Channing Street Copper Co v. Impulse Labs Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Channing Street Copper Company (Delaware)
  • Defendant: Impulse Labs, Inc. (Delaware)
  • Plaintiff's Counsel: Potter Anderson & Corroon LLP
• Case Identification: 1:26-cv-00369, D. Del., 04/03/2026
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because the Defendant, Impulse Labs, Inc., is a Delaware corporation and therefore resides in the district.
• Core Dispute: Plaintiff alleges that Defendant's battery-integrated induction cooktops infringe three patents related to appliance-level, battery-based energy storage systems.
• Technical Context: The technology concerns the integration of batteries directly into household appliances, enabling high-power devices to operate on standard electrical outlets and facilitating home energy management.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted technology based on the prosecution of its own patent applications, during which the U.S. Patent and Trademark Office repeatedly rejected Defendant's claims as anticipated or obvious in view of the published application that became one of the patents-in-suit.

Case Timeline

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

U.S. Patent No. 11,870,263 - "Appliance Level Battery-Based Energy Storage"

The Invention Explained

• Problem Addressed: The patent's background describes the high "soft costs" (e.g., installation, electrical panel upgrades) and complexity associated with home electrification and stationary energy storage, which hinder the adoption of high-power electric appliances and the effective use of renewable energy sources like solar power '263 Patent, col. 1:46-2:23
• The Patented Solution: The invention proposes a decentralized energy storage model where batteries are integrated directly into appliances at the "points of load" '263 Patent, col. 3:20-27 This allows a high-power appliance, like an induction stove, to draw a slow, steady charge from a standard wall outlet but deliver high power for short durations by using the stored energy, thereby obviating the need for expensive dedicated high-amperage circuits '263 Patent, col. 5:60-6:2 Figure 3a of the patent, also depicted in the complaint, illustrates a stove with an internal battery system plugging into a standard wall receptacle Compl. ¶24
• Technical Importance: This approach aims to dramatically lower the barrier to home electrification by eliminating the need for custom electrical work, making the upgrade to electric appliances as simple as a standard appliance replacement '263 Patent, col. 5:46-55

Key Claims at a Glance

• The complaint asserts independent claim 12 Compl. ¶16 Compl. ¶59
• The essential elements of claim 12 are:
  • A powered building system comprising an electric power distribution system, one or more load sources, and one or more battery systems.
  • The battery system is disposed within the load source.
  • The load source has a power cord plugged into a receptacle.
  • The battery is configured to obtain and store power from the receptacle.
  • The load source is configured to be fully powered by the battery, fully powered by the receptacle, and partially powered by both the battery and the receptacle.

U.S. Patent No. 12,191,667 - "Appliance Level Battery-Based Energy Storage"

The Invention Explained

• Problem Addressed: As a continuation of the application leading to the '263 Patent, the '667 Patent addresses the same technical problem of high costs and complexity in home electrification '667 Patent, col. 1:46-2:23
• The Patented Solution: The patented solution is identical to that of the '263 Patent, describing a system of distributed energy storage where batteries are integrated directly into appliances, allowing them to manage power demand and operate on standard electrical infrastructure '667 Patent, col. 3:20-27
• Technical Importance: The technical importance is the same as described for the '263 Patent.

Key Claims at a Glance

• The complaint asserts independent claim 11 Compl. ¶19 Compl. ¶72
• The essential elements of claim 11 are:
  • A powered building system comprising an electric power distribution system, one or more load sources, and one or more battery systems.
  • The battery system is associated with a load source and a receptacle.
  • The battery is configured to obtain and store power from the receptacle.
  • The load source is configured to operate with power obtained from both the battery and the receptacle and also configured to operate with power obtained solely from the first receptacle.

U.S. Patent No. 12,199,435 - "Appliance Level Battery-Based Energy Storage"

Technology Synopsis

This patent, from the same family as the '263 and '667 patents, is also directed to solving the high cost and complexity of home electrification by integrating battery storage directly into appliances '435 Patent, abstract The system allows high-power appliances to draw low, continuous power from a standard outlet to charge an internal battery, which then provides high power for peak operational needs, eliminating the requirement for costly electrical panel upgrades (Compl. ¶¶11; Compl. ¶20; Compl. ¶23).

Asserted Claims

The complaint asserts independent claim 11 Compl. ¶22 Compl. ¶85

Accused Features

The complaint alleges that the Impulse Cooktop, as a battery-integrated appliance, infringes by functioning as a "load source" with an associated battery system designed to be plugged into a standard home "receptacle" and to operate using power from the battery, the receptacle, or a combination of both (Compl. ¶¶27; Compl. ¶30; Compl. ¶37).

III. The Accused Instrumentality

Product Identification

• The primary accused product is the "Impulse Cooktop," with infringement allegations extending to all products integrating or powered by the "Impulse Core" platform Compl. ¶27

Functionality and Market Context

• The Impulse Cooktop is an induction stove with an integrated "High Density LFP Battery Pack" and a "Bi-Directional Inverter" Compl. ¶31 Compl. ¶32 A screenshot from Defendant's website shows the specifications for the 3 kWh battery pack and inverter Compl. p. 14
• The product is designed to be installed without electrical panel upgrades by plugging into standard 120V or 240V outlets Compl. ¶31 Compl. ¶34 A marketing screenshot highlights this as an "Easy install without any electrical panel upgrades" Compl. p. 20 The system charges its battery from the grid and can then operate from the battery, from the grid, or by using the battery to "deliver peak power" Compl. ¶31 Compl. ¶33 Compl. ¶37
• The product is marketed as a key step in home electrification and transforming home power distribution systems Compl. ¶28 The complaint highlights promotional materials stating that "[b]attery-integrated appliances provide power when and where you need it" by building energy reserves directly into the home Compl. ¶29

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The following summary is based on the narrative allegations in the complaint.

U.S. Patent No. 11,870,263 Infringement Allegations

U.S. Patent No. 12,191,667 Infringement Allegations

Identified Points of Contention

• Technical Questions: A primary technical question is how the Impulse Cooktop's power management system actually functions. The complaint relies on marketing statements like "deliver peak power from stored energy" Compl. ¶33 to support the "partially powered by both" and "operate with power obtained from both" limitations. The case may require technical evidence to determine if the system truly blends power from both sources simultaneously, or if it merely switches between them.
• Scope Questions: The term "fully powered" in the '263 Patent may become a point of contention. It raises the question of whether an appliance must be capable of operating at its absolute maximum capacity (e.g., all burners on high) to be considered "fully powered" by a single source, or if the ability to perform its primary function (i.e., cooking) is sufficient.

V. Key Claim Terms for Construction

The Term: "fully powered"

• Context and Importance: This term appears twice in claim 12 of the '263 Patent, requiring the load source to be "fully powered" by the battery alone and "fully powered" by the receptacle alone. Its definition is critical because if "fully" implies the ability to sustain maximum, peak power output, a defendant may argue its product fails to meet this limitation if, for example, the battery can only sustain normal cooking loads but not all burners on maximum simultaneously.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification uses the term in the context of avoiding electrical service upgrades, suggesting the goal is functional replacement, not necessarily identical peak performance. The claims do not specify a duration or power level for this state '263 Patent, col. 5:60-6:14
  • Evidence for a Narrower Interpretation: The problem statement in the patent discusses the need for "high capacity circuits" for appliances like induction ranges '263 Patent, col. 5:62-63 This context might support an argument that "fully powered" means the ability to replicate the high-current performance that such a dedicated circuit would provide.

The Term: "partially powered by both" ('263 Patent) / "operate with power obtained from both" ('667 Patent)

• Context and Importance: These phrases capture the concept of blended power operation. The infringement analysis will likely depend on whether the accused product's power electronics are configured to draw power from the battery and the grid concurrently to drive the appliance's load. Practitioners may focus on this term because a system that merely switches between sources (e.g., uses battery only as a backup) might not infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification discusses the overall system goal of "self-managing their demands on the home and utility grid," which could be interpreted broadly to include any intelligent use of both power sources, not just simultaneous blending '263 Patent, col. 3:25-27
  • Evidence for a Narrower Interpretation: The patent describes load sharing and using the battery to supplement grid power, for example, by powering a cooking session "jointly by the battery 305 and low-capacity outlet" '263 Patent, col. 19:39-42 This language suggests a simultaneous, cooperative power delivery that a defendant might argue its product does not perform.

VI. Other Allegations

Indirect Infringement

• The complaint alleges inducement of infringement, stating that Defendant instructs customers to assemble the claimed system by providing installation guides, user manuals, and videos that direct users to connect the Impulse Cooktop to a home's electrical receptacles Compl. ¶¶49-52 A screenshot from the installation guide provides instructions for connecting the power cable Compl. p. 21 Contributory infringement is alleged on the basis that the Impulse Cooktop is a material component of the invention, is not a staple article of commerce, and has no substantial non-infringing use when used as intended with its battery Compl. ¶¶53-54

Willful Infringement

• The complaint makes detailed allegations of willful infringement based on pre-suit knowledge. It alleges Defendant knew of the technology from the '263 Patent's published application at least by January 2024, when Defendant cited it in an Information Disclosure Statement during the prosecution of its own patent application (Compl. ¶¶41; Compl. ¶61). The complaint further alleges that the USPTO examiner then repeatedly rejected claims in two of Defendant's patent applications as being anticipated or rendered obvious by Plaintiff's published application, placing Defendant on notice of the technology's relevance to its products Compl. ¶¶42-47

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

• A central evidentiary question will be one of technical operation: Does the Impulse Cooktop's power management system actually blend power from the battery and the grid simultaneously to power the cooking elements, as suggested by the claim terms "partially powered by both" and "operate with power from both," or does it operate by switching between these sources?
• A core issue will be one of definitional scope: How will the term "fully powered" be construed? The viability of the infringement allegation may turn on whether this term requires the appliance to replicate its absolute peak performance on a single power source, or merely to be functionally operational.
• A key legal question will concern willfulness: Given the extensive and documented prosecution history where Defendant was repeatedly confronted with Plaintiff's technology as a bar to its own patentability, what arguments can be made to counter the allegation that any infringement was not willful?