DCT

2:23-cv-00160

CogniPower LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:23-cv-00160, E.D. Tex., 04/10/2023
  • Venue Allegations: Venue is alleged to be proper as to Samsung Electronics Co., Ltd. because it is an alien corporation. Venue is alleged to be proper as to Samsung Electronics America, Inc. on the basis that it has committed acts of infringement and maintains regular and established places of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s power adapter products infringe five reissue patents related to demand pulse regulation technology for switched-mode power converters.
  • Technical Context: The technology concerns methods for efficiently and reliably regulating power output in modern electronic chargers by sending control signals across an internal galvanic isolation barrier.
  • Key Procedural History: The complaint alleges a history of business interactions beginning in 2012, when Samsung allegedly approached CogniPower to discuss its technology. Plaintiff alleges it subsequently provided Samsung with proprietary information, data, and prototypes embodying its patented technology, and that it offered Samsung a license on multiple occasions between 2016 and 2020.

Case Timeline

Date Event
2012-07-03 Earliest Priority Date Asserted for Patents-in-Suit
2012-11-19 Priority Date Asserted for Patents-in-Suit
2015-06-30 Original U.S. Patent No. 9,071,152 Issues
2016-01-01 Plaintiff alleges it requested Defendant take a license (approx. date)
2018-09-04 U.S. Reissue Patent No. RE47,031 Issues
2019-11-05 U.S. Reissue Patent No. RE47,713 Issues
2019-11-05 U.S. Reissue Patent No. RE47,714 Issues
2022-08-02 U.S. Reissue Patent No. RE49,157 Issues
2023-02-21 U.S. Reissue Patent No. RE49,425 Issues
2023-04-10 Complaint Filed

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

U.S. Reissue Patent No. RE47,031 - "Power Converter With Demand Pulse Isolation"

  • Issued: Sep. 4, 2018

The Invention Explained

  • Problem Addressed: The patent addresses the technical challenge of conveying feedback information from the secondary (output) side to the primary (input) side of a switched-mode power converter across a galvanic isolation barrier, which is necessary for regulating output voltage or current (RE47,031 Patent, col. 1:46-50). Prior art methods are described as either "quite involved" or difficult to implement reliably (RE47,031 Patent, col. 1:50-2:2).
  • The Patented Solution: The invention proposes a system where the secondary side of the converter generates "demand pulses" when it requires more energy (RE47,031 Patent, Abstract). These pulses are transmitted across the isolation barrier, typically via the power transformer itself, to trigger a commutating switch on the primary side, initiating an energy-bearing cycle to power the output (RE47,031 Patent, col. 3:12-25). This approach simplifies the feedback mechanism by using discrete pulses for control rather than complex analog signal processing.
  • Technical Importance: This control architecture sought to improve the efficiency, stability, reliability, and manufacturing cost of ubiquitous power converters, such as AC/DC adapters (Compl. ¶18).

Key Claims at a Glance

  • The complaint asserts infringement of the patent generally, without specifying claims, but reserves the right to identify specific claims later. Independent Claim 1 is representative and includes the following essential elements:
    • An apparatus for switched-mode power conversion.
    • An input port, a switch, and galvanic isolation circuitry comprising a transformer with primary and secondary windings.
    • A "demand pulse generator" galvanically connected to the secondary winding.
    • The generator is configured to generate demand pulses that are applied via the galvanic isolation circuitry to the switch to adjust commutation frequency.
    • A capacitor and a second rectifier, connected to the secondary winding, poled to charge the capacitor during forward pulses of the apparatus.
    • The demand pulse generator is powered by energy stored in this capacitor.

U.S. Reissue Patent No. RE47,713 - "Power Converter With Demand Pulse Isolation"

  • Issued: Nov. 5, 2019

The Invention Explained

  • Problem Addressed: The ’713 Patent addresses the same technical problem as the ’031 Patent: reliable and efficient feedback control across a galvanic isolation barrier in a power converter (RE47,713 Patent, col. 2:1-11).
  • The Patented Solution: The ’713 Patent also discloses the use of demand pulses generated on the secondary side to control a primary-side switch (RE47,713 Patent, Abstract). The claims focus on a specific control architecture for a flyback converter, where the decision of when to turn on the primary-side switch is made on the secondary side, but the determination of when to turn off the switch originates on the primary side.
  • Technical Importance: This division of control logic sought to provide the benefits of secondary-side regulation while maintaining certain control functions, such as over-current protection, on the high-voltage primary side (RE47,713 Patent, col. 7:14-22).

Key Claims at a Glance

  • The complaint asserts infringement of the patent generally. Claims 1-17 are cancelled. Independent Claim 18 is representative and includes the following essential elements:
    • An article of manufacture comprising a flyback converter with galvanically isolated primary and secondary sides.
    • A primary-side switch to enable power transfer.
    • A secondary-side demand pulse generator that determines when to turn on the primary-side switch.
    • A key limitation that "the determination of when to turn off the primary-side switch is originated on the primary side and not on the secondary side."
    • A first capacitor and rectifier poled to charge the capacitor during forward power converter pulses, with the demand pulses being generated using energy from this capacitor.

Multi-Patent Capsule: U.S. Reissue Patent No. RE47,714

  • Patent Identification: RE47,714, "Power Converter With Demand Pulse Isolation", issued November 5, 2019.
  • Technology Synopsis: The patent describes circuitry for controlling a flyback power converter. The technology uses demand pulses generated on the galvanically isolated secondary (output) side to control a switch on the primary (input) side, with the demand pulse generator being powered by energy captured during forward power converter pulses.
  • Asserted Claims: The complaint asserts the patent generally; the first available independent claim is Claim 18.
  • Accused Features: The power conversion, management, and regulation functionalities of the Accused Instrumentalities are alleged to infringe (Compl. ¶32, ¶37).

Multi-Patent Capsule: U.S. Reissue Patent No. RE49,157

  • Patent Identification: RE49,157, "Power Converter With Demand Pulse Isolation", issued August 2, 2022.
  • Technology Synopsis: The patent describes a flyback converter where a secondary-side circuit determines when to turn on the primary-side switch by sending demand pulses across an isolation barrier. A key feature is that the determination of when to turn the switch off originates on the primary side.
  • Asserted Claims: The complaint asserts the patent generally; the first available independent claim is Claim 18.
  • Accused Features: The power conversion, management, and regulation functionalities of the Accused Instrumentalities are alleged to infringe (Compl. ¶32, ¶38).

Multi-Patent Capsule: U.S. Reissue Patent No. RE49,425

  • Patent Identification: RE49,425, "Power Converter With Demand Pulse Isolation", issued February 21, 2023.
  • Technology Synopsis: The patent claims an apparatus and method for regulating a switched-mode power converter. The system uses a demand pulse generator on the secondary side, powered by a capacitor charged during forward pulses, to control the primary-side switch.
  • Asserted Claims: The complaint asserts the patent generally; the first available independent claim is Claim 18.
  • Accused Features: The power conversion, management, and regulation functionalities of the Accused Instrumentalities are alleged to infringe (Compl. ¶32, ¶39).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities include a non-exhaustive list of Samsung power adapters, such as the 15W Power Adapter, 25W USB-C Fast Charging Wall Charger, 35W Power Adapter Duo, 45W Power Adapter, and 65W Trio Adapter (Compl. ¶33).

Functionality and Market Context

The complaint alleges that these products are switched-mode power converters that implement "demand pulse regulation (DPR) technology" to manage and regulate power output (Compl. ¶32). The complaint further alleges these adapters incorporate specific controller components, such as GP801LS controllers from Diodes Inc., iW9801/iW70x controllers from Renesas Electronics, and/or SC1920C controllers from Power Integrations (Compl. ¶34).

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Instrumentalities infringe the patents-in-suit by implementing power conversion, management, and regulation technology that uses the claimed DPR methods (Compl. ¶32). For each patent, the complaint refers to an appendix (Appendices B-F) containing an "exemplary chart" that allegedly details the manner of infringement (Compl. ¶¶35-39). As these appendices were not provided with the complaint, a detailed element-by-element summary of the infringement allegations is not possible. The core of the infringement theory appears to be that the controllers used in Samsung's adapters perform the claimed functions of generating demand pulses on a secondary side to control a primary-side switch for output regulation.

Identified Points of Contention

  • Technical Questions: A primary technical question will be whether the operation of the accused third-party controller chips (from Diodes Inc., Renesas, and Power Integrations) maps onto the specific architecture required by the claims. For example, for the ’031 and ’713 Patents, discovery will need to establish whether the demand pulse generation circuitry in the accused products is powered by a capacitor charged specifically during "forward pulses", as distinct from flyback pulses or another power source.
  • Scope Questions: For the ’713 Patent, a key point of contention may be the locus of control. The court will have to determine whether the accused devices practice the claimed feature where the determination of when to "turn off" the primary-side switch originates on the primary side. Evidence showing that this determination is made on, or influenced by, the secondary side could support a non-infringement argument.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

"demand pulse generator" (e.g., ’031 Patent, Claim 1)

Context and Importance

This term is central to the claimed invention. The scope of this term will be critical in determining whether the control logic implemented in the accused adapters' third-party controllers constitutes an infringing structure.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes the term functionally, stating its purpose is to "source a pulse of energy... into transformer 100a" to trigger an energy-bearing cycle (RE47,031 Patent, col. 3:15-18). Plaintiff may argue that any circuit structure on the secondary side that performs this function meets the limitation.
  • Evidence for a Narrower Interpretation: The specification discloses specific embodiments of the generator, such as the comparison circuit and pulse generator of FIG. 1 (401a, 503a) and the output-side blocking oscillator of FIG. 2 (503b) (RE47,031 Patent, col. 4:5-8; col. 5:25-33). Defendant may argue the term should be construed as being limited to these structures or their equivalents.

"the determination of when to turn off the primary-side switch is originated on the primary side and not on the secondary side" (e.g., ’713 Patent, Claim 18)

Context and Importance

This functional and negative limitation defines a specific control architecture. Infringement will depend entirely on where this decision-making logic resides in the accused products. Practitioners may focus on this term because it creates a sharp, fact-intensive distinction between potentially infringing and non-infringing control schemes.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes a primary-side current limit implementation where a transistor "shunts current at gate G of MOSFET 200b to ground, limiting gate G voltage to prevent further current rise," which in turn causes a "regenerative turn-OFF" (RE47,031 Patent, col. 4:39-47). Plaintiff may argue that any primary-side mechanism that autonomously terminates the switch's ON-state, such as a simple current sense resistor and comparator, meets this limitation.
  • Evidence for a Narrower Interpretation: Defendant may argue that the term requires the turn-off determination to be made exclusively on the primary side, without any influence from the secondary side. If discovery reveals that the secondary side can, for example, adjust the primary-side current limit threshold, Defendant might argue this level of influence means the "determination" does not originate solely on the primary side.

VI. Other Allegations

Indirect Infringement

The complaint alleges inducement of infringement by third parties (such as end-consumers) through affirmative acts including advertising, marketing, and the creation of product manuals and technical support materials that instruct on the use of the Accused Instrumentalities (Compl. ¶¶43-44).

Willful Infringement

Willfulness is alleged based on Defendants' alleged actual notice of the patents and infringing activities (Compl. ¶40, ¶50). The complaint asserts this notice arises from a multi-year history of interactions, beginning in 2012, in which CogniPower allegedly disclosed its DPR technology to Samsung and repeatedly offered a license (Compl. ¶¶27-29).

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

  • A central issue will be one of evidentiary mapping: can Plaintiff demonstrate through reverse engineering and discovery that the specific, complex operations of the third-party controller chips within Samsung's products practice the patented method? This includes proving not only the generation of demand pulses but also ancillary requirements, such as the method by which the pulse generator is powered (i.e., from forward pulses).
  • A key question of claim scope will be the locus of control: for patents like the ’713 Patent, the dispute may turn on whether the accused devices' control logic strictly matches the claimed architecture where the "turn-off" decision for the primary switch originates exclusively on the primary side, a subtle but potentially dispositive technical distinction.
  • The determination of willfulness will be a major focus: given the complaint's detailed allegations of pre-suit history and knowledge dating back over a decade, the question of whether any infringement was willful, potentially justifying enhanced damages, will likely be a critical and heavily litigated aspect of the case.