Minotaur Systems LLC v. Ev Dot Energy Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Minotaur Systems LLC (Delaware)
  • Defendant: Ev Dot Energy Ltd (England)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00639, E.D. Tex., 06/16/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the district and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s products related to electric vehicle charging infringe a patent for monitoring and associating energy consumption with a specific geographic location.
• Technical Context: The technology addresses the need to accurately track and verify electricity used for charging electric vehicles, distinct from general power consumption, to enable participation in governmental or utility incentive programs.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

U.S. Patent No. 8,417,402, Monitoring of power charging in vehicle, issued April 9, 2013

The Invention Explained

• Problem Addressed: The patent describes a challenge created by incentive programs for electric vehicle (EV) adoption, which may offer credits or discounts for the electricity used to charge a vehicle. Because EVs can be charged at various locations, including standard household outlets, it is difficult to "differentiate between electric energy used for charging the vehicle and energy used for other purposes," which restricts owners to designated charging stations to receive benefits ('402 Patent, col. 1:18-22, 1:29-33).
• The Patented Solution: The invention is an in-vehicle "energy meter unit" designed to solve this tracking problem. The unit contains a location-determining system (like GPS), circuitry to measure the energy supplied to the vehicle's battery, and a processor. The processor links, or "associates," the measured amount of energy with the specific location where the charging occurred. This data can then be transmitted to a central server to validate claims for energy credits ('402 Patent, Abstract; col. 2:34-42). Figure 2 of the patent illustrates the key components of this unit, including a GPS module (38), a power meter (36), and a CPU (30) ('402 Patent, Fig. 2).
• Technical Importance: This technology provides a method for decentralized, verifiable tracking of EV charging, potentially enabling broader and more flexible application of energy incentive programs beyond a fixed network of commercial charging stations ('402 Patent, col. 1:22-26).

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims" of the '402 Patent, referring to "Exemplary '402 Patent Claims" identified in an external exhibit not provided with the complaint (Compl. ¶11). The patent’s independent claims are 1, 7, and 11.
• Independent Claim 1 (An energy meter for an electric vehicle):
  • 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 specify which dependent claims may be asserted.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as the "Exemplary Defendant Products" (Compl. ¶11).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products. It alleges that the products "practice the technology claimed by the '402 Patent" and that infringement is detailed in charts contained in an "Exhibit 2," which was not included with the filed complaint (Compl. ¶¶16-17). No specific product names, features, or operational details are described in the body of the complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe claims of the '402 Patent, and it incorporates by reference "charts comparing the Exemplary '402 Patent Claims to the Exemplary Defendant Products" from a non-proffered Exhibit 2 (Compl. ¶¶16-17). Without this exhibit, a detailed element-by-element analysis based on the complaint's allegations is not possible. The infringement theory, as stated, is that the accused products "satisfy all elements of the Exemplary '402 Patent Claims" (Compl. ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the patent's claims and the general nature of the dispute, the litigation may focus on several key questions:

• Scope Questions: A central issue may be the interpretation of "associating" the energy measure with the location. The court will need to determine the specific technical action required to meet this limitation—for example, whether simply time-stamping two separate data logs is sufficient, or if a more integrated data record is required by the claims.
• Technical Questions: A key factual question will be whether the accused products contain a "location-determining system" and an "energy meter" as distinct or combined components that function as claimed. For instance, if a product estimates energy consumption based on charging time and standard power ratings, it raises the question of whether this legally constitutes "measuring a charge energy" as required by the claim.

V. Key Claim Terms for Construction

• The Term: "associating" (from Claim 1)

• Context and Importance: This term is the functional core of Claim 1, defining the link between the two key pieces of data: energy consumed and location. The breadth of this term will likely dictate the scope of infringement, as it determines how closely integrated the location and energy data must be. Practitioners may focus on this term because its construction will determine whether systems that merely collect location and energy data in parallel, without creating a specific, unified record for each charging event, fall within the claim's scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification does not provide a specific definition of "associating," which may support an argument that the term should be given its plain and ordinary meaning, potentially covering any form of logical linkage between the data points (e.g., storing them with a common identifier or timestamp in a database) ('402 Patent, col. 3:55-59).
  • Evidence for a Narrower Interpretation: A party could argue that the patent's overall objective—to "validate a claim" for energy credits—implies that "associating" requires creating a secure, tamper-resistant data packet where the location and energy data are inextricably linked for a specific charging session to ensure data integrity for verification purposes ('402 Patent, col. 3:12-15).

• The Term: "location-determining system" (from Claim 1)

• Context and Importance: The definition of this term is critical for establishing the first element of Claim 1. The dispute may turn on what types of hardware and software meet this definition and what level of accuracy is required.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification explicitly lists multiple technologies, stating the system can be a "GPS module (or other location-determining hardware, such as cell-tower triangulation, or accelerometers, speedometer, compass, and other dead-reckoning hardware and software, etc)" ('402 Patent, col. 2:12-15). This language suggests the inventor contemplated a broad range of technologies beyond high-precision GPS.
  • Evidence for a Narrower Interpretation: The primary embodiment and figures focus heavily on GPS ('402 Patent, Fig. 2; col. 2:9-12). An argument could be made that while other systems are mentioned, the context of validating a location for financial credits requires a system with a degree of geographic accuracy and reliability comparable to GPS, thereby narrowing the scope to exclude less precise methods.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct and encourage end-users to operate the accused products in a manner that directly infringes the '402 Patent (Compl. ¶14).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge" of the '402 Patent and its infringement at least since the service of the complaint and the associated claim charts (Compl. ¶13). This forms the basis for a claim of post-suit willful infringement.

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

Given the limited factual detail in the complaint, the resolution of this case will likely depend on evidence developed during discovery and the court's construction of key claim terms. The central questions are:

1. A core issue will be one of definitional scope: can the functional term "associating," as used in the patent, be construed broadly to cover any system that logs location and energy data concurrently, or does it require the creation of a specific, integrated data record linking the two for each discrete charging event?
2. A key evidentiary question will be one of technical implementation: what are the precise components and software logic of the accused products? Discovery will be required to determine if they in fact perform the claimed functions of "measuring" energy and "determining" location in a manner that meets the claim limitations as construed by the court.