DCT

7:26-cv-00113

Causam Enterprises Inc v. Jupiter Power LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-00113, W.D. Tex., 07/02/2026
  • Venue Allegations: Venue is alleged to be proper as Defendants have their principal corporate offices in the District and have committed acts of infringement in the District, including the operation and control of battery energy storage systems.
  • Core Dispute: Plaintiff alleges that Defendants' battery energy storage systems and associated energy management software infringe five patents related to the active management and control of electric power grids.
  • Technical Context: The technology concerns the management of distributed energy resources, such as large-scale batteries, to provide stability, operating reserves, and other ancillary services to wholesale electricity markets.
  • Key Procedural History: This action is a First Amended Complaint. The complaint advances theories of joint enterprise and alter ego to hold parent company Jupiter Power LLC and its various subsidiaries jointly liable for the alleged infringement.

Case Timeline

Date Event
2012-07-14 Priority Date for U.S. Patent Nos. 11,782,470; 11,126,213; 10,429,871; and 12,461,547
2012-07-31 Priority Date for U.S. Patent No. 11,747,849
2019-10-01 U.S. Patent No. 10,429,871 Issued
2021-09-21 U.S. Patent No. 11,126,213 Issued
2022 Jupiter Power LLC allegedly contracts with Energy Vault to implement EMS software
2023-09-05 U.S. Patent No. 11,747,849 Issued
2023-10-10 U.S. Patent No. 11,782,470 Issued
2024-03 St. Gall Project Commercial Operation Date (COD)
2025-11-04 U.S. Patent No. 12,461,547 Issued
2025-11-04 Jupiter Power LLC issues press release regarding internal QSE development
2026-07-02 First Amended Complaint Filing Date

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

U.S. Patent No. 11,782,470

  • Patent Identification: U.S. Patent No. 11,782,470 ("'470 Patent"), titled "Method and apparatus for actively managing electric power supply for an electric power grid," issued on October 10, 2023 (Compl. ¶31).

The Invention Explained

  • Problem Addressed: Conventional electric grid management systems lacked effective means to dynamically coordinate, control, and aggregate distributed power and load resources in real-time, resulting in grid instability and inefficient utilization of power resources (Compl. ¶33).
  • The Patented Solution: The patent discloses a system for actively managing an electric power grid using a central server, a "Coordinator," and a plurality of distributed "grid elements" (e.g., generation sources, storage devices, or loads) (Compl. ¶34). The Coordinator manages communications, tracks power values, and coordinates the grid elements to create operating reserves and maintain grid stability, facilitating messages over IP-based or proprietary networks (Compl. ¶¶33-34).
  • Technical Importance: The invention provides a framework for integrating disparate, distributed energy resources into a cohesive, controllable system to support modern grid operations and reliability (Compl. ¶33).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '470 Patent (Compl. ¶81).
  • The complaint alleges infringement of a system claim that appears to include elements such as a coordinator, a server, a plurality of grid elements (power supply sources), IP-based communication of available power, dispatch of power supply sources based on commands, and prioritization of dispatch based on source characteristics (Compl. ¶¶82-86).
  • The complaint does not explicitly reserve the right to assert dependent claims for the '470 Patent.

U.S. Patent No. 11,126,213

  • Patent Identification: U.S. Patent No. 11,126,213 ("'213 Patent"), titled "Method and Apparatus for Actively Managing Electric Power Supply for an Electric Power Grid," issued on September 21, 2021 (Compl. ¶38).

The Invention Explained

  • Problem Addressed: At the time of the invention, conventional grid systems were unable to dynamically coordinate and aggregate distributed resources to provide grid stability, settlement-quality telemetry, and operating reserves for market participants (Compl. ¶40).
  • The Patented Solution: The patent describes a system using a "Coordinator" to manage an IP-based communication and control architecture that integrates servers and a multiplicity of grid elements (Compl. ¶¶40-41). The Coordinator functions as an event manager, issuing power control instructions over networks such as Ethernet or cellular (Compl. ¶41; '213 Patent, col. 8:21-45).
  • Technical Importance: The technology enables the creation of operating reserves for utilities and market participants by actively managing power supply from distributed generation and storage devices (Compl. ¶40).

Key Claims at a Glance

  • The complaint asserts at least Claim 1 of the '213 Patent (Compl. ¶96).
  • The complaint alleges infringement of a system claim that appears to include elements such as a system managing power from a plurality of power supply sources, a coordinator orchestrating communications over an IP-based network, a server that initiates power commands, power storage devices with unique IP addresses, and automatic registration messaging (Compl. ¶¶97-100).
  • The complaint does not explicitly reserve the right to assert dependent claims for the '213 Patent.

Multi-Patent Capsule: U.S. Patent No. 10,429,871

  • Patent Identification: U.S. Patent No. 10,429,871 ("'871 Patent"), titled "Method and Apparatus for Actively Managing Electric Power Supply for an Electric Power Grid," issued on October 1, 2019 (Compl. ¶45).
  • Technology Synopsis: The patent addresses the deficiency in conventional grid architectures to dynamically coordinate distributed supply resources by disclosing an IP-based, coordinated control architecture (Compl. ¶47). This system includes a server, a Coordinator, and grid elements, where the Coordinator manages IP-based communications to enable real-time supply and operating reserve creation (Compl. ¶48).
  • Asserted Claims: At least Claim 1 (Compl. ¶111).
  • Accused Features: The accused features include the use of VaultOS, DOPTOP, and Minerva software to manage BESS assets, facilitating communication over IP-based networks between a server and site-level controllers, and dispatching resources (Compl. ¶¶112-114).

Multi-Patent Capsule: U.S. Patent No. 12,461,547

  • Patent Identification: U.S. Patent No. 12,461,547 ("'547 Patent"), titled "Method and Apparatus for Actively Managing Electric Power Supply for an Electric Power Grid," issued on November 4, 2025 (Compl. ¶52).
  • Technology Synopsis: The patent addresses the inability of conventional grid systems to efficiently manage distributed generation and storage resources by disclosing a coordinator-based architecture (Compl. ¶54). This architecture manages communications, power availability data, and dispatch instructions between servers and power supply sources (Compl. ¶54).
  • Asserted Claims: At least Claim 1 (Compl. ¶125).
  • Accused Features: The Accused EMS Software is alleged to monitor grid frequency conditions and respond to IP-based dispatch instructions from ERCOT for frequency regulation, which the complaint contends constitutes infringing IP-based power control commands (Compl. ¶130).

Multi-Patent Capsule: U.S. Patent No. 11,747,849

  • Patent Identification: U.S. Patent No. 11,747,849 ("'849 Patent"), titled "System, method, and apparatus for electric power grid and network management of grid elements," issued on September 5, 2023 (Compl. ¶59).
  • Technology Synopsis: The patent addresses deficiencies in conventional grid systems related to load curtailment and the coordination of distributed generation by disclosing a coordinator-based architecture (Compl. ¶61). This architecture manages communications, power data, and control instructions between servers and a plurality of power supply sources (Compl. ¶¶61-62).
  • Asserted Claims: At least Claim 1 (Compl. ¶141).
  • Accused Features: The Accused EMS Software is alleged to connect BESS resources through a networked architecture, featuring a coordinator that facilitates IP-based communication with a server, communicates telemetry data, and stores operational status data to control grid operations (Compl. ¶¶142-145).

III. The Accused Instrumentality

  • Product Identification: The "Accused EMS Software," which collectively refers to third-party software, such as Energy Vault's VaultOS, and Defendants' proprietary internal software, including DOPTOP and Minerva (Compl. ¶66). This software is used in conjunction with Defendants' Battery Energy Storage Systems ("BESS") at various project sites (Compl. ¶66).
  • Functionality and Market Context: The Accused EMS Software is alleged to coordinate, monitor, and control a plurality of BESS assets for participation in organized electricity markets, specifically the ERCOT market in Texas (Compl. ¶¶67-68). The complaint provides an architectural diagram from an Energy Vault datasheet describing VaultOS as having two components: "EMS On-Site" deployed at the project site and "EMS Cloud" for centralized remote monitoring and control (Compl. p. 23). The software allegedly uses IP-based industrial control protocols (e.g., ICCP) to communicate with market-facing systems, process telemetry, and execute dispatch messages (Compl. ¶68). The DOPTOP and Minerva software are identified as internal tools for "dispatch optimization" and "price forecasting," respectively (Compl. ¶70). The complaint includes a project overview for the St. Gall BESS facility, identifying "Jupiter Power" as the customer and "VaultOS" as the proprietary EMS software (Compl. p. 24).

IV. Analysis of Infringement Allegations

The complaint does not provide the exact language of the asserted claims. The following tables are constructed based on the narrative infringement allegations presented in the complaint.

'470 Patent Infringement Allegations

Claim Element (from Independent Claim 1, as reconstructed) Alleged Infringing Functionality Complaint Citation Patent Citation
a system for actively managing electric power supply for an electric power grid, the system comprising: at least one coordinator that orchestrates an EMS architecture The Accused Instrumentalities include the use of VaultOS, an EMS software featuring a coordinator that orchestrates Jupiter's EMS architecture. ¶82 '470 Patent, at 4:22-45
facilitating communication over IP-based networks between at least one server... and site-level controllers The coordinator facilitates communication over IP-based networks between at least one cloud-based or market-facing server (Jupiter's QSE server) and site-level controllers that control BESS assets. ¶82 '470 Patent, at 4:22-45
wherein the IP-based communications transmit telemetry reflecting an actual amount of power available from each BESS VaultOS transmits revenue-grade telemetry reflecting the actual amount of power available from each BESS, including State of Charge and Maximum Operating Discharge Power Limit. ¶83 '470 Patent, at 3:55-4:21
wherein a QSE server in communication with the EMS Software... issue[s] power commands... directing the BESS to discharge electricity Jupiter implements a QSE server in communication with the Accused EMS Software to issue power commands through VaultOS directing the BESS to discharge electricity to the grid. ¶84 '470 Patent, at 3:55-4:21
wherein the Accused EMS Software further prioritizes the order in which multiple BESS supply power based on operational characteristics, including State of Charge Using its cloud-based optimization engine and site-level controllers, the Accused EMS Software determines dispatch order among available resources. ¶85 '470 Patent, at 3:55-4:21

'213 Patent Infringement Allegations

Claim Element (from Independent Claim 1, as reconstructed) Alleged Infringing Functionality Complaint Citation Patent Citation
An EMS software system configured to manage power supplied to an electric power grid from a plurality of power supply sources The Accused Instrumentalities include the use of VaultOS, an EMS software system configured to manage power supplied from BESS based on real-time operational data and market conditions. ¶97 '213 Patent, at Abstract
the system comprising: a coordinator that orchestrates an EMS architecture, facilitating communication over IP-based networks between at least one server... and site-level controllers VaultOS features a coordinator that orchestrates Jupiter's EMS architecture, facilitating communication over IP-based networks between at least one cloud-based server and site-level controllers. ¶97 '213 Patent, at 8:21-45
wherein each power storage device includes a unique Internet Protocol (IP) address and is individually addressable over the network The Accused EMS Software manages multiple power storage devices wherein each includes a unique IP address and is individually addressable. ¶100 '213 Patent, at 8:21-45
the power storage devices automatically transmit registration and/or initialization messages to the coordinator Upon deployment and connection, the power storage devices automatically transmit registration and/or initialization messages to the coordinator. ¶100 '213 Patent, at 8:21-45
the coordinator receives the messages... and, upon receipt... automatically registers the power storage devices The coordinator receives the messages from the plurality of power supply sources for registration and, upon receipt, automatically registers them. ¶100 '213 Patent, at 8:21-45
The Accused EMS Software prioritizes the order in which the power supply sources deliver power based on operational characteristics such as State of Charge The Accused EMS Software prioritizes the order of power delivery based on operational characteristics such as State of Charge. ¶100 '213 Patent, at 5:25-34
  • Identified Points of Contention:
    • Scope Questions: The patents describe a "Coordinator" managing communications. A central question will be whether Defendants' combination of third-party software (VaultOS) and proprietary software (DOPTOP, Minerva), which itself is described as having cloud-based and on-site components, collectively meets the definition of the single "Coordinator" element as contemplated by the claims.
    • Technical Questions: The complaint alleges the accused system performs "dispatch optimization" and responds to "ERCOT dispatch instructions" (Compl. ¶¶71, 74). An evidentiary question for the court will be whether these alleged functions are technically equivalent to the claimed functions of creating "operating reserves" and managing "grid stability" as detailed in the patent specifications.

V. Key Claim Terms for Construction

  • The Term: "Coordinator"

  • Context and Importance: This term appears in the independent claims of all asserted patents and is the architectural linchpin of the claimed invention. The infringement dispute may turn on whether the Defendants' multi-part software suite (VaultOS, DOPTOP, Minerva), with its described "EMS Cloud" and "EMS On-Site" components (Compl. p. 23), can be mapped to the single "Coordinator" element.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The abstract of the '871 Patent describes the Coordinator as managing "messaging through a network," which could support a construction that covers a distributed, multi-component software system that collectively manages communications ('871 Patent, abstract).
    • Evidence for a Narrower Interpretation: Figures in the '871 Patent, such as the block diagram in FIG. 21A, depict the "Active Load Director" (the embodiment of the coordinator) as a distinct server-side entity composed of integrated modules (e.g., "Master Event Manager," "ALC Manager") ('871 Patent, FIG. 21A). This could support an argument that the Coordinator must be a more unitary, server-based component, rather than a combination of third-party, proprietary, cloud, and on-site software.

  • The Term: "grid element"

  • Context and Importance: The patents claim systems for managing "grid elements." The complaint alleges that Defendants' BESS assets are the infringing "grid elements" or "power supply sources" (Compl. ¶¶34, 69, 97). The construction of this term will be critical to determining if the patents apply to utility-scale energy storage systems or are limited to the behind-the-meter consumer devices explicitly shown in some patent figures.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The '470 Patent specification states that grid elements can "consume, generate, or store electric power," a broad functional definition that could encompass utility-scale BESS (Compl. ¶34). The '849 Patent also describes managing "distributed energy resources" through a networked architecture, which aligns with the function of BESS (Compl. ¶142).
    • Evidence for a Narrower Interpretation: Figures in the related '871 Patent, such as FIG. 20, explicitly depict "grid elements" as residential devices like pool pumps, HVAC units, and smart appliances ('871 Patent, FIG. 20). A party could argue that the scope of "grid element" should be narrowed by these specific embodiments to cover only behind-the-meter consumer devices, not large-scale, grid-facing BESS assets.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that parent company Jupiter Power LLC intentionally induces infringement by its subsidiary entities (the QSE and RE/DMEs) (Compl. ¶89). The alleged inducing acts include procuring the Accused EMS Software from Energy Vault, directing its use in an infringing manner, and providing the necessary training, personnel, and infrastructure to operate the BESS assets with the software (Compl. ¶¶89-90).
  • Willful Infringement: The complaint alleges that Defendants have been aware of the asserted patents since at least the filing of the original or amended complaint, forming a basis for post-suit willful infringement (Compl. ¶87; Compl. ¶102; Compl. ¶116; Compl. ¶132; Compl. ¶146).

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

  • A core issue will be one of architectural equivalence: does Defendants' distributed system-a combination of third-party cloud/on-site software (VaultOS) and proprietary optimization/forecasting tools (DOPTOP/Minerva)-constitute the single "Coordinator" entity as required by the patent claims, or is there a fundamental mismatch in system architecture?
  • A key evidentiary question will be one of functional scope: do the commercial operations performed by the Accused EMS Software for the ERCOT wholesale market, such as ancillary services and frequency response, perform the specific technical functions of creating "operating reserves" and managing "grid stability" as detailed and defined within the patent specifications, or do they represent a different, non-infringing class of grid service?
  • A central legal question, underpinning the entire case, will be one of enterprise liability: can the Plaintiff successfully prove its joint enterprise and alter ego theories to hold the various Jupiter corporate entities jointly and severally liable for the alleged infringement, or will the corporate separation between the parent, the QSE, and the asset-owning RE/DMEs shield certain defendants from liability?
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