DCT

1:25-cv-00630

Crosslayer Communications LLC v. Eaton Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-630, W.D. Tex., 04/29/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant Eaton has a regular and established place of business in the district, such as its El Paso manufacturing facility, and has committed acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s smart grid automation and microgrid energy systems infringe five patents related to electrical grid fault isolation, service restoration, and dynamic microgrid management.
  • Technical Context: The technology addresses the management of modern electrical grids, which have grown more complex with the integration of distributed energy sources, to improve reliability and mitigate power outages.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the Asserted Patents.

Case Timeline

Date Event
2011-09-13 Earliest Priority Date for ’129, ’243, ’667 Patents
2012-11-29 Earliest Priority Date for ’416, ’790 Patents
2014-10-28 U.S. Patent No. 8,872,667 Issued
2017-10-10 U.S. Patent No. 9,785,129 Issued
2018-03-20 U.S. Patent No. 9,923,416 Issued
2018-06-26 U.S. Patent No. 10,007,243 Issued
2022-05-24 U.S. Patent No. 11,342,790 Issued
2025-04-29 Complaint Filed

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

U.S. Patent No. 9,785,129 - "Fault Isolation and Service Restoration in an Electric Grid"

The Invention Explained

  • Problem Addressed: The patent describes the increasing difficulty electricity suppliers face in monitoring electrical grids for faults, such as downed power lines, and reacting in time to prevent or mitigate power outages, a challenge compounded by the growing complexity of the grid (’129 Patent, col. 1:11-50).
  • The Patented Solution: The invention proposes a system where electrical components on the grid communicate their status to a central computing system via a "notification message." This system can then "predict an electrical fault" based on rules and send a "command action" back to the grid components to reroute electricity and bypass the predicted fault, thereby improving grid reliability both reactively and proactively (’129 Patent, Abstract; col. 2:57-65).
  • Technical Importance: This approach allows for automated, real-time, and granular control over the electrical grid, moving beyond manual intervention to a more intelligent and responsive management system (’129 Patent, col. 4:1-13).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶24-25).
  • Claim 1 (System):
    • A computer infrastructure operable to:
    • receive a notification message of an electrical device on an electrical grid, the message including a status of the device;
    • predict an electrical fault of the device based on a set of rules related to the device and the notification message; and
    • send a command action to at least one of the electrical device and other electrical components in response to the predicted fault, where the command action includes a corrective action to reroute electricity, bypassing the predicted fault.

U.S. Patent No. 10,007,243 - "Fault Isolation and Service Restoration in an Electric Grid"

The Invention Explained

  • Problem Addressed: Similar to the ’129 Patent, this patent addresses the need for more efficient and reliable management of electrical grids to detect faults and prevent power outages (’243 Patent, col. 1:29-50).
  • The Patented Solution: The invention describes a method where a computing system receives a "notification message" indicating the state of an electrical component. In response, the system determines and sends a "command message" with at least one action to the component and other devices on the grid, enabling automated fault isolation and service restoration (’243 Patent, Abstract; col. 1:53-2:2).
  • Technical Importance: The patented solution provides a framework for both centralized and decentralized fault isolation, allowing for more robust grid management that can react to faults even if parts of the communication network are disrupted (’243 Patent, col. 3:20-28).

Key Claims at a Glance

  • The complaint asserts independent claim 1 and reserves the right to assert additional claims (Compl. ¶33-34).
  • Claim 1 (Method):
    • Receiving a notification message including a state of an electrical component on an electrical grid;
    • Determining, by a computing system, a command message including at least one action to take in response to the state; and
    • Sending the command message to at least one of the electrical component and other electrical components on the electrical grid.

U.S. Patent No. 8,872,667 - "Fault Isolation and Service Restoration in an Electric Grid"

  • Technology Synopsis: This patent, from the same family as the ’129 and ’243 patents, discloses systems and methods for improving grid performance. It describes using distributed monitoring devices to report grid measurements and, when abnormalities are detected, automatically requesting a fault isolation operation to isolate a predicted fault (Compl. ¶3).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶43).
  • Accused Features: The complaint accuses Eaton's "Distributed Automation Accused Products" of infringement (Compl. ¶5).

U.S. Patent No. 9,923,416 - "Configuring, Optimizing, and Managing Micro-Grids"

  • Technology Synopsis: This patent addresses the creation and management of dynamic microgrids. It describes a utility operator controlling switches to form a self-sufficient, isolated "island" within the broader distribution grid, which can satisfy its own power demand using local energy resources and thus minimize the customer impact of grid disruptions (Compl. ¶4).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶52).
  • Accused Features: The complaint accuses Eaton's "Microgrid Accused Products" of infringement (Compl. ¶6).

U.S. Patent No. 11,342,790 - "Configuring, Optimizing, and Managing Micro-Grids"

  • Technology Synopsis: This patent, related to the ’416 Patent, also discloses technology for configuring and managing microgrids. The system involves determining premises with energy resources, configuring a microgrid to include them, and electrically isolating that microgrid from the main distribution grid (’790 Patent, Abstract).
  • Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶61).
  • Accused Features: The complaint accuses Eaton's "Microgrid Accused Products" of infringement (Compl. ¶6).

III. The Accused Instrumentality

Product Identification

The complaint identifies two categories of accused products:

  1. Distributed Automation Accused Products: An integrated solution including "FLISR software, Volt/VAR management software, optical sensors, smart sensors and smart sensor software, automatic source transfer controls, capacitor bank controls, recloser controls, voltage regulator controls and automated switchgear controls" (Compl. ¶5).
  2. Microgrid Accused Products: Systems including "Xpert Microgrid Controllers, Pow-R-Line Xpert panelboards & switchboards, battery energy storage systems, XLM supercapacitor modules and cabinets, solar photovoltaic systems, smart inverters and load control devices" (Compl. ¶6).

Functionality and Market Context

  • The Distributed Automation products are alleged to "integrate[] real-time data to detect distribution system disturbances and automatically reconfigure the system, significantly improving reliability" (Compl. ¶5).
  • The Microgrid Accused Products are alleged to be used by Eaton's customers to create and manage dynamic microgrids, which are self-sufficient electrical islands that can operate independently from the main grid to minimize disruptions (Compl. ¶4, ¶6).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references external exhibits (Exhibits F and G) for its detailed infringement analysis of the ’129 and ’243 patents, which were not provided with the complaint. The narrative infringement theory is summarized below in prose.

  • ’129 Patent Infringement Allegations Summary:
    The complaint alleges that Eaton's Distributed Automation Accused Products directly infringe claim 1 of the ’129 Patent (Compl. ¶24). The core of the allegation is that these products perform the claimed system functions by using real-time grid data to detect disturbances (analogous to receiving a "notification message"), processing that data to determine a corrective action (analogous to "predicting an electrical fault" and determining a "command action"), and automatically reconfiguring the grid (analogous to sending the "command action" to reroute electricity) (Compl. ¶3, ¶5).

  • ’243 Patent Infringement Allegations Summary:
    The infringement theory against the ’243 patent is substantively identical to that for the ’129 patent. The complaint alleges the same Distributed Automation Accused Products directly infringe claim 1 of the ’243 patent by performing the claimed method steps (Compl. ¶33). The products' alleged functionality of detecting system disturbances from real-time data and automatically reconfiguring the system is purported to meet the claim limitations of receiving a notification, determining a command, and sending that command to grid components (Compl. ¶3, ¶5).

  • Identified Points of Contention:

    • Scope Questions: A central question may be whether the accused products, described as integrating "real-time data," meet the claim requirements for receiving a discrete "notification message" and determining a "command message." The patents describe these steps in the context of specific communication protocols like Session Initiation Protocol (SIP) (’129 Patent, col. 3:32-35), which raises the question of whether generic data telemetry and automated control logic fall within the scope of the claims.
    • Technical Questions: The complaint provides a high-level functional description of the accused products but lacks detail on their specific operation. A key technical question will be what evidence demonstrates that the accused products' general function of "detect[ing] disturbances" performs the specific, multi-part logical steps required by the claims, such as "predict[ing] an electrical fault... based on a set of rules" (’129 Patent, Claim 1).

V. Key Claim Terms for Construction

  • The Term: "notification message" (from ’129 Patent, Claim 1; ’243 Patent, Claim 1)

    • Context and Importance: This term defines the input that triggers the patented process. Its construction will be critical in determining whether the continuous stream of "real-time data" allegedly used by Eaton's products (Compl. ¶5) constitutes the specific "notification message" required by the claims, or if the claims require a more discrete, structured communication.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claims themselves do not limit the "notification message" to a specific protocol or format, only requiring that it include a "state" of an electrical component (’243 Patent, col. 23:59-61). The specification also refers more generally to receiving "status information" (’129 Patent, col. 3:40-42).
      • Evidence for a Narrower Interpretation: The detailed description of the invention heavily emphasizes the use of Session Initiation Protocol (SIP) as the communication framework (’129 Patent, col. 3:32-35, col. 6:40-45). A party could argue that "notification message" should be understood in this specific technological context, implying a structured message within a session-based protocol rather than any raw data point.

  • The Term: "predict an electrical fault" (from ’129 Patent, Claim 1)

    • Context and Importance: This term describes the core analytical step of the claimed system. The dispute may center on whether a simple, threshold-based alert in the accused system (e.g., if voltage > X, act) meets the requirement to "predict" a fault, or if the term implies a more sophisticated, rule-based inference about a future or developing event.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not specify the complexity of the prediction. Any determination that a fault condition is met could be argued to be a form of prediction.
      • Evidence for a Narrower Interpretation: The specification suggests a proactive capability, allowing fault isolation "before a predicted electrical fault occurs" (’129 Patent, col. 4:5-6). It also describes the system being operable to predict a fault "based on a set of rules" (Claim 1), which may suggest a process more complex than a simple real-time alarm trigger.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Eaton actively induces infringement by providing the accused products to its customers (e.g., utility companies) and providing instructions on how to use them in an infringing manner (Compl. ¶28, ¶37). It specifically identifies Eaton’s "Distribution Automation: Fundamentals of Distribution Automation" website as a source of such instructions (Compl. ¶30, ¶39).
  • Willful Infringement: The complaint does not use the term "willful." It alleges Eaton has knowledge of the patents and its infringement "at least as of the service and filing of this Complaint" (Compl. ¶29, ¶38, ¶47, ¶56, ¶65). This pleading establishes a basis for potential post-suit enhancement of damages but does not allege pre-suit knowledge or willfulness.

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

  • A core issue will be one of technical and definitional scope: Can the patent claims, which describe a structured process of receiving discrete "notification messages," predicting faults, and determining "command messages," be construed to cover the accused products' more generally described function of integrating "real-time data" to "detect disturbances and automatically reconfigure the system"? The outcome may depend on whether the evidence shows a fundamental match or mismatch in the specific technical operations.
  • A key legal question will be one of direct versus indirect liability: The complaint accuses Eaton of both direct and induced infringement. Given that Eaton sells the component systems to utility operators who then operate the electrical grids, the case will likely involve a significant dispute over whether Eaton itself performs every step of the claimed methods, or whether its liability, if any, stems from inducing its customers to do so.
  • An evidentiary question will be one of technological implementation: The patents describe a system built around telecommunications protocols like SIP. The case may turn on evidence showing whether the accused products operate using a fundamentally similar architecture or a distinct technological approach to achieve automated grid management, which would inform both infringement and potential invalidity arguments.