DCT
2:25-cv-02471
Chengdu Shiqiaoshang Technology Co Ltd v. Kanarek
Key Events
Complaint
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: 2:25-cv-02471, E.D.N.Y., 05/04/2025
- Venue Allegations: Venue is alleged to be proper in the Eastern District of New York because the defendant, an individual, resides in the district.
- Core Dispute: Plaintiffs seek a declaratory judgment that their V Mount Batteries do not infringe Defendant's U.S. Patent No. 10,197,630, and that the patent is invalid, following Defendant’s patent infringement reports against Plaintiffs' products on Amazon.com.
- Technical Context: The dispute centers on wireless monitoring systems for professional batteries, such as those used in the audiovisual recording industry, which allow users to remotely track the status of multiple power sources.
- Key Procedural History: The complaint alleges that the patentee narrowed the scope of the asserted claims during prosecution to overcome prior art by adding language requiring the simultaneous display of a plurality of batteries, which may give rise to a prosecution history estoppel defense.
Case Timeline
| Date | Event |
|---|---|
| 2015-04-10 | U.S. Patent No. 10,197,630 Priority Date |
| 2019-02-05 | U.S. Patent No. 10,197,630 Issued |
| 2025-04-30 | Plaintiffs receive infringement notifications from Amazon |
| 2025-05-04 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 10,197,630 - “Wireless Smart Battery System”
The Invention Explained
- Problem Addressed: In professional settings like film production, multiple devices (lights, cameras, monitors) are powered by separate rechargeable batteries. The patent’s background section notes that users lack an efficient way to monitor the status of all these batteries at once from a central location, creating a risk that a device will unexpectedly lose power and disrupt work (’630 Patent, col. 2:3-23). Existing "smart battery" systems require a direct wired connection to the device they power and do not aggregate data from multiple batteries for remote review (’630 Patent, col. 2:8-17).
- The Patented Solution: The invention describes a system, typically embodied in a battery mount plate, that sits between a smart battery and the powered device (’630 Patent, col. 2:43-48). This intermediary plate draws data from the battery’s communication terminals, processes it, and uses a wireless transmitter (e.g., Bluetooth or WiFi) to send the battery’s status to a remote user device, such as a tablet or smartphone (’630 Patent, col. 4:26-38). This allows a user to view the status of a "plurality of batteries" simultaneously on a single display screen, as illustrated in Figure 3B, providing a centralized dashboard for power management on a busy set (’630 Patent, col. 4:56-64).
- Technical Importance: The described solution sought to untether battery status monitoring from the individual powered device, enabling centralized, remote oversight for multi-device, multi-battery workflows common in professional audiovisual environments (’630 Patent, col. 2:38-42).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claims 1 and 5 (Compl. ¶23).
- Independent Claim 1 recites a wireless battery monitoring system comprising:
- A remote device with a display screen that shows simultaneously the status of a plurality of batteries, configured to receive signals from a plurality of wireless communication systems
- A battery power connector
- A battery data connector for connecting with a data terminal of a battery
- A processor connected to the battery data connector to receive and process battery status data
- A wireless communication system to transmit signals from the processor to the remote device
- A device power connector and a device data connector for connecting to a battery-powered device
- A mounting surface (e.g., V-Mount or three-stud mount)
- Independent Claim 5 recites a similar system with largely overlapping elements (Compl. ¶33).
- The complaint notes that dependent claims 2-4 and 6-7 are also not infringed because their respective independent claims are not infringed (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
Plaintiffs’ V Mount Batteries, specifically Model PS099S and Model PS099EP (Compl. ¶24, ¶36).
Functionality and Market Context
- The accused PS099S Product is a standalone V-mount rechargeable lithium-ion battery for powering photographic and videographic equipment (Compl. ¶24). It contains an internal processor and an integrated Bluetooth module that allows it to communicate its own status directly to a user’s mobile device running the NEEWER App (Compl. ¶24). The complaint alleges the battery features standard power terminals on its V-mount interface but lacks any separate data communication pins on that same interface (Compl. ¶24, ¶26).
- The complaint alleges the associated NEEWER App is designed to monitor the real-time status of only a single connected battery at a time (Compl. ¶24, ¶28). A screenshot in the complaint shows the app's user interface displaying detailed metrics for one battery, "PS099S" (Compl. p. 8).
- The PS099EP Product is described as substantially identical but lacking any wireless communication capability whatsoever, instead displaying its status only on a screen on the battery's main body (Compl. ¶36, ¶37).
IV. Analysis of Infringement Allegations
The complaint seeks a declaratory judgment of non-infringement. The following table summarizes the Plaintiffs' position on why their accused PS099S Product and associated app do not meet the limitations of claim 1.
U.S. Patent No. 10,197,630 Infringement Allegations
| Claim Element (from Independent Claim 1) | Accused Functionality and Plaintiff's Non-Infringement Position | 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 NEEWER App used with the PS099S battery is alleged to display status for only one battery at a time and receives signals from only that single battery’s internal Bluetooth module. A provided screenshot shows an interface for a single battery (Compl. p. 8). | ¶28 | col. 6:1-5 |
| a battery data connector configured to make a connection with a data terminal of the battery; | The PS099S battery is alleged to lack a physical "data terminal" on its V-mount interface for data communication. The complaint includes a product image and asserts that its V-mount contacts are solely for power transmission and mechanical fixation (Compl. p. 6). | ¶26 | col. 6:67-col. 7:1 |
| a processor connected to said battery data connector to receive and process data... | The accused battery's internal processor communicates directly with its internal Bluetooth module. The complaint argues this architecture obviates and lacks the claimed intermediary data path of battery terminal -> plate connector -> plate processor -> wireless system. | ¶27 | col. 7:2-6 |
| a device data connector connected to said battery data connector... to transmit the data that pertains to the battery to the battery powered device... | Because the PS099S battery allegedly lacks the claimed "data terminal" and "battery data connector," it cannot perform the claimed function of transmitting data through a "device data connector" to the powered device. | ¶27 | col. 7:19-24 |
| a mounting surface configured to mount the battery in a manner that... connects said battery data connector to said device data connector... | The PS099S product is a standalone battery, not a system including the claimed mounting surface (part of an intermediary plate). Plaintiffs argue they do not make, use, or sell the claimed system configuration, which requires the battery, mount plate, and remote device. | ¶25 | col. 7:25-30 |
Identified Points of Contention
- System vs. Component: A primary issue is whether Plaintiffs can be liable for infringing a system claim when they allegedly sell only a single component (a battery), not the complete claimed system which includes a specific mount plate and a remote device (Compl. ¶25).
- Scope Questions: The dispute raises the question of whether the accused product's architecture falls within the claim scope. The complaint argues for a mismatch, contrasting the patent's intermediary mount-plate-based data relay system with the accused product's direct-to-app wireless communication from within the battery itself (Compl. ¶27).
- Technical Questions: A key factual question will be whether the accused battery's V-mount interface includes any terminals that perform the function of the claimed "data terminal," as the complaint alleges it only has power and fixation contacts (Compl. ¶26). Further, the court will need to determine whether the NEEWER app is capable of "simultaneously" displaying a "plurality of batteries," a feature the complaint alleges is absent and was critical to the patent's allowance (Compl. ¶28-¶31).
V. Key Claim Terms for Construction
"shows simultaneously... attributes and status of a plurality of batteries"
- Context and Importance: This limitation appears central to the non-infringement argument. The complaint alleges the accused system displays only one battery at a time and argues that this "simultaneous plurality" feature was added during prosecution to overcome prior art, creating a prosecution history estoppel that bars any broader interpretation (Compl. ¶28, ¶29). The definition of "simultaneously" and "plurality" will be critical.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The defense may argue that "simultaneously" does not require a single, static screen, but could cover an app that allows a user to quickly toggle between multiple connected batteries, thereby monitoring them in a single session.
- Evidence for a Narrower Interpretation: The specification explicitly describes and depicts a display showing multiple batteries' statuses on the screen at the same time (e.g., "the display is a simultaneous depiction indicative of the status and attributes of each battery...") (’630 Patent, col. 4:58-64). Figure 3B, which shows a grid view of four battery statuses, strongly supports an interpretation requiring a concurrent, multi-battery dashboard view.
"data terminal of the battery"
- Context and Importance: Plaintiffs' non-infringement case relies heavily on the assertion that their battery lacks this physical element on its V-mount interface, preventing the wired data connection to the claimed "battery data connector" on the mount plate (Compl. ¶26). The existence and definition of this physical terminal are therefore dispositive.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patentee may argue that "data terminal" should be construed broadly to cover any physical point from which battery data can be drawn, even if it is not a standard SMBus pin, so long as it is on the battery and allows for connection.
- Evidence for a Narrower Interpretation: The patent repeatedly references industry standards, stating the "battery communication terminal 40 is an SMBus-compliant DATA connector and CLOCK connector" (’630 Patent, col. 4:21-23). This may support an argument that the term should be limited to the specific, standardized data pins found on smart batteries, which the complaint alleges the accused product lacks on its V-mount interface.
VI. Other Allegations
Tortious Interference with Business Relationships
The complaint includes a count for tortious interference, alleging that Defendant's "baseless infringement claim to Amazon" has harmed Plaintiffs' selling relationship with Amazon by causing the imminent removal of product listings and risking permanent closure of their seller accounts (Compl. ¶56).
Invalidity
Plaintiffs allege claims 1-7 of the ’630 patent are invalid for anticipation or obviousness over five named prior art references (Compl. ¶44-48), indefiniteness under § 112 for functional claiming of the "processor" and for the open-ended Markush group for "mounting surface" (Compl. ¶51, ¶53), and lack of enablement for the full scope of "wireless communication system" (Compl. ¶52).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and prosecution history: Did the patentee, by adding the "simultaneously... plurality of batteries" limitation to overcome prior art, unmistakably surrender any claim to systems that display battery statuses one at a time, as is alleged for the accused product?
- A second key issue is one of physical and architectural mismatch: Does the accused system, which relies on direct wireless communication from an integrated module inside a battery, practice the claimed invention, which describes a distinct intermediary mount plate that intercepts data from a battery's "data terminal" and relays it wirelessly? This will turn on both claim construction and a factual analysis of the accused product's hardware.
- A final question relates to liability for system claims: Can a seller of a single component (a battery with an associated app) be held liable for infringing claims to a multi-part system that also requires an intermediary mount plate which the seller allegedly does not provide?