DCT
2:22-cv-00023
Geotag IP LLC v. ams Sensors USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Geotag IP, LLC (Texas)
- Defendant: AMS Sensors USA, Inc. (Austria, with a principal place of business in Texas)
- Plaintiff’s Counsel: Ramey & Schwaller, LLP
- Case Identification: 2:22-cv-00023, E.D. Tex., 01/20/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district, has committed acts of infringement in the district, and conducts substantial business in the forum.
- Core Dispute: Plaintiff alleges that Defendant’s wireless RFID sensor tags, which feature energy harvesting and temperature sensing, infringe a patent directed to self-powered data loggers.
- Technical Context: The technology concerns low-power, batteryless sensor devices that harvest ambient energy to power themselves, a key technology for the Internet of Things (IoT) and supply chain management for monitoring environmental conditions of sensitive goods.
- Key Procedural History: The complaint does not reference any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2014-04-24 | U.S. Patent No. 9,511,910 Priority Date |
| 2016-12-06 | U.S. Patent No. 9,511,910 Issued |
| 2022-01-20 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,511,910 - "Intelligent Wine Capsule"
- Issued: December 6, 2016
The Invention Explained
- Problem Addressed: The patent describes the lack of a "cost-effective or non-intrusive way of tracking the temperature of a bottle of wine," which can degrade when exposed to improper temperatures ('910 Patent, col. 1:24-29).
- The Patented Solution: The invention is a self-powered data logger, envisioned for integration into a wine capsule, that harvests ambient electromagnetic energy (e.g., from an RFID reader) and stores it in a capacitor. Once the stored energy reaches a sufficient voltage threshold, it powers on a processor and memory to take a temperature reading. After storing the data, the system powers down to conserve energy, operating in a periodic "breathing" manner until it is recharged. This allows for long-term, batteryless temperature monitoring ('910 Patent, col. 1:46-64, col. 6:7-12, FIG. 2).
- Technical Importance: The described technology enables a long-lifespan monitoring device that does not rely on a conventional battery, which is advantageous for products like wine that may be stored for extended periods before use ('910 Patent, col. 8:45-59).
Key Claims at a Glance
- The complaint explicitly charts allegations for independent method claim 20 and broadly alleges infringement of claims 1-27, which includes independent apparatus claim 1 (Compl. ¶¶ 8, 10).
- Independent claim 20 recites the essential method steps:
- receiving electromagnetic energy at an energy harvester to form harvested energy;
- transferring the energy to an energy storage component to form stored energy;
- after the stored energy's voltage exceeds a threshold, turning ON a processor and non-volatile memory powered by the stored energy;
- while activated: receiving a temperature signal, storing data representative of that signal in the memory, and discharging the stored energy below the threshold; and
- turning OFF the processor and memory after the data has been stored.
- The complaint reserves the right to assert other claims, including dependent claims (Compl. ¶10).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are Defendant's "Wireless Sensor Tags & Interfaces," specifically identified as "NFC and UHF RFID sensor tags" and the AS39513 product (Compl. pp. 4-5).
Functionality and Market Context
- The complaint describes the accused products as highly integrated solutions for remote sensor data logging, featuring on-chip temperature sensing and "advanced energy harvesting" (Compl. p. 5). The products are marketed for use in cold-chain management, industrial process control, and healthcare applications (Compl. p. 5). A datasheet provided in the complaint for the AS39513 product describes its "harvesting capability," noting that power from an RFID reader can be made available through an external pin (Compl. p. 7). This document also describes a power-up sequence where the chip activates when in a stable RF field and begins an "initialization process" by reading from its EEPROM, a form of non-volatile memory (Compl. p. 5).
IV. Analysis of Infringement Allegations
'910 Patent Infringement Allegations
| Claim Element (from Independent Claim 20) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving electromagnetic energy at an energy harvester to form harvested electromagnetic energy; | Defendant's wireless sensor tags are described as having "advanced energy harvesting" and conforming to NFC and UHF RFID standards, which operate by receiving electromagnetic energy (Compl. p. 5). | ¶9, p. 5 | col. 1:50-52 |
| transferring the harvested electromagnetic energy to at least one energy storage component to form stored energy; | The complaint alleges this element is met but does not provide specific evidence of a distinct energy storage component separate from the operational circuitry (Compl. p. 5). | ¶9, p. 5 | col. 1:52-54 |
| after a voltage of the stored energy exceeds a pre-defined threshold, turning ON at least one processor and at least one non-volatile memory... | A product datasheet states, "Once the chip powers up, either from the battery or the RF field, and the power is stable, the initialization process begins," which the complaint maps to this limitation (Compl. p. 5). | ¶9, p. 5 | col. 5:36-42 |
| while the at least one processor and the at least one non-volatile memory are activated: receiving a temperature signal at the at least one processor from a temperature sensor; | The accused products are described as featuring "on-chip temperature sensing" for applications such as "pharmaceutical cold-chain management" (Compl. p. 6). | ¶9, p. 6 | col. 1:56-59 |
| storing data representative of the temperature signal in the at least one non-volatile memory; and | The complaint alleges the AS39513's ability to perform data logging satisfies this step, referencing its general capability and an excerpt on energy harvesting (Compl. p. 7). | ¶9, p. 7 | col. 6:46-48 |
| discharging the stored energy such that the voltage of the stored energy drops below the pre-defined threshold; and | The complaint makes a conclusory allegation that this step is performed but cites to a datasheet excerpt that describes making harvested power available, not discharging it below a threshold (Compl. p. 7). | ¶9, p. 7 | col. 6:4-7 |
| turning OFF the at least one processor and the at least one non-volatile memory after the data representative of the temperature signal has been stored... | The complaint alleges this element is met but provides no specific evidence of a controlled power-off sequence after data storage, citing only generally to the datasheet (Compl. p. 7). A visual of the initialization process is provided in a screenshot of the AS39513 datasheet (Compl. p. 5). | ¶9, p. 7 | col. 2:16-20 |
- Identified Points of Contention:
- Scope Questions: The patent is titled "Intelligent Wine Capsule" and its background and embodiments focus heavily on this specific application. A central question for the court may be whether the claims, as written, are broad enough to read on the accused general-purpose industrial sensor tags, or if the patent's explicit context limits their scope.
- Technical Questions: A key technical question is whether the accused products perform the full "breathing" cycle as claimed. The complaint provides evidence for powering on in an RF field and sensing temperature. However, it offers less direct evidence for the subsequent, ordered steps of "discharging the stored energy" below a threshold and then "turning OFF... after the data... has been stored." The court may need to determine if the accused device's behavior when an external RF field is removed meets the specific sequence and causality required by these claim limitations.
V. Key Claim Terms for Construction
- The Term: "turning OFF ... after the data representative of the temperature signal has been stored"
- Context and Importance: This term is critical to defining the patented "breathing" power cycle. Its construction will determine whether infringement requires an active, controlled shutdown command or if a passive loss of power when an external energy source is removed is sufficient. Practitioners may focus on this term because the accused products are passive RFID tags that are powered by an external reader, and their "OFF" state may be a direct result of the reader being removed, not an internal command.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation (Passive Power-Off): The specification describes a system that may "shut down to conserve energy and wait for the storage... to become recharged" ('910 Patent, col. 6:4-7). This could be interpreted as a natural power-down due to energy depletion, which would occur when an external RF field is removed.
- Evidence for a Narrower Interpretation (Active Power-Off): The claim's use of "turning OFF" and the specific sequence "after the data... has been stored" may suggest an affirmative action taken by the processor. The summary states the processor and memory "turn OFF after storing the data" ('910 Patent, col. 2:16-20), which could imply a controlled process rather than an incidental loss of power.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement by asserting that Defendant "actively encouraged or instructed" its customers on how to use the accused products in an infringing manner (Compl. ¶10). The factual support cited is the general marketing and functionality of the products as wireless temperature sensors.
- Willful Infringement: The complaint alleges Defendant "has known or should have known of the ‘910 patent... from at least the date of the filing of the lawsuit" (Compl. ¶10). This allegation appears to establish a basis for potential post-suit willfulness only, as no pre-suit knowledge is alleged.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the claims of a patent heavily focused on the specific embodiment of an "Intelligent Wine Capsule" be construed broadly enough to cover general-purpose industrial RFID sensor tags used for cold-chain and process management?
- A key evidentiary question will be one of functional operation: does the accused passive RFID tag's power cycle, which is dependent on the presence of an external reader, perform the specific, ordered "breathing" method of Claim 20? Specifically, does it execute the "discharging" and "turning OFF" steps as an internally managed sequence, or does it simply lose power when the reader is no longer present, raising a question of a potential mismatch in technical operation?