Electronic Edison Transmission Tech LLC v. Samsung Electronics Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Electronic Edison Transmission Technologies, LLC (Wyoming)
  • Defendant: Samsung Electronics Co., LTD (Republic of Korea); Samsung Electronics America, Inc. (New York)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 2:24-cv-00105, E.D. Tex., 02/16/2024
• Venue Allegations: Venue is alleged to be proper for Samsung Electronics Co., LTD as a foreign entity that may be sued in any district. For Samsung Electronics America, Inc., venue is based on its registration to do business in Texas and its maintenance of regular and established places of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s smartphones and smartwatches featuring 'Wireless PowerShare' or 'Reverse Charging' capabilities infringe three patents related to systems and methods for wireless power transfer between mobile devices.
• Technical Context: The technology enables a mobile electronic device, such as a smartphone, to function as a wireless charging source for another device, a feature known in the consumer electronics market as reverse wireless charging.
• Key Procedural History: The three patents-in-suit belong to the same family, with the '415 Patent being a continuation and the '305 Patent being a divisional of the application that issued as the '603 Patent. The complaint notes that all three patents were examined by the same USPTO examiner and lists prior art considered during prosecution, an apparent effort to preemptively assert the patents' validity over that art.

Case Timeline

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

U.S. Patent No. 9,448,603 - "Transferring Power to a Mobile Device"

Issued September 20, 2016

The Invention Explained

• Problem Addressed: The patent addresses scenarios where a user's mobile device has a low battery, but no conventional power source (e.g., an electrical outlet or car charger) is available ('603 Patent, col. 1:24-34).
• The Patented Solution: The invention is a system where a "donor" mobile device with sufficient battery life can wirelessly transfer power to a "receptor" mobile device ('603 Patent, col. 1:35-43). The process is managed by software applications on both devices, which can configure the power transfer and set thresholds for starting or stopping the charging process ('603 Patent, col. 2:30-35). The technology primarily describes using electromagnetic induction, where a primary coil in the donor device generates a magnetic field to induce an electrical current in a secondary coil in the receptor device ('603 Patent, col. 4:30-61).
• Technical Importance: The technology facilitates device-to-device charging, creating a personal mobile charging network independent of fixed power infrastructure ('603 Patent, col. 1:15-23).

Key Claims at a Glance

• The complaint asserts independent claims 1, 6, and 8, as well as dependent claims 2-4 (Compl. ¶37).
• Independent Claim 1 includes these essential elements:
  • A method of transferring power from a donor mobile device with a battery.
  • Configuring a donor wireless power transfer mechanism using a "wireless transmit application."
  • Configuring a receptor wireless power transfer mechanism using a "wireless receive application."
  • Transferring power between the two mechanisms.
  • Receiving and converting the power to electric current at the receptor.
  • The donor mechanism includes a primary coil, and the receptor mechanism includes a secondary coil and a capacitor.
  • The primary coil produces a magnetic field to generate current in the secondary coil, and the capacitor stores an electric charge that "increases battery life when the capacitor is discharged."
• The complaint reserves the right to assert additional claims (Compl. ¶37).

U.S. Patent No. 9,871,415 - "Transferring Power to a Mobile Device"

Issued January 16, 2018

The Invention Explained

• Problem Addressed: Like its parent patent, the '415 Patent addresses the need to charge a mobile device when a user lacks access to a conventional power source but has another charged device available ('415 Patent, col. 1:24-33).
• The Patented Solution: The patent describes a similar system for device-to-device wireless charging managed by software applications ('415 Patent, col. 2:21-42). This patent's claims specifically focus on the transfer continuing until the receiving device's battery reaches a "specific power threshold" and explicitly claim the functional role of a capacitor in the receptor device for storing a charge to increase the life of the receptor's battery ('415 Patent, Claim 1).
• Technical Importance: This invention refines the concept of device-to-device charging by introducing software-based threshold management and a specific circuit element (a capacitor) for enhancing the charge transfer ('415 Patent, col. 2:59-68).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 6, as well as dependent claims 2-4 (Compl. ¶52).
• Independent Claim 1 includes these essential elements:
  • A method for transferring power to a receptor device (with a first battery) from a donor device (with a second battery).
  • Configuring the respective donor and receptor wireless power transfer mechanisms via "wireless transmit" and "wireless receive" applications.
  • Transferring power until the first battery reaches a "specific power threshold."
  • Receiving and converting the power into electric current.
  • Using a primary coil (donor) to create a magnetic field that induces current in a secondary coil (receptor).
  • "Storing an electric charge in a capacitor" in the receptor, which "thereby increasing battery life of the first battery when the capacitor is discharged."
• The complaint reserves the right to assert additional claims (Compl. ¶52).

U.S. Patent No. 10,454,305 - "Transferring Power to a Mobile Device"

Issued October 22, 2019

• Technology Synopsis: This patent, a divisional from the same family, also describes a system for wireless power transfer between mobile devices managed by software ('305 Patent, col. 2:15-30). However, its claims are specifically directed to a system using capacitive coupling, where a primary conductor and a secondary conductor act as capacitor plates with the air between them acting as a dielectric to transfer energy ('305 Patent, Claim 1).
• Asserted Claims: The complaint asserts at least independent claim 4 (Compl. ¶67).
• Accused Features: The accused features are the 'Wireless PowerShare' or 'Reverse Charging' capabilities in Samsung products, which the complaint notes are compliant with the Qi wireless power standard (Compl. ¶67).

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused instrumentalities as products including, but not to, the Samsung Galaxy S20 series, Galaxy smartwatches, and Galaxy Z fold phones (Compl. ¶37).

Functionality and Market Context

• The accused products incorporate a feature branded as 'Wireless PowerShare' or 'Reverse Charging' (Compl. ¶37). This functionality allows the Samsung device to act as a wireless power transmitter, effectively turning its back surface into a charging pad for other Qi-standard compatible devices, such as other phones, watches, or earbuds (Compl. ¶37). The complaint alleges these are "exemplary Products," suggesting they are part of a larger class of allegedly infringing devices sold by Samsung (Compl. ¶40). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits (Exhibits D, E, and F) detailing its infringement contentions (Compl. ¶¶42, 57-58, 72-73). The narrative infringement theory is that Samsung's 'Wireless PowerShare' feature practices the patented methods. The complaint alleges that when a user enables this feature on a Samsung device (the donor) and places another device (the receptor) on it to charge, they are performing the claimed steps of configuring the respective transfer mechanisms via software applications and transferring power using the claimed technologies (Compl. ¶¶37, 40, 42). The complaint further alleges that the products' compliance with the Qi standard for wireless power means they implement the underlying inductive coupling mechanisms described in the patents ('603 Patent; '415 Patent) and that this conduct constitutes direct and indirect infringement (Compl. ¶¶37, 40-41).

• Identified Points of Contention:
  • Scope Questions: A primary question for the '603 and '415 patents is whether the circuitry in Samsung's Qi-compliant products contains a "capacitor" that performs the specific, claimed function of storing a charge and then discharging it to "increase battery life." The defense may argue that any capacitors in its power circuits are for standard rectification and filtering, not for the distinct charge-and-discharge function required by the claims.
  • Technical Questions: A potential dispute arises from the '305 Patent's focus on capacitive coupling. Given that the accused 'Wireless PowerShare' feature is alleged to be compliant with the Qi standard, which is predominantly based on inductive coupling, a central question will be whether the accused products literally practice the capacitive coupling mechanism of the '305 Patent's claims.
  • Scope Questions: The interpretation of "wireless transmit application" and "wireless receive application" will be critical. The dispute may center on whether an integrated operating system feature, such as the toggle for 'Wireless PowerShare' in Android, meets the definition of an "application" as contemplated by the patents, or if the term requires a more distinct software program.

V. Key Claim Terms for Construction

Term 1: "a capacitor storing electric charge that increases battery life when the capacitor is discharged" (from '603 Patent, Claim 1; similar language in '415 Patent, Claim 1)

• Context and Importance: This functional language is central to infringement for the '603 and '415 patents. The outcome will depend on whether this is construed to cover standard power-smoothing capacitors present in most power circuits or if it requires a specific circuit designed to store and discharge a discrete amount of energy for the express purpose of augmenting battery life. Practitioners may focus on this term because it appears to be a key point of novelty distinguishing the invention from conventional wireless power receivers.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification describes a "charge storage device" that "can be one or more capacitors that can store charge for a significant amount of time," which could be argued to encompass various capacitor roles ('603 Patent, col. 5:10-12).
  • Evidence for a Narrower Interpretation: The claim language itself—"increases battery life when... discharged"—is functional and suggests a purpose beyond passive filtering. The claim in the '415 Patent also distinguishes between the "first battery" and the "capacitor," implying they are separate components with different primary functions, which may support a narrower construction requiring a dedicated circuit topology.

Term 2: "wireless transmit application" / "wireless receive application" (from '603 and '415 Patents)

• Context and Importance: The definition of "application" will determine whether activating a built-in OS feature constitutes infringement. If construed narrowly to mean a user-installable program, it could create a non-infringement defense.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a broad definition, stating control software includes "applications that implement software functions that assist in performing certain tasks" ('603 Patent, col. 7:15-18), which could arguably include OS-integrated functions.
  • Evidence for a Narrower Interpretation: The specification lists "an operating system such as Droid, Symbian, IOS" separately from other software like "user interface computer programs" ('603 Patent, col. 7:23-27). A defendant could argue this distinction implies an "application" is a software layer separate from the underlying operating system.

VI. Other Allegations

• Indirect Infringement: The complaint alleges inducement of infringement, stating that Samsung encourages end-users to infringe by distributing "product literature and website materials" that instruct on the use of the 'Wireless PowerShare' feature (Compl. ¶¶40, 55, 70).
• Willful Infringement: Willfulness allegations are based on continued infringement after Samsung received notice of the patents via the complaint. The complaint asserts that Samsung has knowledge "at least as of the service of the present complaint" and continues its allegedly infringing activities despite this knowledge (Compl. ¶¶39-40, 54-55, 69-70).

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

• A core issue will be one of functional scope: does the standard power-conditioning circuitry in Qi-compliant devices perform the specific function of "increasing battery life" via capacitor discharge, as claimed in the '603 and '415 patents, or is this a functional limitation that the accused products do not meet?
• A second central issue will be one of claim construction: can the term "application," used in the context of configuring the power transfer, be construed to read on a deeply integrated operating system feature, or does it require a discrete software program distinct from the OS?
• A key evidentiary question specific to the '305 Patent will be one of technological mismatch: can the plaintiff demonstrate that Samsung's products, which operate on the inductive Qi standard, nevertheless infringe claims that are explicitly limited to a capacitive power transfer mechanism?