DCT

7:26-cv-00100

ChargeLogic LLC v. Tesla Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-00100, W.D. Tex., 03/23/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Tesla, Inc. is incorporated in Texas, maintains its headquarters and principal executive offices in Austin, Texas, and has regular and established places of business in the district, including its "Gigafactory Texas" manufacturing facility. The complaint further alleges that Tesla commits acts of patent infringement within the district, including designing, manufacturing, testing, and selling the accused products.
  • Core Dispute: Plaintiff alleges that Defendant's electric vehicles, charging systems, and associated software infringe six U.S. patents related to intelligent electric vehicle (EV) charging management, including remote control, scheduled charging, and status notifications.
  • Technical Context: The technology at issue concerns systems for intelligently managing the charging of electric vehicles to address issues like grid strain, cost of electricity, and user convenience, which are increasingly significant as the EV market expands.
  • Key Procedural History: The complaint alleges that Tesla had pre-suit knowledge of the asserted patents. Specifically, it claims that the application for the lead '567 Patent was cited by a USPTO examiner as prior art against one of Tesla's own patent applications. As all asserted patents are in the same family, Plaintiff alleges this event establishes pre-suit knowledge of the entire portfolio, which may be relevant to the question of willful infringement.

Case Timeline

Date Event
2008-08-18 Earliest Priority Date for all Asserted Patents
2008-07-01 Apple App Store launched
2010-01-01 Nissan Leaf and Chevrolet Volt sales begin
2011-07-21 '567 Patent application published
2012-01-01 Tesla Model S Software Update v4.3 released
2018-10-02 U.S. Patent No. 10,090,567 issues
2021-01-01 Tesla manufacturing in W.D. Tex. begins
2022-02-22 U.S. Patent No. 11,258,107 issues
2022-01-01 Tesla Semi early production and deliveries begin
2022-11-22 U.S. Patent No. 11,508,996 issues
2023-08-08 U.S. Patent No. 11,721,844 issues
2024-02-20 U.S. Patent No. 11,909,010 issues
2024-02-20 U.S. Patent No. 11,909,011 issues
2024-08-15 USPTO Office Action in Tesla prosecution cites '567 Patent application
2025-04-08 Tesla's U.S. Patent No. 12,272,189 issues
2025-06-01 Tesla Robotaxi service launched
2026-03-23 Complaint filed

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

U.S. Patent No. 10,090,567 (the "'567 Patent"), "Vehicular Battery Charger, Charging System, and Method," issued October 2, 2018

The Invention Explained

  • Problem Addressed: The patent addresses the logistical complexities and grid strain associated with early, "dumb" EV charging processes, where vehicles would draw power unintelligently until full Compl. ¶¶27-30 This created issues like "range anxiety" for consumers and risked overloading community power systems, which were not designed for the concentrated demand of widespread EV adoption Compl. ¶29 '567 Patent, col. 1:40-55
  • The Patented Solution: The patent describes an intelligent charging ecosystem where a user can remotely interact with the vehicle's charger to manage the charging process Compl. ¶33 The system allows a user to input a desired end time for charging and can automatically modulate power delivery based on external factors like the cost of electricity, while also allowing remote initiation of a charging session '567 Patent, abstract '567 Patent, col. 2:5-17 '567 Patent, col. 2:28-30
  • Technical Importance: This technology represented a significant advance in 2008 by integrating vehicle charging with remote user control and economic inputs, at a time when connected vehicle and "Internet of Things" (IoT) concepts were still nascent Compl. ¶¶34-35

Key Claims at a Glance

  • The complaint asserts at least independent claim 8 Compl. ¶54
  • The essential elements of claim 8 include:
    • A vehicle charger adapted for wireless communication with a remote computer, comprising a controller, a display for showing time, and a user-manipulatable control for entering a charging session end time.
    • The controller is configured to automatically change the power supply based on the time needed to charge the battery by the user-entered end time.
    • The controller is also configured to automatically change the power supply at a time associated with the cost of power reaching a threshold, including starting the charge when the cost is at or below the threshold.
    • The controller is responsive to a signal from the remote computer to start charging, where the signal is generated in response to a user selecting a second user-manipulatable control on a screen associated with the remote controller.
  • The complaint reserves the right to assert other claims Compl. ¶52, footnote 23

U.S. Patent No. 11,258,107 (the "'107 Patent"), "Vehicular Battery Charger, Charging System, and Method for Transmitting Battery Charge Threshold Information," issued February 22, 2022

The Invention Explained

  • Problem Addressed: The patent addresses the problem of real-time remote charge-status awareness, which in the early days of EVs required a user to remain near the vehicle or periodically check its status manually Compl. ¶88
  • The Patented Solution: The patent discloses a method for a user to set a predetermined charging threshold (less than 100%) via a remote portable controller. The vehicle's onboard controller then monitors the battery's state of charge and, upon reaching that user-defined threshold, autonomously generates and wirelessly transmits a notification signal to the user's remote device before charging is complete Compl. ¶86 Compl. ¶¶88-89
  • Technical Importance: This method provided a specific, technologically-grounded solution for remote charge-status awareness at a time when such IoT-style connectivity between vehicles and remote user interfaces was not conventional Compl. ¶¶88-89

Key Claims at a Glance

  • The complaint asserts at least independent method claim 6 Compl. ¶86
  • The essential steps of claim 6 include:
    • Establishing wireless communication between a vehicle charger controller and a remote portable controller.
    • Receiving, via a user control, data for a predetermined charge threshold that is less than a full charge.
    • Supplying power to the battery.
    • Comparing the battery's current level of charge to the predetermined threshold.
    • Generating and wirelessly transmitting a signal to the portable controller when the battery's charge level reaches the predetermined threshold, before charging is complete.
  • The complaint reserves the right to assert other claims Compl. ¶84, footnote 24

U.S. Patent No. 11,721,844 (the "'844 Patent")

  • Patent Identification: U.S. Patent No. 11,721,844, "Vehicular Battery Charger, Charging System, and Method for Transmitting Battery Charge Threshold Information," issued August 8, 2023 Compl. ¶112
  • Technology Synopsis: The patent claims a system that provides a technical improvement to vehicle charging by enabling autonomous, threshold-triggered notifications to be sent wirelessly to a user's portable device Compl. ¶119 The system includes an electrically-coupled controller that compares the real-time charge level to a predetermined threshold and, upon reaching it, sends a signal via a wireless transmitter before charging is complete Compl. ¶117 Compl. ¶119
  • Asserted Claims: At least independent system claim 1 Compl. ¶117
  • Accused Features: Tesla's charging system, including the onboard charger (OBC), Battery Management System (BMS), and Mobile App, which allegedly allow a user to set a charge limit and receive wireless notifications when the vehicle reaches that limit Compl. ¶¶123-128

U.S. Patent No. 11,508,996 (the "'996 Patent")

  • Patent Identification: U.S. Patent No. 11,508,996, "Vehicular Battery Charger, Charging System, and Method," issued November 22, 2022 Compl. ¶138
  • Technology Synopsis: The patent addresses the technical challenges of inductive (wireless) EV charging, particularly the problem of precisely aligning the vehicle-mounted receiving coil with the ground-mounted charging pad Compl. ¶146 The invention provides a method of detecting the positional relationship and alignment of the two coils and, in response, enabling a user control on a display to manage the inductive charging Compl. ¶143 Compl. ¶146
  • Asserted Claims: At least independent method claim 15 Compl. ¶143
  • Accused Features: Tesla's wireless charging and vehicle positioning system, as allegedly implemented in the Cybercab, which uses UWB (ultra-wideband) transceivers and on-screen instructions to guide the operator in aligning the vehicle over the charging pad Compl. ¶149 Compl. ¶154

U.S. Patent No. 11,909,010 (the "'010 Patent")

  • Patent Identification: U.S. Patent No. 11,909,010, "Vehicular Battery Charger, Charging System, and Method with In-Vehicle Display of Charge Time," issued February 20, 2024 Compl. ¶161
  • Technology Synopsis: The patent claims a system that provides EV users with predictive charging time estimates, addressing the problem of being uninformed during waiting periods before condition-based charging begins Compl. ¶169 The claimed vehicle charger includes an onboard controller that calculates, displays, and repeatedly updates the estimated time-to-charge on an in-vehicle display, both before and during the active charging session Compl. ¶166 Compl. ¶169
  • Asserted Claims: At least independent system claim 1 Compl. ¶166
  • Accused Features: Tesla's in-car display and Mobile App, which are alleged to provide and continuously update an estimated charge time remaining while the vehicle is charging or awaiting a scheduled charge Compl. ¶¶175, 177-179

U.S. Patent No. 11,909,011 (the "'011 Patent")

  • Patent Identification: U.S. Patent No. 11,909,011, "Vehicular Battery Charger, Charging System, and Method Displaying Charge Information," issued February 20, 2024 Compl. ¶189
  • Technology Synopsis: The patent addresses the technical problem of providing comprehensive, real-time feedback to a user who initiates charging remotely. The claimed system integrates a controller that receives a wireless signal from a remote portable controller to initiate charging, and then, during charging, repeatedly receives charge level signals, estimates the remaining time, and displays both time and charge level information on an in-vehicle display Compl. ¶¶194, 196-197
  • Asserted Claims: At least independent system claim 1 Compl. ¶194
  • Accused Features: Tesla's system, which allegedly allows users to remotely initiate charging via the Mobile App and subsequently view continuously updated information on charge level and time remaining on the in-vehicle display Compl. ¶¶204, 206-210

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as the "Accused Tesla Vehicles" (Model 3, Y, S, X, Cybertruck, and Semi), the forthcoming Cybercab, the Robotaxi service, and associated devices and equipment that connect with these vehicles Compl. ¶¶13-14 Compl. ¶¶38-39 The complaint includes an image of the Tesla Gigafactory in Austin, Texas, where it alleges these products are manufactured and developed Compl. p. 3

Functionality and Market Context

The Accused Products are high-performance electric vehicles that utilize sophisticated software to manage vehicle functions, including battery charging Compl. ¶41 The complaint alleges these vehicles incorporate an onboard charger (OBC), a Battery Management System (BMS), and telematics hardware (cellular/Wi-Fi modems) that enable remote communication and control Compl. ¶¶60-61 Compl. ¶64 Key accused features include "Scheduled Charging" and "Scheduled Departure," which allow users to set charging schedules to align with departure times or take advantage of lower-cost, off-peak electricity rates Compl. ¶42 An image from Tesla's website shows the in-vehicle display for managing these scheduled charging features Compl. p. 16 The Tesla Mobile App allegedly functions as a "remote controller," enabling users to wirelessly monitor and control charging sessions Compl. ¶62 An image from the app shows the interface for remotely starting and stopping a charge Compl. p. 30 The complaint also asserts that some accused products, such as the Cybercab, implement wireless inductive charging guided by an ultra-wideband (UWB) positioning system Compl. ¶149

IV. Analysis of Infringement Allegations

'567 Patent Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
A vehicle charger for charging a battery of a vehicle in the course of a charging session, the vehicle charger adapted for wireless communication with a computer remote from the vehicle and vehicle charger, the computer including a remote controller... Accused Tesla Vehicles include an onboard charger (OBC) and telematics (cellular/WiFi) that enable wireless communication with the Tesla Mobile App, which functions as a remote controller on a user's mobile device Compl. ¶¶60-62 ¶¶60-62 col. 2:5-17
...the vehicle charger comprising: a controller; Accused Products include an onboard Battery Management System (BMS) and associated charging control electronics that function as the claimed controller Compl. ¶64 ¶64 col. 2:24-27
a display coupled to the controller and adapted to display a time; Accused Tesla Vehicles include an interactive in-vehicle touchscreen that is coupled to the controller and displays time information Compl. ¶66 ¶66 col. 2:7-8
and a user-manipulatable control coupled to the controller and operable by a user to enter a time of day at which the charging session will end, The "Scheduled Charge" and "Scheduled Departure" features on the vehicle's touchscreen and Mobile App serve as a user-manipulatable control for entering a desired departure/end time Compl. ¶67 ¶67 col. 2:9-17
wherein the controller automatically changes the supply of electric power to the vehicle battery ... based at least in part upon the time needed to charge the vehicle battery by the time of day entered by the user, The Scheduled Departure feature's logic automatically calculates the necessary start time and controls the charging state (start/stop, charge rate) to ensure the vehicle is charged by the user-set departure time Compl. ¶68 ¶68 col. 2:10-17
wherein the controller automatically changes the supply of electric power to the vehicle battery at a time associated with a cost of power to the battery reaching a threshold cost of power... The "Off-Peak Charging" feature allegedly provides for charging when electricity is cheaper, which the complaint asserts is charging at a time corresponding to a lower tariff or user-defined threshold of cost Compl. ¶69 ¶69 col. 2:2-5
wherein the controller is responsive to at least one signal from the remote controller by changing the supply of electric power to the vehicle battery to start charging, the at least one signal from the remote controller being received by the controller in response to a user selecting a second user-manipulable control on a screen associated with the remote controller. The Mobile App provides on-screen "Start Charging" and "Stop Charging" buttons. The complaint alleges that when a user selects the "Start Charging" button, the vehicle's controller receives a signal and changes the charging state Compl. ¶71 ¶71 col. 2:1-2

Identified Points of Contention

  • Scope Question: A primary point of contention may be whether the term "computer remote from the vehicle", as understood at the time of the invention (priority 2008), can be construed to encompass a modern smartphone running a software application, as alleged in the complaint Compl. ¶62 The interpretation of this term will be critical to determining if the Tesla Mobile App meets the claim limitation.
  • Technical Question: The complaint alleges that Tesla's "Off-Peak Charging" feature meets the limitation of automatically starting a charge "at a time associated with a cost of power... reaching a threshold cost of power" Compl. ¶69 A potential issue for the court is whether this feature operates based on a dynamic, data-driven cost threshold, as the claim language suggests, or if it is merely a time-of-day scheduler that the user sets for periods that happen to have lower electricity rates.
  • Legal Question: Claim 8 recites two distinct user controls: one for setting an end time and a "second user-manipulatable control" on a remote screen to initiate charging. The complaint maps the "Start Charging" button on the Mobile App to this second control Compl. ¶71 The analysis may turn on whether the in-vehicle control for setting the end time and the remote app-based control for starting the charge satisfy the claim's requirement for two distinct controls in the manner described.

'107 Patent Infringement Allegations

The complaint does not provide a claim chart exhibit but describes the infringement theory for method claim 6 in prose Compl. ¶¶91-103 The allegations are summarized as follows: Tesla is accused of infringing by testing and using its vehicles, which allegedly perform the claimed method. The method involves establishing wireless communication between the vehicle's controller (BMS/OBC) and a user's remote portable controller (the Mobile App on a smartphone) (Compl. ¶¶95-97). A user sets a "predetermined threshold level of charge" (e.g., an 80% charge limit) via the charge slider control on the in-car display or Mobile App (Compl. ¶98). While supplying power, the vehicle controller compares the battery's charge level to this threshold (Compl. ¶101). Upon detecting that the battery has reached the threshold, and before charging is complete, the controller generates and wirelessly transmits a signal to the Mobile App, which results in a push notification to the user (Compl. ¶¶99, 102). A screenshot shows the Mobile App's "Charging Notifications" feature, which can alert the user when charging is complete or interrupted Compl. p. 41

Identified Points of Contention

  • Scope Question: Similar to the '567 Patent, a key question will be whether a modern smartphone running the Tesla Mobile App constitutes a "portable controller of a user remote from the vehicle" as the term would have been understood in 2008.
  • Technical Question: Claim 6 requires transmitting the signal "before the charging of the battery is complete." The complaint provides a screenshot of a "Charging Notifications" feature that includes an alert for "Charging Complete" Compl. p. 41 A factual dispute may arise over whether the accused system sends a notification upon reaching a user-set limit (e.g., 80%) which is before charging is technically complete, or if it only notifies when the entire charging session ends.

V. Key Claim Terms for Construction

For the '567 Patent

  • The Term: "a time associated with a cost of power"
  • Context and Importance: This term is critical for the infringement analysis of Tesla's "Off-Peak Charging" feature. Practitioners may focus on this term because its construction will determine whether a simple time-of-day scheduler can infringe, or if the claim requires a more sophisticated system that dynamically responds to actual electricity price data.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent's background discusses the problem of grid strain during peak demand and the desire to shift charging to non-peak periods, which are generally lower cost Compl. ¶28 '567 Patent, col. 1:40-45 This context could support an argument that any time-based schedule designed to operate during off-peak hours is "associated with a cost of power."
    • Evidence for a Narrower Interpretation: The claim requires changing the power supply "at a time associated with a cost of power...reaching a threshold cost of power," and "automatically starting charging when the cost of power...is equal to or less than the threshold cost" '567 Patent, cl. 8 This language suggests a direct comparison to a specific cost value, not just a time window. The specification further supports this by describing the retrieval and use of "power cost information" and a "threshold cost of power" to control charging '567 Patent, col. 14:1-12 '567 Patent, col. 18:1-15

For the '107 Patent

  • The Term: "portable controller of a user"
  • Context and Importance: The complaint's infringement theory hinges on the Tesla Mobile App, running on a smartphone, meeting this limitation. Practitioners may focus on this term because its scope will determine whether a general-purpose device like a smartphone, which did not exist in its modern form at the patent's 2008 priority date, falls within the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The related '567 patent specification, incorporated by reference, describes communication with a "personal computer, phone, PDA, or other processor-based device" '567 Patent, col. 9:1-5, which provides a basis for arguing that a modern smartphone is a type of "phone" or "processor-based device" contemplated by the inventor.
    • Evidence for a Narrower Interpretation: The figures in the related '567 patent depict a dedicated, purpose-built remote device with a physical housing and specific controls '567 Patent, Figs. 5-11, which could support an argument that a "portable controller" refers to a dedicated piece of hardware, not a software application on a general-purpose consumer device.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Tesla induces infringement by providing customers with the Accused Products along with marketing materials, user manuals, and software (the Mobile App) that instruct and encourage them to use the patented charging control features Compl. ¶¶74-76 Compl. ¶¶105-107
  • Willful Infringement: The complaint alleges willful infringement based on pre-suit knowledge of the asserted patents. The primary basis for this allegation is a non-final office action issued during the prosecution of one of Tesla's own patents, which cited the published application for the '567 Patent as a prior art reference Compl. ¶¶45-46 Because all asserted patents are in the same family, the complaint alleges this event provided Tesla with knowledge of the entire portfolio, and that its continued infringement thereafter has been willful Compl. ¶47 Compl. ¶79 Compl. ¶110

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

This case presents several key questions for the court that will likely be central to its resolution:

  • A core issue will be one of claim scope and technological evolution: Can claim terms drafted in 2008, such as "computer remote from the vehicle" and "portable controller", be construed to cover a modern smartphone running a software application? The outcome will depend on how the court interprets the patent's language in the context of the technology available at the time of invention versus the technology of the accused products.
  • A key evidentiary question will be one of functional operation: Does the accused "Off-Peak Charging" feature operate based on a simple, user-defined time schedule, or does it dynamically receive and react to a "threshold cost of power" as specifically required by the language of claim 8 of the '567 Patent? This will likely require a detailed technical examination of how Tesla's software functions.
  • A pivotal legal question will concern willfulness: Does a prior art citation in a USPTO Office Action during the prosecution of a company's unrelated patent application constitute sufficient pre-suit knowledge of the cited patent to support a later claim of willful infringement across a product line? The court's decision on this point could have significant implications for damages.
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