DCT
1:20-cv-01171
NOCO Co Inc v. Shenzhen Gooloo E Commerce Co
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: The NOCO Company, Inc. (Ohio)
- Defendant: Shenzhen GOOLOO E-Commerce Co., Ltd. (China)
- Plaintiff’s Counsel: Vorys, Sater, Seymour and Pease LLP
- Case Identification: 1:20-cv-01171, N.D. Ohio, 05/28/2020
- Venue Allegations: Venue is based on allegations that the Defendant is an alien business entity that imports into, offers to sell, and sells the accused products throughout the United States, including through the Amazon Marketplace.
- Core Dispute: Plaintiff alleges that Defendant’s GOOLOO brand of portable battery jump starters infringes a patent related to safety features for such devices.
- Technical Context: The technology concerns compact, lithium-ion-powered vehicle jump starters that incorporate microcontroller-based safety circuits to prevent sparking or electrical damage from improper battery connections.
- Key Procedural History: An Inter Partes Review (IPR) of the patent-in-suit was initiated (IPR2020-00944) shortly before this complaint was filed. A subsequently issued IPR certificate indicates that claims 1-10 and 12-23 of the patent have been cancelled, including the sole independent claim asserted in this complaint. Only dependent claim 11 was found patentable.
Case Timeline
| Date | Event |
|---|---|
| 2014-07-03 | ’015 Patent Priority Date |
| 2014 | NOCO Genius Boost Launch Date |
| 2015-04-14 | ’015 Patent Issue Date |
| 2020-05-14 | IPR Filed for ’015 Patent |
| 2020-05-28 | Complaint Filing Date |
| 2024-06-11 | ’015 Patent IPR Certificate Issued |
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 dangers associated with traditional jumper cables, such as sparking and short circuits caused by connecting clamps to the wrong battery terminals (reverse polarity) or inadvertently touching the clamps together ('015 Patent, col. 1:16-24). Prior art attempts to solve these issues are characterized as suffering from "complexity, cost or potential for malfunction" ('015 Patent, col. 3:8-12).
- The Patented Solution: The invention is a handheld, lithium-ion-powered jump starter that uses a microcontroller and sensors to create a "smart" connection ('015 Patent, Abstract). The device first uses a "vehicle battery isolation sensor" to confirm it is connected to a vehicle battery and an "reverse polarity sensor" to confirm the connection is correct ('015 Patent, col. 4:20-31). Only when both conditions are met does the microcontroller activate a power switch to allow the internal battery to deliver power to the output terminals, thereby preventing energy flow in unsafe conditions ('015 Patent, col. 4:35-39; col. 5:46-54).
- Technical Importance: This control logic enabled the development of compact, portable jump starters that were safer for consumers, as they electronically prevent the most common and dangerous jump-starting errors ('015 Patent, col. 3:12-17).
Key Claims at a Glance
- The complaint asserts independent claim 1 ('015 Patent, col. 8:4-43; Compl. ¶21).
- The essential elements of independent claim 1 are:
- An internal power supply;
- An output port having positive and negative polarity outputs;
- A vehicle battery isolation sensor configured to detect the presence of a vehicle battery at the output port;
- A reverse polarity sensor configured to detect the polarity of the 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 vehicle battery and a proper polarity connection.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The complaint identifies the GOOLOO GP37-Plus and GP200 models of compact lithium jump starters (the "Infringing Models") (Compl. ¶20).
Functionality and Market Context
- The complaint alleges the Infringing Models are sold to U.S. consumers through the Amazon Marketplace under the "GOOLOO" and "Auto US" brand names (Compl. ¶¶4-5).
- The accused functionality involves a system of components alleged to mirror the patented invention: an internal lithium battery, an output port, a "vehicle battery isolation sensor" described as a "resistive voltage divider," a "reverse polarity sensor" described as an "optocoupler," a power switch, and a microcontroller (Compl. ¶¶22-27). This system allegedly prevents the device from turning on unless a vehicle battery is properly connected (Compl. ¶27). A photograph provided in the complaint shows the plaintiff's own jump starter product connected to a car battery, illustrating the general use case for this type of device (Compl. p. 4).
IV. Analysis of Infringement Allegations
9,007,015 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an internal power supply; | The Infringing Models each have a lithium battery pack that acts as an internal power supply. | ¶22 | col. 4:1-2 |
| an output port having positive and negative polarity outputs; | The Infringing Models each have an output port comprising the device's cable battery terminal connectors. | ¶23 | col. 7:33-34 |
| a vehicle battery isolation sensor... configured to detect presence of a vehicle battery... | The Infringing Models each have a vehicle battery isolation sensor, which includes a resistive voltage divider, that detects the presence of a vehicle battery. | ¶24 | col. 4:26-31 |
| a reverse polarity sensor... configured to detect polarity of a vehicle battery... | The Infringing Models each have a reverse polarity sensor, which includes an optocoupler, that detects whether a vehicle battery is connected with proper polarity. | ¶25 | col. 4:20-22 |
| a power switch connected between said internal power supply and said output port; | The Infringing Models each have a power switch located on a circuit board between the power supply and output port. | ¶26 | col. 4:35-39 |
| a microcontroller configured to receive input signals... and to provide an output signal to said power switch, such that said power switch is turned on... in response to signals from said sensors indicating the presence... and proper polarity... and is not turned on when signals from said sensors indicate either the absence... or improper polarity... | The Infringing Models each have a microcontroller that receives signals from the sensors and is not turned on if a battery is not connected or is connected with reverse polarity, but is turned on when a battery is connected with correct polarity. | ¶27 | col. 5:46-54 |
Identified Points of Contention
- Scope Questions: The complaint alleges that a "resistive voltage divider" meets the "vehicle battery isolation sensor" limitation (Compl. ¶24). The patent specification, however, describes this sensor as an "optically coupled isolator phototransistor" ('015 Patent, col. 5:29-30). This raises the question of whether the claim term, in light of the specification, can be construed broadly enough to read on the allegedly different structure of the accused device.
- Technical Questions: The complaint alleges that the accused microcontroller performs the specific logic recited in the claim (Compl. ¶27). A central evidentiary question will be whether the accused devices' hardware and software, in practice, implement this exact control logic—specifically, that the power switch is enabled only if both presence and correct polarity are detected, and remains disabled in all other specified conditions.
V. Key Claim Terms for Construction
The Term: "vehicle battery isolation sensor"
- Context and Importance: The definition of this term is critical because the complaint identifies a specific, common electronic component (a "resistive voltage divider") as the infringing structure (Compl. ¶24), while the patent's disclosed embodiment is an "optically coupled isolator" ('015 Patent, col. 5:29-30). Practitioners may focus on this term because the infringement analysis may depend on whether the claim is limited to the disclosed structure or can cover any circuit that performs the function of detecting a battery's presence.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim uses broad, functional language, stating the sensor is "configured to detect presence of a vehicle battery" ('015 Patent, col. 8:19-21), which may suggest the specific implementation is not limiting.
- Evidence for a Narrower Interpretation: The specification consistently describes the component as an "optically coupled isolator phototransistor" and depicts it as such in the schematic diagrams ('015 Patent, col. 5:29-30; Fig. 2A-4). This repeated and specific disclosure could be used to argue for a narrower construction limited to that type of sensor.
The Term: "microcontroller configured to... not turned on when signals from said sensors indicate either the absence of a vehicle battery at said output port or improper polarity connection"
- Context and Importance: This limitation defines the conditions under which the device must remain in a safe, "off" state. The infringement analysis will require a detailed examination of the accused device's logic. Practitioners may focus on this term because its scope will determine whether other conditions that keep the device off (e.g., over-temperature, low internal battery) would place the device outside the claim language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that the phrase "is not turned on when..." is illustrative, not exhaustive, and that any device meeting these specific negative conditions infringes, even if it has other "off" conditions. The patent's summary emphasizes the primary safety goal of preventing connection to a non-existent or reversed-polarity battery ('015 Patent, col. 3:17-34).
- Evidence for a Narrower Interpretation: A party could argue that the use of "either... or" creates a closed set of negative conditions. If the accused device's logic for remaining off is different or more complex, it might be argued to not meet this limitation as written.
VI. Other Allegations
The complaint alleges direct infringement under 35 U.S.C. § 271(a) (Compl. ¶30). No allegations of indirect infringement or willful infringement are made.
VII. Analyst’s Conclusion: Key Questions for the Case
- Impact of IPR: The primary question governing this case is the legal effect of the IPR decision that cancelled the sole independent claim asserted in the complaint. As the case cannot proceed on a cancelled claim, the viability of the lawsuit as pleaded is in substantial doubt.
- Definitional Scope: Assuming any valid claims remained, a core issue would be one of claim construction: can the term "vehicle battery isolation sensor", which is disclosed in the patent as an optical isolator, be interpreted to encompass the "resistive voltage divider" allegedly found in the accused devices?
- Functional Operation: A key evidentiary question would be one of technical equivalence: does the accused microcontroller's software and circuitry perform the precise, two-part logical gating function required by Claim 1, or is there a functional difference in its operational logic that would fall outside the claim's scope?