DCT

4:23-cv-00554

NOCO Co v. Youxiangongsi

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:23-cv-00554, S.D. Tex., 03/10/2023
  • Venue Allegations: Venue is alleged to be proper in the Southern District of Texas because Defendants Metasee LLC and Ace Farmer LLC have registered business addresses within the district, and the wrongful acts giving rise to the claims allegedly occurred there.
  • Core Dispute: Plaintiff alleges that Defendant’s Fanttik T8 line of portable vehicle jump starters infringes six patents related to safety-keyed jumper cable plugs, battery cell equalization circuits, and USB charging technology.
  • Technical Context: The technology concerns portable lithium-ion battery jump starters, a consumer electronics category that has largely replaced traditional jumper cables for vehicle owners.
  • Key Procedural History: This filing is a First Amended Complaint. The complaint does not mention any prior litigation between the parties or any administrative patent challenges, such as Inter Partes Review proceedings.

Case Timeline

Date Event
2014-07-03 Priority Date for ’992, ’808, ’023, and ’243 Patents
2017-03-31 Priority Date for ’452 and ’213 Patents
2017-09-26 U.S. Patent No. 9,770,992 Issues
2019-06-25 U.S. Patent No. 10,328,808 Issues
2021-04-20 U.S. Patent No. 10,981,452 Issues
2022-02-22 U.S. Patent No. 11,254,213 Issues
2022-09-20 U.S. Patent No. 11,447,023 Issues
2023-02-21 U.S. Patent No. 11,584,243 Issues
2023-03-10 Complaint Filed

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

U.S. Patent No. 9,770,992

  • Patent Identification: U.S. Patent No. 9,770,992, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection and Jumper Cable Device Therefor," Issued September 26, 2017 (Compl. ¶29).
  • The Invention Explained:
    • Problem Addressed: The patent addresses the safety risks associated with traditional jumper cables, where improper connections between a live battery and a dead battery can cause sparks, short circuits, and potential damage to the vehicle or injury to the user (Compl. ¶24; ’808 Patent, col. 1:11-24).
    • The Patented Solution: The invention is a jumper cable device featuring a single, integrated plug that connects to the portable jump starter. This plug is physically keyed so it can only be inserted into the device’s output port in a single, correct orientation, which ensures that the positive and negative clamps cannot be inadvertently reversed at the jump starter source (Compl. ¶28, ¶40; ’808 Patent, Fig. 4).
    • Technical Importance: This design aims to make the process of jump-starting a vehicle safer and more user-friendly by eliminating a common source of user error (Compl. ¶26, ¶28).
  • Key Claims at a Glance:
    • The complaint asserts infringement of at least independent claim 1 (Compl. ¶41, ¶141).
    • Claim 1 requires:
      • A single plug with one end configured to fit into a single output port of a handheld booster device, providing both positive and negative polarity electrical connections.
      • A pair of cables integrated with the plug, with opposite ends configured to connect to the terminals of the battery being charged.
      • A body of the single plug having a uniform width.
      • The single plug being configured to fit into the outlet port in only a single orientation to ensure proper polarity.

U.S. Patent No. 10,328,808

  • Patent Identification: U.S. Patent No. 10,328,808, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection and Jumper Cable Device Thereof," Issued June 25, 2019 (Compl. ¶30).
  • The Invention Explained:
    • Problem Addressed: This patent, part of the same family as the ’992 patent, addresses the same dangers of incorrect polarity connections when using jumper cables (’808 Patent, col. 1:11-24).
    • The Patented Solution: The invention is a jumper cable device with a single plug designed to connect to a jump starter in only one orientation. A key physical characteristic of this plug is a body that has a "uniform or substantially uniform width" (’808 Patent, Abstract; col. 8:52-54).
    • Technical Importance: The invention provides a specific, physically defined safety connector that simplifies the user experience and reduces the risk of electrical shorts during jump-starting (Compl. ¶28).
  • Key Claims at a Glance:
    • The complaint asserts infringement of at least independent claim 1 (Compl. ¶51, ¶148).
    • Claim 1 requires:
      • A single plug configured to fit into the output port of a jump starter to provide both positive and negative polarity connections.
      • A pair of battery cables integrated with the plug, with opposite ends for connecting to a battery.
      • A body of the single plug having a uniform or substantially uniform width along its length.
      • The single plug being configured to fit into the output port in only a single orientation.

U.S. Patent No. 10,981,452

  • Patent Identification: U.S. Patent No. 10,981,452, "Portable or Hand Held Vehicle Battery Jump Starting Apparatus with Battery Cell Equalization Circuit," Issued April 20, 2021 (Compl. ¶32).
  • Technology Synopsis: The patent addresses the technical challenge of maintaining balanced charges across multiple individual cells within a lithium-ion battery pack during charging and use (Compl. ¶31). The patented solution is a battery cell equalization circuit that actively manages cell voltages, for instance by discharging a cell whose voltage exceeds a threshold, to ensure all cells charge efficiently and to extend the battery's lifespan (Compl. ¶61).
  • Asserted Claims: At least independent claim 1 (Compl. ¶61, ¶155).
  • Accused Features: The internal battery packs and associated battery management circuitry of the T8 jump starters are alleged to practice the claimed equalization methods (Compl. ¶64-67).

U.S. Patent No. 11,254,213

  • Patent Identification: U.S. Patent No. 11,254,213, "Portable or Hand Held Vehicle Battery Jump Starting Apparatus with Battery Cell Equalization Circuit," Issued February 22, 2022 (Compl. ¶33).
  • Technology Synopsis: This patent is also directed to a battery cell equalization circuit for a portable jump starter (Compl. ¶69). The invention describes a system with individual circuits and load resistors for each battery cell, configured to discharge cells that reach a pre-determined upper voltage threshold, thereby maintaining balance across the entire battery pack (Compl. ¶70).
  • Asserted Claims: At least independent claim 1 (Compl. ¶70, ¶162).
  • Accused Features: The internal battery and equalization circuitry within the T8 jump starters are accused of infringement (Compl. ¶73-75).

U.S. Patent No. 11,447,023

  • Patent Identification: U.S. Patent No. 11,447,023, "Portable Vehicle Battery Jump Start Apparatus with Safety Protection and Jumper Cable Device Thereof," Issued September 20, 2022 (Compl. ¶35).
  • Technology Synopsis: The patent addresses the need for a convenient, standardized method for recharging portable jump starters, which previously often required proprietary chargers (Compl. ¶34). The solution is a jump starter incorporating a USB input circuit with a DC/DC converter, allowing the device's internal power supply to be recharged from a common USB power source by increasing the low USB voltage to a suitable charging level (Compl. ¶78).
  • Asserted Claims: At least independent claim 1 (Compl. ¶78, ¶169).
  • Accused Features: The T8 jump starters' USB input ports and internal charging circuitry, which allegedly use a DC/DC converter to recharge the internal battery pack from a USB source, are accused of infringement (Compl. ¶85-87).

U.S. Patent No. 11,584,243

  • Patent Identification: U.S. Patent No. 11,584,243, "Jump Starting Device With USB," Issued February 21, 2023 (Compl. ¶36).
  • Technology Synopsis: This patent describes a jump starting device with a USB input connector and a USB charge circuit (Compl. ¶89). The charge circuit includes a DC-DC converter configured to "upconvert" voltage from the USB input to recharge the device's internal power supply, providing a standardized recharging solution (Compl. ¶90).
  • Asserted Claims: At least independent claim 1 (Compl. ¶90, ¶176).
  • Accused Features: The T8 jump starters' USB input connectors and internal charge circuits are alleged to infringe by using a DC-DC converter to facilitate charging from a USB source (Compl. ¶96-98).

III. The Accused Instrumentality

  • Product Identification: The "Fanttik T8 1300," "Fanttik T8 APEX," and "Fanttik T8 MAX" jump starters, collectively referred to as "the T8 jump starters" (Compl. ¶38).
  • Functionality and Market Context:
    • The accused products are handheld, lithium-ion battery-based devices designed to jump-start vehicles with depleted batteries (Compl. ¶38, ¶43). The complaint presents evidence that the devices include a main unit with an internal power supply, an output port for jumper cables, and jumper cables that terminate in a single, integrated plug (Compl. ¶44). An image in the complaint shows a single plug on the T8 jump starter's cable being inserted into the device's output port (Compl. p. 14). The devices are also alleged to feature USB ports for recharging the internal battery and for charging external electronic devices (Compl. ¶85). The complaint provides a visual demonstrating the T8 jump starters' ability to be charged via a USB port (Compl. p. 32).
    • The complaint alleges that the success and popularity of Plaintiff's products led to imitation and copying by Defendants, positioning the accused T8 jump starters as infringing copycat products (Compl. ¶37).

IV. Analysis of Infringement Allegations

U.S. Patent No. 9,770,992 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a single plug having one end configured to fit into a single output port of the handheld battery charger booster device... the single plug configured to provide both a positive polarity electrical connection and a negative polarity electrical connection... Each T8 jump starter comprises a single plug configured to fit the output port of the booster device, providing both positive and negative electrical connections. ¶44, ¶45 ’808 Patent, col. 8:1-14
a pair of cables having cable ends integrated with the plug, the pair of cables having opposite cable ends configured to separately connect to the terminals of the battery being charged... The T8 jump starters comprise a pair of cables integrated with the plug, with the opposite ends having red and black alligator clips for connecting to a battery. ¶46 ’808 Patent, col. 8:46-51
wherein a body of the single plug has a uniform width... The body of the single plug in each T8 jump starter is alleged to have a uniform width. ¶47 ’808 Patent, col. 8:52-54
wherein the single plug is configured so that the single plug will only fit into the single outlet port of the handheld battery charger booster device in a single orientation to ensure a proper orientation of positive polarity and negative polarity cable connections... The plugs are configured with two connections of differing shapes to ensure they only fit into the outlet port in a single orientation, thereby ensuring proper polarity. ¶48 ’808 Patent, col. 8:55-62

U.S. Patent No. 10,328,808 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a single plug having one end configured to fit into the output port of the jump starter, the single plug configured to provide both a positive polarity electrical connection and a negative polarity electrical connection... Each T8 jump starter is alleged to have a single plug that fits into the output port of the device and provides positive and negative electrical connections. ¶54, ¶55 ’808 Patent, col. 8:1-14
a pair of battery cables having cable ends integrated with the plug, the pair of battery cables having opposite cable ends configured to separately connect to terminals of the battery being charged... The T8 jump starters include a pair of cables with alligator clips integrated with the plug for connecting to a vehicle battery. ¶56 ’808 Patent, col. 8:46-51
wherein a body of the single plug has a uniform or substantially uniform width along a length of the body... In each T8 jump starter, the body of the single plug is alleged to have a uniform or substantially uniform width. ¶57 ’808 Patent, col. 8:52-54
wherein the single plug is configured so that the single plug will only fit into the output port of the jump starter in a single orientation to ensure a proper orientation of the positive polarity electrical connection and the negative polarity electrical connection... The plugs are alleged to have two connections of differing shapes, ensuring they fit into the device in only one orientation to maintain correct polarity. An image in the complaint shows the keyed connectors on the plug (Compl. p. 23). ¶58 ’808 Patent, col. 8:55-62
  • Identified Points of Contention:
    • Scope Questions: A central point of contention for the ’808 Patent may be the scope of the term "substantially uniform width." The analysis will question what degree of variation from perfect uniformity is permissible under this term and whether the accused plugs fall within that scope.
    • Technical Questions: For the equalization patents ('452, '213), the infringement allegations are made on "information and belief" (Compl. ¶65-67). This raises the evidentiary question of what proof Plaintiff has that the accused products' internal circuits perform the specific discharging and charging rate functions as claimed, rather than a different, non-infringing method of battery management.

V. Key Claim Terms for Construction

  • The Term: "uniform or substantially uniform width" (’808 Patent, Claim 1)
  • Context and Importance: The physical shape of the plug is a central limitation of the claim. The addition of "substantially" introduces a degree of ambiguity that is a common focus of claim construction disputes. The definition of this term will directly impact whether the physical dimensions of the accused T8 plugs infringe. Practitioners may focus on this term because the patentability of the claim could hinge on this specific physical characteristic distinguishing it from prior art.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The explicit use of the qualifier "substantially" suggests that the patentee did not intend for the term to mean perfectly or strictly uniform, allowing for minor manufacturing tolerances or insignificant variations in shape (’808 Patent, col. 8:52-54).
    • Evidence for a Narrower Interpretation: The specification describes the plug body as "substantially rectangular-shaped," and the associated Figure 4 depicts a plug body (401a) that appears perfectly rectangular (’808 Patent, col. 8:15-16; Fig. 4). A party could argue that "substantially uniform" should be construed in light of this specific embodiment, limiting it to shapes that are nearly rectangular.

VI. Other Allegations

  • Indirect Infringement: The complaint focuses on allegations of direct infringement by way of importing, offering for sale, selling, and/or using the accused products in the United States (Compl. ¶141, ¶148). It does not plead specific facts to support claims of induced or contributory infringement, such as instructing users via manuals to perform infringing acts.
  • Willful Infringement: The complaint alleges willful infringement for all six asserted patents. The basis for willfulness is the allegation that Defendants compete with Plaintiff, that Plaintiff's patent portfolio is public knowledge, and that, upon information and belief, Defendants had actual knowledge of the patents prior to the lawsuit (Compl. ¶143, ¶150, ¶157, ¶164, ¶171). For the ’243 Patent, knowledge is alleged "since the issuance of the '243 Patent on February 21, 2023," which post-dates the complaint's filing (Compl. ¶178).

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

  • A core issue will be one of definitional scope: how broadly will the court construe the term "substantially uniform width" in the '808 Patent? The outcome of this claim construction will be a critical factor in determining infringement for the patents related to the physical plug design.
  • A key evidentiary question will be one of technical operation: what evidence will discovery yield regarding the internal functionality of the T8 jump starters' battery management and USB charging circuits? The complaint's reliance on "information and belief" for these allegations suggests that proving the precise methods of operation will be central to the dispute over the equalization and USB charging patents.
  • A third question concerns willfulness: can Plaintiff produce evidence beyond mere competitor status to substantiate its claim that Defendants had actual, pre-suit knowledge of the asserted patents? The answer will determine whether enhanced damages remain a possibility in the case.