Comarco Wireless Systems LLC v. Samsung Group

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Comarco Wireless Systems LLC (Texas)
  • Defendant: Samsung Electronics Co., Ltd. (South Korea) and Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Sheridan Ross P.C.
• Case Identification: 2:21-cv-00208, E.D. Tex., 06/08/2021
• Venue Allegations: Venue is alleged as proper for Samsung Electronics America, Inc. based on its maintenance of a regular and established place of business within the Eastern District of Texas. For Samsung Electronics Co., Ltd., a foreign corporation, venue is alleged as proper in any judicial district.
• Core Dispute: Plaintiff alleges that Defendant’s USB chargers and portable electronic devices that comply with the USB Battery Charging 1.2 specification infringe three patents related to systems for intelligently managing power delivery and battery charging.
• Technical Context: The technology concerns methods for a power adapter and a portable electronic device to communicate, enabling the device to identify the type of power source and adjust its battery charging functions accordingly to prevent damage.
• Key Procedural History: The complaint does not reference prior litigation, licensing history, or other significant procedural events related to the patents-in-suit.

Case Timeline

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

U.S. Patent No. 9,413,187 - "Power Supply System Providing Power and Analog Data Signal for Use by Portable Electronic Device to Control Battery Charging"

The Invention Explained

• Problem Addressed: The patent addresses the risk that a portable electronic device, such as a notebook computer, could be damaged if its battery is recharged from an improper DC power source (Compl. ¶12). For example, prior art systems could not distinguish between an automobile cigarette lighter outlet and a higher-voltage airplane "EMPOWER" outlet, creating a fire hazard if a battery malfunction occurred during charging on an airplane (’187 Patent, col. 2:3-8). These systems were described as "deficient because they are incapable of automatically and intelligently informing an electronic device... of the DC power source" (’187 Patent, col. 2:51-57).
• The Patented Solution: The invention is a system within the portable electronic device itself that communicates with a power supply to control charging. The device contains "data circuitry" that sends a first signal and receives a second signal from the power supply via a multi-conductor connector (’187 Patent, col. 11:7-14). The "parameter level" of this second signal allows the device's data circuitry to control whether its "rechargeable battery" is charged, thereby managing the risks associated with different power sources (’187 Patent, col. 11:18-24).
• Technical Importance: This approach shifts some of the power management intelligence from the adapter to the portable device, allowing the device to make its own safety-critical decisions about battery charging based on information received from the power source.

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶22).
• Claim 1 recites a portable electronic device comprising:
  • a rechargeable battery;
  • power circuitry configured to receive direct current and charge the battery;
  • data circuitry configured to provide a first signal to, and receive a second signal from, a power supply via a connector; and
  • wherein the second signal has a parameter level usable by the data circuitry to control the charging of the battery.
• The complaint does not explicitly reserve the right to assert dependent claims.

---

U.S. Patent No. 10,855,087 - "Power Supply Systems"

The Invention Explained

• Problem Addressed: The ’087 Patent addresses the same problem as the ’187 Patent: the inability of conventional DC power adapters to automatically inform an electronic device about the nature of the power source, creating a risk of battery damage or fire, particularly when using airplane EMPOWER outlets (’087 Patent, col. 2:37-57).
• The Patented Solution: The invention is a power supply system (e.g., a charger) that communicates with a portable electronic device (PED) using a specific four-conductor interface. The system's "data circuitry" receives a "first signal" from the PED and provides a "second signal" back to the PED (’087 Patent, col. 11:1-16). This two-way communication, or "handshake" (Compl. ¶13), enables the PED to use the "parameter level" of the second signal to control its own battery charging, for example, by disabling charging when connected to a specific type of power source (’087 Patent, col. 5:20-29). Figure 3 illustrates the overall system, with control circuitry in both the adapter (370) and the electronic device (365) facilitating this communication (’087 Patent, Fig. 3).
• Technical Importance: This patent focuses on the power supply side of the communication protocol, defining a system that can respond to signals from a portable device to enable intelligent charging control.

Key Claims at a Glance

• The complaint asserts at least independent Claim 1 (Compl. ¶23).
• Claim 1 recites a power supply system comprising:
  • power circuitry to provide DC power;
  • data circuitry to receive a first signal from a PED and provide a second signal to the PED;
  • a connector with four conductors to transfer: (1) DC power, (2) a ground reference, (3) the first signal from the PED to the data circuitry, and (4) the second signal from the data circuitry to the PED; and
  • wherein the second signal has a parameter level usable by the PED to control charging.
• The complaint does not explicitly reserve the right to assert dependent claims.

---

U.S. Patent No. 10,951,042 - "Power Supply Systems"

Technology Synopsis

The ’042 Patent claims the portable electronic device side of the intelligent charging system, similar to the ’187 Patent. It describes a portable device with a rechargeable battery and data circuitry that uses a four-conductor connector to engage in two-way signaling with an external power supply to control its own battery charging (’042 Patent, Abstract; col. 11:1-25). The core concept remains the device's ability to intelligently enable or disable charging based on signals received from the power source.

Asserted Claims

The complaint asserts at least independent Claim 1 (Compl. ¶24).

Accused Features

The accused features are Samsung's "Accused PEDs," which include various Galaxy Chromebook and Galaxy Book models (Compl. ¶¶21, 24).

III. The Accused Instrumentality

Product Identification

• The complaint identifies two categories of accused products: "Accused Chargers" and "Accused PEDs" (Portable Electronic Devices) (Compl. ¶¶20-21).
  • Accused Chargers include products such as the Adaptive Fast Charging Wall Charger, Fast Charge Travel Charger, and various portable battery packs (Compl. ¶20).
  • Accused PEDs include various laptop models, such as the Galaxy Chromebook, Galaxy Chromebook 2, Galaxy Book Flex, and Galaxy Book S (Compl. ¶21).

Functionality and Market Context

• The complaint alleges that the relevant technical functionality of the accused products is their compliance with the "USB Battery Charging Specification... Revision 1.2, March 15, 2012 ('the USB BC 1.2 specification')" (Compl. ¶¶20-21).
• The core of the infringement allegation is that the Accused Chargers and Accused PEDs, when used together, form a system that practices the patented inventions by operating according to this public standard (Compl. ¶¶22-24). The complaint does not provide further technical details about the specific operation of the accused products beyond their alleged compliance with the USB BC 1.2 specification.
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused products meet every element of the asserted claims but does not provide claim charts in its exhibits, instead incorporating them by reference as Appendices A, B, and C (Compl. ¶¶22-24, 26, 32, 38). The infringement theory appears to be that compliance with the USB BC 1.2 specification inherently results in an infringing system.

• '187 Patent Infringement Allegations: The complaint alleges that the Accused PEDs, when used with the Accused Chargers, form a system that infringes at least Claim 1 of the ’187 Patent (Compl. ¶22). The narrative suggests that the data communication protocols defined in the USB BC 1.2 standard for managing charging correspond to the claimed "data circuitry" that sends and receives signals to "control... charging" (’187 Patent, col. 11:22-24).
• '087 Patent Infringement Allegations: The complaint alleges that the Accused Chargers infringe at least Claim 1 of the ’087 Patent (Compl. ¶23). The theory appears to be that USB BC 1.2 compliant chargers constitute the claimed "power supply system" that uses a a four-conductor interface (the USB port) to engage in the required signaling with a portable device to manage charging (’087 Patent, col. 11:1-24).
• Identified Points of Contention:
  • Standard-Essentiality Question: A primary issue will be whether compliance with the USB BC 1.2 standard necessarily requires practicing every limitation of the asserted claims. The defense may argue that the standard can be implemented in non-infringing ways or that the standard lacks certain elements required by the claims.
  • Scope Questions: The case may raise questions about the scope of key terms. For instance, does the communication protocol for negotiating power levels in the USB BC 1.2 standard function as the claimed "first signal" and "second signal" used to control charging based on the type of power source (e.g., airplane vs. automobile), as described in the specification? (’087 Patent, col. 5:7-14).
  • Technical Questions: What evidence does the complaint provide that the accused products perform the specific "handshake" to identify the power source type and control charging on that basis (Compl. ¶13), as opposed to performing more general power negotiation as defined by the USB standard?

V. Key Claim Terms for Construction

• Term ('087 Patent, Claim 1): "data circuitry configured to receive a first signal... and to provide a second signal"
• Context and Importance: The definition of this two-way signaling is central to the infringement analysis. The dispute will likely focus on whether the standard power negotiation messages in the USB BC 1.2 protocol constitute the specific "first signal" and "second signal" contemplated by the patent. Practitioners may focus on this term because the patent's specification repeatedly links this signaling to the specific problem of distinguishing between automobile and airplane power sources.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself does not limit the purpose of the signals, only that the "second signal" is "usable... in connection with control of charging" (’087 Patent, col. 11:20-24). This could support an interpretation that any data signals that affect charging behavior meet this limitation.
  • Evidence for a Narrower Interpretation: The detailed description frames the invention as solving the specific problem of distinguishing power source types based on their voltage levels (’087 Patent, col. 3:51-64). An embodiment describes the data signal (Vdata) as having one value for an automobile outlet and another for an airplane outlet, which the device uses to enable or disable charging (’087 Patent, col. 5:7-29). This may support a narrower construction where the signals must relate to identifying the power source type.

---

• Term ('187 Patent, Claim 1): "a parameter level that is usable by the data circuitry in connection with control of charging"
• Context and Importance: This term defines the nature of the information conveyed by the power supply to the portable device. The case will likely turn on whether the information conveyed in the USB BC 1.2 protocol qualifies as the claimed "parameter level."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "parameter level" is broad and could be interpreted to cover any variable aspect of a signal—voltage, current, a digital value—that carries information used to control charging. The claim does not specify what the parameter must represent.
  • Evidence for a Narrower Interpretation: The specification provides a specific example where the "parameter level" is a voltage (e.g., 5.0 Volts or 0.0 Volts) that explicitly indicates whether the power source is an automobile outlet or an airplane outlet (’187 Patent, col. 5:9-14). This could support a narrower construction where the "parameter level" must be a signal that directly communicates the source type for the purpose of enabling or disabling charging.

VI. Other Allegations

• Willful Infringement: The complaint alleges willful infringement for all three patents. The basis for this allegation is that "at least as of the filing of this Complaint, Samsung is aware of the" patents-in-suit and their infringement, suggesting a theory of post-suit willfulness (Compl. ¶¶28, 34, 40).

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

• A core issue will be one of technical mapping: does the communication protocol defined by the public USB BC 1.2 standard, which is designed for general-purpose charging negotiation, perform the specific functions required by the patent claims, which are described in the specification as a safety mechanism to distinguish between different types of DC power sources (e.g., automobile vs. airplane)?
• A second central issue will be one of claim scope: will the term "data circuitry... to provide a second signal," which has a "parameter level" for controlling charging, be construed broadly to cover any power-negotiation communication, or will it be limited to the specification's disclosure of a signal that explicitly identifies the power source type to the portable device?
• A key evidentiary question will be one of proof of infringement: beyond alleging compliance with a standard, what evidence will be presented to demonstrate that the Accused Chargers and PEDs actually perform the specific two-way signaling process described in the patents to control battery charging in the manner claimed?