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., 07/30/2026
• Venue Allegations: Venue is based on the allegation that both Plaintiff and Defendant are Delaware corporations, and therefore reside in the district.
• Core Dispute: Plaintiff alleges that Defendant's battery-integrated induction cooktops infringe three patents related to systems and methods for appliance-level energy storage.
• Technical Context: The technology concerns decentralized home energy storage, where batteries are integrated directly into individual appliances to manage power consumption, support home electrification, and interact with the electrical grid.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted technology based on the prosecution history of its own patent applications. Specifically, it alleges the U.S. Patent and Trademark Office repeatedly rejected Defendant's patent claims as anticipated or obvious in view of the publication of Plaintiff's parent patent application, which may be significant for the allegations of willful infringement.

Case Timeline

Date	Event
2021-03-11	Priority Date for '263, '667, and '435 Patents
2022-08-18	Plaintiff Channing Street Copper Company incorporated
2023 (Early)	Plaintiff began manufacturing its ESE induction stoves
2023-12-01	Plaintiff's first sale of an ESE appliance
2024-01-09	U.S. Patent No. 11,870,263 issued
2024-01-26 (prior to)	Defendant allegedly cited the '263 Patent in an Information Disclosure Statement
2024-01-XX	Defendant announced the release of the Impulse Cooktop
2024-09-16	USPTO issued non-final rejection of Defendant's application citing Plaintiff's patent publication
2025-01-07	U.S. Patent No. 12,191,667 issued
2025-01-14	U.S. Patent No. 12,199,435 issued
2025-01-24	Defendant allegedly had actual knowledge of all three Asserted Patents
2025-08-XX	Defendant allegedly began shipping the Impulse Cooktop
2026-07-30	Complaint Filing Date

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

U.S. Patent No. 11,870,263 - "Appliance Level Battery-Based Energy Storage," issued January 9, 2024

The Invention Explained

• Problem Addressed: The patent's background section identifies the high cost and installation complexity of centralized, whole-home battery storage systems (e.g., Tesla Powerwall) as a significant barrier to home electrification and the adoption of renewable energy ʼ263 Patent, col. 1:56-2:4 These systems often require expensive, custom electrical work and service panel upgrades ʼ263 Patent, col. 5:44-6:17
• The Patented Solution: The invention proposes a decentralized approach by integrating smaller, dedicated battery systems directly into individual appliances, or "load sources" ʼ263 Patent, col. 4:20-26 This allows an appliance to manage its own power needs-drawing from its internal battery, the grid, or both-potentially eliminating the need for costly home electrical upgrades and enabling smarter energy use ʼ263 Patent, col. 5:61-6:5 Figure 3a illustrates this concept with a battery system integrated inside a stove, while Figure 3c shows a configuration where the battery system is a separate unit placed between the appliance and the wall outlet ʼ263 Patent, col. 7:21-45 ʼ263 Patent, col. 9:15-26
• Technical Importance: This "edge computing" model for energy storage aimed to lower the cost and complexity of home battery installation, making it more accessible to homeowners and facilitating the adoption of high-draw electric appliances on standard home wiring ʼ263 Patent, col. 5:44-5:53

Key Claims at a Glance

• The complaint asserts independent claim 12 Compl. ¶101
• The essential elements of independent 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 includes a first battery system disposed within a first load source, where the load source has a power cord plugged into a receptacle.
  • The first battery system has a battery configured to obtain and store power from the receptacle.
  • The first load source is configured to be fully powered by the stored battery power, fully powered by power from the receptacle, and partially powered by both the battery and the receptacle.
• The complaint reserves the right to assert other claims Compl. ¶27

U.S. Patent No. 12,191,667 - "Appliance Level Battery-Based Energy Storage," issued January 7, 2025

The Invention Explained

• Problem Addressed: The ʼ667 Patent, a continuation of the application that led to the '263 Patent, addresses the same technical problem: the high cost and complexity of centralized home energy storage systems for home electrification ʼ667 Patent, col. 1:56-2:4
• The Patented Solution: Like the '263 Patent, the invention describes a system where battery storage is decentralized to individual appliances, which can then operate using power from the battery, the grid, or a combination of both ʼ667 Patent, col. 4:20-34 The specification and figures are substantially similar to those of the '263 Patent.
• Technical Importance: The invention provides a pathway for homeowners to adopt electric appliances and energy storage incrementally, avoiding large upfront investments in electrical upgrades and centralized battery systems ʼ667 Patent, col. 5:44-5:53

Key Claims at a Glance

• The complaint asserts independent claim 11 Compl. ¶114
• The essential elements of independent 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 includes a first battery system associated with a first load source and a first receptacle.
  • The first battery system has a battery configured to obtain and store power from the receptacle.
  • The first load source is configured to operate with power obtained from both the first battery and the first receptacle, and also configured to operate with power obtained solely from the first receptacle.
• The complaint reserves the right to assert other claims Compl. ¶27

Multi-Patent Capsule: U.S. Patent No. 12,199,435

• Patent Identification: U.S. Patent No. 12,199,435, "Appliance Level Battery-Based Energy Storage," issued January 14, 2025 Compl. ¶20
• Technology Synopsis: The '435 Patent, which is also in the same family as the '263 and '667 Patents, discloses a powered building system with decentralized, appliance-level battery storage. The system enables an appliance ("load source") to operate using power from an internal battery, a wall receptacle, or a combination of both, addressing the high cost of centralized home energy storage systems '435 Patent, abstract '435 Patent, col. 1:56-2:4
• Asserted Claims: The complaint asserts independent claim 11 Compl. ¶127
• Accused Features: The allegations target the Impulse Cooktop's integrated battery system and its ability to operate using power drawn from its battery, the wall outlet, or both in combination Compl. ¶¶126-128

III. The Accused Instrumentality

• Product Identification: The accused products are the "Impulse Cooktop" and other products that integrate, connect to, or are powered by the "Impulse Core" technology platform Compl. ¶27
• Functionality and Market Context:
  • The complaint alleges the Impulse Cooktop is a "battery-integrated induction stove" designed to plug into standard American kitchen outlets (120V and 240V) without requiring electrical upgrades Compl. ¶31 It contains an integrated battery and a built-in inverter Compl. ¶33 Compl. ¶36 A diagram from the defendant's website, referenced in the complaint, depicts how such battery-integrated appliances can form a network of energy reserves within a home Compl. ¶29, p. 11
  • The accused product is allegedly marketed as a key component of an "energy independent home," allowing users to store energy (e.g., during off-peak times) and use it later to power the appliance Compl. ¶31 Compl. ¶37 The complaint cites to the product's technical specifications, which list a 3 kWh battery capacity Compl. ¶36, p. 15 It is alleged the cooktop can operate from its battery, from the wall outlet, or from a combination of both sources Compl. ¶37

IV. Analysis of Infringement Allegations

'263 Patent Infringement Allegations

Claim Element (from Independent Claim 12)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first battery system that is disposed within a first load source of the one or more load sources...	The Impulse Cooktop is a load source that is advertised as having an "integrated battery" and a "powerful integrated battery + state of the art induction."	¶30; ¶32	col. 7:21-31
the first load source comprising a first power cord plugged into a first receptacle of the plurality of receptacles...	The Impulse Cooktop "simply plugs into the outlets you already have in your kitchen" and is designed to work with standard 120V and 240V outlets.	¶31; ¶34	col. 7:32-35
the first battery system comprising a first battery configured to obtain and store power from the first receptacle...	The Impulse Cooktop's battery "charges the battery" from the outlet it is plugged into, and can charge during off-peak times.	¶31; ¶33	col. 7:38-45
the first load source being configured to be fully powered by power stored by the first battery...	The Impulse Cooktop's 3 kWh battery, when fully charged, can allegedly "power the stove for at least three meals on a full charge, helping you get through power outages."	¶37	col. 7:38-45
...and configured to be fully powered by power obtained from the first receptacle...	The Impulse Cooktop's troubleshooting guide allegedly instructs users to "[e]nsure the cooktop is connected to wall power" for operation.	¶38	col. 7:38-45
...and configured to be partially powered by both the first battery and power obtained from the first receptacle.	The complaint alleges the Accused Products are configured to operate from power obtained from the battery system and/or from the receptacle.	¶37	col. 7:38-45

'667 Patent Infringement Allegations

Claim Element (from Independent Claim 11)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a first battery system associated with a first load source and a first receptacle of the plurality of receptacles...	The Impulse Cooktop is a load source with an associated battery system that plugs into a receptacle in a home's power distribution system.	¶30; ¶34; ¶35	col. 7:21-35
the first battery system comprising a first battery configured to obtain and store power from the first receptacle...	The Impulse Cooktop's battery obtains and stores power from the electrical grid via the receptacle it is plugged into.	¶30; ¶33	col. 7:38-45
the first load source configured to operate with power obtained from both the first battery and the first receptacle...	The complaint alleges the Accused Products are configured to operate from power obtained from the battery system and/or from the receptacle, implying a blended mode.	¶37	col. 31:30-34
...and also configured to operate with power obtained solely from the first receptacle.	The complaint alleges the Impulse Cooktop can operate while "connected to wall power" and that both the battery and power supply are connected to the stove for operation.	¶38	col. 31:34-37

• Identified Points of Contention:
  • Scope Questions: A central dispute may arise from the subtle but important differences in the functional limitations of the asserted claims. For example, claim 12 of the '263 Patent requires the load source to be configurable to be "fully powered by" the battery, whereas claim 11 of the '667 Patent does not explicitly require a battery-only operational mode. The evidence required to prove the appliance is "fully powered" by the battery, as opposed to merely operating on battery power, may become a key point of contention.
  • Technical Questions: The infringement analysis raises the question of how the accused product's power management system actually functions across different operational states. A key evidentiary question will be whether the Impulse Cooktop's standard operation meets the specific conjunctive requirements of the claims, for example, whether it can be "fully powered" by the receptacle alone ('263 Patent) and also operate "solely" from the receptacle ('667 Patent), and what, if any, technical distinction exists between these claimed configurations.

V. Key Claim Terms for Construction

For the '263 Patent:

• The Term: "fully powered by"
• Context and Importance: This phrase appears twice in asserted claim 12, defining two distinct operational modes: one using only the battery and another using only the receptacle. Its construction is critical because infringement depends on whether the accused product is capable of achieving a state of being "fully powered" in these configurations, as distinct from being "partially powered." Practitioners may focus on this term to dispute whether running "for at least three meals" Compl. ¶37 constitutes being "fully" powered if, for example, high-power functions are restricted.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to provide an explicit definition, which may support an argument for giving the term its plain and ordinary meaning: capable of performing its main functions (e.g., cooking) without another power source. The patent's goal of operating independently of grid constraints supports this view ('263 Patent, col. 5:61-6:5).
  • Evidence for a Narrower Interpretation: The patent contrasts "fully powered" with "partially powered" '263 Patent, col. 32:37-44 A defendant may argue this implies that "fully powered" requires access to 100% of the device's features and power levels, a threshold the battery or a standard outlet may not always meet, thereby avoiding infringement.

For the '667 Patent:

• The Term: "operate with power obtained solely from the first receptacle"
• Context and Importance: This limitation in asserted claim 11 defines a grid-only operational mode. Its interpretation, especially in comparison to the "fully powered by...the first receptacle" language in the '263 Patent, will be central to the infringement analysis for both patents. The distinction, or lack thereof, could determine whether the accused product infringes one patent, both, or neither.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "solely" is an unambiguous term of exclusion. A plaintiff would likely argue it simply means the appliance can run using only grid power, without any contribution from the battery, a function fundamental to any plug-in appliance '667 Patent, col. 7:32-38 The complaint's evidence shows the product connected to "wall power" for updates and operation Compl. ¶38
  • Evidence for a Narrower Interpretation: A defendant might argue that because the battery is an integral part of the system's circuitry, the appliance never operates "solely" from the receptacle, as the power may always be conditioned by or routed through circuitry associated with the battery system, even if the battery itself is not discharging. The patent's emphasis on the integrated nature of the system could be used to support this argument '667 Patent, col. 7:21-31

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement based on Defendant's marketing materials, website statements ("easy [to] install"), and installation guides that allegedly instruct and encourage customers to install and use the Impulse Cooktop in a manner that practices the claimed systems Compl. ¶¶49-51 An image from an installation guide is provided as evidence of these instructions Compl. ¶51, p. 22 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, pointing to user manual instructions to use the appliance only with the battery attached Compl. ¶¶53-54
• Willful Infringement: The complaint asserts willfulness for all three patents based on alleged pre-suit knowledge Compl. ¶107 Compl. ¶120 Compl. ¶133 The primary basis for this allegation is the detailed patent prosecution history of Defendant's own patent applications, where Plaintiff's '263 patent publication was allegedly cited by Defendant in an IDS and repeatedly used by the USPTO as a basis for rejecting Defendant's claims Compl. ¶¶41-47 Plaintiff alleges this history establishes Defendant had knowledge of the patents and the infringing nature of its activities.

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

• A core issue will be one of operational equivalence: The case may turn on a detailed technical analysis of the Impulse Cooktop's power management system. The central question for the court will be whether the product's actual operational modes-battery-only, grid-only, and blended power-functionally align with the specific and subtly different language of the asserted claims, particularly the distinction between being "fully powered by" a source ('263 Patent) and operating "solely" from a source ('667 Patent).
• A second pivotal issue will be the implication of prosecution history on willfulness: A key legal and factual battle will likely center on the extensive prosecution history detailed in the complaint. The court will need to determine if the repeated rejections of Defendant's own patent applications by the USPTO in view of Plaintiff's technology constitutes the kind of specific, pre-suit knowledge and objective recklessness that would support a finding of willful infringement and potential for enhanced damages.
• A third question will be one of claim construction: The dispute will likely involve a debate over the scope of foundational terms. A critical question for claim construction will be whether a term like "fully powered by" requires the appliance to perform all of its functions at maximum capacity, or merely its primary functions, a distinction that could be dispositive for infringement.