DCT
1:24-cv-01378
Vampire Labs LLC v. Anker Innovations Ltd
Key Events
Amended Complaint
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: 1:24-cv-01378, W.D. Tex., 06/10/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is not a resident of the United States and therefore may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s wireless charging products, which comply with the Qi wireless charging standard, infringe a patent related to automatically decoupling a power source to prevent energy waste after a device is fully charged.
- Technical Context: The case concerns inductive (wireless) charging technology, a ubiquitous feature in modern consumer electronics that eliminates the need for physical power cables.
- Key Procedural History: The complaint notes that the patent-in-suit lapsed for failure to pay maintenance fees and was subsequently revived by the USPTO following a petition. This history may be relevant to the calculation of past damages, though the complaint states Plaintiff seeks only future damages.
Case Timeline
| Date | Event |
|---|---|
| 2008-07-04 | ’103 Patent Priority Date |
| 2009-08-01 | Qi low-power specification first published |
| 2013-01-22 | ’103 Patent Issue Date |
| 2024-10-22 | Petition to revive ’103 Patent submitted |
| 2025-06-10 | Complaint Filing Date |
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*
The Invention Explained
- Problem Addressed: The patent addresses the problem of "vampiric power loss," where an inductive charging unit continues to draw power from an AC source even after the target device's battery is fully charged, leading to wasted energy (Compl. ¶21; ’103 Patent, col. 1:25-30, 5:3-11).
- The Patented Solution: The invention is an inductive charging system that includes a series of functional modules to intelligently manage the charging process. It uses a "connection module" to determine when a device is present, a "monitoring module" to assess the battery's charge level, an "activation module" to couple the charger to AC power when the battery is low, and a "separation module" to automatically decouple the AC power when the battery reaches a desired charge state (’103 Patent, col. 2:2-21). This automatic decoupling is intended to prevent the vampiric power loss associated with prior art systems (Compl. ¶22).
- Technical Importance: This approach provided a specific, automated technical solution to improve energy efficiency in the then-emerging field of wireless charging, moving beyond simple continuous power delivery (Compl. ¶¶20, 26).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶47).
- 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.
- The complaint reserves the right to proceed under the doctrine of equivalents (Compl. ¶56).
III. The Accused Instrumentality
Product Identification
The "Accused Systems" are Defendant's wireless inductive charging devices that comply with the Wireless Power Consortium's (WPC) Qi Specification (Compl. ¶46). Specific examples cited include the Anker 544 Wireless Charger, Anker PowerWave Stand, Anker Power Wave Pad, and Anker 333 Wireless Charger (Compl. ¶56).
Functionality and Market Context
The Accused Systems provide wireless charging for consumer electronics like smartphones (Compl. ¶¶46-47). The complaint alleges that compliance with the Qi Specification mandates the functionality claimed in the ’103 Patent (Compl. ¶47). Specifically, it points to the Qi protocol's phases for device detection ("ping phase"), monitoring charge levels via communication packets, and stopping current on the primary coil when charging is complete (Compl. ¶¶49, 58). An included block diagram from a Qi Specification reference design shows a "Communications & Control Unit" managing a "Power Conversion Unit" that includes a primary coil, which is alleged to map to the claimed system (Compl. p. 19).
IV. Analysis of Infringement Allegations
Infringement Allegations (U.S. Patent No. 8,358,103)
| 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 via a "ping phase" as specified by the Qi protocol. | ¶49(a) | col. 2:2-5 |
| a monitoring module to determine when a target device battery is below a charging threshold... | The Accused Systems monitor the battery's charge level through the transmission and receipt of communication packets between the power transmitter and receiver, per the Qi protocol. | ¶49(b) | 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 with the AC source based on communications from the target device indicating its battery is below a threshold. | ¶49(c) | col. 2:8-12 |
| 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 automatically decouple the primary coil from the AC power to stop current when the target device signals it has reached a desired state, such as through receipt of an End Power Transfer (EPT) packet. | ¶49(d) | col. 2:12-16 |
| wherein the separation module is comprised of a relay switch | The complaint alleges this functionality is met by the Qi protocol's requirement to decouple the primary coil from the AC power to stop current. | ¶49(d) | col. 2:19-21 |
| wherein the inductive power apparatus includes at least one of a transformer... a rectification circuit, and a voltage regulation circuit | The Accused Systems, as Qi-compliant power transmitters, include these components as part of their power conversion unit. This is illustrated by a functional block diagram from the Qi Specification. | ¶58; Compl. p. 19 | col. 2:15-19 |
Identified Points of Contention
- Scope Questions: The central dispute may turn on whether the functional states and communication protocols of the Qi standard (Compl. p. 15) can be mapped to the specific "module" limitations of Claim 1. A question for the court will be whether the terms "connection module," "monitoring module," "activation module," and "separation module" require distinct hardware or software structures, or if they can be read to cover the distributed, protocol-driven functionality of a Qi-compliant system.
- Technical Questions: A key technical question will be what component in the Accused Systems constitutes the claimed "relay switch." The complaint alleges the function is met by "decoupling the primary coil from the AC power to stop current on a primary coil" (Compl. ¶49(d)), but it does not identify a specific physical or logical switch component in the accused products that performs this function.
V. Key Claim Terms for Construction
The Term: "separation module"
- Context and Importance: This term is critical because it performs the core function of preventing vampiric power loss. The complaint identifies this module, along with the "activation module" and "relay switch," as a key reason for the patent's allowance over the prior art (Compl. ¶32). How this term is construed will directly impact whether the Qi standard's "End Power Transfer" state infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims describe the module functionally, as something "to automatically decouple the inductive power apparatus" when a condition is met (’103 Patent, col. 18:41-44). This functional language may support an interpretation that covers any component or set of components that achieves the decoupling result, regardless of its specific implementation.
- Evidence for a Narrower Interpretation: The specification discloses specific structures, stating the "separation module may include an opto-coupled relay" (’103 Patent, col. 2:19-21) and depicting it as a distinct block in diagrams like Figure 9 (’103 Patent, Fig. 9). This may support an argument that the term requires a more defined structure than merely a logical state within a control protocol.
The Term: "relay switch"
- Context and Importance: This term, recited as a component of the "separation module," adds a specific structural limitation to Claim 1. The infringement analysis depends on whether the mechanism used in the Accused Systems to stop power transfer qualifies as a "relay switch."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent uses the term in the context of both "an opto-coupled relay or an electromechanical relay" (’103 Patent, col. 4:51-52), suggesting the patentee did not intend to limit the term to a single type of switch. A party could argue it covers any electrical switch that performs the function.
- Evidence for a Narrower Interpretation: The specification consistently discusses the "relay switch" in the context of physically opening the AC circuit (e.g., ’103 Patent, col. 17:50-52). A defendant may argue that modern solid-state power control methods that do not use a traditional relay to physically break the AC connection, but instead stop driving the primary coil via a controller, do not meet this limitation.
VI. Other Allegations
Indirect Infringement
The complaint alleges induced infringement, stating that Anker "instructs customers and users of the Accused Systems regarding how to use them in a manner that infringes" (Compl. ¶51). This allegation is supported by a reference to an Anker blog post that explains how setting a charging limit on a phone reduces battery stress, which allegedly leverages the infringing functionality (Compl. p. 17).
Willful Infringement
While the complaint does not use the word "willful," it requests enhanced damages up to three times the amount found, pursuant to 35 U.S.C. § 284 (Compl. ¶61(b)). The complaint does not contain facts alleging pre-suit knowledge of the patent.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim scope and structure: can the discrete, functionally-defined "modules" of Claim 1 be construed to read on the integrated control logic and protocol states of the industry-wide Qi standard, or do the claims require distinct corresponding components that are absent in the accused devices?
- A second central question will be one of technical equivalence: does the method by which Anker's Qi-compliant chargers cease power transmission—allegedly by a communications and control unit ceasing to drive the primary coil—constitute infringement of the claim limitation requiring a "separation module... comprised of a relay switch"?
- A third key question will relate to damages: given that the patent was revived after lapsing, the determination of the appropriate period and basis for damages, which the plaintiff has limited to "future damages," will be a significant issue for the court (Compl. ¶17).