DCT

6:21-cv-01071

Scramoge Technology Ltd v. Apple Inc

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: Scramoge Technology Ltd. (Ireland)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: BC LAW GROUP, Group
Case Identification: 6:21-cv-01071, W.D. Tex., 11/09/2022
Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple is registered to do business in the state, has transacted business in the District, and maintains regular and established places of business within the District.
Core Dispute: Plaintiff alleges that Defendant’s MagSafe and Apple Watch wireless charging products infringe three patents related to managing power sources, maximizing power transfer efficiency, and controlling wireless charging systems.
Technical Context: The technology at issue involves methods for improving the functionality and efficiency of inductive charging systems, a foundational technology for modern portable consumer electronics.
Key Procedural History: The complaint notes pre-suit knowledge of U.S. Patent 7,825,537. Subsequent to the filing of this complaint, Inter Partes Review (IPR) proceedings at the U.S. Patent and Trademark Office resulted in the cancellation of all claims (1-8) of U.S. Patent 10,193,392 and claims 1-5 and 7 of U.S. Patent 9,490,652. These cancellations cover all claims from the '392 patent and the sole independent claim asserted from the '652 patent, a development that may substantially narrow the scope of the present litigation, pending any appeals.

Case Timeline

Date	Event
2008-11-14	’537 Patent Priority Date
2010-11-02	’537 Patent Issue Date
2013-07-24	’652 Patent Priority Date
2014-01-08	’392 Patent Priority Date
2016-11-08	’652 Patent Issue Date
2019-01-29	’392 Patent Issue Date
2021-10-14	Alleged date of Apple’s knowledge of ’537 Patent
2022-11-09	Second Amended Complaint Filing Date
2023-11-13	IPR Certificate issues cancelling claims of ’652 Patent
2023-12-01	IPR Certificate issues cancelling all claims of ’392 Patent

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

U.S. Patent No. 9,490,652 - Wireless charger equipped with auxiliary power supply and auxiliary power device

Issued November 8, 2016

The Invention Explained

Problem Addressed: The patent describes the inconvenience of wireless chargers that still require a dedicated wired connection to a commercial power supply, rendering them non-portable and potentially unusable if a compatible cable is unavailable (ʼ652 Patent, col. 1:40-54).
The Patented Solution: The invention is a wireless charger that incorporates an "auxiliary power unit," including a rechargeable battery. This unit can be charged by an external power source and can subsequently power the wireless transmission unit independently, allowing the device to function as a portable power bank when disconnected from the wall (ʼ652 Patent, col. 2:14-25). The patent describes a boost converter to ensure the voltage from the battery is sufficient for the wireless transmission unit (ʼ652 Patent, col. 2:31-35).
Technical Importance: This approach integrates the functionality of a portable battery pack directly into a wireless charger, enhancing portability and user convenience (ʼ652 Patent, col. 1:58-63).

Key Claims at a Glance

The complaint asserts independent claim 1 (Compl. ¶10).
Essential elements of claim 1 include:
- a power input unit connected to an external power supply
- a wireless power transmission unit for transmitting power via a magnetic field
- an auxiliary power unit comprising:
  - a battery
  - a charge/discharge module that charges the battery from the power input unit and outputs power from the battery when the external supply is stopped
  - a boost converter that boosts the voltage from the charge/discharge module and provides it to the wireless power transmission unit

U.S. Patent No. 7,825,537 - Inductive power transfer system and method

Issued November 2, 2010

The Invention Explained

Problem Addressed: The patent identifies power transfer efficiency as a primary concern for inductive charging systems, noting that conventional methods relying on precisely matched coils are costly and limit design flexibility (ʼ537 Patent, col. 1:33-47).
The Patented Solution: The invention proposes a system with a control circuit that actively manages power transfer. The circuit monitors a parameter "indicative of an efficiency of power transfer" and "automatically" adjusts characteristics of the time-varying current (such as frequency or duty cycle) to "maximize" that efficiency (ʼ537 Patent, col. 2:15-21). One described method to achieve this is by inducing a "self-resonant oscillation" in the secondary coil of the target device (ʼ537 Patent, col. 4:20-34).
Technical Importance: This dynamic feedback and control system allows for efficient power transfer without requiring the rigid, pre-tuned coil designs of prior art systems, potentially increasing flexibility and adaptability (ʼ537 Patent, col. 4:9-15).

Key Claims at a Glance

The complaint asserts independent claim 1 (Compl. ¶16).
Essential elements of claim 1 (method) include:
- positioning a second inductive element of a target unit near a first inductive element of a base unit
- applying a time varying electric current to the first inductive element
- monitoring at least one parameter indicative of an efficiency of power transfer from the base unit to the target unit
- automatically adjusting at least one characteristic of the time varying electric current to maximize the efficiency of power transfer

Multi-Patent Capsule: U.S. Patent No. 10,193,392

Patent Identification: U.S. Patent No. 10,193,392, "Wireless power transfer device and wireless power transfer system," issued January 29, 2019.
Technology Synopsis: The patent addresses the problem of unwanted harmonic distortion and electromagnetic interference generated by wireless power transmitters (ʼ392 Patent, col. 1:50-54). The solution involves using a power converter with a full bridge inverter and a control part that uses a pulse width modulation (PWM) signal, where the duty ratio is specifically selected to minimize the ratio of harmonic magnitude to the fundamental frequency magnitude (ʼ392 Patent, Abstract).
Asserted Claims: The complaint asserts independent claim 1 (Compl. ¶25).
Accused Features: The complaint alleges that the Apple Watch Magnetic Charging Cable and other Apple Wireless Chargers for the Apple Watch infringe this patent (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

The complaint names a range of Apple's wireless charging products, primarily the MagSafe and Apple Watch accessory lines. This includes the MagSafe Battery Pack, MagSafe Charger, MagSafe Duo Charger, Apple Watch Magnetic Charging Dock, Apple Watch Magnetic Fast Charger to USB-C Cable, and various Apple Watch models sold with chargers (Compl. ¶9, ¶15, ¶24).

Functionality and Market Context

The accused products are designed to provide wireless power to Apple's flagship devices, such as the iPhone and Apple Watch (Compl. ¶15). The complaint alleges these devices use magnetic alignment for positioning and incorporate systems for managing power delivery. For example, the complaint cites Apple's documentation stating the MagSafe Duo Charger "intelligently adapts to conditions to optimize charging" and can "dynamically optimize power delivered to the iPhone" (Compl. p. 7). These products represent a significant component of Apple's ecosystem for its mobile devices.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The infringement theories are summarized below in prose.

’652 Patent Infringement Allegations

The complaint alleges that the MagSafe Battery Pack directly infringes claim 1 of the ’652 patent (Compl. ¶9). The infringement theory posits that the MagSafe Battery Pack contains all elements of the claimed wireless charger. It has a power input unit (its Lightning or USB-C port), a wireless power transmission unit (the wireless charging coil), and an auxiliary power unit (the internal battery and associated circuitry) that allegedly performs the functions of the claimed charge/discharge module and boost converter (Compl. ¶8, ¶10).

’537 Patent Infringement Allegations

The complaint alleges that Apple's wireless chargers, such as the MagSafe Duo Charger, infringe claim 1 of the ’537 patent through their normal operation (Compl. ¶15, ¶17). The core of the infringement theory is that Apple's "intelligent" charging systems perform the claimed method. The complaint provides a screenshot of an Apple support page for the MagSafe Duo Charger, highlighting Apple's own description of the product as one that "intelligently adapts to conditions to optimize charging iPhone 12 at up to 14W of peak power delivery" (Compl. p. 7). Plaintiff's theory maps this "intelligent adaptation" to the claim steps of "monitoring" a parameter indicative of efficiency and "automatically adjusting" the current to "maximize" that efficiency (Compl. ¶16-17). The complaint includes a product image of the MagSafe Duo Charger in use, showing it charging both an iPhone and an Apple Watch (Compl. p. 6).

Identified Points of Contention

Technical Questions (for the ’537 Patent): The central dispute for the remaining viable patent will likely concern the specific function of Apple's charging logic. A question for the court will be whether the evidence shows that Apple's system, which the complaint cites as "intelligently adapt[ing] to conditions to optimize charging" (Compl. p. 7), actually performs the precise method of claim 1. Specifically, does it monitor a parameter "indicative of an efficiency of power transfer" and adjust the current for the express purpose of "maximiz[ing] an efficiency," or does it optimize for a different or compound set of variables, such as thermal management, charging speed, and device safety, which may only indirectly affect efficiency?

V. Key Claim Terms for Construction

Analysis focuses on the '537 patent, which appears to be the primary remaining patent in the dispute.

The Term: "parameter indicative of an efficiency of power transfer" (from claim 1)

Context and Importance: The definition of this term is critical. Infringement depends on whether the parameter Apple's system allegedly monitors falls within the claim's scope. Practitioners may focus on this term because Apple could argue its system monitors parameters like temperature or device authentication status, which are not necessarily "indicative of efficiency" in the manner contemplated by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent provides an example of monitoring voltage at a node in the load circuit ('537 Patent, col. 5:20-23, col. 8:5-7), but does not explicitly limit the parameter to this single measurement. A party could argue that any monitored system variable that correlates with efficiency meets this limitation.
- Evidence for a Narrower Interpretation: The patent's detailed description heavily links the maximization of efficiency to the inducement of a "self-resonant oscillation" in the secondary coil ('537 Patent, col. 4:20-34). A party could argue the "parameter" must be an electrical characteristic, like voltage or current, that allows the control circuit to identify and achieve this specific resonant state.

The Term: "to maximize an efficiency of power transfer" (from claim 1)

Context and Importance: This term defines the goal of the "automatically adjusting" step. Whether Apple's system seeks to "maximize efficiency" as its objective is a core question.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue that any adjustment that results in a higher or optimal level of efficiency under the operating conditions satisfies the "maximize" requirement, even if it is not the sole objective.
- Evidence for a Narrower Interpretation: The term "maximize" suggests achieving the highest possible value. The patent's explicit goal is to drive the system to a state of self-resonant oscillation, which it describes as the "most efficient power transfer" ('537 Patent, col. 4:58-60). A party could argue that this limitation requires the system to be programmed to seek this single peak efficiency point, rather than merely "optimizing" or balancing efficiency against other performance goals like safety or charging speed.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement of the '537 patent, stating that Apple "actively encourage[s] and instruct[s] its customers and end users" to use the accused products in an infringing manner (Compl. ¶17). The factual basis provided includes Apple's user manuals and online instructions, with the complaint referencing screenshots of "how to use" guides for the MagSafe Duo Charger (Compl. pp. 6-7). The complaint also alleges contributory infringement, asserting the accused products are especially made to infringe and are not staple articles of commerce suitable for non-infringing use (Compl. ¶18).

Willful Infringement

The complaint alleges that Apple has had knowledge of the '537 patent since "at least the filing and service of the original complaint" and specifically "on or before October 14, 2021" (Compl. ¶17, ¶21). The willfulness claim is based on Apple's continued alleged infringement despite this knowledge.

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

The post-filing invalidation of claims in two of the three asserted patents significantly reshapes the dispute. The case will likely turn on the following key questions:

Procedural Impact: A threshold issue for the court will be the legal effect of the IPR decisions that cancelled the asserted claims of the ’652 and ’392 patents after the complaint was filed. This development raises the question of whether any claims for infringement of those two patents can proceed.
Claim Scope and Technical Operation: For the remaining ’537 patent, the central issue will be one of claim scope. Can the phrase “maximize an efficiency of power transfer” be construed to read on a system, like Apple's, that allegedly "optimizes" charging by balancing multiple factors including power delivery, temperature, and system activity, or does the patent require a singular focus on achieving peak electrical efficiency?
Evidentiary Proof: A key evidentiary question will be what the evidence reveals about the actual operation of Apple's charging systems. Does discovery show that Apple's products in fact monitor a parameter corresponding to power transfer efficiency and adjust current characteristics with the primary goal of maximizing it, as claimed in the patent, or will the evidence demonstrate a different operational priority?