1:25-cv-01025
Minotaur Systems LLC v. Electrify America LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Minotaur Systems LLC (Delaware)
- Defendant: Electrify America, LLC (Delaware)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 1:25-cv-01025, E.D. Va., 09/12/2025
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Virginia.
- Core Dispute: Plaintiff alleges that Defendant’s electric vehicle charging network and associated systems infringe a patent related to monitoring and verifying the location and amount of energy supplied during vehicle charging events.
- Technical Context: The technology addresses the need for accurate, location-verified tracking of energy consumption for electric vehicles to support billing systems and governmental incentive programs.
- Key Procedural History: The operative pleading is a First Amended Complaint; no other significant procedural events such as prior litigation or administrative patent challenges are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2008-12-19 | U.S. Patent No. 8,417,402 Priority Date |
| 2013-04-09 | U.S. Patent No. 8,417,402 Issues |
| 2025-09-12 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,417,402 - "Monitoring of power charging in vehicle"
The Invention Explained
- Problem Addressed: The patent addresses deficiencies in prior art systems that could not reliably "differentiate between electric energy used for charging the vehicle and energy used for other purposes" or associate charging events with specific geographic locations (’402 Patent, col. 1:19-22; Compl. ¶10). This created verification problems for government incentive programs and limited EV owners to designated charging stations to receive credits (Compl. ¶¶10-11).
- The Patented Solution: The invention is an in-vehicle energy meter unit that combines energy measurement with location determination (’402 Patent, Abstract). The unit uses circuitry to measure the energy supplied to the vehicle's battery and a GPS unit to determine the vehicle’s location at the time of charging, then associates these two data points to create a verifiable record (’402 Patent, col. 2:1-4, 2:35-41). This allows verification that energy consumption at a specific address, such as "1234 Main Street," was used for vehicle charging (’402 Patent, col. 2:30-35).
- Technical Importance: This approach enabled reliable, location-based tracking of energy consumption, which was critical for the administration of accurate billing and incentive programs that were not restricted to specific charging providers (Compl. ¶15).
Key Claims at a Glance
- The complaint asserts independent method claim 7 and discusses dependent claim 10 (Compl. ¶¶13-14, 16-18).
- The essential elements of independent claim 7 are:
- determining a current location of the vehicle;
- determining an amount of energy supplied to a battery on the vehicle at the current location;
- associating the amount of energy supplied with the current location.
- The complaint notes that other claims, including dependent claims, may be asserted in the future (Compl. ¶22).
III. The Accused Instrumentality
Product Identification
The complaint does not identify specific accused products by name, referring to them generally as "Exemplary Defendant Products" (Compl. ¶22). Based on the Defendant's business, these allegations target Electrify America's network of electric vehicle charging stations and the associated software and backend systems used to manage charging sessions.
Functionality and Market Context
The complaint alleges that the accused products practice the technology claimed by the ’402 Patent but does not provide specific details on their technical operation, instead incorporating by reference claim charts from an unattached "Exhibit 2" (Compl. ¶¶27-28). The allegations imply that Defendant’s system determines the location of its charging stations, measures the energy delivered to customers' vehicles, and associates this information for billing and record-keeping purposes.
IV. Analysis of Infringement Allegations
The complaint incorporates infringement allegations by reference to claim charts in "Exhibit 2," which was not provided with the complaint (Compl. ¶28). The following summarizes the infringement theory from the complaint's narrative.
The complaint alleges that Defendant's charging network performs the steps of the asserted claims (Compl. ¶27). The core theory appears to be that when a user charges their vehicle at an Electrify America station, the system inherently performs the claimed method. It "determin[es] a current location of the vehicle" by virtue of the fixed, known location of the charging station itself. Concurrently, it "determin[es] an amount of energy supplied to a battery" through its metering hardware. Finally, it "associat[es] the amount of energy supplied with the current location" in its backend servers to generate a record for billing and user history (Compl. ¶¶12-13, 16). The complaint also highlights the energy loss analysis capabilities described in claim 10 as an inventive concept practiced by the accused systems (Compl. ¶17).
No probative visual evidence provided in complaint.
Identified Points of Contention
- Scope Questions: A primary question may be whether the patent’s claims, which are described in the context of a self-contained "energy meter unit" located "inside the vehicle" (’402 Patent, col. 1:55-56), can be read to cover a distributed charging network where functionality is split between a stationary charger, a user's mobile device, and remote servers.
- Technical Questions: What evidence does the complaint provide that the accused network "determin[es] a current location of the vehicle"? The infringement theory appears to equate the fixed location of the charging station with the "location of the vehicle." A point of contention may be whether this equivalence is technically and legally sufficient to meet the claim limitation, particularly given the patent’s emphasis on an in-vehicle GPS unit for determining the vehicle’s position (’402 Patent, col. 2:1-4).
V. Key Claim Terms for Construction
Term: "determining a current location of the vehicle" (from claim 7)
- Context and Importance: The definition of this phrase is central to the dispute. Practitioners may focus on this term because the infringement theory appears to depend on whether the location of a fixed charging station can satisfy the requirement of determining the vehicle's location. The outcome may hinge on whether the claim requires the determining step to be performed by mobile, on-vehicle hardware.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of claim 7 does not specify the means for determining the location or where the determining entity must be located. An argument could be made that any method that ascertains the vehicle's location at the time of charging meets the limitation.
- Evidence for a Narrower Interpretation: The specification consistently describes the invention as an "energy meter unit 14 for an electric vehicle 12" which "can be placed inside the vehicle 12" and "contains a GPS unit 38" for "determining the location of the vehicle 12 at any given time" (’402 Patent, col. 1:55-56; col. 2:1-4). This repeated linkage to an in-vehicle GPS unit could support a narrower construction requiring the location to be determined from the vehicle's perspective.
Term: "associating" (from claim 7)
- Context and Importance: This term's construction will define the required relationship between the location data and the energy data. The dispute may focus on whether "associating" requires the creation of a unified data record within a single device, as described in the patent, or if a logical link across a distributed network database is sufficient.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "associating" is general, and an argument could be made that any form of data linkage, such as in a remote database that connects a charging session ID to both an energy measurement and a station location, would meet the claim limitation.
- Evidence for a Narrower Interpretation: Claim 1, from which method claim 7 depends, describes "a processor receiving the current location and measure of energy... and associating the measure of charge energy supplied... with the location." This language, describing a single processor receiving and acting on both data points, could support a construction requiring the association to occur within a single, co-located processing unit.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, asserting that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’402 Patent (Compl. ¶25).
- Willful Infringement: The complaint alleges willfulness based on knowledge of the ’402 Patent obtained "at least since being served by this Complaint and corresponding claim charts" (Compl. ¶26). This frames the allegation as one of post-suit willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of architectural scope: can the method claims of the ’402 Patent, which the specification describes as being performed by a discrete, in-vehicle unit, be construed to read on the distributed architecture of Defendant’s public charging network, where key functions are performed by separate and remote components?
- A key infringement question will be one of locational equivalence: does the accused system's use of a stationary charging station's fixed address constitute "determining a current location of the vehicle" as required by the claims, or does the patent demand a determination made from the perspective of the mobile vehicle itself?