DCT
2:20-cv-00269
Garrity Power Services LLC v. Samsung Electronics Co Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Garrity Power Services LLC (Texas)
- Defendant: Samsung Electronics Co. Ltd. (Republic of Korea); Samsung Electronics America, Inc. (New York)
- Plaintiff’s Counsel: Spencer Fane LLP; Capshaw DeRieux, LLP
- Case Identification: 2:20-cv-00269, E.D. Tex., 08/17/2020
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendants are subject to personal jurisdiction and have committed acts of infringement in the district, including through corporate offices and sales of accused products via their e-commerce website.
- Core Dispute: Plaintiff alleges that Defendant’s mobile devices featuring "Wireless PowerShare" functionality infringe a patent related to bidirectional wireless charging technology.
- Technical Context: The technology at issue involves systems that enable a portable electronic device, such as a smartphone, to both receive power wirelessly and act as a wireless power source to charge other devices.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendant with a copy of the patent-in-suit on April 11, 2019, but that licensing discussions were unsuccessful. A subsequent ex parte reexamination of the patent-in-suit, which concluded after the complaint was filed, resulted in the cancellation of all claims asserted in the complaint (Claims 1 and 15).
Case Timeline
| Date | Event |
|---|---|
| 2015-06-30 | U.S. Patent No. 9,906,067 Priority Date |
| 2018-02-27 | U.S. Patent No. 9,906,067 Issued |
| 2019-03-XX | Samsung Galaxy S10 line launched |
| 2019-04-11 | Plaintiff alleges providing Defendant notice of the patent |
| 2019-04-24 | Defendant releases "Wireless PowerShare" advertisement |
| 2019-05-17 | Defendant releases "How to Use Wireless PowerShare" video |
| 2019-08-XX | Samsung Galaxy Note 10 line launched |
| 2019-08-12 | Licensing discussions between parties allegedly end |
| 2020-03-XX | Samsung Galaxy S20 line launched |
| 2020-08-17 | Complaint Filed |
| 2023-06-09 | Reexamination Certificate for '067 Patent issues, cancelling asserted claims |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,906,067 - Apparatus, System and Method to Wirelessly Charge/Discharge a Battery, issued Feb. 27, 2018
The Invention Explained
- Problem Addressed: The patent describes conventional wireless power systems as inefficient, slow, and typically limited to unidirectional power flow (i.e., only for charging a device). (’067 Patent, col. 1:39-48). It notes that discharging a device’s battery still required a physical, metallic connection, which could suffer from corrosion and wear. (’067 Patent, col. 3:5-8, col. 3:59-62).
- The Patented Solution: The invention proposes a wireless power system using two magnetically coupled coils to form a transformer, creating an "electrically isolating path." (’067 Patent, Abstract). This configuration is designed to allow a battery to be both charged and discharged wirelessly through the same interface, enabling efficient, bidirectional power transfer and eliminating the need for separate metallic contacts for discharging. (’067 Patent, col. 4:37-41, col. 4:48-55).
- Technical Importance: The described technology aims to provide a single, unified interface for both wireless charging and discharging, improving efficiency and enabling a portable device to function as both a power recipient and a power source for other devices. (’067 Patent, col. 4:48-55).
Key Claims at a Glance
- The complaint asserts independent claims 1 (an apparatus) and 15 (a system). (Compl. ¶48).
- Independent Claim 1 recites an apparatus comprising:
- a first magnetic core piecepart with a first metallic coil, configured to be coupled to, aligned with, and removable from a second magnetic core piecepart with a second metallic coil to form a transformer; and
- a battery metallically coupled to the first metallic coil, configured to be charged and discharged through the transformer's electrically isolating path.
- Independent Claim 15 recites a system comprising a wireless battery interface and a wireless battery that together include the elements of a removable transformer and a battery configured for bidirectional power transfer, tracking the core concepts of Claim 1.
III. The Accused Instrumentality
Product Identification
- The Accused Products are Samsung-branded mobile devices that support the “Wireless PowerShare” feature, including various models from the Galaxy S10, Note10, S20, Z Flip, and Fold product lines. (Compl. ¶31-33).
Functionality and Market Context
- The "Wireless PowerShare" feature enables the Accused Products to function as wireless charging pads for other Qi-compatible devices, such as headphones, smartwatches, or other smartphones. (Compl. ¶32, p. 9). The complaint highlights this as a key advertised feature of the devices. (Compl. ¶34). A screenshot from a Samsung advertisement shows one phone charging another under the "Wireless PowerShare" banner. (Compl. ¶34, p. 8).
IV. Analysis of Infringement Allegations
The complaint references an external claim chart exhibit that was not filed with the complaint; however, it provides a narrative summary of its infringement theory for at least Claim 1. (Compl. ¶49-50).
’067 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a first magnetic core piecepart having a first metallic coil ... configured to be coupled to, aligned with and removable from a second magnetic core piecepart having a second metallic coil ... to form a transformer | Each Accused Product includes a magnetic core piecepart and metallic coil (the wireless charging assembly) that is configured to couple with the coil of another device to form a transformer. | ¶50 | col. 5:20-28 |
| a battery metallically coupled to said first metallic coil and configured to be charged and discharged through an electrically isolating path of said transformer | The battery within each Accused Product is coupled to its wireless charging coil and is configured to both receive a charge and discharge power through that coil assembly. | ¶50 | col. 2:7-10 |
Identified Points of Contention
- Scope Questions: The complaint alleges infringement by a smartphone (containing the "first magnetic core piecepart") charging a separate device (containing the "second magnetic core piecepart"). This raises the question of whether the claim term "removable from", which in the patent's context could describe two parts of a single system (e.g., a power tool and its battery), can be construed to read on two distinct consumer products.
- Technical Questions: A factual dispute may arise over whether the internal circuitry of the Accused Products meets the "metallically coupled" limitation. The patent discloses a direct coupling to a power train switching circuit (’067 Patent, Fig. 2), and the court would need to determine if the potentially more complex power management system in a modern smartphone is equivalent.
V. Key Claim Terms for Construction
The Term: "metallically coupled"
- Context and Importance: The finding of infringement hinges on the definition of this term. The dispute will likely focus on whether the specific electrical path between the battery and the wireless power coil in the Accused Products qualifies as a "metallic" coupling under the patent's definition.
- Intrinsic Evidence for a Broader Interpretation: The specification defines "metallic" to include connections with "electrically conductive components such as semiconductor devices as well as current-conducting components such as resistors and inductors," not just a simple wire. (’067 Patent, col. 4:48-52).
- Intrinsic Evidence for a Narrower Interpretation: The patent's primary embodiment shows the battery (V401) connected directly to a full-bridge switching circuit that drives the coil. (’067 Patent, Fig. 2). A defendant may argue this implies a dedicated, direct power path that is distinct from the multi-functional power management integrated circuits in the Accused Products.
The Term: "removable from"
- Context and Importance: This term defines the physical relationship between the two halves of the wireless transformer. Its construction is critical to determining if the patent covers the use case of one standalone product (a phone) charging another standalone product (e.g., earbuds).
- Intrinsic Evidence for a Broader Interpretation: A plaintiff could argue the plain meaning supports this term covering any two components that are not permanently affixed and can be physically separated, as is the case when a user moves a phone away from the device it is charging.
- Intrinsic Evidence for a Narrower Interpretation: A defendant could point to language describing a "wireless battery 130" being "docked into the wireless battery interface 120" as suggesting the invention is directed at two complementary parts of a single system, not two independent products. (’067 Patent, col. 4:61-63).
VI. Other Allegations
Indirect Infringement
- The complaint alleges induced infringement, stating that Defendant provides instructions, advertisements, and marketing materials that encourage and teach end-users to use the Accused Products in an infringing manner. (Compl. ¶54). The complaint provides a screenshot of a "How to Use Wireless PowerShare" video from Samsung's official YouTube channel as an example of such instruction. (Compl. ¶55, p. 15).
Willful Infringement
- The claim for willfulness is based on alleged pre-suit knowledge. Plaintiff alleges it sent Defendant a copy of the ’067 Patent on April 11, 2019, putting Defendant on actual notice. (Compl. ¶36, ¶40). The complaint further alleges that Defendant continued to develop, advertise, and sell new products with the accused feature after receiving notice. (Compl. ¶41-42).
VII. Analyst’s Conclusion: Key Questions for the Case
- A threshold issue for the case is one of viability: given that an ex parte reexamination concluded post-filing and resulted in the cancellation of every claim asserted in the complaint (Claims 1 and 15), the central question is whether any basis for the lawsuit remains.
- Assuming the claims were valid, a core issue would be one of definitional scope: can the term "removable from", arguably rooted in the context of a separable component of a single device system (like a battery pack), be construed to cover two entirely separate consumer electronic products being brought into proximity for charging?
- A key evidentiary question would be one of technical conformity: does the complex, integrated power management circuitry in the accused smartphones create a "metallic coupling" between the battery and the wireless coil as the term is used and defined within the patent's specification, or is there a fundamental mismatch in the electrical architecture?