DCT

2:24-cv-00654

Sovereign Peak Ventures LLC v. OnePlus Technology Shenzhen Co Ltd

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Sovereign Peak Ventures, LLC (Texas)
- Defendant: OnePlus Technology (Shenzhen) Co., Ltd. (People's Republic of China)
- Plaintiff’s Counsel: Connor Lee & Shumaker PLLC
Case Identification: 2:24-cv-00654, E.D. Tex., 08/09/2024
Venue Allegations: Plaintiff alleges that venue is proper because Defendant is a foreign entity, making venue appropriate in any judicial district pursuant to 28 U.S.C. § 1391(c)(3). The complaint also alleges that Defendant sells products in the district and has previously consented to or not contested venue in the Eastern District of Texas.
Core Dispute: Plaintiff alleges that Defendant’s smartphones equipped with wireless charging functionality infringe eight U.S. patents related to the design, operation, and internal layout of non-contact charging systems.
Technical Context: The patents relate to inductive wireless charging technology and its integration into compact electronic devices like smartphones, a field where efficient use of internal space and management of electromagnetic interference are significant design challenges.
Key Procedural History: The patents-in-suit originated with Panasonic Corporation and were acquired by Plaintiff. The complaint alleges that Plaintiff provided Defendant with pre-suit notice of infringement on July 15, 2022, including access to a data room containing claim charts, and that Defendant acknowledged receipt of this information but refused to take a license. These allegations form the basis for a claim of willful infringement.

Case Timeline

Date	Event
2011-12-14	Earliest Priority Date ('282 Patent)
2012-02-17	Earliest Priority Date ('481, '735, '225, '075 Patents)
2012-06-28	Earliest Priority Date ('272, '090 Patents)
2015-11-05	Earliest Priority Date ('913 Patent)
2017-04-11	Issue Date (U.S. Patent No. 9,620,282)
2018-04-03	Issue Date (U.S. Patent No. 9,935,481)
2018-06-05	Issue Date (U.S. Patent No. 9,991,735)
2018-08-07	Issue Date (U.S. Patent No. 10,044,225)
2019-03-12	Issue Date (U.S. Patent No. 10,230,272)
2019-11-05	Issue Date (U.S. Patent No. 10,468,913)
2020-02-25	Issue Date (U.S. Patent No. 10,574,090)
2020-04-21	Accused Product Launch (OnePlus 8 Pro)
2021-03-23	Accused Product Launch (OnePlus 9, 9 Pro)
2021-07-20	Issue Date (U.S. Patent No. 11,070,075)
2022-01-11	Accused Product Launch (OnePlus 10 Pro)
2022-07-15	Plaintiff Alleges Pre-Suit Notice to Defendant
2023-12-05	Accused Product Launch (OnePlus 12)
2024-08-09	Complaint Filing Date

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

U.S. Patent No. 9,620,282 - “Noncontact connector apparatus and system using inductive coupling between coils”

Issued: April 11, 2017

The Invention Explained

Problem Addressed: The patent's background section describes a technical challenge in wireless power transfer systems where strong electromagnetic coupling between transmitter and receiver coils can create an undesirable "double-peaked narrow-band" frequency response, which prevents stable, wide-band operation (’282 Patent, col. 2:5-20).
The Patented Solution: The invention claims to solve this by introducing a magnetic body between the two coils. This body is designed to increase the self-inductance of each coil, which in turn lowers the coupling coefficient between them. This adjustment transforms the system's frequency response from the problematic double-peaked characteristic to a more stable "single-peaked wide-band characteristic," enabling efficient power transfer over a broader range of operating frequencies (’282 Patent, Abstract; col. 2:21-38).
Technical Importance: This method provides a way to engineer more robust wireless charging systems that are less sensitive to frequency shifts and minor physical misalignments between the device and the charger (’282 Patent, col. 2:35-38).

Key Claims at a Glance

The complaint asserts at least independent claim 10 (Compl. ¶84).
Essential elements of claim 10 include:
- A power transfer apparatus comprising a power receiver circuit and a noncontact connector apparatus.
- The noncontact connector apparatus includes a receiver coil with a winding on a second plane, designed to electromagnetically couple with a transmitter coil on a first plane.
- The apparatus also includes a "second magnetic body" adjacent to the receiver coil that covers at least part of its winding.
- A functional requirement that the "frequency characteristic of transmission efficiency...changes from a double-peaked narrow-band characteristic to a single-peaked wide-band characteristic."

U.S. Patent No. 9,935,481 - “Mobile terminal including wireless charging module and battery pack”

Issued: April 3, 2018

The Invention Explained

Problem Addressed: The patent addresses the difficulty of integrating both a non-contact charging module and other components like an NFC antenna into a thin mobile device without performance degradation due to interference or inefficient use of limited internal space (’481 Patent, col. 1:12-25).
The Patented Solution: The invention discloses specific internal layouts for a mobile terminal's components. It arranges the battery pack and the main circuit board in a non-overlapping "plan view." The wireless charging module is then positioned to overlap with either the battery pack or the circuit board, but not both simultaneously. This configuration aims to optimize the use of space while managing the placement of key components to maintain a thin device profile (’481 Patent, Abstract; col. 4:1-20).
Technical Importance: This architectural approach to component placement enables the integration of multiple functionalities common in modern smartphones (e.g., wireless charging, NFC) within a compact form factor without compromising performance.

Key Claims at a Glance

The complaint asserts at least independent claim 1 (Compl. ¶97).
Essential elements of claim 1 include:
- A mobile terminal comprising a substantially planar wireless charging module, a substantially planar battery pack, and a circuit board substrate.
- The battery pack is configured to store power from the wireless charging module.
- The circuit board controls the terminal's operation.
- A specific spatial arrangement where, in a plan view, the wireless charging module overlaps the circuit board or the battery pack, but the circuit board and the battery pack do not overlap each other.

U.S. Patent No. 9,991,735 - “Electronic device including non-contact charging module and battery”

Issued: June 5, 2018
Technology Synopsis: This patent addresses the internal layout of electronic devices to accommodate both a non-contact charging module and an NFC antenna. The invention describes arrangements where the charging module and battery are placed in distinct, non-overlapping regions, with the NFC antenna positioned to avoid interference, enabling both functionalities to coexist in a compact housing.
Asserted Claims: At least claim 1 (Compl. ¶110).
Accused Features: The complaint alleges that the internal arrangement of the wireless charging module, battery, NFC antenna, and circuit board in the Accused Products infringes this patent (Compl. ¶52-61).

U.S. Patent No. 10,044,225 - “Electronic device including non-contact charging module”

Issued: August 7, 2018
Technology Synopsis: This patent focuses on an electronic device where a non-contact charging module and a sheet antenna (like an NFC antenna) are housed together but are not stacked. This non-laminated arrangement is intended to suppress deterioration in power transmission efficiency that can occur when the two components interfere with each other.
Asserted Claims: At least claim 1 (Compl. ¶123).
Accused Features: The complaint accuses the spatial relationship and non-stacked configuration of the wireless charging module and NFC antenna within the Accused Products (Compl. ¶52-61).

U.S. Patent No. 10,230,272 - “Mobile terminal including wireless charging coil and magnetic sheet having inwardly receding portion”

Issued: March 12, 2019
Technology Synopsis: This invention describes a specific geometry for the magnetic sheet used in a wireless charging module. The sheet is rectangular, but one or more of its corners has an "inwardly receding portion," meaning the corner is cut or shaped differently from a standard right-angle corner. This specific shape is intended to optimize performance or fit within a constrained internal layout.
Asserted Claims: At least claim 1 (Compl. ¶136).
Accused Features: The complaint alleges the magnetic sheet in the Accused Products is rectangular and has corner portions that recede inwardly, with one receding distance being greater than others, mapping to the patent claims (Compl. ¶63). A photograph of the magnetic sheet with an overlay of the claimed shape is provided as evidence (Compl. p. 32).

U.S. Patent No. 10,468,913 - “Electronic device including non-contact charging module”

Issued: November 5, 2019
Technology Synopsis: The patent describes an electronic device with a specific arrangement of a charging coil, a magnetic body, a battery, a camera, and a communication coil (e.g., NFC). The components are divided into two separated regions in a plan view to manage space and prevent interference, with the battery, charging coil, and magnetic body located in a second region separate from the camera and communication coil.
Asserted Claims: At least claim 1 (Compl. ¶149).
Accused Features: The complaint alleges the Accused Products arrange their internal components into distinct regions as claimed, with the battery, charging coil, and magnetic material separated from the NFC antenna and camera (Compl. ¶74-75).

U.S. Patent No. 10,574,090 - “Mobile terminal including wireless charging coil and magnetic sheet having inwardly receding portion”

Issued: February 25, 2020
Technology Synopsis: Similar to the ’272 Patent, this invention relates to a mobile terminal where the magnetic sheet for the wireless charging coil has a specific shape with an "inwardly receding portion" at one or more corners. This design accommodates other internal components and manages magnetic flux.
Asserted Claims: At least claim 1 (Compl. ¶162).
Accused Features: The complaint realleges that the magnetic sheet within the Accused Products has the claimed inwardly receding corner geometry (Compl. ¶63).

U.S. Patent No. 11,070,075 - “Electronic device including non-contact charging module and battery”

Issued: July 20, 2021
Technology Synopsis: This patent describes an internal layout for a mobile device where the wireless charging module overlaps with either the circuit board or the battery pack. It is a continuation of the family that includes the ’481 and ’735 patents, focusing on efficient spatial arrangement of these core components.
Asserted Claims: At least claim 10 (Compl. ¶175).
Accused Features: The complaint accuses the internal component layout of the Accused Products, specifically the overlapping relationship between the charging module and the battery/circuit board, as infringing (Compl. ¶79).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are smartphones sold by Defendant, including the OnePlus 8 Pro, 9, 9 Pro, 10 Pro, and 12, and other similar products featuring wireless charging (Compl. ¶21, 80).

Functionality and Market Context

The Accused Products are mobile devices that support wireless charging based on the Qi standard promulgated by the Wireless Power Consortium (WPC) (Compl. ¶23). Their internal architecture includes a wireless power receiver circuit, a receiver coil, a magnetic shielding sheet, a battery pack, a main circuit board substrate, and an NFC antenna (Compl. ¶28, 29, 33, 41, 45, 46). The complaint includes several annotated photographs from a device teardown to illustrate these components, such as one identifying the receiver coil inside the device housing (Compl. p. 12, ¶30). Defendant markets its wireless charging technology, under brands like "SUPERVOOC" and "AIRVOOC," as a key feature, promoting its speed and convenience (Compl. ¶24, 25).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,620,282 Infringement Allegations

Claim Element (from Independent Claim 10)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A power transfer apparatus comprising: a power receiver circuit; and a noncontact connector apparatus connected to the power receiver circuit...	The Accused Products are identified as power transfer apparatuses containing wireless power receiver circuitry and a noncontact connector apparatus (wireless charging module).	¶26-29	col. 6:3-6
...the noncontact connector apparatus comprises a receiver coil that is provided to be adjacent, so as to be electromagnetically coupled, to a transmitter coil...	The Accused Products contain a receiver coil within their wireless charging module designed to couple with a transmitter coil in a wireless charger.	¶30-31	col. 6:7-10
...the receiver coil includes a winding wound on a second plane opposed to be adjacent to a first plane on which the transmitter coil is provided...	The receiver coil winding is on a plane within the phone, which is opposed to the plane of the transmitter coil when the phone is placed on a charging pad.	¶32	col. 6:11-14
...the noncontact connector apparatus further comprises a second magnetic body which is adjacent to the receiver coil and which covers at least part of the winding of the receiver coil...	The complaint identifies a shielding material, described as a "second magnetic body," located adjacent to the receiver coil. A photograph shows this component covering the coil winding.	¶33-34	col. 6:15-18
...a frequency characteristic of transmission efficiency from the transmitter coil to the receiver coil changes from a double-peaked narrow-band characteristic to a single-peaked wide-band characteristic.	The complaint alleges that because the Accused Products use Qi-compliant components, their coupling coefficient is lowered, which results in the claimed change from a double-peaked to a single-peaked frequency response.	¶35-39	col. 7:31-35

Identified Points of Contention (’282 Patent)

Functional Questions: A primary point of contention may be the final functional limitation. The complaint alleges the claimed "change" in frequency characteristic occurs as a consequence of using Qi-compliant components, supporting this with a generic graph from a technical publication (Compl. p. 17, ¶38). What evidence does the complaint provide that this specific functional behavior is actually exhibited by the Accused Products themselves, as opposed to being a general principle of some wireless charging systems?
Scope Questions: How will the court construe the term "changes"? Does it require that the system be capable of operating in both the double-peaked and single-peaked modes, or is it sufficient that the final, as-built product operates in the single-peaked mode as a result of design choices that avoided a double-peaked mode?

U.S. Patent No. 9,935,481 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A mobile terminal comprising: a wireless charging module including a charging coil, the wireless charging module being substantially planar;	The Accused Products are identified as mobile terminals containing a substantially planar wireless charging module with a charging coil.	¶41	col. 8:51-53
a battery pack configured to store power from the wireless charging module, the battery pack being substantially planar;	The Accused Products contain a substantially planar battery pack that stores power received from the wireless charging module.	¶45	col. 8:54-56
and a circuit board substrate configured to control operation of the mobile terminal...	The Accused Products contain a main circuit board that controls their operation.	¶46	col. 8:57-59
...wherein the wireless charging module, the battery pack, and the circuit board substrate are arranged in a plan view such that the wireless charging module overlaps the circuit board substrate or the battery pack...	The complaint alleges the wireless charging module is arranged to overlap either the circuit board or the battery pack.	¶47	col. 8:60-63
...and the circuit board substrate and the battery pack do not overlap each other.	Annotated photographs are provided to show that the main circuit board and the battery pack are located in separate, non-overlapping areas of the device's interior.	¶47, 58	col. 8:63-65

Identified Points of Contention (’481 Patent)

Scope Questions: A central issue may be the construction of "overlaps." Does this term require direct physical stacking, or merely alignment along the thickness axis of the device in a "plan view"? The complaint uses annotated photographs showing this alignment (Compl. p. 27, ¶58).
Technical Questions: What are the precise boundaries of the claimed "wireless charging module," "circuit board substrate," and "battery pack"? A defendant may argue that these are not discrete, non-overlapping components as claimed, but rather are more integrated in the actual product, potentially raising questions about whether the claim language accurately reads on the accused device's architecture.

V. Key Claim Terms for Construction

For the ’282 Patent

The Term: "frequency characteristic...changes from a double-peaked narrow-band characteristic to a single-peaked wide-band characteristic"
Context and Importance: This functional language is the core of the asserted apparatus claim's novelty. Infringement will depend not just on the presence of physical components but on proving that they cause this specific operational effect. Practitioners may focus on this term because it links the physical structure (coils, magnetic body) to a specific performance outcome, making it a potential point of dispute over both infringement and indefiniteness.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent's detailed description explains this change as a general physical phenomenon resulting from lowering the coupling coefficient 'k' by increasing self-inductance (’282 Patent, col. 7:1-35), which could support an interpretation where any system designed according to this principle infringes.
- Evidence for a Narrower Interpretation: The patent provides specific graphs (e.g., Fig. 5) illustrating the "double-peaked" and "single-peaked" responses. A defendant may argue these figures define the required characteristics, potentially requiring the accused device to exhibit a response that closely matches the patent's exemplary graphs.

For the ’481 Patent

The Term: "overlaps"
Context and Importance: The infringement analysis for the asserted claim hinges on the spatial relationship between three key internal components. The definition of "overlaps" in a "plan view" will determine whether the layout of the Accused Products falls within the claim scope.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "overlaps," and the specification describes components as being "disposed to be placed one on top of the other" (’481 Patent, col. 6:12-13), which may suggest that any positional correspondence along the device's thickness axis (the Z-axis) is sufficient.
- Evidence for a Narrower Interpretation: The patent's figures (e.g., FIG. 15A) show distinct components in specific arrangements. A defendant could argue that "overlaps" implies a more direct stacking relationship or a certain degree of vertical alignment, potentially excluding arrangements where components are merely adjacent or partially aligned.

VI. Other Allegations

Indirect Infringement

The complaint alleges that Defendant induces infringement by its customers. This allegation is based on Defendant selling the Accused Products and providing instructional materials, such as user manuals, that allegedly encourage users to operate the devices in an infringing manner (e.g., by using the wireless charging feature) (Compl. ¶90, 103).

Willful Infringement

The complaint makes a specific and fact-based allegation of willful infringement. It states that Plaintiff gave Defendant notice of infringement on July 15, 2022, by providing access to a data room with the asserted patents and claim charts. The complaint further alleges that Defendant acknowledged receipt of this information on May 14, 2024, but continued its allegedly infringing conduct without taking a license, reflecting a business decision to "efficiently infringe" (Compl. ¶92, 186).

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

A core issue will be one of functional proof: For the patents claiming a specific operational characteristic (like the '282 Patent), can Plaintiff demonstrate through empirical testing of the Accused Products that they actually exhibit the claimed "change" in frequency response, or will the infringement theory rest on asserting that such behavior is an inherent property of any Qi-compliant device?
A second central issue will be one of claim construction and spatial definition: For the patents directed to internal component layouts (like the '481 Patent), how will the court define the boundaries of the claimed "modules" and construe relational terms like "overlaps" and "adjacent" in the context of a densely packed modern smartphone, where components may be integrated in complex ways?
A key question for damages will be culpability: Do the complaint's specific allegations of pre-suit notice, which included providing detailed claim charts, followed by continued alleged infringement, constitute the type of egregious conduct required under Halo to support a finding of willful infringement and justify an award of enhanced damages?