DCT
1:25-cv-02272
Ningde Amperex Technology Ltd v. Zhuhai CosMX Battery Co Ltd
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ningde Amperex Technology Limited (China)
- Defendant: Zhuhai CosMX Battery Co., Ltd. (China)
- Plaintiff’s Counsel: Quinn Emanuel Urquhart & Sullivan, LLP
- Case Identification: 1:25-cv-2272, E.D. Va., 12/05/2025
- Venue Allegations: Venue is alleged to be proper because the Defendant is not a resident of the United States and may therefore be sued in any judicial district.
- Core Dispute: Plaintiff seeks a declaratory judgment that it is the rightful owner of Defendant’s patent, alleging the patent claims an invention derived from Plaintiff's misappropriated trade secrets and confidential designs.
- Technical Context: The dispute concerns the mechanical design and structure of lithium-ion "coin cell" batteries, which are widely used in small consumer electronics like wireless earbuds and smartwatches.
- Key Procedural History: The complaint alleges a history of conflict between the parties, including a prior U.S. litigation where a jury found Defendant willfully infringed a different Plaintiff patent, and a separate patent infringement lawsuit in China where Defendant asserted the Chinese counterpart of the patent-in-suit against Plaintiff.
Case Timeline
| Date | Event |
|---|---|
| 2019-09-01 | Plaintiff (ATL) allegedly begins development of a new coin cell battery design. |
| 2019-11-01 | Plaintiff allegedly sends confidential designs to vendors under NDA. |
| 2020-03-03 | Priority date of U.S. Patent No. 12,107,286. |
| 2020-05-03 | Date on or before which Defendant allegedly acquired Plaintiff's trade secrets. |
| 2020-05-25 | Chinese counterpart patent ('486 CN Patent) is filed. |
| 2020-11-10 | Chinese counterpart patent ('486 CN Patent) is granted. |
| 2021-09-09 | U.S. patent application leading to the '286 Patent is published. |
| 2021-11-01 | Release of Huawei Watch GT 3, which allegedly contains Plaintiff's batteries. |
| 2022-07-01 | Release of Huawei FreeBuds Pro 2, which allegedly contains Plaintiff's batteries. |
| 2022-11-01 | Release of Huawei Watch GT Cyber, which allegedly contains Plaintiff's batteries. |
| 2024-02-01 | Jury trial in prior litigation (E.D. Tex.) results in willfulness verdict against Defendant. |
| 2024-05-01 | Defendant files patent infringement lawsuit in China against Plaintiff. |
| 2024-09-06 | Plaintiff files a second infringement lawsuit against Defendant in the U.S. (E.D. Tex.). |
| 2024-10-01 | U.S. Patent No. 12,107,286 issues. |
| 2025-12-05 | Complaint is filed in the present action. |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 12,107,286 - Housing Assembly of Button Cell, Button Cell and Electronic Product
- Patent Identification: U.S. Patent No. 12,107,286, "Housing Assembly of Button Cell, Button Cell and Electronic Product," issued October 1, 2024 (’286 Patent).
The Invention Explained
- Problem Addressed: The patent's background section describes that button cells in the prior art suffer from poor sealability at the joint between upper and lower housings, which can lead to liquid leakage and "bring adverse effects on the quality and performance of button cells" (’286 Patent, col. 5:21-27).
- The Patented Solution: The invention proposes a housing assembly where a conductive part (such as a "conductive nail") penetrates through a hole in the main housing and is sealed in place, for example, with an insulating rubber ring (’286 Patent, col. 10:59-65; Fig. 4). This design purports to create a more robust and simpler seal compared to prior art butt-joint sealing methods, thereby improving the battery's reliability and performance (Compl. ¶19; ’286 Patent, col. 6:1-8).
- Technical Importance: Achieving a reliable seal is critical for the safety and longevity of miniaturized, high-energy-density batteries used in wearable and portable electronics (Compl. ¶3, ¶5).
Key Claims at a Glance
- The complaint focuses on the overall design claimed in the patent but specifically references elements from independent claim 1 and dependent claim 7 (Compl. ¶21, ¶54).
- Independent Claim 1 recites, in part:
- A housing assembly of a button cell comprising a housing and a conductive part.
- The housing is provided with a through hole, and the conductive part penetrates through the through hole.
- A sealing rubber ring for sealing and insulating the conductive part and an inner wall of the through hole.
- The conductive part comprises a columnar part penetrated through the through hole.
- An end of the columnar part facing the cell is provided with a sheet part integrally formed with the columnar part.
- An end of the columnar part facing away from the cell extends outwardly with a flanging around the columnar part.
- At least a part of a housing wall has a thinning area smaller than other parts of the housing wall, configured to rupture first to release internal pressure.
- An insulating sheet is clamped between the cell and the second tab.
III. The Accused Instrumentality
Product Identification
- The subject of this declaratory judgment action is U.S. Patent No. 12,107,286 itself.
Functionality and Market Context
- The complaint alleges that the '286 Patent claims a battery structure that was not invented by Defendant, but was instead developed by Plaintiff and documented in its confidential design documents (Compl. ¶12-13, ¶39). Plaintiff alleges that its own commercially valuable lithium-ion coin cell batteries, such as models HB1160ECW and 512021 used in products like the Huawei Watch GT 3 and Huawei FreeBuds Pro 2, embody this proprietary design (Compl. ¶9, ¶16). The complaint presents the '286 Patent as an improper attempt by Defendant to claim ownership over Plaintiff's technology (Compl. ¶23). A side-by-side visual comparison is provided in the complaint to show the alleged identity between the patented design and Plaintiff's confidential design (Compl. ¶20, p. 7).
IV. Analysis of Infringement Allegations
As this is a declaratory judgment action for ownership and invalidity, not a direct infringement suit, the central allegation is that the claimed invention was derived from Plaintiff's own confidential designs. The following table summarizes this core allegation by mapping elements of the patent's claim to features of Plaintiff's design as described in the complaint.
'286 Patent Derivation Allegations
| Claim Element (from Independent Claim 1) | Alleged Corresponding Feature in Plaintiff's Design | Complaint Citation | Patent Citation |
|---|---|---|---|
| a housing assembly... comprising: a housing and a conductive part | A battery assembly comprising a housing and a pole. | ¶13 | col. 17:59-62 |
| the housing is provided with a through hole, and the conductive part penetrates through the through hole | "There is a through-hole on the housing, and the pole is inserted into the through-hole." | ¶13 | col. 18:1-3 |
| a sealing rubber ring for sealing and insulating the conductive part and an inner wall of the through hole | "The sealing ring is provided between the pole and the inner wall of the through-hole." | ¶13 | col. 18:3-6 |
| the conductive part comprises a columnar part... and an end of the columnar part facing the cell is provided with a sheet part integrally formed with the columnar part | "The pole includes a cylindrical portion inserted into the through-hole, and one end of the cylindrical portion facing the inner side of the housing is provided with a sheet-like portion integrated with the cylindrical portion." | ¶13 | col. 18:6-10 |
| an end of the columnar part facing away from the cell extends outwardly with a flanging around the columnar part | "The end of the cylindrical portion extending outward from the shell is surrounded by a flange." | ¶13 | col. 18:10-12 |
| a gasket is provided between the flanging and the sealing rubber ring (from Claim 7) | "There is a gasket set between the flange and the sealing ring..." | ¶13, ¶21 | col. 18:50-51 |
- Identified Points of Contention:
- Derivation and Inventorship: The central question is factual: does the evidence support the allegation that the invention claimed in the '286 Patent was derived from Plaintiff's pre-existing confidential designs? This inquiry will likely focus on comparing the claimed features to Plaintiff’s designs, the timeline of events, and the alleged connections between the named inventors and individuals with access to Plaintiff’s trade secrets (Compl. ¶15, ¶18).
- Technical Identity: A key technical question will be whether the structure claimed in the '286 Patent is identical to Plaintiff's design, as alleged. The complaint provides a visual comparison of Figure 4 from the '286 Patent and a drawing of "ATL's Coin Cell Battery Design," asserting they contain "identical structural elements" (Compl. ¶20). The degree of similarity or identity shown in such evidence will be a primary focus.
V. Key Claim Terms for Construction
While the case centers on derivation rather than infringement, the interpretation of certain claim terms may still be relevant to comparing the patented invention with Plaintiff's designs.
The Term: "sealing rubber ring"
Context and Importance: Claim 1 requires a "sealing rubber ring," while dependent claim 7 adds "a gasket... between the flanging and the sealing rubber ring" (’286 Patent, col. 18:50-51). The specification also describes the gasket as helping to "tightly compress the insulating rubber ring" (’286 Patent, col. 10:59-62). Practitioners may focus on whether the "sealing rubber ring" is a distinct component from the "gasket" or if the terms describe a single functional system. The precise relationship between these components in the claim language will be critical for comparing against Plaintiff's design, which is alleged to include both a "sealing ring" and a "gasket" (Compl. ¶13).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The use of "sealing rubber ring" alone in independent claim 1 could suggest it is the essential sealing component, with the gasket being an optional, additional element introduced in a dependent claim.
- Evidence for a Narrower Interpretation: The specification’s description of the gasket’s function in compressing the ring may suggest that the two components are intended to work together as a specific sealing mechanism, potentially limiting the scope of how the "sealing rubber ring" limitation is met in practice (’286 Patent, col. 10:59-65).
The Term: "integrally formed"
Context and Importance: Claim 1 requires the "sheet part" of the conductive element to be "integrally formed with the columnar part" (’286 Patent, col. 18:9-10). This term relates to the structure and manufacturing of a key component. The determination of derivation will require comparing this claimed feature to the corresponding structure in Plaintiff's design, which is described as having "a sheet-like portion integrated with the cylindrical portion" (Compl. ¶13).
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term could be interpreted to cover components made as a single piece as well as components permanently joined together (e.g., by welding) to function as a single unit. The specification notes that parts can be "separately processed and connected by welding or the like, or may be integrally formed" (’286 Patent, col. 14:65-col. 15:1).
- Evidence for a Narrower Interpretation: A party could argue the term implies formation from a single, continuous piece of material, distinguishing it from multi-piece assemblies that are welded or otherwise joined post-formation.
VI. Other Allegations
- Misappropriation of Trade Secrets: The complaint alleges that Defendant acquired Plaintiff's confidential design information through improper means, such as by hiring former employees of Plaintiff and its vendors who had access to the designs (Compl. ¶15, ¶18, ¶58). The filing of the patent application that led to the '286 Patent is alleged to be an act of disclosing and misappropriating those trade secrets (Compl. ¶58).
- Correction of Inventorship: Plaintiff alleges that its employees, including at least Guowen Zhang, are the true inventors of the technology claimed in the '286 Patent (Compl. ¶53). The complaint seeks to have the named inventors removed and Plaintiff's employees added, and for the patent to be assigned to Plaintiff (Compl. ¶40; Prayer for Relief (a), (f)).
VII. Analyst’s Conclusion: Key Questions for the Case
This case appears to be less about claim construction and infringement, and more about the factual history of the invention's conception and the parties' conduct. The central questions for the court will likely be:
- A core issue will be one of derivation and ownership: Can Plaintiff produce sufficient evidence to prove that the invention described and claimed in the '286 Patent was conceived by its own employees and that the named inventors derived the invention from Plaintiff's misappropriated trade secrets?
- A key evidentiary question will be one of linkage and transfer: What evidence connects the named inventors on the '286 Patent to Plaintiff's confidential information? The case may turn on proof of a chain of communication or employment history that demonstrates a plausible pathway for the alleged misappropriation.