DCT

1:25-cv-01300

CyboEnergy Inc v. Yotta Energy Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:25-cv-01300, W.D. Tex., 08/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business within the Western District of Texas and has committed the alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s power inverters infringe two patents related to methods for maximizing solar power generation in low-light conditions and for providing system status information via a visual message system.
  • Technical Context: The technology concerns solar power mini-inverters, which convert direct current (DC) from individual or small groups of solar panels into alternating current (AC) for use by the power grid or local electrical loads.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2011-06-30 U.S. Patent No. 9,331,488 Priority Date
2013-03-07 U.S. Patent No. 9,331,489 Priority Date
2016-05-03 U.S. Patent No. 9,331,488 Issue Date
2016-05-03 U.S. Patent No. 9,331,489 Issue Date
2025-08-13 Complaint Filing Date

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

U.S. Patent No. 9,331,489 - "Maximizing Power Production at Low Sunlight by Solar Power Mini-Inverters," issued May 3, 2016

The Invention Explained

  • Problem Addressed: The patent describes a problem where conventional solar inverters must shut down during periods of low sunlight (such as sunrise, sunset, or partial shading) because the connected solar panel(s) cannot produce enough DC power to both operate the inverter's internal electronics and generate usable AC power (’489 Patent, col. 4:11-24). This forced shutdown results in a loss of potential power generation.
  • The Patented Solution: The invention is a multi-channel mini-inverter that can operate in a "low power mode." In this mode, the inverter dedicates one of its input channels to exclusively draw DC power from its connected solar panel to run the inverter’s internal circuits. This allows the remaining channels to use all of the limited power they receive to continue generating AC power for the grid, extending the inverter's operational time each day (’489 Patent, col. 5:25-42; Fig. 3).
  • Technical Importance: This approach is designed to increase the total energy harvested by a solar power system by enabling power generation to continue during marginal light conditions when other inverters would be inactive (’489 Patent, col. 5:53-63).

Key Claims at a Glance

  • The complaint asserts infringement of claims 1-16 (Compl. ¶8).
  • Independent Claim 1 recites the essential elements of a multiple channel DC-to-AC power inverter, including:
    • At least two DC power input ports.
    • An AC power output port for supplying power to an electric grid.
    • A DC-DC boost converter for each input port.
    • A DC power combiner and a DC-AC inverter.
    • A digital microcontroller arranged to run the inverter in a "normal or low power mode based on calculated DC input power."
    • A DC power supply that is "configured with one input channel and its connected solar panel dedicated to supply DC power to the DC power supply when the digital microcontroller detects that calculated input power is below a pre-determined value."
  • The complaint reserves the right to assert dependent claims (Compl. ¶8).

U.S. Patent No. 9,331,488 - "Enclosure and Message System of Smart and Scalable Power Inverters," issued May 3, 2016

The Invention Explained

  • Problem Addressed: The patent identifies the need for an effective and user-friendly method for installers to understand the operational status of increasingly complex multi-channel solar inverters, both for the system as a whole and for each individual input channel (’488 Patent, col. 11:7-15).
  • The Patented Solution: The patent discloses an inverter that incorporates a "message system" using light-emitting diodes (LEDs). This system includes a general "system status LED" to indicate the overall state of the inverter and separate, individual "channel status LEDs" for each DC input. A digital microcontroller controls the color and flashing pattern of these LEDs to provide specific diagnostic information about the inverter and each connected solar panel (’488 Patent, Abstract; col. 2:3-9).
  • Technical Importance: This provides installers with immediate, on-site visual diagnostic feedback, which may reduce installation time and simplify the process of troubleshooting connections and performance issues in a multi-panel solar array (’488 Patent, col. 11:15-22).

Key Claims at a Glance

  • The complaint asserts infringement of claims 1-17 (Compl. ¶15).
  • Independent Claim 1 recites the elements of a multiple channel power inverter, including standard power conversion components (DC input channels, AC output, boost converters, DC power combiner, DC-AC inverter) and a control system, culminating in the key element:
    • "a message system connected to said digital microcontroller and arranged to indicate the status of the power inverter and the status of each input channel."
  • The complaint reserves the right to assert dependent claims (Compl. ¶15).

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentalities as "power inverters" that Defendant YOTTA "maintains, operates, manufactures, offers for sale and sells" (Compl. ¶8, ¶15). No specific product models or names are provided in the body of the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the specific technical functionality of the accused power inverters or their market positioning. It states that support for the infringement allegations is contained in attached exhibits, which were not filed with the complaint (Compl. ¶9, ¶16).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart Exhibits B and D for the ’489 and ’488 Patents, respectively, but these exhibits were not provided with the public filing (Compl. ¶9, ¶16). The narrative theory of infringement is therefore based on the general allegations in the complaint.

Plaintiff alleges that Defendant’s power inverters practice the inventions claimed in the patents-in-suit (Compl. ¶8, ¶15). For the ’489 Patent, this suggests an allegation that the accused products implement a low-power operational mode where one of multiple input channels is used to power the inverter’s own electronics while the others continue to generate AC power. For the ’488 Patent, this suggests an allegation that the accused products include an LED-based indicator system that provides status information for both the overall inverter and for each of its individual input channels.

Identified Points of Contention

  • Factual Question (’489 Patent): A central question will be whether the accused inverters, in low-light conditions, actually perform the function of dedicating a single solar panel input to power internal electronics while other inputs continue to export AC power, as required by Claim 1 of the ’489 Patent.
  • Factual Question (’488 Patent): The analysis may focus on whether the accused inverters possess a "message system" that indicates both the overall system status and the status of "each input channel" distinctly, as required by Claim 1 of the ’488 Patent.
  • Scope Question: The dispute may raise the question of whether the functionality of the accused products meets the specific limitations recited in the asserted claims.

V. Key Claim Terms for Construction

U.S. Patent No. 9,331,489

  • The Term: "one input channel... dedicated to supply DC power to the DC power supply" (from Claim 1).
  • Context and Importance: This phrase defines the core inventive concept of the low-power mode. The outcome of the infringement analysis for the ’489 Patent will likely depend on the construction of this term and whether the accused products' operation falls within that construction.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the function as selecting a channel to "stop[] pulling power... for AC power generation" so its power can instead "enter DC power supply 36" (’489 Patent, col. 5:30-37). A party may argue that any operational mode that achieves this function, regardless of the specific software or hardware implementation, meets the limitation.
    • Evidence for a Narrower Interpretation: The description and Figure 3 illustrate a specific architecture where DC power from one solar panel "can pass through the DC converter... and DC power combiner... and enter DC power supply" (’489 Patent, col. 5:34-37). A party may argue the term "dedicated" requires a specific and exclusive routing of power from one channel for this purpose, consistent with the disclosed embodiment.

U.S. Patent No. 9,331,488

  • The Term: "a message system... arranged to indicate the status of the power inverter and the status of each input channel" (from Claim 1).
  • Context and Importance: This term is central to defining the required diagnostic capability. The infringement analysis for the ’488 Patent will turn on whether the accused device's indicators provide these two distinct types of status information.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states the purpose of the message system is to be an "effective and user-friendly way of communicating with the solar system installers" (’488 Patent, col. 11:12-15). This suggests a functional definition, where any visual system that effectively communicates both overall and per-channel status could be covered.
    • Evidence for a Narrower Interpretation: The specification consistently describes and illustrates an embodiment with physically separate LEDs: "a system status LED 26" and multiple "channel status LED[s] 28" (’488 Patent, col. 3:4-7; Fig. 1). A party could argue that the claim requires distinct indicators for the system and the channels, not a single indicator that conveys both types of information.

VI. Other Allegations

Indirect Infringement

The complaint alleges both induced and contributory infringement for each patent. The allegations are based on Defendant providing instructional materials (manuals, videos, etc.) that allegedly encourage infringing use, and on the assertion that the accused products have no substantial non-infringing uses (Compl. ¶10-11, ¶17-18).

Willful Infringement

The complaint does not plead pre-suit knowledge but makes a contingent claim for willful infringement in the prayer for relief, seeking enhanced damages if discovery reveals that the Defendant knew of the patents-in-suit prior to the lawsuit (Compl. p. 7, ¶e).

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

This dispute appears to center on highly specific product functionalities. The resolution will likely depend on the answers to two primary questions:

  1. A core question of technical operation: Does discovery reveal evidence that the accused YOTTA inverters actually implement the specific "low power mode" claimed in the ’489 Patent, where one input channel is functionally set aside to power internal electronics while others continue generating AC power?
  2. A secondary question of definitional scope: For the ’488 Patent, can the phrase "a message system... to indicate the status of the power inverter and the status of each input channel" be construed to read on the accused devices' indicator lights, and does that system provide the two distinct types of information required by the claim?