DCT

2:25-cv-00883

Minotaur Systems LLC v. BP PLC

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00883, E.D. Tex., 09/24/2026
  • Venue Allegations: Venue is asserted on the basis that the Defendant is not a resident of the United States and may therefore be sued in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s electric vehicle charging systems and methods infringe a patent related to on-board monitoring of energy consumption and associating that consumption data with the vehicle's specific location.
  • Technical Context: The technology addresses the need to accurately account for the energy an electric vehicle consumes during charging, particularly when using non-dedicated power sources like standard household outlets.
  • Key Procedural History: This First Amended Complaint follows an Original Complaint, service of which Plaintiff alleges established Defendant's actual knowledge of the patent and infringement. The case is a member case consolidated with a lead case against a different defendant, Minotaur Systems LLC v. BP p.l.c.

Case Timeline

Date Event
2008-12-19 U.S. Patent 8,417,402 Priority Date
2009-12-21 U.S. Patent 8,417,402 Application Filing Date
2013-04-09 U.S. Patent 8,417,402 Issue Date
2026-09-24 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 8,417,402 (“the ’402 Patent”), titled “Monitoring of power charging in vehicle,” issued on April 9, 2013. Compl. ¶¶8-9

U.S. Patent No. 8,417,402 - "Monitoring of power charging in vehicle"

The Invention Explained

  • Problem Addressed: The patent's background describes the limitations of conventional energy measurement for electric vehicles (EVs) Compl. ¶10 Prior systems measured energy at a fixed point, such as a utility meter for a building or a meter within a dedicated charging station Compl. ¶10 This approach could not distinguish the energy drawn by a charging EV from energy consumed by other appliances when using a standard outlet, nor could it link a quantity of energy to the specific mobile vehicle that received it Compl. ¶¶11-12 This restricted the ability to apply charging-specific credits or incentive programs unless owners used designated charging stations ’402 Patent, col. 1:26-31
  • The Patented Solution: The invention proposes an on-board energy meter unit installed within the vehicle itself ’402 Patent, col. 1:55-56 This unit performs three key functions: it determines the vehicle's current location using a system like GPS; it measures the amount of energy supplied to the vehicle's battery during a charging session; and it associates the measured energy amount with the determined location ’402 Patent, abstract Compl. ¶14 This creates a verifiable record that ties a specific quantity of energy to a particular vehicle and a specific place, overcoming the deficiencies of fixed-point metering Compl. ¶18 ’402 Patent, col. 2:45-53
  • Technical Importance: This on-board, location-aware measurement architecture enables accurate accounting for EV charging regardless of the power source, facilitating the administration of governmental incentives, dynamic billing, and the collection of aggregated energy usage data tied to geographic areas ’402 Patent, col. 1:13-17 ’402 Patent, col. 3:28-34

Key Claims at a Glance

  • The complaint focuses on independent method claim 7, asserting that its combination of steps represents an inventive concept over prior art systems Compl. ¶21 Compl. ¶23
  • 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 also discusses the inventive concepts of dependent claims 8, 9, 10, and 17, suggesting they may be asserted as the case proceeds Compl. ¶¶28-29

III. The Accused Instrumentality

Product Identification

The complaint accuses "Exemplary Defendant Products" of infringement but identifies them only in Exhibit 2, which was not publicly filed with the complaint Compl. ¶31 The defendant is named EV DOT ENERGY LTD, suggesting the accused instrumentalities are likely electric vehicle charging systems, related software, or services.

Functionality and Market Context

The complaint does not provide a technical description of how the accused products operate. It alleges that the products "practice the technology claimed by the '402 Patent" and that they are made, used, sold, and imported by the Defendant Compl. ¶31 Compl. ¶36 The complaint's infringement theory relies on charts in the unprovided Exhibit 2 to demonstrate that the accused products "satisfy all elements of the Exemplary '402 Patent Claims" Compl. ¶36 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an unprovided exhibit to detail its infringement allegations Compl. ¶37 The narrative infringement theory presented in the complaint is as follows:

The complaint asserts that the Defendant's products perform the method of Claim 7 of the ’402 Patent, either literally or under the doctrine of equivalents Compl. ¶31 The core of the allegation is that the accused products execute a process that was not "well-understood, routine, or conventional" as of the patent's priority date Compl. ¶23 This process allegedly involves determining the location of a vehicle, separately determining the amount of energy supplied to that vehicle's battery at that location, and then associating the two pieces of information to create a unified record Compl. ¶23 Compl. ¶26 Plaintiff contends this specific, ordered combination of steps is what provides a record "attributable both to a specific vehicle's battery and to a specific place," a result that prior art fixed-point metering could not achieve Compl. ¶26 The complaint also alleges infringement occurs through Defendant's internal testing of the accused products Compl. ¶32

  • Identified Points of Contention:
    • Scope Questions: A central dispute may concern the claim phrase "determining an amount of energy supplied to a battery on the vehicle." The question will be whether this limitation requires a measurement to be taken by a device on the vehicle, as shown in the patent's embodiments, or if it could be read to cover a system where a stationary charger measures the energy and communicates that data to a vehicle-based system for association with a location.
    • Technical Questions: The infringement analysis will likely require evidence detailing how the accused products perform the "associating" step. The court may need to determine if merely logging energy and location data with a common timestamp in a database meets this limitation, or if the claim requires a more specific technical binding of the data as the complaint suggests when it argues the recited association is "not an association of arbitrary data" Compl. ¶22

V. Key Claim Terms for Construction

  • The Term: "determining an amount of energy supplied to a battery on the vehicle" (from Claim 7)

    • Context and Importance: This term is critical because it defines the point of measurement, which the patent posits as its key departure from the prior art. Whether the accused products "determine" the energy amount in the manner required by the claim will be a focal point of the infringement analysis.
    • Intrinsic Evidence for a Broader Interpretation: A party could argue that "determining" is a broad term that does not exclusively mean "measuring directly." It could encompass calculating the amount supplied to the battery based on a measurement taken elsewhere (e.g., at the charger) and then adjusting for known or estimated losses.
    • Intrinsic evidence for a Narrower Interpretation: A party could argue the specification defines "determining" as an action performed by an on-board unit. The patent repeatedly describes an "energy meter unit 14 for an electric vehicle 12" that "can be placed inside the vehicle 12" and "monitors energy received" to charge the battery '402 Patent, col. 1:55-60 The patent's explicit criticism of fixed, off-vehicle metering points further supports a construction requiring the determination to originate from the vehicle itself ’402 Patent, col. 1:10-31

  • The Term: "associating" (from Claim 7)

    • Context and Importance: This step creates the final, allegedly novel data record. The definition of "associating" will dictate what technical link between the energy and location data is required to infringe.
    • Intrinsic Evidence for a Broader Interpretation: The plain meaning of "associate" could support an interpretation where any form of linking, such as creating a database entry with fields for both energy and location for a given charging session, would suffice.
    • Intrinsic Evidence for a Narrower Interpretation: The complaint argues the invention involves binding a "resolved quantity to the place of delivery" Compl. ¶22 The patent specification describes using the associated data to "validate a claim(s) by an energy source" that it supplied energy at a specific address, suggesting a robust and verifiable link rather than a simple co-logging of data ’402 Patent, col. 3:9-15 This purpose-driven language may support a narrower construction requiring the creation of a single, integrated data record.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "product literature and website materials" that instruct customers on how to use the accused products in an infringing manner Compl. ¶34 The pleading anchors the knowledge element of this claim to the time Defendant was served with the original complaint in this matter Compl. ¶35
  • Willful Infringement: The complaint alleges willful infringement based on Defendant's continued infringement after gaining "Actual Knowledge of Infringement" from the service of the original complaint and its accompanying claim charts Compl. ¶33 Compl. ¶34

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

  • A core issue will be one of technical implementation: Does the accused system "determine" the energy supplied to the battery via an on-vehicle measurement, as described in the '402 Patent's embodiments, or does it measure energy at the stationary charger and transmit that data? The case may turn on whether the court construes the claim term "determining" to be limited to the former.
  • A second key question will be definitional scope: What level of technical integration is required to satisfy the "associating" limitation? The court will need to decide whether simply logging location and energy data for the same session is sufficient, or if the claim requires the creation of a more structurally bound data record for purposes of verification, as suggested by the patent's specification.
  • Finally, a central question for damages will be one of scienter: Since the allegations of willful and induced infringement are based on knowledge obtained from the original complaint, the Defendant’s conduct after the date of service will be critical in determining its potential liability for enhanced damages or indirect infringement.