Electronic Edison Transmission Tech LLC v. Motorola Solutions Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Electronic Edison Transmission Technologies, LLC (Wyoming)
  • Defendant: Motorola Solutions, Inc. (Delaware)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC; Sinergia Technology Law Group, PLLC
• Case Identification: 2:24-cv-00399, E.D. Tex., 05/31/2024
• 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 offices in Plano and Allen, and has previously acknowledged proper venue in this district in unrelated litigation.
• Core Dispute: Plaintiff alleges that Defendant’s smartphones equipped with "Wireless Power Share" functionality infringe a patent related to systems and methods for wirelessly transferring power between mobile devices.
• Technical Context: The technology at issue concerns reverse wireless charging, which allows a consumer electronic device like a smartphone to act as a wireless charging pad to power another device.
• Key Procedural History: The complaint notes that Defendant acknowledged venue was proper in the Eastern District of Texas in a prior case, STA Group LLC v. Motorola Solutions, Inc., Case No. 2:23-cv-00030. No other significant procedural events are mentioned.

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 the scenario where a user's mobile device has a low battery, but no conventional power source (e.g., wall outlet, charger) is available, while another of the user's mobile devices has substantial battery life remaining (Compl. ¶23; ’603 Patent, col. 1:24-32).
• The Patented Solution: The invention is a system allowing a "donor" mobile device (e.g., a laptop) to wirelessly transfer power to a "receptor" mobile device (e.g., a mobile phone). This process is managed by software applications on both the donor and receptor devices, which can configure and initiate the power transfer. The patent describes various transfer technologies, including inductive and capacitive coupling ('603 Patent, Abstract; col. 3:49-67; Fig. 1).
• Technical Importance: The described technology provides a method for on-the-go charging between personal electronic devices, enhancing convenience and extending the operational time of a low-battery device by using another device as a mobile power source ('603 Patent, col. 3:51-4:3).

Key Claims at a Glance

• The complaint asserts independent claims 1 and 8, and dependent claim 4 (Compl. ¶22, ¶33).
• Independent Claim 1 (Method):
  • Configuring a donor wireless power transfer mechanism (WPTM) on a donor mobile device using a wireless transmit application.
  • Configuring a receptor WPTM on a receptor mobile device using a wireless receive application.
  • Transferring power from the donor to the receptor device using the respective WPTMs.
  • Receiving and converting the power into electric current at the receptor.
  • The WPTMs include a primary coil (donor) and a secondary coil (receptor), with the receptor also including a capacitor that stores electric charge to increase battery life upon discharge.
• Independent Claim 8 (Method):
  • Configuring a WPTM on a receptor mobile device using a wireless receive application.
  • Determining a receptor power threshold using the wireless receive application.
  • Receiving and converting power from a donor device.
  • The WPTM includes a power adapter with a coil, circuit elements, and a capacitor to store charge that increases battery life upon discharge.
• The complaint reserves the right to assert additional claims (Compl. ¶33).

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities include, but are not limited to, the Motorola Edge+, Motorola Edge 40, Motorola Edge 40 pro, Motorola Edge, Motorola Razr+, Motorola Razr 40 Ultra, and Motorola Edge 30 Ultra smartphones (Compl. ¶33).

Functionality and Market Context

• The complaint alleges these products incorporate "Wireless Power Share" functionality, which implements the Qi standard for wireless power transfer. This feature allows the accused Motorola phone to act as a "donor mobile device," transferring power from its own battery to another "receptor mobile device" that is compatible with wireless charging (Compl. ¶33). The complaint identifies the Motorola Edge+ as an exemplary product for its infringement allegations (Compl. ¶33).
• No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not include the claim chart exhibit it references (Exhibit B). The following summary is based on the narrative allegations in the complaint body, primarily paragraph 33.

’603 Patent Infringement Allegations (Claim 1)

’603 Patent Infringement Allegations (Claim 8)

Identified Points of Contention

• Technical Questions: A central question will be whether the accused products contain the specific "capacitor" structure recited in claims 1 and 8. The claims require a capacitor that stores charge and then discharges specifically to "increase battery life." The complaint does not plead facts showing that standard power management integrated circuits in the accused phones perform this precise, claimed function, which may differ from general power smoothing or conditioning.
• Scope Questions: Claim 8 requires the WPTM to include a "power adapter." The patent specification depicts the "power adapter" as a distinct physical object (e.g., '603 Patent, Fig. 4A-4C). The infringement analysis will raise the question of whether an entire mobile phone receiving a charge can be construed to be or to include a "power adapter" as that term is used in the patent.

V. Key Claim Terms for Construction

• The Term: "a power adapter" (Claim 8)

  • Context and Importance: The viability of the infringement allegation for claim 8 hinges on this term's definition. If construed narrowly to mean a separate, physical accessory used for charging (as depicted in patent figures 4A-4C), the claim may not read on the accused system, where power is transferred directly from one phone to another. Practitioners may focus on this term because of the potential mismatch between the claim language and the accused functionality.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint does not provide a basis for a broad interpretation. A plaintiff might argue that any set of components that "adapts" power for a device's battery meets the term's plain meaning, regardless of its physical housing.
    • Evidence for a Narrower Interpretation: The patent specification consistently discusses and depicts the "power adapter" as a distinct unit that is separate from the "laptop computer" (donor) and "mobile telephone" (receptor) ('603 Patent, col. 8:19-28; Figs. 4A-4C). This provides strong intrinsic evidence for a narrower construction limited to an accessory-like device.

• The Term: "a capacitor storing electric charge that increases battery life when the capacitor is discharged" (Claims 1, 8)

  • Context and Importance: This functional language is highly specific and will be a focal point of the technical infringement analysis. Infringement depends on identifying a component in the accused phones that not only stores charge but does so for the claimed purpose of "increasing battery life" upon discharge.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A plaintiff could argue that any capacitor in the power receipt pathway that smooths voltage and current contributes to the overall health and longevity of the battery, thereby "increasing" its effective life, and should fall within the scope of the claim.
    • Evidence for a Narrower Interpretation: The claim language recites a specific causal function: the discharge increases battery life. Defendant may argue this requires more than incidental power conditioning and points to a dedicated circuit designed to supplement or recondition the battery, a feature not typically present in standard Qi receiver circuits. The patent itself provides little detail to distinguish between these interpretations, making it a likely point of dispute.

VI. Other Allegations

• Indirect Infringement: The complaint alleges that Motorola induces infringement by distributing product literature and website materials that instruct end users on how to use the accused "Wireless Power Share" feature (Compl. ¶36). The complaint also makes a conclusory allegation of contributory infringement (Compl. ¶34).
• Willful Infringement: Willfulness is alleged based on Defendant's continuation of infringing activities after receiving notice of infringement via the filing and service of the complaint (Compl. ¶31, ¶36, ¶37). No pre-suit knowledge is alleged.

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

The resolution of this dispute may depend on the court's determination of the following key questions:

1. Evidentiary Sufficiency: A primary evidentiary question will be one of technical mapping: can Plaintiff demonstrate that the standard power management circuitry within the accused Motorola smartphones contains the specific "capacitor" element recited in the asserted claims, which is functionally defined as storing and discharging energy for the express purpose of "increasing battery life"?

2. Definitional Scope: The case will involve a critical issue of claim construction: can the term "power adapter," as used in claim 8 and depicted in the specification as a separate physical unit, be interpreted broadly enough to read on the integrated power-receiving circuits of an entire mobile phone?

3. Functional Mismatch: A central point of contention will likely be one of operative function: does the accused "Wireless Power Share" feature, which enables a simple on/off power transfer, perform the method of "configuring" a WPTM through a "wireless...application" and managing power "thresholds" as described in the patent, or is there a fundamental mismatch between the claimed method and the accused functionality?