Cogent Insights Licensing Inc v. Siemens Gamesa Renewable Energy Sau

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Cogent Insights Licensing Inc. (Canada)
  • Defendant: Siemens Gamesa Renewable Energy, S.A.U. (Spain)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:26-cv-12, E.D. Tex., 01/07/2026
• Venue Allegations: Venue is asserted on the basis that 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 at issue addresses methods for improving the practicality and efficiency of using common induction motors as power generators, particularly for applications like hybrid electric vehicles or independent power generation.
• Key Procedural History: The complaint does not mention any prior litigation, administrative proceedings, or licensing history related to the patent-in-suit. The patent-in-suit claims priority to a provisional application filed in 2001.

Case Timeline

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

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

The Invention Explained

• Problem Addressed: The patent’s background section states that while induction motors are inexpensive, efficient, and rugged, their use as standalone generators has been limited. A primary issue is voltage instability when powering reactive (inductive or capacitive) loads, which are common in AC power systems. This instability renders the generator unsuitable for many normal operations. (’016 Patent, col. 2:52-60).
• The Patented Solution: The invention proposes a system that overcomes this limitation by rectifying the AC output of the induction generator into direct current (DC). Because pure DC power is resistive and not reactive, this approach solves the voltage instability problem. (’016 Patent, col. 5:7-15). The system architecture generally includes a prime mover (like an engine) driving an induction generator, whose output is fed through a phase shift circuit and an AC to DC converter to an energy reservoir, such as a battery bank (’016 Patent, Fig. 1; col. 6:4-33). A key aspect of the disclosed method is operating the induction motor at an "overspeed"—a rotational speed significantly higher than its rated speed—to substantially increase the power output beyond the motor's nameplate rating (’016 Patent, col. 10:55-61).
• Technical Importance: This patented approach purports to make hybrid electric technology more practical and economical by enabling the use of widely available, low-cost induction motors in a manner that enhances their power output and overcomes their traditional limitations in standalone generator applications. (’016 Patent, col. 1:15-18, col. 5:4-7).

Key Claims at a Glance

• The complaint asserts "exemplary method claims" without specifying claim numbers (Compl. ¶11). Independent method claim 1 is representative.
• Essential elements of Independent Claim 1 include:
  • 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, where the overspeed is at least about 10% greater than the rated speed;
  • choosing the induction motor such that its second power rating (at overspeed) is substantially equal to the chosen power rating of the prime mover;
  • driving the induction motor with the prime mover to act as an induction generator; and
  • operating the induction generator at that overspeed.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint identifies the accused products as the "Exemplary Defendant Products" identified in charts referenced as Exhibit 2 (Compl. ¶11). However, Exhibit 2 was not filed with the complaint. No specific product names, models, or categories (e.g., wind turbines) are mentioned in the body of the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context. It alleges in a conclusory manner that the accused products "practice the technology claimed by the '016 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of "exemplary method claims" of the ’016 Patent by Defendant’s making, using, selling, importing, and internally testing the accused products (Compl. ¶11-12). It states that claim charts in a referenced but unfiled Exhibit 2 compare the asserted claims to the accused products and demonstrate that all claim elements are satisfied (Compl. ¶13-14). No probative visual evidence provided in complaint. Because the claim charts were not provided, the complaint's narrative theory of infringement is limited to the general assertion that the accused products practice the claimed technology.

• Identified Points of Contention: Given the bare allegations, the central disputes will likely emerge during discovery and claim construction. Based on the patent and the nature of the asserted claims, key questions may include:
  • Operational Questions: What evidence does the complaint provide that Defendant’s products are operated at an "overspeed" of at least 10% greater than the induction generator's rated speed, as required by Claim 1? This raises a factual question about the standard operating parameters of the accused systems.
  • Design and Selection Questions: The claims require a specific relationship between the selected prime mover and the induction motor, namely that the motor's power rating at overspeed is "substantially equal" to the prime mover's power rating. A significant point of contention may be whether the accused systems were designed and assembled based on this specific selection criterion, or if any operational overlap with the claim language is merely incidental.

V. Key Claim Terms for Construction

• Term: "overspeed"

  • Context and Importance: This term is central to the inventive concept of enhancing power output. Infringement of method claim 1 hinges on whether the accused products are operated in this state. Practitioners may focus on this term because its definition ("at least about 10% greater than the rated speed") includes the word "about," which introduces ambiguity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims explicitly provide a floor ("at least about 10% greater," Claim 1) and suggest a wide range of possibilities, with dependent claims reciting overspeeds of "about 50 to 100%" (Claim 9). The specification also discusses a specific example where operating at double the rated speed (a 100% overspeed) doubles the power output (’016 Patent, col. 11:13-40).
    • Evidence for a Narrower Interpretation: A defendant may argue that the term should be construed in the context of achieving the specific advantages described in the patent, such as a substantial power increase. The specification notes that while overspeeds less than 10% are possible, they "will not obtain all of the advantages" (’016 Patent, col. 11:41-45). This language could be used to argue that merely incidental or transient operation above the rated speed does not meet the claim limitation.

• Term: "substantially equal"

  • Context and Importance: This term defines the required relationship between the power rating of the prime mover and the power rating of the induction motor when operated at overspeed. As a term of degree, its construction will be critical in determining the scope of the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent does not provide a numerical range for "substantially equal," suggesting the term should be given its plain and ordinary meaning, which typically allows for some reasonable deviation.
    • Evidence for a Narrower Interpretation: A defendant could argue that the term implies a close technical matching required for the "highly efficient and widely available" system described (’016 Patent, col. 11:55-60). The patent’s emphasis on matching the speed-power characteristics of diesel engines to induction motors could be cited to support a construction requiring a specific, functional correspondence rather than a loose approximation (’016 Patent, col. 11:50-55).

VI. Other Allegations

The complaint does not contain allegations of indirect or willful infringement. It requests that the case be declared "exceptional" for the purpose of recovering attorneys' fees but alleges no specific facts to support such a finding (Compl., Prayer for Relief E.i.).

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

Based on the complaint and the patent-in-suit, the litigation will likely center on fundamental questions of claim scope and evidentiary proof.

• A core issue will be one of definitional scope: Can the term "overspeed," defined as "at least about 10% greater than the rated speed," be met by variable-speed systems (such as wind turbines) that may operate across a range of speeds, and what does "substantially equal" require when matching the power ratings of the system's core components?
• A key evidentiary question will be one of design versus operation: Does the plaintiff need to prove not only that the accused systems operate in a manner that falls within the claim language, but also that their components were chosen and selected based on the specific power-matching criteria recited in the method claims?