Cogent Insights Licensing Inc v. Envision Energy Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cogent Insights Licensing Inc. (Canada)
  • Defendant: Envision Energy Ltd. (China)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-1230, E.D. Tex., 12/18/2025
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to power supplies that use induction motors as generators.
• Technical Context: The technology concerns methods for using common induction motors as efficient, rugged power generators, particularly for hybrid electric systems or independent power generation.
• Key Procedural History: No prior litigation, licensing history, or other procedural events are mentioned in the complaint.

Case Timeline

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

U.S. Patent No. 7,330,016 - “Induction generator power supply”

• Issued: February 12, 2008

The Invention Explained

• Problem Addressed: The patent describes the limitations of using induction motors as standalone power generators ('016 Patent, col. 2:42-53). While rugged and inexpensive, their output voltage is unstable when powering reactive (inductive or capacitive) loads, which are extremely common, rendering them "of limited usefulness for independent AC power generation" ('016 Patent, col. 2:63-65).
• The Patented Solution: The invention proposes a system where a prime mover (e.g., a diesel engine) drives an induction motor, causing it to act as a generator ('016 Patent, Fig. 1). The key insight is to rectify the generator's three-phase AC output into direct current (DC) ('016 Patent, col. 5:7-11). Because pure DC power is resistive, this overcomes the instability problem associated with reactive loads ('016 Patent, col. 5:11-14). This DC power can then be stored in an "energy reservoir" like a battery bank and converted back to AC by an inverter if needed ('016 Patent, col. 6:22-26). The patent also teaches intentionally operating the induction motor at an "overspeed"—a rotational speed significantly higher than its rated speed—to increase the power output beyond the motor's nameplate rating ('016 Patent, col. 10:55-61).
• Technical Importance: This approach allows for the use of widely available, low-cost induction motors to create efficient and robust power supplies for applications like hybrid electric vehicles ('016 Patent, col. 1:15-19).

Key Claims at a Glance

• The complaint asserts "exemplary method claims" of the ’016 Patent (Compl. ¶11). Independent claim 1 is a method claim.
• Independent Claim 1:
  • selecting a prime mover having a chosen power rating;
  • choosing an induction motor having a first power rating at a rated speed and a second power rating at an overspeed, said overspeed being at least about 10% greater than the rated speed;
  • choosing the induction motor such that the second power rating is substantially equal to the chosen power rating of the prime mover;
  • driving the induction motor with the prime mover so that it acts as an induction generator; and
  • operating the induction generator at said overspeed.
• The complaint does not explicitly reserve the right to assert dependent claims.

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 describe the specific functionality or identity of the accused products. It states that they are identified in charts included as Exhibit 2, which was not provided with the complaint document (Compl. ¶13). Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality's specific features, operation, or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the '016 Patent" and that they "satisfy all elements of the Exemplary '016 Patent Claims" (Compl. ¶13). It incorporates claim charts by reference from an unprovided exhibit (Compl. ¶14). As the charts are not available, a detailed element-by-element analysis is not possible. The narrative infringement theory is limited to the assertion of direct infringement through the making, using, selling, or importing of the accused products (Compl. ¶11) and through internal testing by Defendant's employees (Compl. ¶12). No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the asserted method claims and the general nature of the technology, the infringement analysis may raise several technical and legal questions for the court:

• Scope Questions: A central question may be whether Defendant's systems, which could include large-scale wind turbines or energy storage solutions, perform the method steps of "choosing" and "selecting" components with specific power ratings as required by claim 1.
• Technical Questions: A key factual dispute may concern the claim element requiring "operating the induction generator at said overspeed." The case could turn on what evidence Plaintiff presents to demonstrate that Defendant's products are, in fact, operated at a speed "at least about 10% greater than the rated speed" of the induction motor component ('016 Patent, col. 13:34-36).

V. Key Claim Terms for Construction

The Term: "overspeed"

• Context and Importance: This term is the technical core of the asserted independent claim, defining the operational state of the induction generator. Its construction will be critical for determining whether the accused products perform the claimed method, as the entire inventive concept of enhanced power output hinges on this specific mode of operation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent repeatedly provides a quantitative floor, stating the overspeed should be "at least about 10%, 25%, 50% or 75% greater than the rated speed" ('016 Patent, col. 11:46-48). This use of "at least about" suggests the patentee did not intend to limit the term to a precise figure but rather a general range above the rated speed.
  • Evidence for a Narrower Interpretation: The specification provides a detailed example where an 1800 RPM motor is turned at 3600 RPM, a 100% overspeed ('016 Patent, col. 11:12-16). A defendant may argue that the term should be understood in the context of such significant increases in speed that approximately "double the motor power rating" ('016 Patent, col. 11:39-40), not merely marginal increases.

The Term: "substantially equal"

• Context and Importance: This term links the power rating of the prime mover to the enhanced power rating of the induction motor at overspeed. The infringement analysis for this element will depend on the degree of variance permitted by the term "substantially." Practitioners may focus on this term because it directly relates to the deliberate design and matching of components, a key step in the asserted method claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "substantially" is a term of approximation, suggesting that the power ratings do not need to be identical. The patent’s general disclosure focuses on the overall system design rather than mandating precise numerical equality ('016 Patent, col. 4:1-3).
  • Evidence for a Narrower Interpretation: The patent explains that the system is designed to match the power characteristics of diesel engines to induction motors ('016 Patent, col. 11:50-54). A party could argue that "substantially equal" should be construed to mean a match close enough to achieve the stated benefits of an efficient, directly-driven system, excluding mismatched components.

VI. Other Allegations

• Willful Infringement: The complaint does not contain a specific count for willful infringement or allege any facts related to pre-suit or post-suit knowledge by the Defendant. The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, which relates to awards of attorney fees (Compl. p. 4, ¶ E.i).

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

This dispute, as framed by the complaint, raises foundational questions of both claim scope and factual proof that will be central to the litigation.

• A core issue will be one of definitional scope: How much deviation is permitted by claim terms such as "at least about 10%" and "substantially equal"? The court's construction of these terms of degree will define the boundaries of infringement.
• A key evidentiary question will be one of operational proof: What evidence can Plaintiff provide to demonstrate that Defendant’s commercial products are actually operated in the "overspeed" condition required by the asserted method claims, as opposed to merely being capable of such operation?