Cogent Insights Licensing Inc v. Kawasaki Heavy Industries Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cogent Insights Licensing Inc. (Canada)
  • Defendant: Kawasaki Heavy Industries, Ltd. (Japan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-01232, E.D. Tex., 12/18/2025
• Venue Allegations: Venue is asserted based on the defendant being a foreign corporation and having committed alleged acts of patent infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s products infringe a patent related to induction generator power supplies.
• Technical Context: The technology concerns power supply systems that use common induction motors as generators, particularly by operating them above their rated speed to increase power output and efficiency for applications like hybrid electric vehicles.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

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

• Patent Identification: U.S. Patent No. 7,330,016, "Induction generator power supply," issued February 12, 2008 (the "’016 Patent").

The Invention Explained

• Problem Addressed: The patent background describes how practical limitations have historically restricted the use of induction motors as generators. A primary issue is their inability to power reactive (inductive or capacitive) loads, leading to output voltage instability that renders them "unsuitable for normal operation" in standalone power generation applications (’016 Patent, col. 2:52-60).
• The Patented Solution: The invention proposes a system that overcomes this limitation by rectifying the three-phase AC output of the induction generator into direct current (DC) (’016 Patent, col. 5:8-13). Because pure DC power is resistive, not reactive, this approach solves the voltage instability problem. The DC power can then be stored in an "energy reservoir" like a battery bank and, if needed, converted back to AC power using an inverter (’016 Patent, Fig. 1; col. 6:23-26). A key aspect of the method is operating the induction motor at a significant "overspeed"—well above its rated speed—to substantially increase its power output relative to its size and cost (’016 Patent, col. 11:1-10).
• Technical Importance: This approach was designed to make rugged, inexpensive, and low-maintenance induction motors viable for independent power generation, particularly in hybrid electric systems, by enhancing their power-to-weight ratio and solving their historical incompatibility with common electrical loads (’016 Patent, col. 1:13-19, col. 11:7-10).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary method claims" (Compl. ¶11). The first independent claim is Claim 1.
• 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;
  • said choosing step further comprising choosing the induction motor such that the second power rating is substantially equal to the chosen power rating;
  • driving the induction motor with the prime mover so that the induction motor acts as an induction generator; and
  • operating the induction generator at said overspeed.
• The complaint alleges infringement of "one or more claims," suggesting the right to assert additional independent or dependent claims may be reserved (Compl. ¶11).

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 purportedly detailed in claim charts attached as Exhibit 2 (Compl. ¶11, ¶13). Exhibit 2 was not filed with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality. It alleges that Defendant's employees "internally test and use these Exemplary Products" (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products practice the technology claimed by the ’016 Patent" and "satisfy all elements of the Exemplary ’016 Patent Claims" (Compl. ¶13). However, it provides no specific factual allegations regarding how any accused product infringes. Instead, it incorporates by reference claim charts in an unattached exhibit (Compl. ¶14). Without these charts or a narrative infringement theory, a detailed analysis is not possible.

• Identified Points of Contention: Based on the asserted method claim, the infringement analysis may raise several technical and legal questions.
  • Scope Questions: The asserted method claim includes steps of "selecting a prime mover" and "choosing an induction motor." A central legal question may be whether a manufacturer, such as the Defendant, can be held liable for direct infringement of such a method claim through its design, manufacturing, and internal testing activities, or whether these steps are properly attributable to a different actor (Compl. ¶11-12).
  • Technical Questions: A key technical question may be whether the accused products operate an induction motor at an "overspeed" of "at least about 10% greater than the rated speed," as required by Claim 1. Establishing that the accused products meet the specific limitation that the motor's power rating at overspeed is "substantially equal to the chosen power rating" of the prime mover will also be a central evidentiary issue.

V. Key Claim Terms for Construction

The Term: "choosing an induction motor" (and "selecting a prime mover")

• Context and Importance: These terms define actions that form the initial steps of the claimed method. Practitioners may focus on these terms because their construction will be critical to determining whether a single actor—the Defendant—can be said to perform all steps of the method, which is a requirement for direct infringement. The dispute will likely center on whether the Defendant's internal design and component sourcing processes satisfy these claim elements.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A party could argue that the patent's description of a "method for enhancing the operation of an electrical power supply" encompasses the engineering and design choices made by a manufacturer when creating such a supply (’016 Patent, col. 4:45-47).
  • Evidence for a Narrower Interpretation: A party could argue that the specification frames the invention as a set of steps for building a system, which may imply that the "choosing" and "selecting" is done by a system integrator rather than the manufacturer of a finished product (’016 Patent, col. 4:55-61).

The Term: "overspeed"

• Context and Importance: This term is a core technical limitation, defined in Claim 1 as being "at least about 10% greater than the rated speed." The presence of the word "about" introduces indefiniteness that often requires judicial construction. The infringement analysis will depend on the precise numerical range assigned to this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discloses numerous, and significantly higher, exemplary ranges for overspeed, including "at least about 25%, 50%, 75%, 10 to 300%, 25 to 300%, or 50 to 100% greater than the rated speed" (’016 Patent, col. 4:51-54). The breadth of these examples may support a more flexible interpretation of "about 10%."
  • Evidence for a Narrower Interpretation: The Summary of the Invention introduces the "at least about 10%" limitation distinctly and ahead of the other, higher ranges, which could suggest it is a specific threshold for the broadest embodiment of the invention (’016 Patent, col. 4:50-51).

VI. Other Allegations

• Indirect Infringement: The complaint includes only a count for "Direct Infringement" and does not allege facts to support either induced or contributory infringement (Compl. ¶11).
• Willful Infringement: The complaint does not explicitly allege willful infringement or plead facts showing the Defendant had pre-suit knowledge of the ’016 Patent. It does, however, request that the case be declared "exceptional" to permit an award of attorneys' fees under 35 U.S.C. § 285 (Compl., Prayer for Relief ¶E.i).

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

• A core issue will be one of actor-based liability: Can the plaintiff establish that the defendant, as a product manufacturer, performs every step of the asserted method claims—including "selecting" and "choosing" components—thereby meeting the single-entity requirement for direct infringement?
• A key evidentiary question will be one of technical proof: In the absence of detailed factual allegations in the pleading, what evidence will emerge to demonstrate that the accused products' power systems are designed and operated in a manner that satisfies the specific "overspeed" and power-rating-matching limitations of the asserted claims?