Koji IP LLC v. Ossia Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Koji IP, LLC (Texas)
  • Defendant: Ossia Inc. (Delaware)
  • Plaintiff’s Counsel: NEXTLAW, PLLC
• Case Identification: 2:25-cv-00993, W.D. Wash., 05/27/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has a regular and established place of business in the district and has committed the alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant’s wireless power charging systems, products, and services infringe a patent related to smart wireless power transfer between devices.
• Technical Context: The technology at issue involves systems for wirelessly charging electronic devices, a field with significant market application for consumer electronics, industrial sensors, and Internet of Things (IoT) devices.
• Key Procedural History: The complaint notes that Plaintiff and its predecessors have entered into settlement licenses with other entities, but asserts that these licenses did not involve admissions of infringement or the production of patented articles, a statement likely intended to preemptively address potential defenses related to patent marking under 35 U.S.C. § 287.

Case Timeline

Date	Event
2016-12-19	U.S. Patent No. 10,790,703 Priority Date
2020-09-29	U.S. Patent No. 10,790,703 Issue Date
2025-05-27	Complaint Filing Date

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

U.S. Patent No. 10,790,703 - "Smart wireless power transfer between devices"

• Patent Identification: U.S. Patent No. 10,790,703, issued September 29, 2020.

The Invention Explained

• Problem Addressed: The patent seeks to provide improved solutions for "wirelessly powering and charging powered devices in a smart manner," addressing the need for more efficient and intelligent wireless power transfer technologies. (’703 Patent, col. 1:39-41).
• The Patented Solution: The invention describes a system with a "powering device" and a "powered device" that use two separate wireless channels. A "close-range wireless communication" channel (e.g., Bluetooth, NFC) is used for the devices to discover and communicate with each other. Based on this communication, a separate "powering circuitry" that creates a "radiative powering region" can be conditionally activated or deactivated. This allows the system to intelligently manage power transfer, for instance, by only activating the main power beam when an authorized, low-battery device is detected. (’703 Patent, Abstract; col. 2:50-65).
• Technical Importance: This two-channel approach, using a low-power communication link to control a high-power energy link, represents a method to enhance the efficiency, safety, and intelligence of wireless power systems, which were key challenges for making at-a-distance wireless charging practical. (’703 Patent, col. 1:32-38).

Key Claims at a Glance

• The complaint asserts independent claim 1 and dependent claims 2-4. (Compl. ¶10).
• The essential elements of independent claim 1 are:
  • A wireless power transfer system comprising a battery power source, wireless communication circuitry, and wireless powering circuitry.
  • The wireless communication circuitry establishes a "close-range wireless communication" over which a message is sent from the powered device.
  • The wireless powering circuitry includes a transmitter that emits electromagnetic waves to form a "radiative powering region" to charge the powered device.
  • The powering circuitry is activated when the close-range communication is established.
  • The transmission power of the communication circuitry is controlled to make its range "substantially narrower" than the range of the radiative powering region.
  • A message is issued by the powered device when its battery is below a threshold, and the powering circuitry is activated in response to receiving that message.
  • When the system itself is battery-powered, it makes a determination about the "level of drop" in its own battery level over time, and only allows activation of the powering circuitry if that drop is below a threshold.

III. The Accused Instrumentality

Product Identification

The complaint accuses Defendant’s "systems, products, and services" for wireless power charging. (Compl. ¶¶ 9-10).

Functionality and Market Context

The complaint does not provide specific details on the technical functionality of the accused instrumentalities beyond alleging that they perform wireless power charging and infringe the ’703 Patent. (Compl. ¶¶ 9-10). Similarly, the complaint makes no specific allegations regarding the commercial importance or market position of the accused products. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references a claim chart in an "Exhibit B" that was not provided with the filed complaint. (Compl. ¶11). The complaint’s narrative theory alleges that Defendant directly infringes, literally or under the doctrine of equivalents, by maintaining, operating, and administering systems that practice the inventions of claims 1-4 of the ’703 Patent. (Compl. ¶10). The complaint does not, however, offer a paragraph-by-paragraph breakdown of how the accused products meet the specific limitations of the asserted claims.

• Identified Points of Contention:
  • Scope Questions: The infringement analysis may raise questions about the scope of relative terms in the claims. A central question will be how the court construes "substantially narrower" when comparing the range of the communication circuitry to that of the radiative powering region. (’703 Patent, col. 46:18-22). Another will be the interpretation of the final limitation requiring a "determination... whether a level of drop in a battery level... is below a threshold," a complex condition that may not be present in all power management systems. (’703 Patent, col. 46:31-38).
  • Technical Questions: A key factual question for the court will be whether the accused system actually implements the specific two-channel architecture of Claim 1. What evidence does the complaint provide that the accused product's powering circuitry activates in response to receipt of a message from the powered device, as required by the claim, rather than using a different control logic? (’703 Patent, col. 46:25-30).

V. Key Claim Terms for Construction

• The Term: "close-range wireless communication"

• Context and Importance: This term is foundational to the patent's "smart" functionality, as it defines the control channel that manages the power channel. Its construction will determine whether a broad or narrow set of communication protocols (e.g., Bluetooth, Wi-Fi, proprietary methods) falls within the claim scope.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification provides a non-exhaustive list of examples, including "WLAN or Wi-Fi," "Bluetooth and ZigBee," "RFID," "NFC," "ultrasonic communication, an IR communication, and the likes," which suggests the term is meant to be illustrative rather than limiting. (’703 Patent, col. 7:31-39).
  • Evidence for a Narrower Interpretation: A party might argue that the term, read in context of its purpose for "discovery" and its required "substantially narrower" range, should be limited to protocols inherently designed for short-range device pairing, potentially excluding certain implementations of Wi-Fi. (’703 Patent, col. 46:13-22).

• The Term: "a determination is made whether a level of drop in a battery level of the battery power source in a given time period is below a threshold"

• Context and Importance: This highly specific limitation in Claim 1 defines a sophisticated power-saving feature for when the powering device itself is running on battery. Practitioners may focus on this term because its precise, multi-step nature—calculating a rate of change rather than just a static level—presents a high bar for infringement that may not be met by simpler power management schemes.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A party could argue the term should be construed functionally to cover any logic where the powering device assesses its own battery drain rate before deciding to power another device.
  • Evidence for a Narrower Interpretation: The specification provides a detailed flowchart (FIG. 41) and description of this exact process, which could be used to argue that the claim requires the specific steps of measuring a "level of drop... in a given time period" and comparing it to a threshold, not just any general battery management. (’703 Patent, FIG. 41; col. 41:19-35).

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement claim is based on allegations that Defendant instructs its customers on how to use the accused products in an infringing manner. (Compl. ¶12). The contributory infringement claim is based on allegations that the accused products have no substantial non-infringing uses. (Compl. ¶13).
• Willful Infringement: The complaint alleges knowledge of the ’703 Patent as of the filing date of the lawsuit and seeks a finding of willful infringement based on Defendant's continued alleged infringement after acquiring this knowledge. (Compl. ¶¶ 12, 13; Prayer for Relief ¶e). Plaintiff explicitly reserves the right to amend its complaint to allege pre-suit knowledge if revealed in discovery. (Compl. ¶12, n.1).

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

• A central issue will be one of claim scope: can the complex, multi-step conditional logic of Claim 1—requiring a specific determination of the rate of drop in the powering device's own battery before allowing power transfer—be construed to cover the power management functions allegedly present in the accused system?
• A key evidentiary question will be whether discovery reveals that the accused products actually implement the claimed two-channel architecture, where a "close-range" communication channel with a "substantially narrower" range is used to control the activation of a separate "radiative powering region" in response to a specific low-battery message from a powered device.
• A third question will relate to marking and damages: given Plaintiff is a non-practicing entity, its discussion of prior settlement licenses suggests that compliance with the marking statute, 35 U.S.C. § 287, and the date from which damages can be calculated may become a point of contention.