Minotaur Systems LLC v. BP PLC

I. Executive Summary and Procedural Information

• Parties & Counsel:

  • Plaintiff: Minotaur Systems LLC (Delaware)
  • Defendant: BP p.l.c. (UK)
  • Plaintiff’s Counsel: Rabicoff Law LLC

• Case Identification: 2:25-cv-00883, E.D. Tex., 08/26/2025

• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because the defendant is a foreign corporation.

• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to systems for monitoring electric vehicle charging by associating the amount of energy supplied with the geographic location of the charging event.

• Technical Context: The technology addresses the need to accurately track and verify electric vehicle charging for incentive programs, which often provide credits or discounts for energy used specifically for vehicle charging.

• Key Procedural History: The complaint does not reference 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

• Patent Identification: U.S. Patent No. 8,417,402, issued April 9, 2013 (the “'402 Patent”).

The Invention Explained

• Problem Addressed: The patent’s background section describes the challenge of administering governmental incentive programs for electric vehicle (EV) charging. To properly grant discounts or credits, it is necessary to differentiate between electricity used to charge an EV and electricity used for other purposes, and to verify the location of the charging event ('402 Patent, col. 1:10-23).

• The Patented Solution: The invention is an in-vehicle "energy meter unit" that solves this problem by combining location and energy data. As described in the specification and depicted in Figure 2, the unit contains a location-determining system (e.g., a GPS module), energy measuring circuitry, and a central processing unit (CPU). The CPU receives location data and energy measurement data and associates the amount of energy supplied to the vehicle's battery with the specific location where the charging occurred ('402 Patent, Abstract; col. 2:10-17). This associated data can then be transmitted to a central server for processing incentive claims ('402 Patent, col. 2:4-9).

• Technical Importance: This technology enables automated and verifiable reporting for EV charging, which can facilitate the administration of large-scale incentive programs without restricting users to designated charging stations ('402 Patent, col. 1:24-32).

Key Claims at a Glance

• The complaint asserts infringement of unspecified "exemplary claims" (Compl. ¶11). Claim 1 is the first independent claim of the ’402 Patent.

• Claim 1 of the ’402 Patent requires:

  • 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 identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are allegedly identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶16). This exhibit was not provided with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused instrumentalities. It alleges only that the unspecified products "practice the technology claimed by the '402 Patent" (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an unprovided "Exhibit 2" to support its infringement allegations (Compl. ¶16, ¶17). Without this exhibit, a detailed element-by-element analysis is not possible based on the complaint's text. The complaint's narrative theory alleges that Defendant’s "Exemplary Defendant Products" directly infringe by being made, used, sold, and internally tested, and that these products "satisfy all elements of the Exemplary '402 Patent Claims" (Compl. ¶11, ¶12, ¶16).

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the claim language and the general nature of the technology, several potential points of contention may arise during litigation.

• Scope Questions: A central question may concern the scope of the term "associating." The dispute could turn on whether the accused products must create a single, unified data record linking energy and location data at the time of charging, or if the claim can be read to cover systems where energy and location data are logged separately and correlated later by software.

• Technical Questions: A likely technical question is whether the method used by the accused products to determine energy consumption qualifies as an "energy meter for measuring a charge energy." For instance, if the accused products calculate energy consumption based on data from a vehicle's general battery management system rather than using a distinct hardware meter, the parties may dispute whether this software-based calculation meets the claim limitation.

V. Key Claim Terms for Construction

The Term: "associating" (from Claim 1)

• Context and Importance: This term is the active link between the two key pieces of data in the claim: the energy measurement and the location. Its construction will define the required relationship between these data points. Practitioners may focus on this term because a narrow definition could require a specific type of integrated data structure, while a broader definition could cover less direct methods of correlation.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the processor "receiving the current location and measure of energy" and "associating" them, without specifying the precise mechanism or data format for this association ('402 Patent, col. 4:51-56). This lack of specificity may support a construction that encompasses any logical linking of the two data types.
  • Evidence for a Narrower Interpretation: The stated purpose of the invention is to "validate a claim" and "facilitate proper credits" tied to a specific address ('402 Patent, col. 3:9-15). This purpose might support a narrower construction requiring a robust, contemporaneous data-linking process sufficient for auditable financial transactions.

The Term: "energy meter for measuring a charge energy supplied to a battery" (from Claim 1)

• Context and Importance: This term defines the component responsible for quantifying the energy. The dispute will likely center on whether this requires a dedicated hardware device or if it can be satisfied by software functionality within a larger system.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term "energy meter" is not explicitly defined in the specification, potentially leaving it open to its plain and ordinary meaning, which could include software-based measurement systems that perform the same function as a hardware meter ('402 Patent, col. 2:15).
  • Evidence for a Narrower Interpretation: Figure 2 of the patent depicts the "Power Meter" (36) as a distinct block, separate from the "CPU" (30) ('402 Patent, Fig. 2). This graphical separation could be cited to argue that the claim requires a physically or logically distinct component dedicated to energy measurement, rather than a software function running on a general-purpose processor.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’402 Patent (Compl. ¶14).

• Willful Infringement: The complaint asserts that Defendant has actual knowledge of infringement based on the service of the complaint and its attached (but unprovided) claim charts (Compl. ¶13). This forms a basis for an allegation of post-suit willful infringement.

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

• A primary issue will be one of evidentiary development: The complaint is devoid of specific factual allegations identifying the accused products or describing their operation. Consequently, the initial phase of the case will likely focus on discovery to establish the basic facts of what Defendant's products are and how they function.

• A central claim construction question will be the definitional scope of "associating": Can this term be satisfied by a system that merely time-stamps separate energy and location data logs for later correlation, or does it require the creation of a single, integrated data record at the time of charging? The resolution of this issue will significantly impact the infringement analysis.

• A key technical question will be one of structural interpretation: Does the claim limitation "energy meter" require a distinct hardware component as arguably depicted in the patent’s figures, or can it be met by software within a vehicle’s broader battery management or telematics system that calculates energy usage?