NOCO Co Inc v. Shenzhen Anband Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: The NOCO Company, Inc. (Ohio)
  • Defendant: Shenzhen Anband Technology Co., Ltd. (China)
  • Plaintiff’s Counsel: Vorys, Sater, Seymour and Pease LLP
• Case Identification: 1:17-cv-02205, N.D. Ohio, 10/19/2017
• Venue Allegations: Venue is alleged to be proper on the basis that the defendant is an alien business entity that imports, offers to sell, and sells its products in the United States.
• Core Dispute: Plaintiff alleges that Defendant’s Aickar-brand compact lithium jump starters infringe a patent related to safety features for portable vehicle battery chargers.
• Technical Context: The technology concerns portable, lithium-ion-based vehicle jump starters that incorporate electronic safety systems to prevent sparking or damage from improper connections, such as reverse polarity.
• Key Procedural History: The complaint asserts infringement of U.S. Patent No. 9,007,015. A subsequent Inter Partes Review (IPR) proceeding, IPR2020-00944, filed after the complaint, concluded with an IPR Certificate issued on June 11, 2024. This proceeding resulted in the cancellation of claims 1-10 and 12-23 of the patent, including the primary claim asserted in this litigation, Claim 1. This development raises a significant question regarding the viability of the infringement action as originally pleaded.

Case Timeline

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

U.S. Patent No. 9,007,015 - “Portable Vehicle Battery Jump Start Apparatus With Safety Protection,” issued April 14, 2015

The Invention Explained

• Problem Addressed: The patent’s background section describes the dangers associated with traditional vehicle jump-starting, where connecting jumper cables incorrectly can cause sparks, short circuits, and damage to batteries or persons, particularly in cases of "reverse polarity" connections (’015 Patent, col. 1:16-23).
• The Patented Solution: The invention is a handheld, portable jump starter containing its own power source (a lithium-ion battery). It employs a microcontroller-based system that uses dedicated sensors to confirm two conditions before allowing power to flow: first, that the device is actually connected to a vehicle battery (an "isolation" function), and second, that it is connected with the correct polarity. Only when both conditions are verified does a power switch, such as a field-effect transistor (FET), close the circuit to deliver jump-starting current (’015 Patent, Abstract; col. 3:35-49). This logic is depicted in the functional block diagram of Figure 1.
• Technical Importance: This technology sought to provide a safer and more foolproof method for consumers to jump-start a vehicle without needing a second car or risking the hazards of conventional jumper cables (Compl. ¶¶ 9-10).

Key Claims at a Glance

• The complaint asserts infringement of at least independent Claim 1 (Compl. ¶¶ 17, 19).
• The essential elements of independent Claim 1 are:
  • An internal power supply.
  • An output port with positive and negative outputs.
  • A "vehicle battery isolation sensor" to detect the presence of a connected vehicle battery.
  • A "reverse polarity sensor" to detect the correct polarity of the connection.
  • A "power switch" connecting the internal supply to the output port.
  • A "microcontroller" programmed to receive signals from both sensors and only turn on the power switch when the signals indicate both the presence of a battery and a proper polarity connection.

III. The Accused Instrumentality

Product Identification

• The "Infringing Models" are identified as the "500A Peak 13600mAh Portable Car Battery Jump Starter" and the "800A Peak 19800mAh Car Jump Starter," sold under the brand name Aickar (Compl. ¶18).

Functionality and Market Context

• The complaint alleges these are compact lithium jump starters that incorporate the safety features claimed by the ’015 Patent (Compl. ¶18). The accused functionality includes a lithium battery pack, an output connector, an "optocoupler sensor" to sense a battery's presence, another sensor to detect reverse polarity (indicated by a red LED), a transistor acting as a power switch, and a microcontroller that controls the device based on signals from these sensors (Compl. ¶19). A photograph included in the complaint depicts Plaintiff's own "Genius Boost" product connected to a car battery to illustrate the technology at issue (Compl. ¶11, p. 3).

IV. Analysis of Infringement Allegations

’015 Patent Infringement Allegations

Identified Points of Contention

• Scope Questions: A central question for the court would be whether the accused product's "optocoupler sensor" and generic "sensor" meet the functional and structural definitions of the claimed "vehicle battery isolation sensor" and "reverse polarity sensor" as understood in light of the patent's specification.
• Technical Questions: The complaint alleges in a conclusory manner that the accused microcontroller performs the specific, multi-condition logic required by the final limitation of Claim 1. A key factual dispute would concern the precise operational logic of the accused device's microcontroller and whether it matches the logic recited in the claim.

V. Key Claim Terms for Construction

• The Term: "vehicle battery isolation sensor"

  • Context and Importance: This term defines a key component of the patented safety system. The infringement analysis hinges on whether the accused "optocoupler sensor" (Compl. ¶19) falls within the scope of this term. Practitioners may focus on this term because its construction will determine whether a specific type of electronic component meets the claim limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is primarily functional, defining the sensor by what it does: "configured to detect presence of a vehicle battery" (’015 Patent, col. 8:12-13). This could support an interpretation that covers any component capable of performing this detection function, regardless of its specific internal mechanism.
    • Evidence for a Narrower Interpretation: The specification describes a specific embodiment using an "optically coupled isolator phototransistor" and provides a detailed circuit diagram (’015 Patent, col. 5:27-38; Fig. 2A-4). A party could argue this detailed disclosure limits the scope of the term to optical isolators or structurally similar components.

• The Term: "microcontroller"

  • Context and Importance: The claim's longest limitation recites a specific set of logical operations that the "microcontroller" must be "configured to" perform. The infringement determination depends on whether the accused device's processor performs this exact logic.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to the controller as a "programmable microcontroller unit (MCU)" and identifies a commercially available example, suggesting the term is not limited to a custom or unique processor but encompasses general-purpose programmable devices (’015 Patent, col. 4:11-20).
    • Evidence for a Narrower Interpretation: The detailed functional requirements recited in the claim itself—receiving signals from two different sensors and enabling the power switch only when a specific combination of conditions is met—could be interpreted as defining the "microcontroller" not just as a piece of hardware, but as a hardware-plus-software system that must perform that exact logical sequence. Any deviation in the accused device's control logic could be argued to fall outside the claim.

VI. Other Allegations

• Indirect Infringement: The complaint does not include specific counts or factual allegations to support claims of induced or contributory infringement.
• Willful Infringement: The complaint does not allege that Defendant had pre-suit knowledge of the ’015 Patent, nor does it make a specific claim for willful infringement.

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

• A dispositive threshold issue is one of mootness: given that the asserted Claim 1 of the ’015 Patent was cancelled in a subsequent Inter Partes Review, the primary question is whether any viable cause of action remains from the original complaint, which is now directed to an invalid patent claim.
• Setting aside the subsequent invalidation, a central technical question would have been one of evidentiary sufficiency: does the accused Aickar product’s combination of an "optocoupler" and a "transistor" constitute the claimed "vehicle battery isolation sensor" and "power switch," and does its control software execute the precise, multi-step logical function required by the "microcontroller" limitation of Claim 1? The complaint’s allegations would require substantial technical evidence to prove a direct correspondence in operation.