Lamplight Licensing LLC v. Ametek Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Lamplight Licensing LLC (Texas)
  • Defendant: Ametek, Inc. (Delaware)
  • Plaintiff’s Counsel: PRA Law; Chong Law Firm PA
• Case Identification: 5:22-cv-00050, S.D. Tex., 05/31/2022
• Venue Allegations: Venue is alleged based on Defendant’s commission of infringing acts within the Southern District of Texas and its maintenance of a regular and established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to managing battery power in electronic devices during a power outage.
• Technical Context: The technology concerns power management systems, such as those in internet gateways or routers, that use a battery backup to maintain critical functions (e.g., telephone service) during a mains power failure.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

Date	Event
2013-03-12	U.S. Provisional Application 61/777,445 Filing Date ('393 Patent Priority)
2013-06-12	'393 Patent Application Filing Date
2017-07-25	'393 Patent Issue Date
2022-05-31	Complaint Filing Date

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

U.S. Patent No. 9,716,393 - “Battery Backup Remaining Time Arrangement”

• Patent Identification: U.S. Patent No. 9,716,393, “Battery Backup Remaining Time Arrangement,” issued July 25, 2017.
• The Invention Explained:
  • Problem Addressed: When a device on battery backup begins shutting down non-essential components to save power, the current draw can fluctuate significantly. This can cause the device to miscalculate the remaining battery time, potentially leading to a "race" condition where a critical component that should remain active (e.g., a telephone interface) erroneously shuts down because it receives a temporarily low, and false, reading of remaining battery life (ʼ393 Patent, col. 1:36-52).
  • The Patented Solution: The invention avoids this problem by, during a "transitional shutdown delay interval" immediately following a power loss, calculating the remaining battery time using a pre-determined, stored value for current consumption rather than measuring the actual, fluctuating current draw. This ensures the remaining time calculation is stable and unaffected by the transient power spikes and dips that occur as various components are powered down, preventing the "race" condition ('393 Patent, Abstract; col. 3:51-64). The process is illustrated in the flowchart of Figure 2, which distinguishes between normal operation and backup operation.
  • Technical Importance: This method provides a more stable and reliable way to manage power-down sequences in battery-backed devices, ensuring that essential functions are preserved for as long as possible during a power failure without being prematurely terminated by transient electrical events ('393 Patent, col. 3:61-67).
• Key Claims at a Glance:
  • The complaint asserts independent claim 1 ('393 Patent, Compl. ¶11).
  • Independent Claim 1 Elements:
    • An apparatus for generating a signal indicative of a battery remaining time, comprising:
    • a source of a mains supply voltage for energizing a first load circuit and a second load circuit, prior to an interruption in said mains supply voltage;
    • a battery for providing battery backup operation to energize said second load circuit after said interruption in said mains supply voltage is detected; and
    • a processor coupled to said first load circuit and configured to initiate a current drain reduction in said first load circuit after detection of said interruption,
    • and to access a stored battery current magnitude value for use in calculating a battery remaining time indicative signal,
    • such that, during a transitional shutdown delay interval of the apparatus that follows the detection of said interruption, said battery remaining time indicative signal is based on said stored battery current magnitude value that is unaffected by real time variations and transient loading of said battery current magnitude during said transitional shutdown delay interval and is instead based on a current magnitude in a steady state of said battery backup operation.
  • The complaint does not explicitly reserve the right to assert dependent claims, but infringement allegations are made "literally or by the doctrine of equivalents" (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint refers to "Exemplary Defendant Products" but does not name any specific products, models, or services (Compl. ¶11). It states these products are identified in "charts incorporated into this Count" via 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 accused products' functionality, features, or market context. It makes only a conclusory allegation that the "Exemplary Defendant Products practice the technology claimed" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an exhibit that was not provided with the filing (Compl. ¶¶13-14). The complaint’s narrative allegations are conclusory, stating only that the accused products "satisfy all elements of claim 1 of the ’393 Patent" (Compl. ¶13). As such, a detailed claim chart cannot be constructed from the available documents. No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: A central issue will be identifying the specific Ametek products and then adducing evidence of their internal operation. The plaintiff will need to prove that the accused products' processors perform the specific sequence of steps recited in Claim 1.
  • Technical Question: A key factual dispute may be whether the accused products, when operating on battery backup, calculate remaining battery time using a stored current value as claimed, or if they use a real-time measurement of the actual current draw. The distinction between these two methods is the core of the patented invention.
  • Scope Question: The case may raise the question of what constitutes a "transitional shutdown delay interval." The patent specification provides an example of "1-4 minutes" ('393 Patent, col. 3:4-5), which may be used to argue for a specific temporal scope for this claim element.

V. Key Claim Terms for Construction

• The Term: "stored battery current magnitude value"

• Context and Importance: This term is critical because the invention's point of novelty is using a pre-determined, stored value instead of a real-time measurement to avoid calculation errors from transient current loading. The infringement analysis will turn on whether the accused products use a "stored" value in the manner claimed.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify when or how the value must be stored, only that the processor "access[es] a stored... value." This could support a construction that covers any value that is not a contemporaneous, real-time measurement ('393 Patent, col. 5:4-5).
  • Evidence for a Narrower Interpretation: The specification provides examples where the value is "estimated," "pre-programmed during manufacturing," or "stored... in the factory" ('393 Patent, col. 4:51-59, col. 5:28-30). A defendant may argue these examples limit the term to a static, pre-set value, as opposed to one that might be dynamically calculated and stored just prior to the power interruption.

• The Term: "transitional shutdown delay interval"

• Context and Importance: This term defines the specific period during which the inventive method is operative. Establishing the existence and duration of such an interval in the accused products will be a prerequisite for finding infringement. Practitioners may focus on this term because its boundaries—when it begins and ends—are not explicitly defined in the claim itself.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim describes the interval as one "that follows the detection of said interruption" during which "current drain reduction" is initiated ('393 Patent, col. 5:7-14). This could support a construction covering any period after a power loss where some components are being shut down.
  • Evidence for a Narrower Interpretation: The specification describes this interval as a "shutdown delay of, for example, 1-4 minutes" during which "selected devices... experience a shutdown delay" ('393 Patent, col. 3:3-8). This specific example could be used to argue that the term requires a distinct, programmed delay of a certain duration, not just any period of transient activity.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement (inducement or contributory infringement). It alleges only direct infringement by Defendant and its customers (Compl. ¶11).
• Willful Infringement: The complaint does not allege willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, but the complaint body lacks any factual allegations (e.g., pre-suit knowledge, egregious conduct) that would typically support such a finding (Compl., Prayer for Relief ¶E.i).

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

This case appears to be in its earliest stages, with the complaint providing minimal factual detail beyond the identification of the patent-in-suit. The resolution of the dispute will likely depend on the answers to the following questions:

1. A primary evidentiary question will be whether the Plaintiff can demonstrate, through discovery, that the unspecified Ametek products actually perform the specific power management method of Claim 1. The complaint's lack of detail on the accused products suggests this will be a central focus of discovery.

2. A core issue will be one of technical implementation: assuming a relevant Ametek product is identified, does its power management system, during a component shutdown sequence, calculate remaining battery life using a stored, static current value as required by the patent, or does it rely on a real-time, dynamic measurement of current draw?

3. The case may also present a question of claim scope: can the term "transitional shutdown delay interval" be defined with sufficient certainty, and if so, do the accused products operate with a corresponding interval that is distinct from normal battery operation?