DCT

2:25-cv-00974

Electronic Edison Transmission Tech LLC v. Nothing Technology Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00974, E.D. Tex., 09/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones, which feature reverse wireless charging, infringe a patent related to systems and methods for transferring power between mobile devices.
  • Technical Context: The technology enables a mobile device with a sufficient battery level to act as a wireless charging source for another nearby mobile device, addressing the common problem of a depleted battery when no conventional power source is available.
  • Key Procedural History: The complaint notes that the asserted patent was examined and allowed by the USPTO after consideration of prior art, which Plaintiff argues supports the patent's novelty and non-obviousness.

Case Timeline

Date Event
2011-09-03 Priority Date for U.S. Patent No. 9,448,603
2016-09-20 U.S. Patent No. 9,448,603 Issued
2025-09-23 Complaint Filed

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

U.S. Patent No. 9,448,603 - “Transferring Power to a Mobile Device”

  • Patent Identification: U.S. Patent No. 9,448,603, “Transferring Power to a Mobile Device,” issued September 20, 2016 (’603 Patent).

The Invention Explained

  • Problem Addressed: The patent addresses situations where a user's mobile device has a low battery, but no conventional power source (e.g., an electrical outlet) is available, while another user-accessible mobile device has substantial battery life remaining (Compl. ¶16; ’603 Patent, col. 1:22-32).
  • The Patented Solution: The invention provides for a "donor" mobile device to wirelessly transfer power to a "receptor" mobile device using various technologies, including inductive or capacitive coupling (Compl. ¶16; ’603 Patent, Abstract; col. 4:16-28). A software application on the devices allows a user to configure and manage the power transfer, for example by setting power thresholds to start or stop the charging process (’603 Patent, col. 7:46-54).
  • Technical Importance: The technology enables ad-hoc power sharing between personal electronic devices, increasing their utility and uptime without reliance on dedicated charging infrastructure (’603 Patent, col. 3:58-68).

Key Claims at a Glance

  • The complaint asserts at least independent claim 8 (Compl. ¶15, ¶26).
  • The essential elements of independent claim 8, a method claim, are:
    • configuring a wireless power transfer mechanism on the receptor mobile device using a wireless receive application;
    • determining a receptor power threshold using a wireless receive application;
    • receiving power from the donor mobile device and converting it into electric current using the wireless power transfer mechanism;
    • wherein the wireless power transfer mechanism includes a power adapter having a coil, circuit elements to transfer power, and a capacitor to store electric charge that increases battery life when discharged.
  • The complaint does not explicitly reserve the right to assert other claims, but alleges infringement of "one or more claims, including at least Claim 8" (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the "Nothing Phone 3" as an exemplary accused product (Compl. ¶26).

Functionality and Market Context

  • The complaint alleges the Nothing Phone 3 includes a "Wireless Reverse Charging" functionality (Compl. ¶26). This feature, which is described as compliant with the Qi wireless power standard, enables the phone to act as a wireless power source to charge other Qi-compatible devices, such as another Nothing Phone 3, when they are placed back-to-back (Compl. ¶26).
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart attached as Exhibit B purporting to detail the infringement of claim 8 by the accused products (Compl. ¶26, ¶31). However, Exhibit B was not included with the provided complaint document. The narrative allegations state that the "Wireless Reverse Charging" functionality of the Nothing Phone 3 enables the device to wirelessly transfer power from its internal battery to another device, and that this functionality practices the technology claimed in the ’603 Patent (Compl. ¶26). The complaint alleges this infringement is direct, both literally and under the doctrine of equivalents, and is also induced and contributory (Compl. ¶26-27).

  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over whether the integrated circuitry within the accused Nothing Phone 3 can be properly characterized as a "power adapter" as required by claim 8. The defense may argue this term refers to a physically separate accessory, as depicted in certain figures of the patent (e.g., ’603 Patent, Fig. 4A-4C), not integrated phone components.
    • Technical Questions: The complaint does not specify which component of the Nothing Phone 3 constitutes the claimed "capacitor to store electric charge that increases battery life when the capacitor is discharged." The functionality and role of any accused capacitor within the phone's power management system will likely be a key technical question for the court.

V. Key Claim Terms for Construction

  • The Term: "power adapter" (from claim 8)
  • Context and Importance: This term's construction appears central to the dispute. Plaintiff's infringement theory requires that the internal components of the Nothing Phone 3 collectively constitute a "power adapter." If the term is construed more narrowly to mean only a separate, external device used to facilitate power transfer, the infringement allegation against the phone itself may be more difficult to sustain.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's claims and summary repeatedly describe a system where a "donor mobile device" transfers power directly to a "receptor mobile device," which may support an interpretation that the necessary "adapter" functionality is integrated within the mobile devices themselves (’603 Patent, Abstract; col. 2:11-19). The term is not explicitly defined in the specification.
    • Evidence for a Narrower Interpretation: The detailed description includes a specific embodiment showing a separate, external "power adapter 402" that receives power from a donor device (a laptop) and later transfers that stored energy to a receptor device (a mobile phone) (’603 Patent, col. 8:19-31; Figs. 4A-4C). This explicit depiction of a physically distinct adapter could be used to argue for a narrower construction limited to such external accessories.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement of infringement, stating that Nothing distributes "product literature and website materials" that instruct end users on how to use the accused "Wireless Reverse Charging" feature in an infringing manner (Compl. ¶29-30). The complaint also makes a conclusory allegation of contributory infringement (Compl. ¶26).
  • Willful Infringement: The complaint alleges knowledge of infringement "at least as of the service of the present complaint," forming the basis for a claim of post-suit willful infringement if Defendant's conduct continues (Compl. ¶24, ¶28-29).

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

The resolution of this case may turn on the following central questions:

  1. A core issue will be one of definitional scope: Can the term "power adapter," as used in claim 8 and depicted in the specification as a separate accessory, be construed to read on the integrated reverse-charging hardware and software within the accused Nothing Phone 3?
  2. A critical evidentiary question will be how Plaintiff maps the specific elements of claim 8 to the accused device. In particular, the case will require technical evidence demonstrating that the Nothing Phone 3 contains a "capacitor to store electric charge that increases battery life when the capacitor is discharged" and that this component functions in the manner required by the claim.