Chengdu Shiqiaoshang Technology Co Ltd v. Ross Kanarek

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Chengdu ShiQiaoShang Technology Co., Ltd., and Shenzhen Yulonglong Technology Co., Ltd. (People's Republic of China)
  • Defendant: Ross Kanarek (New York)
  • Plaintiff’s Counsel: Glacier Law LLP
• Case Identification: 1:25-cv-02471, E.D.N.Y., 05/04/2025
• Venue Allegations: Venue is asserted based on the Defendant's residence within the Eastern District of New York.
• Core Dispute: Plaintiffs seek a declaratory judgment that their V Mount batteries do not infringe Defendant’s patent on wireless battery monitoring systems and that the patent is invalid, filed in response to infringement reports made by Defendant to Amazon.com.
• Technical Context: The technology concerns systems for remotely and wirelessly monitoring the status of multiple batteries, particularly those used in professional audiovisual equipment like cameras and lights.
• Key Procedural History: The action was precipitated by infringement notifications sent from Amazon.com to the Plaintiffs, based on a report filed by the Defendant. The complaint alleges that the patentee narrowed the patent’s claims during prosecution by adding a limitation requiring the simultaneous display of a "plurality of batteries" to overcome prior art, which may give rise to prosecution history estoppel.

Case Timeline

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

U.S. Patent No. 10,197,630 - "Wireless Smart Battery System"

• Patent Identification: U.S. Patent No. 10,197,630, "Wireless Smart Battery System," issued February 5, 2019.

The Invention Explained

• Problem Addressed: In professional environments like a film set, technicians manage numerous battery-powered devices. The patent identifies a problem where existing smart battery systems require a direct wired connection for monitoring and lack a centralized interface to view the status of multiple batteries at once, creating a risk of unexpected power loss and work disruption (’630 Patent, col. 2:2-19).
• The Patented Solution: The invention proposes a system, typically embodied in a battery mount plate, that sits between a smart battery and the device it powers. This intermediary system includes a processor and a wireless transmitter. It reads status data from the battery's data terminals and wirelessly transmits it to a remote device, such as a tablet or smartphone, allowing a user to see the status of multiple batteries simultaneously on a single screen (’630 Patent, Abstract; col. 2:27-43). The system architecture is illustrated in the patent’s figures, showing multiple battery systems reporting to a single remote display (e.g., ’630 Patent, Fig. 3B, Fig. 4).
• Technical Importance: This system architecture centralizes battery status information, decoupling monitoring from any single powered device and enabling a single user to remotely manage the power needs of an entire set of equipment (’630 Patent, col. 2:38-43).

Key Claims at a Glance

• The complaint asserts non-infringement of independent claims 1 and 5.
• Independent Claim 1 recites a wireless battery monitoring system comprising, among other elements:
  • A remote device with a display screen that "shows simultaneously... attributes and status of a plurality of batteries."
  • A battery power connector and a battery data connector for connecting to a battery.
  • A processor to receive and process battery data.
  • A wireless communication system to transmit signals to the remote device.
  • Device power and data connectors to connect to a battery-powered device.
  • A specific type of "mounting surface" (e.g., V-Mount).
• Independent Claim 5 recites a similar system but is framed to include "a plurality of battery-powered, audiovisual recording industry devices" being powered by the batteries.
• The complaint states that dependent claims 2-4 and 6-7 are also not infringed (Compl. ¶35).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are Plaintiffs' "V Mount Batteries," specifically Model PS099S and Model PS099EP, and the associated NEEWER App for the PS099S model (Compl. ¶24, ¶28, ¶36).

Functionality and Market Context

• The PS099S Product is described as a standalone V-mount battery containing an internal processor and an integrated Bluetooth module (Compl. ¶24). This allows the battery to communicate its own status directly to the NEEWER App on a user's mobile device. The complaint alleges it lacks separate data communication pins on its V-mount interface for communicating with an external mount plate (Compl. ¶24, ¶26).
• The PS099EP Product is described as lacking any wireless communication capability and only displaying its status on a built-in screen on the battery's body (Compl. ¶37).
• The complaint alleges these products are popular on Amazon, which constitutes Plaintiffs' primary sales channel in the United States (Compl. ¶12, ¶17). An image in the complaint shows the various power output ports on the accused battery. (Compl. p. 6).

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement. The core allegations are summarized below.

’630 Patent Infringement Allegations

• Identified Points of Contention:
  • System vs. Component: A central dispute is whether the sale of Plaintiffs' standalone battery, which contains its own internal wireless system, can infringe claims directed to a multi-component system where those functions reside in a separate mount plate. The complaint argues it does not sell the claimed "system" (Compl. ¶25).
  • Scope of "Simultaneously... a plurality of batteries": The complaint alleges the accused app displays only one battery's status at a time (Compl. ¶28). This raises a question of claim scope, which the complaint argues is narrowed by prosecution history, where this limitation was allegedly added to overcome prior art, thereby disclaiming coverage of single-battery display systems (Compl. ¶29-31).
  • Technical Mismatch in Data Path: The patent claims a specific data flow: from battery data terminals, through a processor in a mount plate, and then wirelessly to a remote device. The complaint alleges the accused product uses a fundamentally different architecture: an integrated processor and Bluetooth module within the battery housing communicates directly with a remote app, bypassing the claimed intermediary data path entirely (Compl. ¶27).

V. Key Claim Terms for Construction

• The Term: "a processor... to receive and process data"

  • Context and Importance: The complaint argues this is a functional limitation subject to 35 U.S.C. § 112(f) and that the patent fails to disclose the corresponding algorithm or specific structure for performing the "process data" function, rendering the claim indefinite (Compl. ¶51). Practitioners may focus on this term because a finding of indefiniteness would invalidate the asserted claims.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (Non-Means-Plus-Function): A party could argue that "processor" has a generally understood structural meaning to one of skill in the art and that the patent’s diagrams, which show "processor 60" connected to other components, provide sufficient structure to avoid § 112(f) treatment (’630 Patent, col. 4:34-38; Fig. 7A).
    • Evidence for a Narrower Interpretation (Means-Plus-Function/Indefinite): The complaint contends "processor" is used as a generic placeholder for the function it performs ("process data") and that the specification does not disclose an algorithm for how this processing is accomplished, which is required when a general-purpose processor is claimed functionally (Compl. ¶51).

• The Term: "other audiovisual recording industry standard mounting surface"

  • Context and Importance: This term appears in a Markush group defining the system's mounting surface. The complaint alleges the term is indefinite because "other... standard" lacks objective boundaries and the specification provides no guidance on what qualifies (Compl. ¶53). The construction will determine if this limitation is definite enough to be valid.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation (Definite): The patentee may argue that a person of ordinary skill in the art of audiovisual equipment would understand what constitutes an "industry standard mounting surface" beyond the specifically enumerated V-Mount and three-stud mount, and that the term reasonably confines the claim's scope.
    • Evidence for a Narrower Interpretation (Indefinite): The complaint points out that the patent specification provides no definition or criteria for this "other" category, making the scope of the claim unascertainable to the public. The patent itself only provides two specific examples (’630 Patent, col. 7:29-31).

VI. Other Allegations

• Indirect Infringement: The complaint for declaratory judgment asserts that Plaintiffs do not indirectly infringe. The argument is that the accused products are staple articles of commerce with substantial non-infringing uses (e.g., direct power supply) and that Plaintiffs do not provide or instruct users to assemble the complete claimed system (Compl. ¶25).
• Willful Infringement: This issue is not raised directly as to patent infringement. However, the complaint includes a separate count for tortious interference with business relationships, alleging that Defendant's infringement reports to Amazon were "baseless" and made with intent to harm (Compl. ¶56-57).

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

• A core issue will be one of infringement and claim scope: Does the accused system, which integrates wireless communication within a standalone battery and allegedly displays only one battery's status at a time, fall within the scope of claims directed to a multi-component system that "simultaneously" displays a "plurality of batteries"? The effect of the alleged prosecution history disclaimer will be central to this question.
• A key validity question will be one of indefiniteness under § 112: Will the term "processor," claimed by its function to "process data," be deemed a means-plus-function limitation lacking the required disclosure of a corresponding algorithm, or will the "other... standard mounting surface" language be found fatally vague, rendering the asserted claims invalid?
• A third question concerns the system vs. component distinction: Can the sale of a single component (a "smart" battery) be found to infringe a claim for an entire multi-component system, or does this configuration fall outside the claim's literal scope and lack the elements required for a finding of indirect infringement?