DCT
2:24-cv-00335
Electronic Edison Transmission Tech LLC v. Google LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Electronic Edison Transmission Technologies, LLC (Wyoming)
- Defendant: Google LLC (Delaware)
- Plaintiff’s Counsel: Garteiser Honea, PLLC; Sinergia Technology Law Group, PLLC
- Case Identification: 2:24-cv-00335, E.D. Tex., 08/09/2024
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains regular and established places of business in the district, including data centers and the physical presence of employees, and has committed acts of infringement there. The complaint cites a prior ruling in Agis Software Development LLC v. Google LLC which found venue proper for Google in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Pixel smartphones and Pixel Buds, which feature reverse wireless charging, infringe a patent related to transferring power between mobile devices.
- Technical Context: The technology concerns enabling a mobile device with a sufficient charge, such as a smartphone, to act as a wireless power source for another mobile device, such as wireless earbuds, without needing a dedicated power outlet.
- Key Procedural History: The complaint notes that the asserted patent was examined and allowed by the USPTO over several prior art references. No prior litigation or post-grant proceedings involving the asserted patent are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2011-09-03 | Priority Date for U.S. Patent No. 9,448,603 |
| 2016-09-20 | Issue Date for U.S. Patent No. 9,448,603 |
| 2024-08-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,448,603 - "Transferring Power to a Mobile Device," issued Sep. 20, 2016
The Invention Explained
- Problem Addressed: The patent addresses the scenario where a consumer's mobile device has a low battery, but no conventional power source (e.g., wall outlet, car charger) is available, while another of the consumer's mobile devices has substantial battery life remaining (ʼ603 Patent, col. 1:23-32).
- The Patented Solution: The invention is a method and system where one mobile device (a "donor") can wirelessly transfer power to another (a "receptor") (ʼ603 Patent, col. 1:35-42). The process is controlled by software applications on both devices, which configure the respective wireless power transfer mechanisms and allow a user to set thresholds for the power transfer (e.g., stop charging when the donor's battery falls to 50%) (ʼ603 Patent, col. 7:46-59; Fig. 5). The transfer itself can be accomplished through various wireless technologies, including inductive coupling, which uses magnetic fields generated by coils in each device (ʼ603 Patent, col. 4:16-33).
- Technical Importance: The technology provides a mobile, device-to-device charging solution, enhancing the utility and continuous operation of portable electronics in situations where traditional charging infrastructure is inaccessible (ʼ603 Patent, col. 3:56-62).
Key Claims at a Glance
- The complaint asserts independent claims 1, 6, and 8, as well as dependent claims 2-4 (Compl. ¶32).
- Independent Claim 1 (Method):
- configuring a donor wireless power transfer mechanism on the donor mobile device using a wireless transmit application;
- configuring a receptor wireless power transfer mechanism on the receptor mobile device using a wireless receive application;
- transferring power from the donor to the receptor device using the respective power transfer mechanisms;
- receiving and converting the received power into electric current at the receptor device;
- wherein the donor mechanism includes a primary coil and the receptor mechanism includes a secondary coil and a capacitor; and
- the capacitor stores electric charge that increases battery life when the capacitor is discharged.
III. The Accused Instrumentality
Product Identification
- The accused products are Google’s Pixel 5, Pixel 6, Pixel 7, Pixel 7 Pro, and Pixel 8 smartphones, which act as donor devices, and Google’s Pixel Buds, which act as receptor devices (Compl. ¶32).
Functionality and Market Context
- The complaint targets the "Battery Share" feature in the accused Pixel smartphones (Compl. ¶33). This feature allows a Pixel phone to function as a Qi-standard wireless charging pad. A user can enable Battery Share through the phone's settings interface, place a compatible device like the Pixel Buds on the back of the phone, and initiate a power transfer via magnetic induction (Compl. ¶¶33, 35). The complaint alleges Google configures this functionality in the devices' firmware and provides instructional materials for its use (Compl. ¶¶34, 39). The complaint refers to a visual in its exhibits to show the “Battery Share” functionality being activated via the Google Pixel 8 settings user interface (Compl. ¶33).
IV. Analysis of Infringement Allegations
The complaint references a claim chart exhibit (Exhibit B) that was not publicly available with the pleading. The following summary is based on the narrative allegations in the complaint body.
’603 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| configuring a donor wireless power transfer mechanism on the donor mobile device using a wireless transmit application; | Google configures the Pixel 8 smartphone to include "Battery Share" functionality, which the complaint defines as a "wireless transmit application," activated via the settings user interface. The complaint references a visual from its exhibits depicting this activation. | ¶33 | col. 12:28-31 |
| configuring a receptor wireless power transfer mechanism on the receptor mobile device using a wireless receive application; | Google configures the Pixel Buds with a "wireless receive application" in its firmware, enabling them to be charged by the Pixel 8 when placed on its back. The complaint refers to visuals in its exhibits for this point. | ¶34 | col. 12:32-35 |
| transferring power from donor mobile device to the receptor mobile device... | Power is transferred from a Pixel 8 smartphone to Pixel Buds via Qi wireless power transfer using magnetic induction. The complaint points to its exhibits for evidence of this transfer. | ¶35 | col. 12:36-40 |
| receiving and converting received power into electric current... | The Pixel Buds receive the power transmitted from the Pixel 8 via magnetic induction and convert it to charge their battery. The complaint again directs to its exhibits for this element. | ¶36 | col. 12:41-44 |
| wherein the donor wireless power transfer mechanism includes a primary coil...and the receptor...includes a secondary coil, receptor circuit elements and a capacitor... | The Pixel 8 smartphone (donor) contains a primary coil, and the Pixel Buds (receptor) contain a secondary coil and a capacitor as part of their power receiver circuitry. | ¶37 | col. 12:45-56 |
| ...the capacitor storing electric charge that increases battery life when the capacitor is discharged. | The complaint alleges it would be "apparent to a person having ordinary skill in the art" that the capacitor in the Pixel Buds circuitry stores an electric charge that "further increases the battery life." | ¶37 | col. 12:56-59 |
- Identified Points of Contention:
- Scope Question: A dispute may arise over whether the integrated "Battery Share" feature in the Pixel's operating system constitutes a "wireless transmit application" as claimed. The patent specification illustrates distinct software blocks for this function, which may raise the question of whether an integrated OS feature meets this limitation (’603 Patent, Fig. 3).
- Technical Question: The infringement reading of the final limitation—"the capacitor storing electric charge that increases battery life when the capacitor is discharged"—may be a central point of contention. The complaint makes a conclusory assertion that this function is "apparent" (Compl. ¶37). The case may turn on whether the capacitor in the Pixel Buds performs this specific charge-and-discharge function to supplement battery life, or if it merely serves a standard power conditioning role (e.g., smoothing current), which is common in all power circuits.
V. Key Claim Terms for Construction
The Term: "wireless transmit application" / "wireless receive application"
- Context and Importance: The definition of "application" is critical to determining whether Google's integrated "Battery Share" OS feature infringes. Practitioners may focus on this term because the patent's description and figures could be argued to support a narrower definition than what the complaint alleges.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes these as "software applications that implement software functions" and "control software (SW) applications," which could be argued to cover any software module, including an integrated OS feature, that performs the recited functions (ʼ603 Patent, col. 7:20-23).
- Evidence for a Narrower Interpretation: Figure 3 of the patent depicts "Wireless Transmit SW 312" and "Wireless Receive SW 322" as distinct software blocks separate from the general "Control SW," which could support an argument that the claims require a discrete, standalone application rather than a feature embedded within a larger OS (ʼ603 Patent, Fig. 3).
The Term: "the capacitor storing electric charge that increases battery life when the capacitor is discharged"
- Context and Importance: This functional language is highly specific and likely to be the dispositive limitation for infringement. The analysis will depend on whether the accused capacitor performs this exact function, beyond standard power conditioning.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any capacitor in a charging circuit, by smoothing current and improving efficiency, indirectly "increases battery life," and it "discharges" as part of its normal operation.
- Evidence for a Narrower Interpretation: The phrase "when the capacitor is discharged" suggests a specific, event-driven function rather than continuous, passive operation. The specification mentions that a "charge storage device" can be "one or more capacitors that can store charge for a significant amount of time," implying a function more akin to a supplemental power reservoir than a simple smoothing capacitor (ʼ603 Patent, col. 5:12-15). This may support a construction requiring a capacitor (e.g., a supercapacitor) that actively discharges to provide power.
VI. Other Allegations
- Indirect Infringement: Plaintiff alleges that Google induces infringement by distributing "product literature and website materials instructing end users" on how to use the "Battery Share" feature in an infringing manner (Compl. ¶¶39, 43). This allegation also serves as an alternative theory to address potential divided infringement issues, where some method steps are performed by Google and others by the end user (Compl. ¶38).
- Willful Infringement: The complaint alleges willfulness based on post-suit conduct, asserting that Google has actual knowledge of its infringement "at least since being served by this Complaint and corresponding claim chart" and has continued its allegedly infringing activities (Compl. ¶¶41, 44).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central evidentiary question will be one of technical function: Does the capacitor within the accused Google Pixel Buds perform the specific function required by Claim 1—storing charge and then discharging to "increase battery life"—or does it merely perform a standard power-conditioning role found in typical wireless charging circuits? The complaint's conclusory allegation on this point suggests it will be a heavily contested factual issue.
- The case will also involve a core issue of definitional scope: Can the term "wireless transmit application," as used in the patent, be construed to cover an integrated operating system feature like "Battery Share," or does the patent's disclosure limit the term to a distinct, separable software program?
- A third question relates to divided infringement: If the "transferring" and "receiving" steps are deemed to be performed by the end user, does Google's provision of the products and instructional materials create liability for direct infringement under the "direction or control" test articulated in Akamai?