DCT
1:24-cv-01377
Vampire Labs LLC v. Apple Inc
Key Events
Amended Complaint
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: 1:24-cv-01377, W.D. Tex., 08/27/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Apple maintains multiple regular and established places of business within the district.
- Core Dispute: Plaintiff alleges that Defendant’s wireless charging products, including its MagSafe line, infringe a patent related to technology for automatically decoupling a charger from its AC power source to prevent "vampiric power loss" when a device is fully charged.
- Technical Context: The technology at issue addresses energy efficiency in inductive power systems, a commercially significant feature in the widespread consumer market for wirelessly charged devices like smartphones and wearables.
- Key Procedural History: The complaint discloses that the patent-in-suit lapsed for failure to pay maintenance fees and that a petition to reinstate it was filed with the USPTO in October 2024. The complaint also highlights the patent's prosecution history, noting the examiner's statement that the claims were allowed over prior art due to the combination of an "activation module" and a "separation module comprised of a relay switch."
Case Timeline
| Date | Event |
|---|---|
| 2008-07-04 | U.S. Patent No. 8,358,103 Priority Date |
| 2009-01-01 | Plaintiff allegedly met with Apple to present technology (approx.) |
| 2009-08-01 | Wireless Power Consortium published first Qi specification (approx.) |
| 2012-09-04 | Parent patent cited in Office Action against Apple |
| 2013-01-22 | U.S. Patent No. 8,358,103 Issued |
| 2024-10-22 | Plaintiff filed Petition to reinstate lapsed '103 Patent |
| 2025-08-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
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"*
- 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 "’103 Patent").
The Invention Explained
- Problem Addressed: The patent addresses the problem of "vampiric power loss," where inductive charging units continue to draw power from an AC source even after the target device's battery is fully charged or the device is disconnected. This results in wasted energy, which the patent notes can contribute to unnecessary power generation and associated environmental and financial costs (Compl. ¶¶14, 16; ’103 Patent, col. 1:25-62).
- The Patented Solution: The invention is an inductive charging system designed to intelligently manage its connection to an AC power source. It uses a series of functional modules: a "connection module" to detect when a device is present, a "monitoring module" to determine the device's battery level, an "activation module" to automatically connect AC power and begin charging when the battery is low, and a "separation module" containing a "relay switch" to automatically decouple the system from AC power when the battery reaches a desired charge state (Compl. ¶¶20, 23; ’103 Patent, Abstract, col. 2:2-21). A block diagram in Figure 9 illustrates the relationship between these modules ('103 Patent, Fig. 9).
- Technical Importance: At the time of the invention, this technology offered a solution to improve the energy efficiency of nascent wireless charging systems, a key consideration for consumer electronics (Compl. ¶¶8, 17).
Key Claims at a Glance
The complaint bases its allegations on at least Claim 1 (Compl. ¶¶28, 40).
- Independent Claim 1: An inductive battery charging system comprising:
- 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 a power level of the target device battery is below the charging threshold;
- 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,
- wherein the separation module is comprised of a relay switch,
- wherein the inductive power apparatus includes at least one of a transformer to inductively generate an electric current, a rectification circuit, and a voltage regulation circuit.
III. The Accused Instrumentality
Product Identification
The complaint identifies the accused instrumentalities as "Apple's inductive charging products that comply with the Qi Specification," including but not limited to Apple's "MagSafe Charger, iPhones and similar devices, and Apple's accessories/wearables, including the Apple Watch line of products" (the "Accused Systems") (Compl. ¶¶27, 41).
Functionality and Market Context
The Accused Systems are alleged to provide wireless charging that conforms to the Qi standard, an industry specification for wireless power transfer (Compl. ¶27). The complaint points to Apple's "Optimized Battery Charging" feature, which learns from a user's daily charging habits to manage the charging cycle, as an example of infringing functionality (Compl. ¶42). A screenshot from an Apple support page describes this feature, noting the iPhone will "delay charging past 80% in certain situations" (Compl. p. 17). The complaint alleges that the Qi protocol, as implemented by Apple, includes functions for detecting a device, monitoring its battery level, and controlling the power transfer, thereby mapping to the claimed invention (Compl. ¶30).
IV. Analysis of Infringement Allegations
- Claim Chart Summary: The complaint alleges that the functionality specified by the Qi standard, and implemented in the Accused Systems, meets the limitations of Claim 1.
’103 Patent Infringement Allegations
| 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 within the Qi protocol, including a "ping phase," for determining when a target device is coupled to the charging apparatus (Compl. p. 13). | ¶¶30a, 43 | col. 2:2-4 |
| a monitoring module to determine when a target device battery is below a charging threshold | Functionality within the Qi protocol for monitoring a device battery's charge level through the transmission and receipt of communication packets. | ¶¶30b, 43 | col. 2:5-7 |
| 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 within the Qi protocol for automatically initiating charging through the receipt of End Power Transfer (EPT) data packets when the battery is below a certain threshold. | ¶¶30c, 43 | 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 within the Qi protocol for automatically ceasing charging, which allegedly involves "decoupling the primary coil from the AC power to stop current on a primary coil." | ¶¶30d, 43 | col. 2:12-15 |
| wherein the separation module is comprised of a relay switch | The complaint alleges the Qi protocol functionality for stopping the current on the primary coil utilizes a "relay switch" to achieve decoupling. A functional block diagram from the Qi specification is provided (Compl. p. 19). | ¶¶30d, 43 | col. 2:20-21 |
| wherein the inductive power apparatus includes at least one of a transformer... a rectification circuit, and a voltage regulation circuit | The Accused Systems are alleged to contain the necessary components for inductive power transfer, including a primary coil (transformer), inverter, and voltage sense circuitry. | ¶¶43-44 | col. 2:15-20 |
- Identified Points of Contention:
- Scope Questions: A central point of contention may be the meaning of the term "relay switch." The complaint notes that this limitation was a basis for the patent's allowance (Compl. ¶25). The dispute may focus on whether the term, as used in the patent, can be construed to read on the modern, solid-state power control circuitry in Apple's products, or if its meaning is restricted to a more traditional electromechanical or opto-coupled relay as discussed in the patent's specification.
- Technical Questions: The analysis may raise the question of whether the technical mechanism used by the Qi protocol to halt power transfer—which typically involves modulating the current in the primary coil rather than physically opening a circuit—performs the same function as the claimed "separation module comprised of a relay switch." The complaint's allegation of "decoupling the primary coil from the AC power" may be scrutinized to determine if it accurately describes the operation of the Accused Systems (Compl. ¶30d).
V. Key Claim Terms for Construction
The Term: "relay switch"
- Context and Importance: The construction of this term appears central to the infringement analysis, as it was identified by the patent examiner as a reason for allowance (Compl. ¶25). Practitioners may focus on this term because its scope will determine whether the accused solid-state power management systems can be found to infringe.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification discloses that the "separation module may include an opto-coupled relay or an electromechanical relay," suggesting the patentee contemplated both solid-state and mechanical embodiments ('103 Patent, col. 4:50-52). The claim itself is not limited to a specific type of relay.
- Evidence for a Narrower Interpretation: The consistent use of the term "relay" and specific embodiments like the "opto-coupled relay 462" could be used to argue that the claim requires a distinct switching component, rather than integrated power-throttling logic that may be present in a modern system-on-a-chip ('103 Patent, Fig. 11).
The Term: "decouple"
- Context and Importance: This term defines the function performed by the "separation module." The dispute will likely concern whether transitioning to a low-power or standby state, as is common in Qi-compliant chargers, constitutes "decoupling," or if the term requires a more complete electrical isolation from the AC power source.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The stated goal of the invention is to prevent "vampiric power loss" ('103 Patent, Abstract). An interpretation where "decouple" means any action that substantially eliminates such loss could be advanced.
- Evidence for a Narrower Interpretation: The specification uses phrases like "cut alternating current power" and describes an operation where a connection is "electrically open," which may support an argument that a full electrical break is required ('103 Patent, col. 7:51-54, col. 8:25-27).
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 practices the claimed methods (Compl. ¶31).
- Willful Infringement: The complaint makes detailed allegations of pre-suit knowledge to support its claim for willful infringement. It alleges that in 2009, Plaintiff met with Apple personnel, including an individual who was later a named inventor on a related Apple patent, to present the patented technology (Compl. ¶35). Further, it alleges that the application leading to the '103 Patent was cited by the USPTO against an Apple patent application, and that a parent patent was cited as a primary reference in multiple rejections of Apple's own patent claims (Compl. ¶¶36-38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "relay switch," a key limitation added during prosecution, be construed to cover the integrated, solid-state power management circuits in modern Qi-compliant devices like Apple's MagSafe charger, or is its meaning confined to the discrete relay components described in the patent?
- A key technical question will be one of functional operation: does the accused Qi protocol's method of halting power transfer by ceasing current in a primary coil constitute "decoupling" as claimed in the patent, or is there a fundamental mismatch between the accused system's power-throttling protocol and the patent’s claimed on/off switching mechanism?
- Given the specific allegations of a 2009 meeting and repeated USPTO citations, a significant focus of the case will likely be on willfulness: whether the evidence demonstrates that Apple had pre-suit knowledge of the '103 Patent and its technology, and if its subsequent actions could be considered egregious enough to warrant enhanced damages.