NOCO Co v. Shenzhen Lianfa Tong Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: The NOCO Company, Inc. (Ohio)
  • Defendant: Shenzhen Lianfa Tong Technology Co., Ltd.; Shenzhen Mediatek Tong Technology Co., Ltd.; Shenzhen Bi Te Yi Technology Co., Ltd. (all of China)
  • Plaintiff’s Counsel: Vorys, Sater, Seymour and Pease LLP
• Case Identification: The NOCO Company, Inc. v. Shenzhen Lianfa Tong Technology Co., Ltd., 1:19-cv-01855, N.D. Ohio, 04/02/2020
• Venue Allegations: Venue is alleged on the basis that Defendants are alien business entities that import, offer to sell, and sell the accused products within the United States, and are thus deemed residents of the judicial district for venue purposes.
• Core Dispute: Plaintiff alleges that Defendants’ portable lithium-ion vehicle jump starters infringe a patent related to safety features that prevent electrical connection under unsafe conditions, such as incorrect polarity.
• Technical Context: The technology concerns portable, battery-powered devices for jump-starting vehicles, a market where safety and ease of use are significant consumer considerations.
• Key Procedural History: A subsequent Inter Partes Review (IPR) proceeding, IPR2020-00944, was initiated at the Patent Trial and Appeal Board after this complaint was filed. The IPR resulted in the cancellation of claims 1-10 and 12-23 of the asserted patent. The sole claim asserted in this complaint, Claim 1, is among those that were cancelled. This development fundamentally impacts the viability of the infringement claim as 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 describes the risks associated with traditional vehicle jump-starting, including sparking and short circuits caused by accidentally touching clamps together or connecting them to the wrong battery terminals (reverse polarity) (’015 Patent, col. 1:16-23; Compl. ¶10).
• The Patented Solution: The invention is a handheld, lithium-ion battery-powered jump starter that incorporates safety logic. It uses distinct sensors to first detect the presence of a vehicle battery and second, to detect if the connection polarity is correct. A microcontroller processes these sensor inputs and only allows the internal battery to supply power to the output clamps if a battery is detected and the polarity is correct, thereby preventing power flow in an open-circuit or reverse-polarity state (’015 Patent, Abstract; col. 3:15-37). The functional relationship between the sensors, microcontroller, and power switch is illustrated in the block diagram of Figure 1 (’015 Patent, FIG. 1).
• Technical Importance: This approach aimed to make jump-starting safer and more user-friendly by automating the safety checks that were previously a source of human error, using a compact, portable form factor enabled by lithium-ion batteries (Compl. ¶¶12, 15).

Key Claims at a Glance

• The complaint asserts independent claim 1, which was subsequently cancelled in IPR proceedings (Compl. ¶19; ’015 Patent, IPR Certificate).
• The key elements of the now-cancelled Claim 1 included:
  • an internal power supply;
  • an output port having positive and negative polarity outputs;
  • a vehicle battery isolation sensor connected in circuit with the outputs, configured to detect the presence of a vehicle battery;
  • a reverse polarity sensor connected in circuit with the outputs, configured to detect the polarity of a connected vehicle battery;
  • a power switch connected between the internal power supply and the output port; and
  • a microcontroller configured to receive signals from both sensors and to turn on the power switch only when the signals indicate both the presence of a battery and a proper polarity connection.
• The complaint does not explicitly reserve the right to assert other claims.

III. The Accused Instrumentality

Product Identification

• The complaint names two groups of accused products: the "Infringing Beatit Models" (including models B7, B10, D11, and others) and the "Infringing Lemsir Models" (including models L6, V1, V3, and V8) (Compl. ¶¶20, 29). The complaint includes a photograph of its own Genius Boost® product connected to a car battery to illustrate the relevant product category (Compl. p. 4).

Functionality and Market Context

• The accused products are described as compact, lithium-ion jump starters sold through online marketplaces like Amazon.com (Compl. ¶¶21, 30).
• The complaint alleges these products perform the key safety functions of the patent, including using an internal lithium battery, providing power through positive and negative clamps, and incorporating sensor-driven logic to prevent activation when a battery is not connected or is connected with reverse polarity (Compl. ¶¶22, 31).

IV. Analysis of Infringement Allegations

The following table summarizes the infringement allegations for the now-cancelled Claim 1 of the ’015 Patent as pleaded in the complaint.

’015 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: The complaint alleges multiple alternative hardware implementations for the claimed "sensors" (e.g., a resistive divider or a pulsing circuit for the isolation sensor). This raises the question of whether the patent's claims, had they survived, would be broad enough to encompass these varied electronic designs, or if they would be construed more narrowly to cover only the specific opto-isolator embodiment detailed in the specification (’015 Patent, col. 5:13-39).
  • Technical Questions: The complaint asserts that the accused products' microcontrollers perform the claimed logic but provides no detail on their specific programming or configuration. A central dispute would likely involve reverse engineering or discovery to determine if the accused devices’ software/firmware in fact implements the specific two-part conditional logic required by the claim (i.e., checking for both presence and correct polarity before activation).

V. Key Claim Terms for Construction

"vehicle battery isolation sensor"

• Context and Importance: The definition of this term is critical because the complaint alleges infringement by two different types of circuits (a resistive divider and a pulsing circuit) (Compl. ¶25). Its construction would determine whether the claim is limited to a particular type of sensor or can cover any circuit that performs the function of detecting a battery's presence.
• Intrinsic Evidence for a Broader Interpretation: The claim language is functional, defining the sensor by what it does: "configured to detect presence of a vehicle battery" (’015 Patent, col. 8:6-9).
• Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific embodiment using an "optically coupled isolator phototransistor" (’015 Patent, col. 5:25-39). A party could argue this specific disclosure limits the scope of the more general claim term.

"microcontroller configured to... provide an output signal... in response to signals from said sensors indicating the presence of a vehicle battery at said output port and proper polarity connection"

• Context and Importance: This term defines the core logic of the invention. The infringement analysis hinges on whether the accused devices perform this exact two-condition logical AND operation before enabling the power switch.
• Intrinsic Evidence for a Broader Interpretation: The patent describes the microcontroller's role functionally, stating it "receives various inputs and produces informational as well as control outputs," suggesting any microcontroller programmed to achieve this outcome could infringe (’015 Patent, col. 4:11-13).
• Intrinsic Evidence for a Narrower Interpretation: The claim requires a specific causal link: the output signal to the switch must be "in response to" signals indicating both presence and proper polarity. An accused device that, for example, checks these conditions sequentially or uses a different logical pathway might be argued to fall outside this scope.

VI. Other Allegations

• Indirect Infringement: The complaint alleges direct infringement under 35 U.S.C. § 271(a) and does not plead separate counts for indirect or contributory infringement (Compl. ¶39).
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement or facts to support pre-suit knowledge of the patent.

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

• The foremost question is one of case viability: given that the sole asserted patent claim (Claim 1) was cancelled in an Inter Partes Review proceeding after the complaint was filed, what legal basis, if any, remains for the lawsuit as it is currently pleaded?
• A secondary, now-hypothetical, issue would have been one of definitional scope: can the functional terms "vehicle battery isolation sensor" and "reverse polarity sensor" be construed broadly enough to cover the multiple, distinct electronic circuits alleged in the complaint, or are they limited by the specific embodiments disclosed in the patent?
• Finally, a key evidentiary question would have been one of operational proof: what evidence exists to demonstrate that the accused microcontrollers are specifically "configured" to execute the precise two-part logical test required by the claim, as opposed to performing a similar but technically distinct safety function?