DCT

3:22-cv-00884

Comarco Wireless Systems LLC v. LG Electronics Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:22-cv-00884, N.D. Tex., 04/20/2022
  • Venue Allegations: Venue is alleged to be proper for LG Electronics, Inc. as a foreign corporation. For LG Electronics Alabama, Inc., venue is based on its alleged regular and established places of business within the Northern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s power adapters and portable electronic devices that are compliant with the USB Battery Charging 1.2 specification infringe patents related to intelligent power supply systems that use a dedicated data signal to control battery charging.
  • Technical Context: The technology addresses the safe charging of portable devices from various power sources by enabling a "handshake" between the charger and the device to determine and deliver an appropriate power level.
  • Key Procedural History: The patents-in-suit are part of a large family of applications sharing a common priority claim to a U.S. patent application filed in 2004. The complaint does not mention any prior litigation, licensing history, or post-grant proceedings involving these patents.

Case Timeline

Date Event
2004-01-15 Earliest Priority Date for Patents-in-Suit ('933 Application)
2012-03-15 USB Battery Charging Specification Rev. 1.2 published
2016-08-09 U.S. Patent No. 9,413,187 Issued
2020-12-01 U.S. Patent No. 10,855,087 Issued
2021-03-16 U.S. Patent No. 10,951,042 Issued
2022-04-20 Complaint Filed

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

U.S. Patent No. 9,413,187, Power Supply System Providing Power and Analog Data Signal for Use by Portable Electronic Device to Control Battery Charging, Issued August 9, 2016

The Invention Explained

  • Problem Addressed: The patent addresses the risks associated with charging portable devices from different types of DC power sources, such as an automobile outlet versus an airplane's EMPOWER outlet, which provide different voltage ranges (’187 Patent, col. 1:39-61). Using the wrong connector or a flawed one could lead to improper battery charging, which could cause overheating, fire, and damage to the electronic device, a particularly acute danger on an airplane (’187 Patent, col. 2:1-9).
  • The Patented Solution: The invention is a system comprising both a power supply and a portable electronic device that communicate to ensure safe charging. The power supply's data circuitry sends an analog data signal to the portable device over a dedicated signaling line, separate from the power and ground lines (’187 Patent, Abstract). This analog signal informs the portable device about the power supply's capabilities, allowing the device's controller to decide whether to enable or disable battery charging (’187 Patent, col. 4:21-44).
  • Technical Importance: The system automates the safety check, removing the need for a user to manually select the correct physical adapter tip for different power environments, thereby reducing the risk of human error (’187 Patent, col. 2:38-51).

Key Claims at a Glance

  • The complaint asserts at least Independent Claim 1 (Compl. ¶23).
  • Essential elements of Claim 1 include:
    • A system including a portable electronic device (with a rechargeable battery) and an external power supply system.
    • The power supply system contains power circuitry and data circuitry.
    • The data circuitry receives a "first signal" from the device and provides a "second signal" to the device.
    • A four-conductor connector links the two, with conductors for DC power, ground, the first signal, and the second signal.
    • The "second signal" is specified as an "analog signal" with a parameter level indicating the power supply's potential power output level.

U.S. Patent No. 10,855,087, Power Supply Systems, Issued December 1, 2020

The Invention Explained

  • Problem Addressed: The patent describes the deficiency in prior art power adapters that are unable to "automatically and intelligently" inform an electronic device about the nature of the connected DC power source (e.g., automobile vs. airplane) (’087 Patent, col. 2:51-58). This creates a risk that a device might attempt to recharge its battery from a source not intended for that purpose, such as an airplane's EMPOWER system, potentially leading to malfunctions or fire (’087 Patent, col. 2:8-12).
  • The Patented Solution: The invention is a power supply system with its own "data circuitry" that communicates with a portable electronic device using a four-conductor connector (’087 Patent, Abstract). The power supply receives a "first signal" from the device and, in response, sends a "second signal" back to the device. This second signal carries a "parameter level" that the device can use to control its battery charging, for instance, by disabling it when connected to a specific type of power source (’087 Patent, col. 6:15-28, Fig. 6). Figure 3 illustrates an embodiment where comparison circuitry (320) within the adapter determines the source type and generates the appropriate data signal (Vdata) to send to the device (’087 Patent, col. 4:50-54).
  • Technical Importance: This invention shifts the intelligence for source identification into the power adapter itself, enabling a universal adapter to work safely with various devices and power sources without user intervention.

Key Claims at a Glance

  • The complaint asserts at least Independent Claim 1 (Compl. ¶24).
  • Essential elements of Claim 1 include:
    • A power supply system with power circuitry and data circuitry.
    • The data circuitry is configured to receive a "first signal" from a portable electronic device and provide a "second signal" to that device.
    • A four-conductor connector is used to transfer DC power, ground, the first signal (device-to-adapter), and the second signal (adapter-to-device).
    • The data circuitry provides the second signal "in coordination with the first signal."
    • The second signal has a "parameter level" usable by the device to control charging.
  • The complaint does not explicitly reserve the right to assert dependent claims but makes general allegations of infringement of "one or more claims" (Compl. ¶33).

U.S. Patent No. 10,951,042, Power Supply Systems, Issued March 16, 2021

Technology Synopsis

This patent claims the other side of the interaction: the portable electronic device itself. It describes a device with a rechargeable battery, power circuitry to receive power, and data circuitry configured to communicate with an external power supply over a four-conductor interface (’042 Patent, Abstract). The device's data circuitry sends an "output signal" to the power supply and receives an "input signal" from it, using the input signal to control the charging of its own battery (’042 Patent, col. 12:3-23, Claim 11).

Asserted Claims

At least Independent Claim 1 is asserted (Compl. ¶25).

Accused Features

The complaint accuses LG's portable electronic devices (PEDs), such as various models of its smartphones, which feature rechargeable batteries and USB-C ports compliant with the USB BC 1.2 specification (Compl. ¶¶22, 25).

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused products: "Accused Chargers" and "Accused PEDs" (Portable Electronic Devices) (Compl. ¶¶ 21-22).

Functionality and Market Context

  • The Accused Chargers are power adapters, including the "LG Travel Power Adapter," that are compliant with the USB Battery Charging (BC) 1.2 specification and provide charging via a USB-C connection (Compl. ¶21).
  • The Accused PEDs are LG's portable devices, including numerous specified smartphone models such as the LG V60 ThinQ 5G and LG VELVET 5G. These devices contain rechargeable batteries and USB-C ports, and are also alleged to be compliant with the USB BC 1.2 specification (Compl. ¶22).
  • The complaint alleges that these products, through their compliance with the USB BC 1.2 standard, perform the claimed signaling and power control functions (Compl. ¶¶ 21-25). The extensive list of popular smartphone models suggests the products have a significant commercial presence (Compl. ¶22).

IV. Analysis of Infringement Allegations

No probative visual evidence provided in complaint. The complaint references claim chart exhibits that were not attached to the pleading itself. Therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

'187 Patent Infringement Allegations (System Claim)

The complaint alleges that the combination of an Accused Charger and an Accused PED infringes at least Claim 1 of the ’187 Patent (Compl. ¶23). The theory is that the products, by operating according to the USB BC 1.2 standard, form a system that meets every claim element. The charger provides DC power and ground via the USB-C VBUS and GND pins. The USB-C data lines (e.g., D+ and D-) are alleged to function as the claimed third and fourth conductors. Over these lines, the PED purportedly sends a "first signal," and the charger responds with the claimed "second signal," an "analog signal" that informs the PED about the charger's characteristics, which the PED then uses to control battery charging.

'087 Patent Infringement Allegations (Power Supply Claim)

The complaint alleges that the Accused Chargers directly infringe at least Claim 1 of the ’087 Patent (Compl. ¶24). The infringement theory posits that the charger's hardware and firmware constitute the claimed power and data circuitry. The USB-C port provides the four-conductor interface. The charger's data circuitry is alleged to be configured to receive a "first signal" from a connected PED over one data line and, in response, provide a "second signal" over another data line to enable the PED to control charging, consistent with the USB BC 1.2 protocol.

Identified Points of Contention

  • Scope Questions: A primary question for the court will be whether the general-purpose data lines of a USB-C connector (D+, D-) can be construed to be the distinct "third conductor" and "fourth conductor" for signaling as described in the patents. A related question for the '187 Patent is whether the signaling mechanism in the USB BC 1.2 standard—which involves detecting voltage levels or shorts on the data lines—qualifies as an "analog signal" as required by Claim 1.
  • Technical Questions: The infringement theories rely on the operation of the USB BC 1.2 standard. A key factual dispute may be whether the signaling flow in that standard matches the claimed sequence. The patents describe the power supply's "data circuitry" receiving a signal and responsively generating another. The court will need to examine whether the accused products operate in this manner or if, for example, the PED simply detects a static hardware configuration in the charger (e.g., shorted data pins) without the charger's "data circuitry" actively generating a responsive signal.

V. Key Claim Terms for Construction

Term 1: "analog signal" (’187 Patent, Claim 1)

  • Context and Importance: This term is critical because Claim 1 of the '187 Patent explicitly requires the signal from the power supply to the device to be "analog." The accused USB BC 1.2 standard involves a device detecting certain voltage levels on the charger's data lines. Practitioners may focus on this term because its construction could be dispositive; if the USB BC 1.2 signaling is found to be digital, infringement of this claim may be difficult to prove.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification discusses using "analog components" and providing "voltage programming... voltages" (e.g., V.sub.Vprogram) to set the output voltage in a linear fashion, which may support a broader understanding of analog control schemes (’187 Patent, col. 4:16-26).
    • Evidence for a Narrower Interpretation: The specification's primary embodiment for distinguishing power sources involves a simple comparison of the input DC voltage to a single reference threshold (e.g., 14.3 Volts) to produce one of two output data signals (’187 Patent, col. 4:50-65). A party could argue this binary-like outcome points away from a truly "analog" signal in the context of the invention's core purpose.

Term 2: "data circuitry" (’087 Patent, Claim 1)

  • Context and Importance: The claims of the '087 Patent require the power supply to possess "data circuitry" that receives and sends signals. Chargers compliant with USB BC 1.2 can be implemented with simple, passive components like resistors to set the voltage on the data lines. Practitioners may focus on this term because the defendant will likely argue that such simple hardware does not meet the "data circuitry" limitation, which the patent specification appears to equate with more complex, active components.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claims do not explicitly require the "data circuitry" to be active, complex, or programmable. A party could argue that even a simple resistor network that affects a data line in response to being connected to a device constitutes "data circuitry" under a plain and ordinary meaning.
    • Evidence for a Narrower Interpretation: The detailed description and figures consistently depict "data circuitry" as including more sophisticated components, such as a "comparator 500" (Fig. 5A) or a "processor 505" (Fig. 5B) (’087 Patent, col. 6:3-14). A court might be persuaded to limit the scope of "data circuitry" to these more active embodiments disclosed in the specification.

VI. Other Allegations

Willful Infringement

The complaint alleges that LG's infringement is and has been willful for all three patents-in-suit. The basis for this allegation is that LG has had knowledge of the patents and their infringement "at least as of the filing of this Complaint" and has continued its allegedly infringing activities nonetheless (Compl. ¶¶ 29, 35, 41).

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

  • A core issue will be one of definitional scope: can the patent term "analog signal," as used in the ’187 Patent, be construed to read on the voltage-level detection scheme of the USB BC 1.2 standard? Similarly, can the term "data circuitry," as used in the ’087 Patent, be interpreted to cover the simple passive resistor configurations used in standard-compliant USB chargers, or is it limited to the more complex, active circuits shown in the patent's embodiments?
  • A key evidentiary question will be one of technical operation: does the accused system's "handshake" under the USB BC 1.2 standard function as claimed in the patents? The case may turn on evidence demonstrating whether the accused power supply's circuitry actually receives a "first signal" from the device and responsively generates a "second signal," or if the device simply reads a static characteristic of the charger, a fundamentally different technical operation.