechargeable battery pack, a control circuit, a power switch, and an output port... | The main body of the Accused Battery Tender® jump starter, which contains the battery and control circuitry. | ¶137 | col. 4:40-44 |
| wherein the control circuit detects when it is safe to couple the handheld booster device to the vehicle's battery and connects the rechargeable battery pack to the output port thru the power switch... | The device's safety system, advertised as providing "spark-proof and reverse polarity protection," which allegedly ensures that power is not sent to the clamps until a correct connection is detected. | ¶¶137, 153 | col. 4:44-49 |
| a jumper cable device comprising a plug and a pair of cables...the plug being configured to connect to the output port...in a specific orientation... | The "Smart Alligator Clips" accessory, which includes jumper cables and a keyed plug that connects to the booster's output port in only one way. The complaint includes an image of this accessory. | ¶139 | col. 4:49-54 |
| wherein the handheld booster device further comprises an input port for providing power from an external source... | The USB-C and/or micro-USB ports used to charge the device's internal battery. | ¶140 | col. 5:1-4 |
| ...a charge circuit...including an upconverter circuit...and a pair of series connected transistor devices... | The internal circuitry, also accused of infringing the ’143 Patent, used to convert input voltage and manage current flow for recharging the internal battery. | ¶141 | col. 5:4-13 |
Identified Points of Contention
- Scope Questions: A central question for the ’143 Patent may be whether the claim term "USB input port" should be construed to literally cover newer USB standards (e.g., USB-C) that are present in the accused products but may not have been prevalent when the patent application was filed. The complaint's inclusion of an alternative doctrine of equivalents argument suggests Plaintiff anticipates a dispute on this term's literal scope. (Compl. ¶89).
- Technical Questions: For the ’696 Patent, a key dispute may arise over the limitation "control circuit detects when it is safe." The complaint relies heavily on marketing statements about "spark-proof" technology. (Compl. ¶153). The case may turn on whether the accused products' actual electronic implementation for achieving this safety feature performs the same function, in the same way, to achieve the same result as the specific sensor and switching arrangement described in the patent specification. (Compl. ¶150).
V. Key Claim Terms for Construction
The Term: "USB input port" (’143 Patent, Claim 1)
- Context and Importance: The definition of this term is critical because the accused products utilize modern USB standards (e.g., Type-C). (Compl. ¶86). Whether this term is construed broadly to cover all evolving forms of USB or is limited to those existing at the time of the invention will determine if infringement is literal or must be proven under the more stringent doctrine of equivalents.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification may refer to "USB" in a general sense as a source of charging power, which a party could argue should not be limited to any particular physical connector or version of the standard. (’143 Patent, col. 7:46-51).
- Evidence for a Narrower Interpretation: The patent’s figures or specific embodiments may only depict older, more established USB connectors (e.g., USB-A or Micro-USB). A party could argue that the claims should be limited to the structures actually disclosed and known to artisans at the time.
The Term: "control circuit detects when it is safe to couple" (’696 Patent, Claim 1)
- Context and Importance: This term captures the core "smart" safety feature of the invention. Practitioners may focus on this term because the infringement analysis will depend on whether the accused device's method of preventing sparks is technically equivalent to the method claimed in the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is functional. A party could argue that any circuit that performs the function of detecting safety and enabling power falls within its scope, regardless of the specific implementation. (’696 Patent, col. 8:46-49).
- Evidence for a Narrower Interpretation: The specification describes a specific implementation using a "car battery reverse sensor" and a "car battery isolation sensor" that provide inputs to a microcontroller, which in turn controls a switch. (’696 Patent, col. 6:55-65, Fig. 1). A party could argue that "detects when it is safe" is not a generic function but requires the specific multi-step verification process disclosed in the patent's detailed description.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendant Deltona Transformer Corporation (DTC) actively induced infringement by the other Deltran Defendants. This is based on allegations that DTC, as the owner of the "Battery Tender" brand, directs and encourages the design, manufacture, and sale of the accused products by providing "guidelines, rules, or written parameters" and by requesting and testing samples of the products. (Compl. ¶¶53, 54, 79, 174).
- Willful Infringement: Willfulness is alleged based on Defendants’ purported knowledge of the asserted patents and their relation to earlier patents that were the subject of prior litigation between the parties. (Compl. ¶¶69-77). The complaint alleges that the applications for the patents-in-suit were pending during these prior lawsuits and that Defendants knew of them "as of the date of each patent's issuance," suggesting pre-suit knowledge. (Compl. ¶75, 163).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "USB input port," as used in the ’143 Patent, be construed to literally encompass modern USB standards like USB-C, or will the analysis be confined to the doctrine of equivalents, raising the bar for proving infringement?
- A key evidentiary question will be one of technical implementation: does the accused products' advertised "spark-proof" safety feature operate in substantially the same way as the multi-sensor detection and switching system claimed in the ’696 Patent, or is there a fundamental mismatch in their method of operation that places it outside the patent's scope?
- A central question of corporate liability will be whether Plaintiff can pierce the corporate structure to hold the brand owner, DTC, liable for inducing infringement based on its licensing, quality control, and testing activities, or if those activities fall short of the legal standard for inducement.