DCT
1:19-cv-11045
Battery Conservation Innovations LLC v. Hocoma Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Battery Conservation Innovations, LLC (Texas)
- Defendant: Hocoma Incorporated (Delaware)
- Plaintiff’s Counsel: Chavous Intellectual Property Law LLC
- Case Identification: 1:19-cv-11045, D. Mass., 05/03/2019
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is deemed a resident of the District of Massachusetts, conducts business there, and has a regular and established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Valedo line of wearable medical sensors infringes a patent related to methods for conserving battery power in electronic devices by detecting periods of inactivity.
- Technical Context: The technology at issue concerns automated power management in battery-operated devices, a critical feature for extending the operational life of portable electronics.
- Key Procedural History: The patent-in-suit is a continuation of a prior application, but the complaint does not mention any other prior litigation, licensing history, or post-grant proceedings.
Case Timeline
| Date | Event |
|---|---|
| 2011-12-27 | U.S. Patent No. 9,239,158 Priority Date |
| 2016-01-19 | U.S. Patent No. 9,239,158 Issue Date |
| 2019-05-03 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,239,158, “Battery-Conserving Flashlight And Method Thereof,” issued January 19, 2016
The Invention Explained:
- Problem Addressed: The patent's background section describes the common problem of portable electronic devices, specifically flashlights, being left on after use, which drains the battery and renders the device unusable for its next intended purpose (’158 Patent, col. 1:26-34). This leads to the waste of batteries and natural resources (’158 Patent, col. 1:35-39).
- The Patented Solution: The invention proposes a system within an electronic device that uses a controller and a motion sensor to determine if the device is stationary for a predetermined period. If no motion is detected, the controller "decouples" the battery from the power-consuming components (e.g., the illumination source) to conserve energy (’158 Patent, Abstract; col. 4:11-18). The system may also activate a visual or audible indicator to alert the user before the device deactivates (’158 Patent, col. 4:46-59).
- Technical Importance: This technology provides an automated solution to prevent inadvertent battery drain in simple portable devices, thereby extending their useful life between charges or battery replacements.
Key Claims at a Glance:
- The complaint asserts infringement of at least independent claim 15 (Compl. ¶14).
- The essential elements of independent claim 15 are:
- A body including an opening for accessing an interior of the body;
- At least one battery disposed in the body and configured for powering the device;
- A controller configured to determine if the body is in motion, and if it is not in motion for a first predetermined period of time, the controller decouples the battery from the electronic device to conserve energy; and
- A visual indicator on an exterior surface, which the controller activates.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
- Product Identification: The "Valedo digital back coach" and similar products (the “Product”) (Compl. ¶16).
- Functionality and Market Context: The accused Product is a wearable medical device system consisting of two motion sensors that attach to a user's body to provide real-time feedback for therapeutic back exercises (Compl. ¶17). The sensors contain a 3D gyroscope, a 3D accelerometer, and a 3D magnetometer to calculate movement angles and accelerations (Compl. p. 4). A key feature cited in the complaint is the Product's power management system, which includes a "standby mode" and a "deep sleep mode" to save battery power during periods of inactivity (Compl. p. 5). For example, the complaint references a product manual stating that the sensors enter "deep sleep mode" after approximately five minutes if they cannot connect to a computing device but sense continual movement, which is described as "important during transport to save battery power" (Compl. p. 5). The complaint also highlights the Product's use of an integrated rechargeable polymer Li-ion battery (Compl. p. 5).
IV. Analysis of Infringement Allegations
’158 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A battery-conserving electronic device comprising: a body including an opening for accessing an interior of the body; | The Product is alleged to be a battery-conserving electronic device that includes a body. The complaint does not specify an opening but alleges this element is met. A visual in the complaint shows the sensor's housing. (Compl. ¶17-18). | ¶18 | col. 6:40-42 |
| at least one battery disposed in the body and configured for powering the device; | The Product contains an "Integrated Recharging Solution (polymer Li-ion battery, 3.7V, 160mAh)" disposed within the body to power the device. A complaint visual highlights the battery component. (Compl. ¶19, p. 6). | ¶19 | col. 6:43-44 |
| a controller disposed in the body configured to determine if the body is in motion, wherein if the body is not in motion for a first predetermined period of time, the controller decouples the at least one battery from the electronic device to conserve energy in the at least one battery; | The Product includes a controller (CPU & Firmware) and motion sensors (gyroscope, accelerometer) that determine if the body is in motion. The complaint alleges that if the body is not in motion for a predetermined time, the device enters "Standby Mode/Deep Sleep Mode," wherein the controller "decouples at least one battery from the electronic device to conserve energy." (Compl. ¶20-21). | ¶21 | col. 6:45-51 |
| and a visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator. | The Product is alleged to have indicator LEDs on its exterior surface. The complaint cites product documentation stating the sensors are "equipped with an LED and blinks and flashes to communicate what it's doing or if it needs charging." The complaint alleges the controller activates this indicator. (Compl. ¶22, p. 12). | ¶22 | col. 7:4-8 |
- Identified Points of Contention:
- Scope Questions: The ’158 patent is titled "Battery-Conserving Flashlight" and its background and embodiments focus on this application. A central question may be whether claim 15, which recites a general "battery-conserving electronic device," can be read to cover a complex medical device like the accused Valedo sensor, or if its scope should be interpreted more narrowly in light of the specification's focus.
- Technical Questions: A key technical question is what "decouples the at least one battery from the electronic device" means in practice. The complaint alleges that the Product's "Standby Mode/Deep Sleep Mode" performs this function (Compl. ¶21). However, it is a question for the court whether placing a device in a low-power "sleep mode" is technically equivalent to "decoupling" the battery, which the patent specification illustrates with a physical switch (222) that disconnects the power source (’158 Patent, Fig. 2; col. 4:16-18).
V. Key Claim Terms for Construction
The Term: "decouples"
Context and Importance: This term is central to the infringement analysis. The defendant will likely argue that its "deep sleep mode" is a low-power state, not a full "decoupling," while the plaintiff will argue the term covers any action that achieves the claimed energy conservation. Practitioners may focus on this term because the patent's own description appears to tie it to the operation of a switch breaking a circuit.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism of decoupling, only the function: "to conserve energy in the at least one battery" (’158 Patent, col. 7:4-5). This functional language may support an interpretation that includes low-power states that achieve the same result.
- Evidence for a Narrower Interpretation: The specification describes the controller (224) operating a "switch 222" to connect or disconnect the battery (220) from the illumination source (108) (’158 Patent, col. 4:5-18). This specific embodiment may be used to argue that "decouples" implies a more complete, switch-like disconnection of power rather than merely placing components into a sleep state.
The Term: "visual indicator"
Context and Importance: The infringement allegation for this element rests on the Product's LEDs that "blinks and flashes to communicate what it's doing or if it needs charging" (Compl. ¶22, p. 12). The definition of "visual indicator" is important because the patent describes it as an alert that the device will shut down due to inactivity (’158 Patent, col. 4:46-59), whereas the accused functionality appears related to operational status (pairing, charging) rather than an impending power-off event.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Claim 15 broadly requires a "visual indicator disposed on an exterior surface... wherein the controller activates the visual indicator" (’158 Patent, col. 7:6-8), without specifying the purpose or timing of the indication. This may support reading the claim on any controller-activated external light.
- Evidence for a Narrower Interpretation: The detailed description explains that the visual indicator serves as "an alert to the user that the flashlight has been left on" and is activated "after a predetermined period of time" of non-use (’158 Patent, col. 5:53-59). This suggests the indicator's function is specifically to warn of an impending, inactivity-based shutdown, a function not explicitly alleged for the accused LEDs.
VI. Other Allegations
- Indirect Infringement: The complaint includes a general allegation that Defendant induced infringement through the actions of its customers (Compl. ¶25). However, it does not plead specific facts, such as quoting from user manuals, that would show Defendant actively instructed users to perform the allegedly infringing steps.
- Willful Infringement: The complaint alleges Defendant has knowledge of its infringement "at least as of the service of the present complaint" (Compl. ¶13). This allegation, as stated, would only support a claim for post-suit willfulness, as no facts supporting pre-suit knowledge of the patent are alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional and technical scope: can the accused product's "deep sleep mode," which is likely a low-power state, be found to meet the claim requirement to "decouple" the battery from the electronic device? This will depend heavily on the court's construction of the term "decouples" in light of the patent's specification.
- A second key question will be one of functional purpose: does the accused product's general-status LED, which indicates pairing or charging status, function as the "visual indicator" claimed in the patent? The case may turn on whether the claim is interpreted to require an indicator that specifically warns of an impending shutdown due to inactivity, as described in the patent's preferred embodiment.
- Finally, a significant question of patent scope exists: can claims from a patent explicitly framed around solving a problem in simple "flashlights" be broadly applied to a complex, multi-component medical sensor? The defense may argue that the context of the invention limits the claims to simpler devices, creating a potential mismatch with the accused technology.