DCT
1:24-cv-01377
Vampire Labs LLC v. Apple Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vampire Labs, LLC (Texas)
- Defendant: Apple, Inc. (California)
- Plaintiff’s Counsel: DiNovo Price LLP; SLC Trial Law, PLLC
- Case Identification: [Vampire Labs, LLC](https://ai-lab.exparte.com/party/vampire-labs-llc) v. [Apple, Inc.](https://ai-lab.exparte.com/party/apple-inc), 1:24-cv-01377, W.D. Tex., 02/07/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Apple maintains regular and established places of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s Qi-compliant wireless charging products, including MagSafe chargers and associated devices, infringe a patent related to automatically decoupling a charger from its power source to prevent "vampiric" energy loss.
- Technical Context: The technology concerns power management in inductive (wireless) charging systems, a ubiquitous feature in modern consumer electronics, with a focus on improving energy efficiency.
- Key Procedural History: The complaint notes that the patent-in-suit lapsed for failure to pay maintenance fees and that a petition to revive the patent was filed with the USPTO. It also cites the Examiner's "Reasons for Allowance" during prosecution, which highlighted specific claim limitations related to automatically coupling and decoupling power via a relay switch as being novel over the prior art.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-04 | Earliest Priority Date for ’103 Patent |
| 2009-08-01 | Qi low-power specification published by WPC (approx. date) |
| 2012-09-19 | Notice of Allowability issued for ’103 Patent |
| 2013-01-22 | ’103 Patent Issued |
| 2024-10-22 | Petition to revive lapsed ’103 Patent filed |
| 2025-02-07 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 8,358,103, "Automatic Coupling of an Alternating Current Power Source and an Inductive Power Apparatus to Charge a Target Device Battery," issued January 22, 2013.
The Invention Explained
- Problem Addressed: The patent addresses "vampiric power loss," which occurs when an inductive charger continues to draw power from an AC source even after the target device's battery is fully charged ('103 Patent, col. 1:30-35; Compl. ¶14). This includes "no load loss" from the transformer's internal components and "parasitic loading" after charging is complete, contributing to wasted energy ('103 Patent, col. 5:3-20).
- The Patented Solution: The invention is a system that intelligently manages the charging process. It includes modules to determine when a device is coupled to the charger, monitor the device's battery level, and, critically, automatically decouple the inductive charger from the AC power source when a desired charge level is reached ('103 Patent, col. 2:2-15). The system is also capable of automatically re-engaging the AC power if it detects the battery level has fallen below a certain threshold, thereby maintaining the charge without continuous power draw ('103 Patent, col. 2:7-11). The system architecture is depicted in figures such as Figure 9, showing distinct modules for connection, monitoring, activation, and separation (Compl. ¶24).
- Technical Importance: The technology provides a method to enhance the energy efficiency of wireless chargers, a significant consideration given the widespread adoption of such devices and growing concerns about aggregate power consumption ('103 Patent, col. 1:47-50).
Key Claims at a Glance
- The complaint asserts infringement of at least independent claim 1 (Compl. ¶35).
- The essential elements of independent claim 1 include:
- An inductive battery charging system with a connection module to determine when a target device is coupled to an inductive power apparatus.
- A monitoring module to determine when a target device battery is below a charging threshold while using power from a supplemental power source.
- An activation module to automatically couple the inductive power apparatus and an alternating current power source when the battery level is below the charging threshold.
- A separation module to automatically decouple the inductive power apparatus and the AC power source when a desired charging state is observed.
- The separation module is comprised of a relay switch.
- The inductive power apparatus includes a transformer, a rectification circuit, and a voltage regulation circuit.
- The complaint reserves the right to assert other claims and proceed under the doctrine of equivalents (Compl. ¶36).
III. The Accused Instrumentality
Product Identification
The "Accused Systems" are identified as Apple’s inductive charging products that comply with the Qi Specification, including the MagSafe Charger, iPhones, and the Apple Watch line of products (Compl. ¶36). An exemplary image of an Apple MagSafe Charger connected to an iPhone is provided in the complaint (Compl. p. 11).
Functionality and Market Context
The complaint alleges that the accused products' infringement stems from their compliance with the Qi wireless charging standard and from specific features implemented by Apple (Compl. ¶27, ¶30). A central feature identified is "Optimized Battery Charging," which the complaint describes as a system where the iPhone learns the user's daily charging routine and delays charging past 80% until it predicts the phone will be unplugged (Compl. ¶37). The complaint includes a screenshot of an iPhone's lock screen notification, which states "Optimized Battery Charging Scheduled to finish charging by 1:30 PM," to illustrate this functionality (Compl. p. 15). The complaint also references a state diagram from the Qi Specification to describe the protocol phases, including "Selection," "Ping," and "Power Transfer," that allegedly map to the patent's claimed modules (Compl. p. 13).
IV. Analysis of Infringement Allegations
Claim Chart Summary
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a connection module to determine when a target device is coupled to an inductive power apparatus | Functionality is allegedly provided by the Qi Specification's "ping phase," where the charger detects the presence of a compatible device. | ¶30(a), ¶38 | col. 2:2-5 |
| a monitoring module to determine when a target device battery is below a charging threshold while using power from a supplemental power source | Functionality is allegedly provided by Apple's "Optimized Battery Charging" feature, which monitors the battery's charge level (e.g., 80%) and learns user habits to manage charging. This is also alleged to occur via Qi protocol communication packets. | ¶30(b), ¶37-38 | col. 2:5-8 |
| an activation module to automatically couple the inductive power apparatus and an alternating current power source when a power level of the target device battery is below the charging threshold | Functionality is allegedly provided by the Qi protocol, where the system couples the power source via receipt of EPT (End Power Transfer) data packets or other signals indicating charging should resume. | ¶30(c), ¶38 | col. 2:8-11 |
| a separation module to automatically decouple the inductive power apparatus and the alternating current power source when a desired charging state of the target device battery is observed | Functionality is allegedly provided by the Qi protocol, which decouples the primary coil from the AC power source upon reaching a desired state (e.g., 80% or 100% charge) via receipt of EPT data packets. This is illustrated by Apple's "Optimized Battery Charging" feature. | ¶30(d), ¶37-38 | col. 2:12-15 |
| wherein the separation module is comprised of a relay switch | The complaint alleges the Accused Systems use a "relay switch" to perform the decoupling, pointing to the Qi Specification's allowance for stopping current on a primary coil. A functional block diagram from the Qi specification is referenced to show the power conversion unit (Compl. p. 17). | ¶30(d), ¶38 | col. 2:16-21 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over the term "relay switch". The complaint alleges infringement by modern, semiconductor-based consumer electronics. The case may turn on whether the solid-state power control circuitry in Apple's products can be construed as a "relay switch" as that term is used in the patent, especially given that the prosecution history cited in the complaint identifies this exact element as a basis for patentability (Compl. ¶25).
- Technical Questions: A question of fact may be whether Apple's "Optimized Battery Charging" feature, which is marketed as a battery health and user convenience feature, performs the same function in the same way as the patent's system, which is described as a means to prevent "vampiric power loss." The motivation and triggering conditions (user habits vs. a fixed charge threshold) may be a point of dispute.
V. Key Claim Terms for Construction
- The Term: "relay switch"
- Context and Importance: This term is critical because the complaint highlights that the USPTO Examiner explicitly relied on the presence of a "separation module... comprised of a relay switch" as a key reason for allowing the patent claims (Compl. ¶25). Its construction will therefore be a focal point of the infringement analysis. Practitioners may focus on this term because its definition could either be broad enough to cover modern solid-state switching components or be limited to more traditional electromechanical devices.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term is not limited to a single type, stating the method may include "deactivating a solid state relay, such as an opto-coupled relay" ('103 Patent, col. 3:6-7). This language may support an argument that the term encompasses modern, non-mechanical switching circuits.
- Evidence for a Narrower Interpretation: The specification also states that in another aspect, "an electromechanical relay may be used" ('103 Patent, col. 3:9-10). A defendant could argue this reference, combined with the common understanding of "relay" at the time of invention, implies a more structural, physical component rather than any semiconductor that performs a switching function.
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Apple induces infringement by providing instructions to customers and users on how to operate the Accused Systems in a manner that infringes the ’103 Patent (Compl. ¶31).
- Willful Infringement: The complaint does not contain a separate count for willful infringement or allege specific facts demonstrating Apple's pre-suit knowledge of the ’103 Patent. However, it requests enhanced damages of up to three times the amount found, which is the statutory remedy for willful infringement (Compl. ¶43.b).
VII. Analyst’s Conclusion: Key Questions for the Case
- Patent Enforceability: A threshold question for the court will be the status of the patent itself. Given the complaint's disclosure that the patent lapsed for non-payment of maintenance fees, the outcome of the pending petition to revive the patent at the USPTO will determine if a cause of action exists at all (Compl. ¶10).
- Definitional Scope: The case will likely hinge on a question of claim construction: can the term "relay switch", which was a key limitation for patentability, be interpreted to read on the integrated, solid-state power management circuitry found in modern consumer electronics like Apple's MagSafe products?
- Functional Mismatch: A key evidentiary question will be one of technical operation: does Apple's "Optimized Battery Charging" feature, designed to improve battery longevity based on learned user behavior, perform the specific function of the claimed "separation module," which is described as a system to prevent vampiric power loss by decoupling from AC power when a charge threshold is met?