DCT
0:22-cv-60219
Cayago Tec GmbH v. Iaqua Hong Kong Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Cayago Tec GmbH (Germany) and Cayago Americas, Inc. (Florida)
- Defendant: Iaqua (Hong Kong) Ltd (Hong Kong)
- Plaintiff’s Counsel: Assouline & Berlowe, P.A.; Schröder, Joseph & Associates, LLP
- Case Identification: 0:22-cv-60219, S.D. Fla., 02/01/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant Iaqua (Hong Kong) Ltd transacts business in the district, has entered into contracts with Florida residents, and has placed infringing products into the stream of commerce with the knowledge they would be sold in Florida. The complaint also alleges the Defendant purposely availed itself of the jurisdiction by appearing in a related case in the same district.
- Core Dispute: Plaintiff alleges that Defendant’s personal watercraft, sold under the SeaDart, Stingray, and DiveJet brands, infringe three U.S. patents related to rechargeable battery unit construction, electric motor cooling systems, and redundant energy storage in watercraft.
- Technical Context: The technology concerns the design and construction of high-performance, electric-powered personal water scooters, a niche segment of the luxury marine and water sports market.
- Key Procedural History: The complaint references a prior 2019 lawsuit filed by the Plaintiff against a different entity, iAqua Distribution LLC, in the same district. That lawsuit, which alleged infringement of the '019 and '888 patents, resulted in a settlement agreement and a permanent injunction against iAqua Distribution LLC. The complaint also notes that Plaintiffs have engaged in patent enforcement actions in several other countries, including Germany, France, Spain, Turkey, and Mexico.
Case Timeline
| Date | Event |
|---|---|
| 2004-10-12 | U.S. Patent No. 7,963,814 Priority Date |
| 2011-06-21 | U.S. Patent No. 7,963,814 Issued |
| 2013-01-18 | U.S. Patent No. 9,694,888 Priority Date |
| 2013-01-18 | U.S. Patent No. 9,774,019 Priority Date |
| 2017-07-04 | U.S. Patent No. 9,694,888 Issued |
| 2017-09-26 | U.S. Patent No. 9,774,019 Issued |
| 2019 | Plaintiffs filed lawsuit against iAqua Distribution LLC |
| Late 2019 | Plaintiffs and iAqua Distribution LLC settled the 2019 lawsuit |
| 2022-02-01 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,774,019 - "Rechargeable Battery Unit for a Watercraft," issued September 26, 2017
The Invention Explained
- Problem Addressed: The patent describes the challenge of designing powerful, high-density battery units that can fit within the limited, compact space available in a watercraft hull (’019 Patent, col. 1:39-49).
- The Patented Solution: The invention proposes a modular battery unit where multiple individual rechargeable batteries are connected into a "rechargeable battery cell" using a holding arrangement. This arrangement consists of holders with receptacles that receive the ends of the batteries, allowing for a compact and standardized assembly. The patent further explains that these standardized battery cells can be lined up and electrically coupled in a series ("cascaded") to achieve higher voltages and power densities within a pipe-like housing ('019 Patent, Abstract; col. 2:31-43; Fig. 2).
- Technical Importance: This modular design provides a method for creating scalable and powerful battery packs in a compact, robust form factor suitable for the demanding environment of a personal watercraft ('019 Patent, col. 2:1-4).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶44).
- The essential elements of Claim 1 include:
- A holding arrangement with two holders, each having receptacles.
- A plurality of rechargeable batteries connected by the holding arrangement to form a rechargeable battery cell.
- At least one pole connector to electrically couple some of the batteries.
- A configuration where two or more of these rechargeable battery cells are lined up and electrically coupled.
- A structure where the two holders of each cell are separated by a clearance distance, with each holder receiving one of the two poles of each battery.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 7,963,814 - "Electric motor-driven water craft, which is cooled by the surrounding water," issued June 21, 2011
The Invention Explained
- Problem Addressed: High-power electric motors used in watercraft generate substantial heat, which can limit performance and efficiency. The patent notes that prior cooling systems were often complicated, heavy, and difficult to maintain ('814 Patent, col. 1:26-34).
- The Patented Solution: The invention describes a cooling system that uses the surrounding water as a direct coolant. The motor's stator is placed in "heat-conducting contact" with a receiver housing via a "heat-conducting unit." This receiver housing is itself arranged at least partially within the watercraft's flow channel, allowing the heat from the motor to be efficiently transferred to the water flowing through the channel ('814 Patent, Abstract; col. 2:29-36).
- Technical Importance: This design allows for effective and continuous cooling without requiring separate, complex cooling apparatus, thereby simplifying the watercraft's construction and enabling sustained high-power output ('814 Patent, col. 2:37-43).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 19 (Compl. ¶60).
- The essential elements of Claim 19 include:
- A motor-driven watercraft with a body, a flow channel, and a screw driven by an electric motor.
- The electric motor having an internal rotor.
- A stator in heat-conducting contact with a receiver housing of the motor by a heat-conducting unit.
- The receiver housing being made at least partially of a heat-conducting material.
- The receiver housing being arranged at least partially in the flow channel.
- The complaint does not explicitly reserve the right to assert dependent claims for this patent.
U.S. Patent No. 9,694,888 - "Watercraft Comprising a Redundant Energy Accumulator," issued July 4, 2017
- Technology Synopsis: The patent addresses the problem of operational reliability, where the failure of a single battery could strand a user at sea ('888 Patent, col. 1:36-41). The solution is a watercraft with two separate energy stores (e.g., batteries) installed in the hull, arranged on both sides of the central longitudinal plane to provide redundancy ('888 Patent, Abstract; col. 1:36-46). The invention also describes placing these energy stores in a "flooding chamber" that allows water to flow through and cool the components ('888 Patent, col. 1:63-65).
- Asserted Claims: The complaint asserts infringement of at least Claim 1 (Compl. ¶72).
- Accused Features: The accused DiveJet and Stingray Series watercraft are alleged to embody the claimed invention by comprising a hull, a flow duct, a motor, two energy stores installed in a flooding chamber on both sides of the longitudinal axis, and a propeller (Compl. ¶72).
III. The Accused Instrumentality
- Product Identification: The complaint names the SeaDart Ace watercraft, as well as various models in the "Stingray Series" and "DiveJet Series" (Compl. ¶¶31, 33).
- Functionality and Market Context: The accused products are described as self-propelled, electric-powered "sea toys and watercrafts/sea scooters" that function as a hybrid of a surface water scooter and an underwater scooter (Compl. ¶¶2, 10). The complaint alleges that the models within the Stingray Series and DiveJet Series are "essentially identical" to each other and to the SeaDart, with differences mainly related to performance metrics (e.g., speed, depth) and exterior components (Compl. ¶¶34-36). The complaint suggests these products directly compete with Plaintiff's SEABOB® F5 Series (Compl. ¶18). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint does not provide detailed infringement contentions or claim charts. The analysis below is based on the asserted claims and the general allegations made against the accused products.
'9,774,019 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A rechargeable battery unit for a watercraft, the rechargeable battery unit comprising: a holding arrangement including two holders, each holder having a plurality of receptacles; | The accused products are alleged to contain a rechargeable battery unit that includes a holding arrangement with two holders containing receptacles. | ¶44 | col. 2:15-16 |
| a plurality of rechargeable batteries connected to one another by the holding arrangement to form a rechargeable battery cell, each of the rechargeable batteries having two poles; | The holding arrangement in the accused products is alleged to connect multiple batteries to form a battery cell. | ¶44 | col. 1:53-56 |
| at least one pole connector electrically coupling at least some of the rechargeable batteries to one another; | The accused products are alleged to use at least one pole connector for electrical coupling of the batteries. | ¶44 | col. 2:17-20 |
| wherein two or more rechargeable battery cells are lined up with one another and electrically coupled to one another; and | The battery units in the accused products are alleged to contain at least two such battery cells that are lined up and electrically connected. | ¶44 | col. 2:31-33 |
| wherein the two holders of the holding arrangement of each rechargeable battery cell are separated by a clearance distance, each holder receiving a respective one of the two poles of each rechargeable battery. | The holders within each battery cell of the accused products are alleged to be separated by a distance and configured to receive opposite poles of the batteries. | ¶44 | col. 4:50-60 |
- Identified Points of Contention:
- Evidentiary Question: The complaint lacks any specific evidence (e.g., teardowns, product manuals, technical diagrams) showing how the accused products meet these limitations. The primary point of contention will be whether discovery reveals that the internal battery architecture of the accused products contains the specific "holding arrangement" and "lined up" cell structure required by Claim 1.
- Scope Question: A dispute may arise over the definition of "holding arrangement." The defense could argue that this term is limited to the specific embodiments shown in the patent (e.g., holders with concentric rings of receptacles), while the plaintiff may argue for a broader construction covering any structure that holds batteries together to form a cell.
'7,963,814 Infringement Allegations
| Claim Element (from Independent Claim 19) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A motor-driven watercraft, having a body on which a user at least partially rests or stands and having a flow channel... | The accused SeaDart watercraft is alleged to be a motor-driven watercraft with the described body and flow channel. | ¶60 | col. 1:7-14 |
| the electric motor (3) having an internal rotor, | The electric motor in the accused watercraft is alleged to be an internal rotor type. | ¶60 | col. 2:29-30 |
| a stator (21) in heat-conducting contact with a receiver housing (3.5) of the electric motor (3) by a heat-conducting unit (22), | The stator in the accused watercraft's motor is alleged to be in heat-conducting contact with a receiver housing via a heat-conducting unit. | ¶60 | col. 2:30-33 |
| in an area adjacent the heat-conducting unit (22) the receiver housing (3.5) formed at least partially of a material capable of conducting heat, and | The receiver housing in the accused watercraft is alleged to be made of a heat-conductive material. | ¶60 | col. 2:33-35 |
| the receiver housing (3.5) arranged at least partially in the flow channel (8). | The motor's receiver housing in the accused watercraft is alleged to be positioned at least partially within the water flow channel for cooling. | ¶60 | col. 2:35-36 |
- Identified Points of Contention:
- Technical Question: The central technical question is whether the accused watercraft's motor is actually cooled in the specific manner claimed. The complaint provides no evidence that the motor's stator is in "heat-conducting contact" with its housing via a distinct "heat-conducting unit," or that the housing is arranged in the flow channel to achieve this cooling effect.
- Scope Question: The meaning of "heat-conducting unit" may be a key issue for claim construction. The parties may dispute whether this requires a separate component (as the name might suggest) or if it can be read more broadly to cover a thermal interface material or a direct press-fit between the stator and the housing, as described in an embodiment ('814 Patent, col. 2:45-48).
V. Key Claim Terms for Construction
Term from the ’019 Patent: "holding arrangement"
- Context and Importance: This term is the central structural element of Claim 1 of the '019 Patent. The infringement analysis will hinge on whether the structure used to assemble the batteries in the accused products falls within the scope of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract describes the invention broadly as having batteries "connected to one another by means of a holding arrangement to form a rechargeable battery cell." This language could support an interpretation where any structure that connects batteries into a cell qualifies.
- Evidence for a Narrower Interpretation: The specification's detailed description and figures show a specific embodiment where the holders (20) have concentric rings of receptacles (21.1, 22.1) and alignment elements (24, 25) ('019 Patent, Fig. 1; col. 4:1-55). A defendant may argue that these disclosed features limit the term to a more complex structure than a simple battery tray.
Term from the ’814 Patent: "heat-conducting unit"
- Context and Importance: This term defines the interface that enables the claimed cooling mechanism in Claim 19 of the '814 Patent. Whether the accused product infringes will depend on the nature of the thermal connection between its motor's stator and housing.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the form of the "unit." This may support a construction that covers any feature or material that facilitates heat transfer, not just a discrete component.
- Evidence for a Narrower Interpretation: The specification discloses an embodiment where the unit is a "heat-conducting casting compound" ('814 Patent, col. 2:45-48). A defendant may argue that the term "unit" implies a structurally distinct element or a specific type of thermal compound, rather than simple surface-to-surface contact between the stator and its housing.
VI. Other Allegations
- Indirect Infringement: For all three patents, the complaint alleges both induced infringement under 35 U.S.C. § 271(b) and contributory infringement under § 271(c) (Compl. ¶¶47-50, 63-66, 75-78). The allegations are stated on "information and belief" and assert that the Defendant "directed their manufacturers, customers, and users to infringe" without providing specific factual support, such as references to user manuals or marketing materials.
- Willful Infringement: The complaint alleges that the Defendant had "actual knowledge" of the patents-in-suit prior to its infringing activities and that the infringement is "willful and deliberate" (Compl. ¶¶45-46, 61-62, 73-74). The basis for knowledge of the '019 and '888 patents is supported by the allegation of a prior 2019 lawsuit and settlement involving those same patents (Compl. ¶¶15-17). The complaint does not allege that the '814 patent was part of that prior dispute, which may raise a question as to the basis for pre-suit knowledge for that specific patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- An Evidentiary Question of Technical Fact: The complaint is factually sparse and makes its allegations largely on "information and belief." A threshold question for the case will be what the evidence uncovered during discovery reveals about the internal design of the accused products. Does their architecture incorporate the specific "holding arrangement" of the '019 patent, the direct water-cooling system of the '814 patent, and the dual-battery "flooding chamber" of the '888 patent?
- A Definitional Question of Claim Scope: The dispute will likely focus on the construction of key structural terms. A core issue will be whether terms like "holding arrangement" ('019 Patent) and "heat-conducting unit" ('814 Patent) are interpreted broadly or are limited to the specific structural embodiments detailed in the patent specifications.
- A Question of Willfulness and Intent: Given the prior litigation history involving the '019 and '888 patents, a central issue will be the strength of the willfulness claim. The court will have to determine whether the defendant's alleged infringement, particularly any conduct after the 2019 settlement involving a related entity, was objectively reckless, potentially exposing the defendant to enhanced damages.