DCT
2:19-cv-02339
Kanarek v. Blueshape USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ross Kanarek (New York) and Core SWX, LLC (New York)
- Defendant: Blueshape USA, Inc. (Florida), BLUESHAPE Professional Video Power Systems (Italy), and United Production Services, Inc., d/b/a BOLD DISTRIBUTION, INC. (Tennessee)
- Plaintiff’s Counsel: MOHEN COOPER LLC
- Case Identification: 2:19-cv-02339, E.D.N.Y., 04/22/2019
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of New York because Defendants conduct substantial business and sell the accused products to customers within the district.
- Core Dispute: Plaintiff alleges that Defendant’s professional battery systems infringe a patent related to the wireless, simultaneous monitoring of multiple batteries from a single remote device.
- Technical Context: The technology addresses power management for professional equipment, particularly in the audiovisual industry, where multiple battery-powered devices are often used concurrently on location.
- Key Procedural History: The complaint notes that Plaintiff sent Defendants a notice letter detailing the alleged infringement on February 6, 2019, one day after the patent-in-suit was issued, and that receipt of this letter was acknowledged by Defendants.
Case Timeline
| Date | Event |
|---|---|
| 2015-04-10 | '630 Patent Priority Date |
| 2019-02-05 | U.S. Patent No. 10,197,630 Issued |
| 2019-02-06 | Plaintiff sent infringement notice letter |
| 2019-04-22 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,197,630 - "Wireless Smart Battery System"
- Issued: February 5, 2019.
The Invention Explained
- Problem Addressed: The patent's background section describes the challenge in professional environments, like a film set, where multiple, distinct battery-powered devices operate simultaneously. Monitoring the power status of each battery individually is inefficient and risks unexpected equipment shutdowns that can disrupt work. (’630 Patent, col. 2:3-23).
- The Patented Solution: The invention is a system that intercepts data from one or more "smart" batteries and wirelessly transmits their status to a single remote user device, such as a tablet or smartphone. This allows a user to view the real-time status (e.g., charge level) of multiple batteries simultaneously on one screen. A preferred embodiment is a battery mount plate that sits between a device and its battery, incorporating the necessary processor and wireless communication hardware to perform this function. (’630 Patent, col. 2:36-43; Fig. 3B).
- Technical Importance: The technology centralizes battery monitoring for complex, multi-device workflows, aiming to improve operational efficiency and prevent unexpected power failures. (’630 Patent, col. 2:16-20).
Key Claims at a Glance
- The complaint identifies independent claims 1 and 5 as asserted claims (Compl. ¶28).
- Independent Claim 1 recites a "wireless battery monitoring system" comprising:
- a remote device having a display screen that shows simultaneously attributes and status of a plurality of batteries
- a battery power connector and a battery data connector
- a processor connected to the power and data connectors to receive and process battery data
- a wireless communication system to transmit signals to the remote device
- a device power connector and a device data connector
- a mounting surface (e.g., V-Mount, three-stud mount) to connect the battery to a battery-powered device
- Independent Claim 5 is similar to claim 1 but adds the limitation of "a plurality of battery-powered, audiovisual recording industry devices" being powered by the batteries.
- The complaint notes that dependent claims 2-4, 6, and 7 are also implicated (Compl. ¶28).
III. The Accused Instrumentality
Product Identification
- The "Granite Link, Granite Two, Granite Mini and/or other similar products" (Compl. ¶8).
Functionality and Market Context
- The complaint alleges the accused products constitute a system for wirelessly monitoring batteries. The "GRANITE TWO AND GRANITE MINI battery packs" are advertised as featuring "Wi-Fi connectivity that transmits battery data in real time" (Compl. ¶14). The "Granite Link" product is described as a "handy tool for battery control on the field" that works with the Granite batteries via a "must-have App, free of charge, to help manage the battery fleet" (Compl. ¶13). This system allegedly allows an operator to "monitor the state of batteries in close proximity" and enables "Multiple batteries can be monitored simultaneously from a single device" (Compl. ¶11). The complaint references a depiction on the defendant’s website allegedly showing the status of three batteries at the same time. This alleged screenshot from the defendant's website shows the state of charge, wireless connectivity, and other attributes for three batteries simultaneously (Compl. ¶31).
IV. Analysis of Infringement Allegations
’630 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a remote device having a display screen that shows simultaneously in the display screen attributes and status of a plurality of batteries, the remote device being configured to receive signals from a plurality of wireless communication systems that pertain to attributes or status of the plurality of batteries | The accused system includes a "must-have App" for a remote device (e.g., smartphone) that allows a user to "remotely monitor multiple batteries simultaneously from a single device." | ¶28, ¶31 | col. 6:56-65 |
| a battery power connector configured to make an electrical connection with a power terminal of a battery; a battery data connector configured to make a connection with a data terminal of the battery | The Granite Link product is sold to be used with Granite Two and Granite Mini batteries, which allegedly provides for the transmission of "battery data in real time" and creates a "wireless battery monitoring system," thereby implying the necessary data and power connections to the batteries. | ¶12, ¶14, ¶31 | col. 7:1-5 |
| a processor connected to said battery power connector to receive power from the battery, said processor also being connected to said battery data connector to receive and process data that pertains to attributes or status of the battery | The complaint alleges the accused products, when used together, provide a "wireless battery monitoring system" that monitors battery status, which implies the presence of a processor to receive and process the battery data as claimed. | ¶31 | col. 7:1-6 |
| a wireless communication system connected to said processor and configured to receive signals from said processor and to wirelessly transmit the received signals to the remote device | The accused Granite battery packs are advertised as featuring "Wi-Fi connectivity that transmits battery data in real time." | ¶14 | col. 7:7-10 |
| a device power connector ... a device data connector ... a mounting surface configured to mount the battery in a manner that connects said battery power connector to said device power connector and connects said battery data connector to said device data connector | The Granite Link product is described as a tool that "Works with GRANITE TWO and GRANITE MINI," suggesting it functions as an intermediary component between the battery and a device, consistent with the claimed mounting surface that facilitates the required connections. | ¶13, ¶31 | col. 7:11-29 |
Identified Points of Contention
- Structural Questions: A central question may be whether the accused system—which appears to consist of separate components (a hardware accessory, batteries, and a software application)—meets the structural limitations of a single, integrated "wireless battery monitoring system" as recited in the claims. The court may need to determine if the claim requires all hardware elements to be in a single housing, as depicted in the patent’s preferred embodiment.
- Technical Questions: The infringement theory appears to depend on the internal architecture of the "Granite Link" accessory. A key factual question will be whether this accessory contains a "processor" that is "connected to" the battery power and data terminals to "receive and process data," as required by the claim, or if it functions as a simpler data conduit, with the primary processing logic located in the remote smartphone application.
V. Key Claim Terms for Construction
The Term: "wireless battery monitoring system"
- Context and Importance: This term appears in the preamble and is referenced in the body of the independent claims. Its construction is critical because it will define the overall scope of the claimed apparatus. Practitioners may focus on this term because the accused infringement appears to be based on a combination of distinct products (hardware, batteries, software app), and the defense may argue this combination does not constitute the single "system" claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent abstract states the system may be "installed in the battery, in a battery-powered device, in a battery mount plate, [or] in an attachment," suggesting the invention is not strictly limited to a single form factor (’630 Patent, Abstract).
- Evidence for a Narrower Interpretation: The claims recite a specific list of interconnected physical components, including connectors and a "mounting surface," and the detailed description heavily features a single, integrated battery mount plate as the preferred embodiment. This may support an interpretation requiring a unitary hardware apparatus. (’630 Patent, col. 2:36-43; col. 7:11-29).
The Term: "a processor connected to said ... battery data connector to receive and process data"
- Context and Importance: The allegation of infringement hinges on the accused Granite Link device performing this function. The definition of "process" and the nature of the "connection" will be dispositive. If the processor in the accused device simply relays data without meaningful processing, or if the primary processing occurs on the remote device, it may raise questions of non-infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification does not narrowly define "process data," which could allow for an interpretation covering basic data formatting or handling before wireless transmission.
- Evidence for a Narrower Interpretation: The description states the "processor 60 processes information sent between the rechargeable battery 110 and the device 100 and transmits the result of said processing to the wireless communication system," which suggests more than merely relaying raw data (’630 Patent, col. 5:19-22). The figures depict the processor as a distinct component within the hardware housing, suggesting a direct, local connection (’630 Patent, Fig. 7A).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendants instruct customers on how to use the accused products in an infringing manner through promotional materials, user guides, and an integration video (Compl. ¶¶ 46-48). The complaint also alleges contributory infringement, asserting the products are especially adapted for infringing use and are not suitable for substantial non-infringing use (Compl. ¶¶ 54, 57).
- Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint alleges that Plaintiffs sent a notice letter to Defendants on February 6, 2019—the day after the patent issued—and that Defendants acknowledged receipt of this letter (Compl. ¶¶ 27, 32, 38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of structural scope: Does the combination of Defendants' separate products—the Granite Link accessory, Granite batteries, and a smartphone application—constitute the single, integrated "wireless battery monitoring system" with the specific physical components recited in Claim 1?
- A key evidentiary question will be one of technical operation: What is the precise function of the processor within the accused "Granite Link" hardware? The case may turn on evidence showing whether it performs the claimed "processing" of battery data itself, or if it merely acts as a pass-through for data that is ultimately processed by the remote user's device.