DCT
2:20-cv-10837
Battery Conservation Innovations LLC v. Itrack LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Battery Conservation Innovations, LLC (a Texas LLC with a Florida office address)
- Defendant: iTrack, LLC (a Michigan LLC)
- Plaintiff’s Counsel: Kizzia Johnson, PLLC; Maxwell Goss, PLLC
- Case Identification: 2:20-cv-10837, E.D. Mich., 03/31/2020
- Venue Allegations: Venue is alleged to be proper because the Defendant is a Michigan company deemed to be a resident of the district, and alternatively, because acts of infringement allegedly occur in the district where Defendant has a regular and established place of business.
- Core Dispute: Plaintiff alleges that Defendant’s TK102 Mini GPS Tracker infringes a patent related to technology for conserving battery power in electronic devices by entering a low-power state when no motion is detected.
- Technical Context: The technology at issue involves using motion sensors to automatically power down components of a portable electronic device to extend battery life, a common feature in modern battery-powered products.
- Key Procedural History: The patent-in-suit, U.S. Patent No. 9,239,158, is a continuation of a prior application that issued as U.S. Patent No. 8,610,372, a fact which may be relevant to interpreting claim scope based on the shared specification and prosecution history.
Case Timeline
| Date | Event |
|---|---|
| 2011-12-27 | Priority Date for U.S. Patent No. 9,239,158 |
| 2016-01-19 | U.S. Patent No. 9,239,158 Issued |
| 2020-03-31 | Complaint Filed |
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 addresses the problem of portable electronic devices, such as flashlights, being accidentally left on, which drains the battery and leads to waste when the device is needed again (’158 Patent, col. 1:25-39).
- The Patented Solution: The invention provides an electronic device with a motion sensor and a controller. The controller monitors for motion and, if the device remains stationary for a "predetermined period of time," it decouples the battery from a power-consuming component (e.g., an illumination source) to conserve energy (’158 Patent, Abstract; col. 4:16-22). The system can also provide a visual or audible warning to the user before it powers down, and the user can prevent the shutdown by moving the device (’158 Patent, col. 5:10-19).
- Technical Importance: The described solution automates power management in simple portable devices to extend battery life without requiring constant user intervention (’158 Patent, col. 2:37-45).
Key Claims at a Glance
- The complaint asserts independent Claim 15 (Compl. ¶14).
- The essential elements of 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 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; and
- A visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator.
- The complaint states that Plaintiff may assert other claims in the future (Compl. ¶14).
III. The Accused Instrumentality
Product Identification
- The TK102 Mini GPS Tracker and "any similar products" are the accused instrumentalities (Compl. ¶16).
Functionality and Market Context
- The accused product is a portable GPS tracking device powered by a replaceable battery housed within its body (Compl. ¶¶ 18-19). The complaint alleges the product includes a "sleep by shock/vibration" mode, described in its user manual, which is a battery-conserving feature (Compl. ¶17). According to the manual, when this mode is activated and "no movement or vibration is detected for 5 minutes," the device enters a sleep mode where the "GPS module will shut down and the LED will turn off" to increase battery life (Compl. ¶¶ 17, 20-21, and screenshot at p. 8). The complaint provides an image from the product's user manual showing the exterior LED status light (Compl. p. 8).
IV. Analysis of Infringement Allegations
'158 Patent Infringement Allegations
| Claim Element (from Independent Claim 15) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a body including an opening for accessing an interior of the body; | The product has a housing that can be opened by a user to access the interior where the battery is housed. | ¶18 | col. 3:52-56 |
| at least one battery disposed in the body and configured for powering the device; | The product contains at least one replaceable battery inside its body to power the device. | ¶19 | col. 3:59-62 |
| 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 processor and motion sensors that detect motion. If no motion is detected for a predetermined time (5 minutes), the processor enters a sleep mode, shutting down the GPS module to conserve battery power. | ¶20 | col. 2:54-58 |
| and a visual indicator disposed on an exterior surface of the body, wherein the controller activates the visual indicator. | The product has an "LED status indicator" on its exterior. The complaint alleges this indicator may function differently in different situations, implying controller activation. A screenshot shows the LED turns off when sleep mode is entered. | ¶21 | col. 4:46-49 |
- Identified Points of Contention:
- Scope Questions: A threshold question may be whether shutting down a single major component (the GPS module) while another component (the GSM module) remains active constitutes "decoupl[ing] the at least one battery from the electronic device" as required by the claim (Compl. p. 8).
- Technical Questions: A central dispute may arise over the "activates the visual indicator" limitation. The complaint points to an LED that turns off when the device enters sleep mode (Compl. p. 8). This raises the question of whether turning an indicator off can satisfy a claim limitation that requires the controller to activate it, especially when the patent specification describes activation as an "alert to the user" prior to shutdown (’158 Patent, col. 4:52-56).
V. Key Claim Terms for Construction
The Term: "decouples the at least one battery from the electronic device"
Context and Importance: This term's construction is critical to infringement. The accused product allegedly shuts down its GPS module but keeps its GSM module active (Compl. p. 8). The court's interpretation will determine whether powering down only a portion of the device's circuitry meets this limitation.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue the claim's purpose is to "conserve energy," and thus any controller action that substantially reduces power consumption by cutting power to a main component should be considered "decoupling." The patent's abstract states the controller decouples the battery "from the illumination source," suggesting decoupling from a key component, not necessarily the entire device.
- Evidence for a Narrower Interpretation: A party could argue that the plain meaning of "decouples... from the electronic device" implies a full disconnection of power from the device as a whole. Figure 2 shows a "switch 222" that appears to disconnect the "battery 220" from the primary load (
illumination source 108), which in the context of a simple flashlight represents the entire functional device.
The Term: "activates the visual indicator"
Context and Importance: Practitioners may focus on this term because the accused product's LED turns off to signify sleep mode, whereas the claim requires the controller to activate the indicator. The outcome of this construction could be dispositive for this claim element.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any controller-initiated change of state (from on to off, or on to blinking) constitutes an "activation" in the sense of making the indicator perform its function of signaling a status change.
- Evidence for a Narrower Interpretation: A party is likely to argue that the plain meaning of "activates" is to turn on or make active. The specification supports this by describing the visual indicator as an "alert to the user" that the device will shut down, implying an affirmative warning signal, such as flashing the light, rather than simply turning it off as part of the shutdown itself (’158 Patent, col. 4:52-56; col. 5:21-25).
VI. Other Allegations
- Willful Infringement: The complaint alleges that the Defendant has had knowledge of its infringement "at least as of the service of the present complaint" (Compl. ¶13). This allegation appears to form the basis for a claim of post-filing willful infringement only, as no facts supporting pre-suit knowledge are pleaded.
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this case may depend on the court's findings on two key questions of claim interpretation and factual comparison:
- A core issue will be one of definitional scope: can the claim term "decouples the at least one battery from the electronic device" be construed to read on a device that powers down one major component (a GPS module) while another (a GSM module) remains powered and operational?
- A key evidentiary question will be one of functional meaning: does the accused product's action of turning an LED status light off as part of entering a low-power state satisfy the claim requirement that the controller "activates the visual indicator," particularly when the patent describes this function as an affirmative "alert" to the user?