DCT
1:24-cv-01378
Vampire Labs LLC v. Anker Innovations Ltd
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Vampire Labs, LLC (Texas)
- Defendant: Anker Innovations Ltd. (Hong Kong)
- Plaintiff’s Counsel: DiNovo Price LLP; SLC Trial Law, PLLC
- Case Identification: Vampire Labs, LLC v. Anker Innovations Ltd., 1:24-cv-01378, W.D. Tex., 11/12/2024
- Venue Allegations: Venue is asserted on the basis that Defendant is not a resident of the United States and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s Qi-compliant wireless charging products infringe a patent related to technology for automatically decoupling a charger from its AC power source to reduce "vampire" energy loss.
- Technical Context: The technology at issue addresses energy conservation in the ubiquitous market for consumer electronic device chargers, specifically those using inductive (wireless) power transfer.
- Key Procedural History: The complaint discloses that the patent-in-suit lapsed due to a failure to pay maintenance fees. Plaintiff filed a petition with the USPTO to have the patent reinstated based on an "unintentionally delayed payment." The outcome of this petition will directly impact the availability of damages in this litigation.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-04 | Earliest Priority Date for U.S. Patent No. 8,358,103 |
| 2009-08-01 | WPC publishes Qi low-power specification (approx. date) |
| 2013-01-22 | U.S. Patent No. 8,358,103 Issues |
| 2024-10-22 | Plaintiff files Petition to Accept Delayed Payment with USPTO |
| 2024-11-12 | 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 Invention Explained
- Problem Addressed: The patent addresses the problem of "vampiric power loss," where inductive charging units continuously consume AC power even after the target device's battery is fully charged or when no device is present (Compl. ¶18; ’103 Patent, col. 1:51-62). This contributes to unnecessary power generation and financial waste.
- The Patented Solution: The invention is a system that intelligently manages power consumption by automatically decoupling the inductive charger from the alternating current (AC) power source when the target device's battery reaches a desired charge state. It then automatically re-couples the power source if the battery level falls below a certain threshold (’103 Patent, Abstract, col. 2:11-15). This functionality is managed through a series of interconnected modules that detect the device, monitor its battery, and activate or deactivate a relay switch controlling the AC power connection (Compl. ¶23, Fig. 9).
- Technical Importance: The technology provides a method for energy conservation in consumer charging devices, which are often left plugged in for extended periods after charging is complete (’103 Patent, col. 1:47-54).
Key Claims at a Glance
- The complaint asserts infringement of at least independent Claim 1 (Compl. ¶34).
- Independent Claim 1 recites an inductive battery charging system with the following key elements:
- A "connection module" to determine when a target device is coupled to the inductive power apparatus.
- A "monitoring module" to determine when the 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 AC power source when the battery level is below the 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".
- Plaintiff reserves the right to assert other claims and to proceed under the doctrine of equivalents (Compl. ¶35).
III. The Accused Instrumentality
Product Identification
- The "Accused Systems" include the Anker 544 Wireless Charger, Anker PowerWave Stand, Anker Power Wave Pad, Anker 333 Wireless Charger, and other Anker wireless charging stations that comply with the Qi Specification (Compl. ¶¶26, 35). An image provided in the complaint shows the Anker PowerWave Stand charging a phone both vertically and horizontally (Compl. p. 9).
Functionality and Market Context
- The Accused Systems are consumer products that provide wireless charging for Qi-compatible devices, such as smartphones (Compl. ¶25). The complaint alleges their operation follows the Qi Specification's protocols, which involve multiple phases such as "Selection," "Ping," "Negotiation," and "Power Transfer" to manage the charging process (Compl. ¶27, ¶28). A graphic in the complaint depicts a state diagram of these protocol phases (Compl. p. 10).
IV. Analysis of Infringement Allegations
’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 | The Accused Systems determine device coupling through a "ping phase" as specified in the Qi protocol (Compl. ¶28(a)). The complaint asserts this module is present in the Accused Systems (Compl. ¶36). | ¶28, ¶36 | 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 | The Accused Systems monitor the target device's battery level through the transmission and receipt of communication packets as specified in the Qi protocol (Compl. ¶28(b)). This module determines when the battery is below a threshold (e.g., less than fully charged) (Compl. ¶36). | ¶28, ¶36 | 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 | The Accused Systems automatically couple the power apparatus and AC source when the battery is below the threshold, allegedly through receipt of EPT (End Power Transfer) data packets as defined by the Qi protocol (Compl. ¶28(c), ¶36). | ¶28, ¶36 | 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...is observed | The Accused Systems allegedly use a relay switch to decouple the apparatus from the AC source when the battery reaches a desired state, as signaled by EPT data packets that trigger decoupling of the primary coil from the AC power (Compl. ¶28(d), ¶36). A patent flowchart illustrates this logic (Compl. ¶21, Fig. 14). | ¶28, ¶36 | col. 2:11-15 |
| wherein the separation module is comprised of a relay switch | The complaint alleges this element is met by the Accused Systems' functionality for decoupling the primary coil from AC power to stop the current, which it equates to a relay switch function (Compl. ¶28(d), ¶36). | ¶36 | col. 2:20-22 |
| 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 these components, with the complaint referencing a functional block diagram from the Qi Specification showing a "Power Conversion Unit" with an inverter and primary coil, which corresponds to the claimed elements (Compl. ¶37, p. 14). | ¶36, ¶37 | col. 1:11-14 |
Identified Points of Contention
- Scope Questions: A central dispute may arise over whether the patent’s functionally-claimed "modules" (e.g., "connection module", "separation module") can be interpreted to cover the software- and protocol-defined states of the Qi standard (e.g., "ping phase"). The patent’s figures depict these as distinct hardware blocks, while the infringement theory relies on interpreting a communication protocol (Compl. ¶23, Fig. 9; Compl. p. 10, Fig. 34).
- Technical Questions: The infringement allegation for the "separation module" raises a key technical question. Claim 1 requires this module to "decouple the inductive power apparatus and the alternating current power source" using a "relay switch." The complaint's evidence points to the Qi standard's instruction to "decoupl[e] the primary coil from the AC power" (Compl. ¶28(d)). A court may need to determine whether ceasing to drive the primary coil is equivalent to physically decoupling the entire apparatus from the AC wall outlet via a relay switch, as the latter is a common method to eliminate vampire power loss.
V. Key Claim Terms for Construction
- The Term: "separation module to automatically decouple the inductive power apparatus and the alternating current power source"
- Context and Importance: The construction of this term appears critical. The dispute may turn on whether "decouple...the alternating current power source" requires a physical disconnection of the AC mains input (as a relay switch implies) or if it can be satisfied by the Qi protocol's function of merely halting power transmission to the inductive coil while the charger's internal power conversion circuitry remains connected to the AC source.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: Plaintiff may argue that the term should be interpreted functionally to mean ceasing the flow of power for the purpose of charging, pointing to claim language that focuses on the automatic nature of the action when a "desired charging state...is observed" (’103 Patent, col. 18:46-48).
- Evidence for a Narrower Interpretation: The explicit inclusion of a "relay switch" in Claim 1, and repeated references to an "opto-coupled relay" in the specification for the purpose of opening the AC circuit, may support a narrower construction requiring a physical break in the AC power line (’103 Patent, col. 2:20-22, col. 2:50-52). The patent's flowchart also depicts an action to "disable 'on current' to relay switch to limit vampiric power consumption" (Compl. ¶21, Fig. 14).
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant instructs customers on how to use the Accused Systems in an infringing manner (Compl. ¶30). It cites a blog post on Anker’s website that explains the benefits of limiting a phone’s charge level, which allegedly encourages use of the patented functionality (Compl. ¶29, p. 12).
- Willful Infringement: The complaint includes a prayer for enhanced damages under 35 U.S.C. § 284, preserving a claim for willful infringement (Compl. ¶40(b)). However, the complaint does not allege specific facts indicating Defendant’s pre-suit knowledge of the ’103 Patent, such as receipt of a notice letter.
VII. Analyst’s Conclusion: Key Questions for the Case
- A Threshold Procedural Question: A gating issue for the case is whether the USPTO will grant Plaintiff’s petition to revive the lapsed ’103 Patent. As acknowledged in the complaint, the patent's unenforceability for a period of time creates significant uncertainty over the scope and availability of damages, which may influence the litigation and settlement strategy of both parties.
- A Core Claim Construction Question: The case will likely hinge on a question of definitional scope: can the claim term "decouple the...alternating current power source," which the patent ties to a "relay switch," be construed to cover the accused Qi-compliant chargers' function of ceasing to energize the primary inductive coil, or does it require a physical disconnection from the AC mains?
- An Evidentiary Question of Technical Equivalence: A central factual dispute will be whether the software-driven states of the Qi communication protocol, as implemented in the Accused Systems, constitute the discrete hardware-style "modules" described and claimed in the ’103 Patent. Plaintiff’s ability to map these protocol functions to the claimed module structures will be critical to its infringement case.