DCT

8:25-cv-01941

Minotaur Systems LLC v. Blink Charging Co

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:25-cv-01941, D. Md., 06/17/2025
  • Venue Allegations: Venue is alleged to be proper in the District of Maryland because Defendant maintains an established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s electric vehicle charging products and systems infringe a patent related to monitoring and associating power charging events with specific geographic locations.
  • Technical Context: The technology concerns the tracking of energy consumption for electric vehicles, a field of increasing importance for administering governmental or utility incentive programs that rely on verifiable charging data.
  • Key Procedural History: The complaint alleges that Plaintiff is the assignee of the patent-in-suit. It further alleges that the filing and service of the complaint provides Defendant with actual knowledge of infringement, forming a basis for post-suit infringement allegations. No other procedural history is mentioned.

Case Timeline

Date Event
2008-12-19 Priority Date for U.S. Patent No. 8,417,402
2013-04-09 Issue Date for U.S. Patent No. 8,417,402
2025-06-17 Complaint Filed

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

U.S. Patent No. 8,417,402 - Monitoring of power charging in vehicle

Issued April 9, 2013

The Invention Explained

  • Problem Addressed: The patent describes a need to differentiate between electricity used to charge an electric vehicle and electricity used for other purposes, particularly to enable vehicle owners to benefit from incentive programs without being restricted to designated charging stations (ʼ402 Patent, col. 1:11-32).
  • The Patented Solution: The invention is an in-vehicle "energy meter unit" that measures the amount of energy supplied to the vehicle's battery during a charging session. Crucially, the unit includes a location-determining system (e.g., GPS) to record the specific location of the vehicle at the time of charging. A processor then associates the energy measurement with the location data, which can be transmitted to a central server to validate claims for energy credits or discounts ('402 Patent, Abstract; col. 2:33-43; Fig. 2).
  • Technical Importance: This technology sought to provide a verifiable, location-specific record of charging, enabling the administration of incentive programs for electric vehicle use beyond a closed network of proprietary charging stations ('402 Patent, col. 1:11-20).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims in its body, instead incorporating by reference claim charts from an "Exhibit 2" that was not attached to the filed complaint (Compl. ¶11, ¶16-17). Analysis of specific claim elements is therefore not possible based on the provided documents.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products or services. It refers generically to "Exemplary Defendant Products" that are purportedly identified in the unattached Exhibit 2 (Compl. ¶11, ¶16).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's specific functionality or market position.

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s products infringe the ʼ402 Patent but provides the substantive infringement theory in "the claim charts of Exhibit 2," which are incorporated by reference but not included with the complaint (Compl. ¶17). A detailed analysis of the infringement allegations is therefore not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

The complaint does not provide sufficient detail for analysis of specific points of contention regarding infringement.

V. Key Claim Terms for Construction

As the asserted claims are not identified, this analysis considers a term from independent claim 1 that is central to the patent's disclosure.

"location-determining system"

Context and Importance

The definition of this term is central to the scope of the invention. The infringement analysis will depend on whether the technology used in the accused products, once identified, falls within the patent's definition of such a "system." Practitioners may focus on this term because the patent explicitly lists both a primary example (GPS) and several alternatives, creating a potential dispute over the breadth of equivalents covered by the claim.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification explicitly states that the "GPS module 38" is just one example of a "location-determining system" and that the term also covers "other location-determining hardware, such as cell-tower triangulation, or accelerometers, speedometer, compass, and other dead-reckoning hardware and software, etc" ('402 Patent, col. 2:12-16). This language could support a broad construction encompassing a wide range of location-finding technologies.
  • Evidence for a Narrower Interpretation: The patent’s primary embodiment, abstract, and Figure 1 all prominently feature a "GPS unit" and "GPS Satellites" ('402 Patent, Abstract; Fig. 1). A party could argue that these repeated, specific disclosures anchor the meaning of "location-determining system" to GPS-like satellite-based technologies, and that dissimilar methods fall outside the scope of the invention as it was described and envisioned.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendant sells the accused products and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner (Compl. ¶14-15).

Willful Infringement

The complaint does not use the term "willful," but alleges that service of the complaint constitutes actual knowledge of infringement (Compl. ¶13). It further alleges that Defendant’s continued infringing activities despite this knowledge warrant a finding that the case is "exceptional" under 35 U.S.C. § 285, which is the statutory basis for enhanced damages and attorneys' fees often associated with willfulness (Compl. ¶14, ¶E.i.).

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

Given the limited detail in the complaint, the initial phase of this case will likely focus on procedural and foundational issues before turning to substantive technical disputes.

  • A preliminary question is one of pleading sufficiency: the complaint omits the identification of the accused products and asserted claims, instead referencing an unattached exhibit. The court may need to address whether the complaint, as filed, provides the defendant with adequate notice of the infringement claims against it.
  • Assuming the case proceeds, a core issue will be one of definitional scope: can the term "location-determining system", which the patent illustrates with examples like GPS and cell-tower triangulation, be construed to cover the specific technology that Defendant’s charging network uses to identify the location of a charging event?
  • A key evidentiary question will be one of technical operation: once the accused products are identified, what evidence will show that they perform the critical step of "associating" a specific measurement of "charge energy" with a "current location" in the integrated manner required by the claims of the '402 Patent?