Minotaur Systems LLC v. Elmec Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Minotaur Systems LLC (Delaware)
  • Defendant: Elmec Inc. (Canada)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00638, E.D. Tex., 06/16/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has an established place of business in the District and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s electric vehicle charging products infringe a patent related to monitoring and reporting the location and amount of energy supplied to an electric vehicle.
• Technical Context: The technology addresses the need to accurately track electric vehicle charging for participation in governmental or utility incentive programs, which often require differentiating between energy used for vehicles and general household consumption.
• Key Procedural History: No prior litigation, Inter Partes Review (IPR) proceedings, or licensing history is mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 8,417,402 - Monitoring of power charging in vehicle

• The Invention Explained:
  • Problem Addressed: As electric vehicles grew in popularity, government incentive programs were created to encourage their use. The patent’s background section notes the difficulty in differentiating electricity used for charging a vehicle from electricity used for other purposes, particularly at a home outlet, which could restrict vehicle owners from benefiting from such programs unless they used designated public stations ( ’402 Patent, col. 1:15-32).
  • The Patented Solution: The patent describes an in-vehicle "energy meter unit" designed to solve this problem. As depicted in Figure 1, the unit combines an energy meter, a location-determining system (e.g., GPS), and a processor ( ’402 Patent, col. 2:10-17). When a vehicle is plugged in, the unit measures the energy supplied to the battery and simultaneously records the vehicle's geographic location. The processor then associates the amount of energy charged with that specific location, creating a verifiable record that can be transmitted to a central data collection server for managing credits or billing ( ’402 Patent, col. 2:35-42; col. 2:55-67).
  • Technical Importance: This technology purports to enable accurate, location-based verification of EV charging, thereby allowing energy suppliers and program administrators to extend credits or special rates to users regardless of where they charge their vehicle ( ’402 Patent, col. 1:24-32).
• Key Claims at a Glance:
  The complaint asserts infringement of "exemplary claims" without specifying claim numbers, but incorporates by reference an exhibit containing claim charts (Compl. ¶11, ¶16). Based on the technology described, analysis centers on the patent’s broadest independent claim, Claim 1.
  • Independent Claim 1:
    • An energy meter for an electric vehicle comprising;
    • a location-determining system for determining a current location of the vehicle;
    • an energy meter for measuring a charge energy supplied to a battery on the vehicle; and
    • a processor receiving the current location and measure of energy charging the battery and associating the measure of charge energy supplied to the battery with the location at which the battery was supplied with the charge energy.
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products in its main body. It refers to "Exemplary Defendant Products" which are identified in claim charts attached as Exhibit 2 (Compl. ¶11). This exhibit was not provided with the complaint.

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '402 Patent" (Compl. ¶16). Based on this allegation, the accused functionality involves monitoring the charging of electric vehicles. The complaint alleges that Defendant makes, uses, sells, and imports these products and provides "product literature and website materials" that instruct end users on their use (Compl. ¶11, ¶14). The complaint does not provide specific details on the products' market positioning.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of the ’402 Patent but provides its detailed infringement theory in claim charts (Exhibit 2), which are incorporated by reference but not included in the provided filing (Compl. ¶16-17). The core allegation is that the "Exemplary Defendant Products" practice the claimed technology and "satisfy all elements of the Exemplary '402 Patent Claims" (Compl. ¶16). No probative visual evidence provided in complaint.

Identified Points of Contention

• Lacking specific product details, analysis of the allegations raises several high-level questions for the court.
  • Scope Questions: A central dispute may revolve around whether the accused products contain the three distinct components required by Claim 1: a "location-determining system," an "energy meter," and a "processor." A question for the court is whether these functions must be performed by discrete hardware modules as depicted in the patent's embodiments (e.g., ’402 Patent, Fig. 2) or if they can be met by software operating on general-purpose hardware within a charging system or vehicle.
  • Technical Questions: The claim requires a processor that "associat[es]" the energy measurement with the location. The infringement analysis will depend on evidence showing how the accused products link these two specific data points. A key question will be whether the accused products perform this specific association step, or if they merely collect location and energy data independently, leaving any "association" to be performed by a user or a separate backend system, which may not satisfy the claim limitation.

V. Key Claim Terms for Construction

The Term: "location-determining system"

• Context and Importance: This term's construction is critical because it defines the scope of the first element of Claim 1. Defendant may argue for a narrow construction limited to the primary embodiment (GPS), while Plaintiff will likely argue for a broader meaning to encompass modern location technologies.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification explicitly states that the system is not limited to GPS, listing alternatives such as "cell-tower triangulation, or accelerometers, speedometer, compass, and other dead-reckoning hardware and software" ( ’402 Patent, col. 2:12-15).
  • Evidence for a Narrower Interpretation: The abstract and primary embodiment focus heavily on a "GPS unit" (’402 Patent, Abstract; col. 2:1-3). A defendant might argue that the alternatives listed are merely a generic recitation and that the true invention is centered on a dedicated satellite-based positioning system.

The Term: "associating"

• Context and Importance: This term in Claim 1 is the active step performed by the processor and is central to the invention's purpose. The dispute will likely focus on what technical process qualifies as "associating" the energy data with the location data.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term itself is not explicitly defined, which could support an argument for giving it its plain and ordinary meaning, covering any form of linking, tagging, or storing the two data points together in a single record.
  • Evidence for a Narrower Interpretation: The specification describes a specific data flow where a "processor [is] receiving the current location and measure of energy" and then acts upon them ( ’402 Patent, col. 3:52-56). This could support a narrower construction requiring that a single processor directly receive both discrete inputs and perform the linking function, potentially excluding systems where these functions are distributed or performed asynchronously.

VI. Other Allegations

Indirect Infringement

• The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" which allegedly instruct customers on how to use the accused products in a manner that directly infringes the ’402 Patent (Compl. ¶14-15).

Willful Infringement

• The willfulness allegation is based on post-suit conduct. The complaint asserts that the filing and service of the complaint itself provides Defendant with "actual knowledge of infringement" and that any continued infringing activity thereafter is willful (Compl. ¶13-14). No allegations of pre-suit knowledge are made.

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

• A core issue will be one of structural correspondence: Do the accused products contain the distinct elements of a "location-determining system," an "energy meter," and a "processor" as required by Claim 1, or is the allegedly infringing functionality performed by a more integrated or software-defined architecture that falls outside the claim's scope?
• A key evidentiary question will be one of operational proof: What evidence will be presented to demonstrate that the accused products perform the specific claim step of "associating" the energy measurement with the location data, as opposed to merely enabling the separate collection of those two data types for potential later use?
• The case may also turn on a question of claim scope: Can the term "location-determining system," which the patent explicitly broadens beyond GPS, be construed to read on the specific location-finding technologies implemented in the accused products, whatever they may be?