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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

TEXARKANA DIVISION

POWERMAT TECHNOLOGIES LTD., 

Plaintiff,

v. 

ANKER INNOVATIONS LTD.

Defendant.

Case No.

JURY TRIAL DEMANDED

COMPLAINT FOR PATENT INFRINGEMENT

Plaintiff Powermat Technologies Ltd. (“Powermat”), by and through its undersigned 

counsel, files this complaint under 35 U.S.C. § 271 against Defendant Anker Innovations Ltd. 

(“Anker”), and alleges as follows, upon actual knowledge with respect to itself and its own acts, 

and upon information and belief as to all other matters.

NATURE OF THE ACTION

1. This is an action for patent infringement arising under the Patent Laws of the United

States, 35 U.S.C. § 1, et seq.

THE PARTIES

2. Plaintiff Powermat Technologies Ltd. is an Israeli limited liability company with a 

principal place of business located at 94 Derech Shlomo Shmeltzer, Bldg Brosh, Kiryat Arie, Petah 

Tivka 4970602, Israel.

3. Upon information and belief, Defendant Anker Innovations Ltd. is a corporation 

organized and existing under the laws of Hong Kong, with a principal place of business located at 

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Room 1318-19, Hollywood Plaza, 610 Nathan Road, Mongkok, Kowloon, Hong Kong SAR, 

Peoples Republic of China.

JURISDICTION AND VENUE

4. This Court has subject matter jurisdiction over the subject matter of this action 

pursuant to 28 U.S.C. §§ 1331 and 1338(a) because the action arises under the patent laws of the 

United States, 35 U.S.C. § 271, et seq.

5. This Court has personal jurisdiction over Anker pursuant to due process and/or the 

Texas Long Arm Statute because, inter alia, (i) Anker has done and continues to do business in 

the United States, including in the State of Texas; (ii) Anker has committed and continues to 

commit acts of patent infringement in the United States, including in the State of Texas, including 

making, using, offering to sell, and/or selling accused products in the United States and Texas, 

and/or importing accused products into the United States and Texas, including by Internet sales 

and sales via retail and wholesale stores, inducing others to commit acts of patent infringement in 

the United States and Texas, and/or committing at least a portion of any other infringements 

alleged herein. 

6. In addition, or in the alternative, this Court has personal jurisdiction over Anker 

pursuant to Fed. R. Civ. P. 4(k)(2).

7. Venue is proper in this district as to Defendant. Anker is organized under the laws 

of Hong Kong. 28 U.S.C. § 1391(c)(3) provides that “a defendant not resident in the United States 

may be sued in any judicial district, and the joinder of such a defendant shall be disregarded in 

determining where the action may be brought with respect to other defendants.”

PATENTS-IN-SUIT

8. The Asserted Patents are U.S. Patent Nos. 8,283,812; 8,626,461; 9,048,696; 

8,981,598; 9,006,937; 9,083,204; and 8,049,370.

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9. U.S. Patent No. 8,283,812 (“the ’812 Patent,” attached hereto at Exhibit 1) duly 

issued on October 9, 2012, and is entitled “Inductive Power Providing System Having Moving 

Outlets.” Powermat is the owner by assignment of the ’812 Patent and possesses all rights under 

the ’812 Patent, including the exclusive right to recover for past and future infringement. 

10. U.S. Patent No. 8,626,461 (“the ’461 Patent,” attached hereto at Exhibit 2) duly 

issued on January 7, 2014, and is entitled “Efficiency Monitor for Inductive Power Transmission.” 

Powermat is the owner by assignment of the ’461 Patent and possess all rights under the ’461 

Patent, including the exclusive right to recover for past and future infringement.

11. U.S. Patent No. 9,048,696 (“the ’696 Patent,” attached hereto at Exhibit 3) duly 

issued on June 2, 2015 and is entitled, “Transmission-Guard System and Method for an Inductive 

Power Supply.” Powermat is the owner by assignment of the ’696 Patent and possess all rights 

under the ’696 Patent, including the exclusive right to recover for past and future infringement.

12. U.S. Patent No. 8,981,598 (“the ’598 Patent,” attached hereto at Exhibit 4) duly 

issued on March 17, 2015 and is entitled, “Energy Efficient Inductive Power Transmission System 

and Method.” Powermat is the owner by assignment of the ’598 Patent and possesses all rights 

under the ’598 Patent, including the exclusive right to recover for past and future infringement.

13. U.S. Patent No. 9,006,937 (“the ’937 Patent,” attached hereto at Exhibit 5) duly 

issued on April 14, 2015 and is entitled, “System and Method for Enabling Ongoing Inductive 

Power Transmission.” Powermat is the owner by assignment of the ’937 Patent and possesses all 

rights under the ’937 Patent, including the exclusive right to recover for past and future 

infringement.

14. U.S. Patent No. 9,083,204 (“the ’204 Patent,” attached hereto at Exhibit 6) duly 

issued on July 14, 2015 and is entitled, “Transmission-Guard System and Method for an Inductive 

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Power Supply.” Powermat is the owner by assignment of the ’204 Patent and possesses all rights 

under the ’204 Patent, including the exclusive right to recover for past and future infringement.

15. U.S. Patent No. 8,049,370 (“the ’370 Patent,” attached hereto at Exhibit 7) duly 

issued on November 1, 2011 and is entitled, “Centrally Controlled Inductive Power Transmission 

Platform.” Powermat is the owner by assignment of the ’370 Patent and possesses all rights under 

the ’370 Patent, including the exclusive right to recover for past and future infringement.

BACKGROUND

Powermat’s History

16. Powermat was founded in 2006 in Neve Ilan, Israel, with the mission of enabling a 

100% wireless future, in which devices and machines enjoy seamless, unlimited access to wireless 

power. 

17. Powermat offers a suite of standards-based and proprietary wireless power 

solutions, which have been incorporated into products and services across the globe, spanning a 

multitude of industries and sectors, including automotive, robotics, defense, consumer electronics, 

healthcare, and telecommunications.

18. A core aspect of Powermat’s wireless charging technology is inductive charging—

a type of wireless power transfer that uses induction coils to create an alternating electromagnetic 

field, thereby transferring energy from a transmitter unit (e.g., a wireless charging station) to a 

receiver unit (e.g., a smartphone). The receiver unit then converts the energy into power that can 

charge a battery (e.g., the battery within the smartphone).

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19. Powermat was one of the first companies to enter the domain of magnetics 

induction, reflected today in Powermat’s significant brand recognition and technology leadership, 

and in the quality and breadth of its patent portfolio. 

20. In its early years (2006-2011), Powermat focused on introducing wireless power to 

consumers and building out its ecosystem of power transmitters and receivers. During this period, 

Powermat formed a number of strategic partnerships to commercialize its products, including with 

companies such as Homedics, T-Mobile, and General Motors. Products developed over this period 

included wireless charging platforms, mats, and other surfaces, as well as cases and backdoors for 

smartphones and gaming devices.

21. In 2012, Powermat partnered with Duracell to expand its retail presence in the 

United States and the United Kingdom. That same year, Powermat partnered with Starbucks in 

what started as a ten-store pilot in Boston, and later turned into a 12,000-plus charging spot 

installation across five U.S. cities—New York, San Francisco, Los Angeles, Chicago, and Boston. 

Powermat’s charging networks were installed by a number of significant brands, including 

McDonald’s, Coffee Bean & Tea Leaf, Madison Square Garden, and Westfield. 

22. As a recognized leader and pioneer in wireless charging, Powermat collaborated 

with Procter & Gamble, Starbucks, and AT&T in 2012 to form the Power Matters Alliance (PMA), 

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a non-profit industry organization whose mission was to advance a suite of standards and protocols 

for wireless power transfer for mobile electronic devices. Around that same time, Powermat 

specifications were added as a requirement for certain mobile devices sold by AT&T, including 

Samsung, LG, ASUS, and Kyocera.

23. Today, Powermat’s technology can be found in millions of products, including 

mobile devices, electronic accessories, and automobiles. Recognizing its significant role in the 

wireless charging space, Powermat also developed a broad and extensive patent portfolio.

Powermat’s Patent Portfolio and the WPC

24. Powermat’s patent portfolio includes well over 150 patents, with dozens more 

pending, directed to various aspects of wireless charging. These patents cover both the power 

transmitter side (e.g., the functionality incorporated into a wireless charging pad) and the power 

receiver side (e.g., the functionality incorporated into products to allow wireless charging, 

including such products as mobile phones, wireless earbuds, watches, and more).

25. Many patents in Powermat’s portfolio predate the major wireless charging 

standards, including Qi (pronounced “chee”)—the most widely adopted wireless charging 

standard. Many of the most popular consumer electronics goods are compatible with Qi. 

26. The Qi Standard is developed and maintained by the Wireless Power Consortium 

(WPC). Many of Powermat’s patents are essential to practicing the Qi Standard. The first version 

(Version 1.0) of the Qi Standard was issued in July 2010.

1 All of the patents that Powermat asserts 

in this Complaint are Standard Essential Patents (SEPs), reflecting Powermat’s significant 

contributions to the Qi Standard.

1 See https://www.wirelesspowerconsortium.com/knowledge-base/specifications/history-of-the-qispecification.html.

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27. Similar to many standard setting organizations (SSOs), the WPC has an intellectual 

property rights (IPR) policy, requiring that its members make certain SEPs available for license

on reasonable and non-discriminatory (RAND) terms. 

28. Specifically, the WPC’s current IPR policy designates certain rights as “necessary” 

for the implementation of the Qi Standard. 

“Necessary Claims” means only those claims of any patent which would 

necessarily be infringed by implementation of an Approved Wireless Power 

Specification. A patent claim is “necessarily infringed” only when there is no 

technically reasonable non-infringing alternative for implementing an Approved 

Wireless Power Specifications (or portion thereof) without infringing the relevant 

patent claim.

For the avoidance of doubt, the Members understand that no undertaking or 

licensing obligation hereunder (or pursuant to the Corporation in any way) shall 

require or extend to include patents or claims related to: (i) implementations of 

other recognized standards, even if those are referenced in the Approved Wireless 

Power Specification; (ii) any portions of products or devices other than those 

wireless charging portions of a product or device which are needed in order to 

comply with an Approved Wireless Charging Specification; or (iii) semiconductor 

manufacturing or semiconductor process intellectual property.

WPC (IPR) Policy, Article I Patent Licensing, Section 1.1 at 2 (available at 

https://www.wirelesspowerconsortium.com/data/downloadables/2/7/1/8/20200624-wpc-inc-iprpolicy.pdf). 

29. The WPC’s IPR policy requires its members to license its “Necessary Claims” for 

RAND terms, with respect to power transmitters (e.g., a device that transmits a wireless power 

charging signal) and power receivers (e.g., a device that receives a wireless power charging signal) 

that are fully compliant with an Approved Wireless Power Specification:

Each member undertakes to grant or cause the grant, on its own behalf on behalf of 

its Affiliated Entities and, subject to faithful performance of license terms, nonexclusive, non-transferrable, non-sublicenseable, world-wide licenses:

(a) on RAND Terms under its Necessary Claims to make, use, sell, offer to sell, 

import and otherwise dispose of Compliant Transmitters,

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(b) on RAND Terms under its Necessary Claims to make, use, sell, offer to sell, 

import and otherwise dispose of Compliant Other Receivers, and

(c) on RF Terms under its Necessary Claims solely to make, use, sell, offer to 

sell, import, and otherwise dispose of Compliant Lower Power Receivers.2

Id., Section 1.3 at 4.

30. As a longtime member of and significant contributor to the WPC, Powermat takes 

its RAND obligations seriously. As a result, Powermat has established standard rates for the 

licensing of its SEPs, which are RAND (i.e., consistent with its obligations under the WPC’s IPR 

policy) and have been accepted by the industry. Powermat has also established standard royalty 

rates for its non-SEPs, which have also been accepted by the industry.

31. Anker is also a member of the WPC, and in fact has declared several of its products, 

including many of the products identified in this Complaint, as complying with the Qi Standard.

32. Additionally, the Qi Standard provides examples of reference designs that can be 

implemented by manufacturers to ensure that their power transmitters and receivers are in 

compliance therewith. For each reference design, the Qi Standard provides a general description

and a functional block diagram, along with mechanical and electrical details for the corresponding 

component. 

33. A manufacturer of a Qi-compliant product can specify to the public, via the WPC’s 

website, the particular reference design(s) with which its products comport. In this regard, Anker 

has identified the reference designs with which several of its products are compliant. 

2 “Lower Power Receiver” is defined as a Receiver that is not capable of receiving more than 5 watts of charging 

power from a Transmitter. Id., Section 1.1 at 2.

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https://www.wirelesspowerconsortium.com/products/12316. 

34. Anker has identified, on the WPC website, several of the accused products listed 

herein as complying with one or more Qi reference designs.

Powermat’s Negotiations with Anker

35. Anker is aware that Powermat is a member of the WPC, and that it has many patents 

that contain “Necessary Claims” under the WPC’s IPR Policy. 

36. Anker is also aware that Powermat has several patents that a party must infringe in 

order to comply with a particular Qi reference design, including reference designs Anker has 

admitted adopting through the WPC’s website.

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37. Powermat has reached out to Anker on numerous occasions regarding its wireless 

charging patent portfolio. For example, Anker has been aware of Powermat’s patent portfolio 

relating to wireless charging since at least November 11, 2018.

38. For example, on that date, Mr. Alex Levit from Powermat sent a letter to Anker’s 

legal department, explaining that it was the owner of certain essential patents that are necessary 

for compliance with the Qi Standard, as well as other wireless charging standards. Mr. Levit also 

explained that Anker had been incorporating Powermat’s patented technology into its products, at 

least by virtue of its purported compliance with the Qi Standard. The letter included exemplary 

infringement claim charts for several of Powermat’s SEPs, including 

the ’812, ’461, ’696, ’598, ’937, and ’204 Patents asserted herein (in Counts 1, 2, 3, 4, 5, and 6, 

respectively). The parties also exchanged a number of communications between December 2018 

and January 2019 regarding potential business opportunities, including conducting at least one inperson meeting in January 2019, but no agreement was reached. 

39. On August 5, 2020, Powermat sent a letter to Messrs. Ben Zhang and Owen Yu of 

Anker regarding Anker’s need to license Powermat’s portfolio. That letter identified several Anker 

products and a list of SEPs to which those products required a license, including all patents asserted 

herein. Powermat did not receive a response to its August 5, 2020 letter.

40. On November 12, 2020, Powermat sent follow-up emails to Messrs. Kola Xiang, 

George Tang, and Ben Zhang at Anker, enclosing the August 5, 2020 letter. Powermat did not 

receive a substantive response to its November 12, 2020 email. Between December 21, 2020 and 

September 2021, Powermat sent at least five follow-up emails, to which it received no meaningful 

response. 

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41. On January 30, 2023, Powermat (through its outside counsel) sent a letter to 

Anker’s legal department, reiterating that Powermat’s patent portfolio includes a number of patents 

that are necessary for implementing the Qi Standard (SEPs). The letter identified several Anker 

products, including Anker’s wireless chargers, magnetic wireless chargers, 3-in-1 Cube, wireless 

charger stands, wireless charger stations, and wireless car chargers (e.g., MagGo), and listed a 

number of Powermat patents, including the ’696, ’598, ’937, and ’204 Patents asserted herein (in 

Counts 3, 4, 5, and 6, respectively). Powermat did not receive a response to its January 30, 2023 

letter.

42. On May 11, 2023, Powermat sent follow-up letters to Anker’s legal and intellectual 

property departments reiterating the above and identifying additional patents, including 

the ’812, ’461, ’696, ’598, and ’370 Patents asserted herein (in Counts 1-4 and 7, respectively). To 

date, Powermat has not received a response to its May 11, 2023 letter. In fact, Anker has refused 

to engage in any meaningful discussions regarding the licensing of its patent portfolio.

43. In view of Anker’s refusal to negotiate in good faith, or even to acknowledge 

Powermat’s correspondence or otherwise engage in any discussions about licensing Powermat’s 

SEPs, Anker has demonstrated that it is an unwilling licensee.

44. The United States Department of Justice, with the United States Patent and 

Trademark Office (USPTO) and the National Institute of Standards and Technology (NIST), have 

made clear that patent owners and potential licensees of SEPs should “engage in good-faith 

negotiations to reach F/RAND license terms” to “help reduce the costs and other burdens 

associated with litigation.” 2019 Policy Statement on Remedies for SEPs Subject to Voluntary 

F/RAND Commitments, https://www.justice.gov/atr/page/file/1228016/download (December 19, 

2019).

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45. Anker has been operating and continues to operate without a license to Powermat’s 

standards-essential and other patents. The parties’ licensing negotiations to-date have been 

unsuccessful due to Anker’s refusal to respond to Powermat’s several communications or 

otherwise engage in good-faith discussions about licensing Powermat’s patent portfolio.

46. Powermat is left with no choice but to bring the instant action to protect and enforce 

its intellectual property rights and the substantial investments made therein.

COUNT 1 – INFRINGEMENT OF U.S. PATENT NO. 8,283,812

47. Powermat incorporates paragraphs 1-46 above by reference.

48. The ’812 Patent discloses a protection system and method for preventing an 

inductive power system or transmitter from transmitting power in the absence of an electric load 

(e.g., a mobile device with wireless charging capability). The ’812 Patent discloses that this may 

be achieved, for example, by detecting whether a primary inductor of a power outlet is inductively 

coupled to a secondary inductor and transmitting power, and disconnecting the primary inductor 

from its power supply if no secondary inductor is detected.

49. Defendant has directly infringed one or more claims of the ’812 Patent in this 

district and elsewhere in Texas, including at least claims 9-11 literally and/or under the doctrine 

of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its wireless 

charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 737 MagGo 

Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic Wireless 

Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-in-1 Stand), 

533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 Wireless 

Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 Magnetic 

Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic Battery 

(MagGo), 521 Magnetic Battery (PowerCore 5K), and 533 Wireless Power Bank (PowerCore 10K) 

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(collectively, “the ’812 Accused Products”). Powermat reserves the right to discover and pursue 

any additional infringing devices that incorporate infringing functionalities. For the avoidance of 

doubt, the ’812 Accused Products are identified to describe the Defendant’s infringement and in 

no way limit the discovery and infringement allegations against Defendant concerning other 

devices that incorporate the same or reasonably similar functionalities. 

50. At least some of the asserted claims of the ’812 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 313 Wireless Charger (Pad) (“Anker 313 Pad”) as 

complying with the Qi Standard. In addition, Anker has indicated the Anker 313 Pad as comporting 

with the Qi Standard’s A11a power transmitter design. As such, the Anker 313 Pad, and all 

materially similar Anker products, infringe at least claims 9-11 of the ’812 Patent, literally and/or 

under the doctrine of equivalents.

51. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, is a 

wireless charger, and therefore is and/or includes an inductive power outlet for transmitting power 

to an electric load. 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

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52. Additionally, each of the ’812 Accused Products, including for example, the Anker 

313 Pad, is configured to prevent the transmission of power in the absence of an electric load. For 

example, Anker advertises the Anker 313 Pad as including a “MultiProtect” safety system 

“equipped with foreign object detection, short circuit protection, temperature control and more, so 

you can experience wireless charging with total peace of mind.”

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy. 

53. Additionally, on information and belief, the Anker 313 Pad is compliant with the 

Qi Standard, which describes the removal of power in the absence of an electric load. 

54. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, also 

includes at least one primary inductor wired to a power supply. For example, the Anker 313 Pad 

includes a primary coil that is wired to a power supply connectable, for example, to a wall outlet 

via, for example, the USB/micro-USB cable included with the Anker 313 Pad. 

55. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, also 

includes at least one primary detector in the locality of the primary inductor, for inductively 

coupling with a secondary inductor wired to said electric load. For example, on information and 

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belief, the Anker 313 Pad is Qi-compliant and configured consistent with Qi’s A11a power 

transmitter design, which requires at least one primary detector in the locality of the primary 

inductor..

56. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, is 

configured to transmit power by way of the primary inductor contained therein. For example, the 

Anker 313 Pad includes a primary inductor (coil) underneath a surface, on which a secondary unit 

may be placed for wireless charging (receiving power transmitted by the primary inductor in the 

Anker 313 Pad).

57. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, is 

configured to detect that the primary inductor is transmitting power (e.g., using the current monitor, 

per Qi’s A11a power transmitter design). Each of the ’812 Accused Products, including for 

example, the Anker 313 Pad, is also configured to detect that the primary inductor is inductively 

coupled to a secondary inductor.

58. Each of the ’812 Accused Products, including for example, the Anker 313 Pad, is 

configured to disconnect the primary inductor from the power supply if no secondary inductor is 

detected. For example, the Anker 313 is indicated as compliant with the Qi Standard, which 

requires the removal of power in the absence of an electric load. 

59. The foregoing features and capabilities of the Anker 313 Pad, and Anker’s

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Anker’s direct infringement by satisfying every element of at least 

claims 9-11 of the ’812 Patent, under 35 U.S.C. § 271(a).

60. Defendant has indirectly infringed at least claims 9-11 of the ’812 Patent in this 

judicial district and elsewhere in the United States by, among other things, actively inducing the 

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use, offering for sale, selling, or importation of at least the ’812 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’812 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

user guides, such as those for the Anker 313 located at the following website: 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

Defendant is therefore liable for infringement of the ’812 Patent pursuant to 35 U.S.C. § 271(b). 

61. Defendant has indirectly infringed at least claims 9-11 of the ’812 Patent by, among 

other things, contributing to the direct infringement of others, including customers of the ’812

Accused Products by making, offering to sell, or selling, in the United States, or importing a 

component of a patented process, constituting a material part of the invention, knowing the same 

to be especially made or especially adapted for use in infringement of the ’812 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

62. For example, the ’812 Accused Products include at least one component to 

inductively transmit power and prevent the transmission of such power in the absence of an electric 

load. This is a component of a patented machine, manufacture, or combination, or an apparatus for 

use in practicing a patented process. Furthermore, such component is a material part of the 

invention and upon information and belief is not a staple article or commodity of commerce 

suitable for substantial non-infringing use. Thus, Defendant is liable for infringement of the ’812

Patent pursuant to 35 U.S.C. § 271(c).

63. Defendant has been on notice of the ’812 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

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that its continued actions would actively induce and contribute to actual infringement of at least 

claims 9-11 of the ’812 Patent. 

64. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’812 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’812 Patent, and that the ’812 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’812 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’812 Patent. 

65. Powermat has been damaged by Defendant’s infringement of the ’812 Patent. 

COUNT 2 – INFRINGEMENT OF U.S. PATENT NO. 8,626,461

66. Powermat incorporates paragraphs 1-65 above by reference.

67. The ’461 Patent is directed to an apparatus for monitoring power efficiency in a 

wireless power transmission system. For example, the ’461 Patent discloses an inductive power 

outlet that contains a power monitor for measuring input power received by a primary coil from a 

power supply, a signal detector for detecting signals carrying data relating to output power received

by a secondary coil inductively coupled with the primary coil, and a processor that receives data 

relating to input power and output power and determines an index of power-loss indicative of the 

efficiency of the inductive coupling.

68. Defendant has directly infringed one or more claims of the ’461 Patent in this 

district and elsewhere in Texas, including at least claims 13-14 literally and/or under the doctrine 

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of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its wireless 

charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 737 MagGo 

Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic Wireless 

Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-in-1 Stand), 

533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 Wireless 

Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 Magnetic 

Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic Battery 

(MagGo), 521 Magnetic Battery (PowerCore 5K), and 533 Wireless Power Bank (PowerCore 10K) 

(collectively, “the ’461 Accused Products”). Powermat reserves the right to discover and pursue 

any additional infringing devices that incorporate infringing functionalities. For the avoidance of 

doubt, the ’461 Accused Products are identified to describe the Defendant’s infringement and in 

no way limit the discovery and infringement allegations against Defendant concerning other 

devices that incorporate the same or reasonably similar functionalities. 

69. At least some of the asserted claims of the ’461 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 533 Wireless Charger (3-in-1 Stand) (“Anker 533”) 

as complying with the Qi Standard. In addition, Anker has indicated the Anker 533 as comporting 

with the Qi Standard’s A11a power transmitter design. As such, the Anker 533, and all materially 

similar Anker products, infringe at least claims 13-14 of the ’461 Patent, literally and/or under the 

doctrine of equivalents.

70. Each of the ’461 Accused Products, including for example, the Anker 533, includes 

a primary coil and is configured for inductively coupling with a secondary coil wired to an electric 

load (e.g., a secondary coil wired to a battery within an iPhone). 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 18 of 51 PageID #: 18
19

https://www.anker.com/products/b2538?variant=42455408574614.

71. Each of the ’461 Accused Products, including for example, the Anker 533, also 

includes an efficiency monitor. For example, Anker advertises the Anker 533 as offering “multiple 

advanced safety options such as surge protection, temperature control and more to keep you and 

your devices safe.” 

https://www.anker.com/products/b2538?variant=42455408574614.

72. Each of the ’461 Accused Products, including for example, the Anker 533, also 

includes an input power monitor configured to measure input power received by the primary coil 

from the power supply. For example, on information and belief, the Anker 533 is compliant with 

the Qi Standard, including, for example, version 1.2.4 of the Qi Wireless Power Transfer 

System/Power Class 0 Specification. On information and belief, the Anker 533 follows the MPA20 Reference Design appended thereto, which describes an input power monitor, such as a 

current sensing element, to measure the input power received by the primary coil. See, e.g., Qi 

MP-A20 Addendum at 18.

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 19 of 51 PageID #: 19
20

73. Each of the ’461 Accused Products, including for example, the Anker 533, also 

includes a signal detector configured to detect signals carrying data pertaining to output power 

received by the secondary coil. For example, consistent with the Qi Standard, the Anker 533 is 

configured to perform a digital ping of the secondary side, for example, by applying a power signal 

and detecting a responsive packet from the secondary side containing a Signal Strength Packet 

carrying data pertaining to power received by the secondary coil of a secondary device. During a 

Power Transfer Phase, the Anker 533 is configured to detect a Control Error Packet carrying data 

pertaining to power received by the secondary coil of a secondary device.

74. Each of the ’461 Accused Products, including for example, the Anker 533, also 

includes a processor configured to receive data pertaining to the input power and the output power. 

For example, in accordance with the configuration set forth in the MP-A20 reference design, the 

Anker 533 incorporates at least one controller configured to receive and decode messages and 

perform power control algorithms based on input and output power.

75. Each of the ’461 Accused Products, including for example, the Anker 533, also 

includes a processor configured to determine an index of power-loss indicative of the efficiency 

of an inductive coupling between the primary coil and the secondary coil. For example, on 

information and belief, the Anker 533 complies with the Extended Power Profile (EPP) set forth 

in the Qi Standard. On information, in accordance with the EPP, the Anker 533 calculates an index 

of power loss, for example, in support of foreign object detection. See, e.g., 

https://www.wirelesspowerconsortium.com/products/12342.

76. Each of the ’461 Accused Products, including for example, the Anker 533, is 

configured such that the index of power-loss includes at least an efficiency quotient Q, defined as 

the ratio of the output power to the input power, or an efficiency differential Δ, defined as the 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 20 of 51 PageID #: 20
21

difference between the output power and the input power. For example, in accordance with the 

EPP, the Anker 533 calculates an index of power loss, for example, in support of foreign object 

detection. According to the Qi standard, one of the methods for calculating the power loss is to 

calculate the difference between the power transmitted by the primary coil and the power received 

by the secondary coil. 

77. The foregoing features and capabilities of the Anker 533, and Defendant’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Defendant’s direct infringement by satisfying every element of at least 

claims 13-14 of the ’461 Patent, under 35 U.S.C. § 271(a). 

78. Defendant has indirectly infringed at least claims 13-14 of the ’461 Patent in this 

judicial district and elsewhere in the United States by, among other things, actively inducing the 

use, offering for sale, selling, or importation of at least the ’461 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’812 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

user guides, such as those for the Anker 533 located at the following website: 

https://www.anker.com/products/b2538?variant=42455408574614. Defendant is therefore liable 

for infringement of the ’461 Patent pursuant to 35 U.S.C. § 271(b). 

79. Defendant has indirectly infringed at least claims 13-14 of the ’461 Patent by, 

among other things, contributing to the direct infringement of others, including customers of 

the ’461 Accused Products by making, offering to sell, or selling, in the United States, or importing 

a component of a patented process, constituting a material part of the invention, knowing the same 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 21 of 51 PageID #: 21
22

to be especially made or especially adapted for use in infringement of the ’461 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

80. For example, the ’461 Accused Products include at least one component to 

inductively transmit power and monitor power transmission efficiency. This is a component of a 

patented machine, manufacture, or combination, or an apparatus for use in practicing a patented 

process. Furthermore, such component is a material part of the invention and upon information 

and belief is not a staple article or commodity of commerce suitable for substantial non-infringing 

use. Thus, Defendant is liable for infringement of the ’461 Patent pursuant to 35 U.S.C. § 271(c).

81. Defendant has been on notice of the ’461 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 13-14 of the ’461 Patent. 

82. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’461 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’461 Patent, and that the ’461 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’461 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’461 Patent. 

83. Powermat has been damaged by Defendant’s infringement of the ’461 Patent. 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 22 of 51 PageID #: 22
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COUNT 3 – INFRINGEMENT OF U.S. PATENT NO. 9,048,696

84. Powermat incorporates paragraphs 1-83 above by reference.

85. The ’696 Patent is directed to an apparatus and method of transferring power to an 

inductive power receiver. For example, the ’696 Patent discloses an inductive power outlet that 

includes a platform with a primary inductive coil, for supporting an inductive power receiver with 

a secondary coil; an alignment mechanism for facilitating alignment between the outlet and 

receiver, and formation of an inductive coupling having a characteristic resonant frequency; and a 

driving circuit that includes a switching circuit for providing an oscillating driving voltage to 

induce a secondary voltage in a secondary inductive coil, where the driving circuit produces the 

oscillating driving voltage at a transmission frequency substantially different from the 

characteristic resonant frequency of the inductive couple.

86. Defendant has directly infringed one or more claims of the ’696 Patent in this 

district and elsewhere in Texas, including at least claims 1-7, 9, 10, and 14 literally and/or under 

the doctrine of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its 

wireless charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 

737 MagGo Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic 

Wireless Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-

in-1 Stand), 533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 

Wireless Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 

Magnetic Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic 

Battery (MagGo), 522 Magnetic Wireless Charger (3-in-1 Stand), 521 Magnetic Battery 

(PowerCore 5K), 533 Wireless Power Bank (PowerCore 10K), PowerWave Magnetic 2-in-1 Stand 

Lite, PowerWave 3-in-1 Stand with Watch Charging Cable Holder, PowerWave Select+ Magnetic 

Pad, and PowerWave Select Magnetic Stand (collectively, “the ’696 Accused Products”). 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 23 of 51 PageID #: 23
24

Powermat reserves the right to discover and pursue any additional infringing devices that 

incorporate infringing functionalities. For the avoidance of doubt, the ’696 Accused Products are 

identified to describe the Defendant’s infringement and in no way limit the discovery and 

infringement allegations against Defendant concerning other devices that incorporate the same or 

reasonably similar functionalities. 

87. At least some of the asserted claims of the ’696 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 737 MagGo as complying with the Qi Standard. 

In addition, Anker has indicated the Anker 737 MagGo as comporting with the Qi Standard’s A11a 

power transmitter design. As such, the Anker 737 MagGo, and all materially similar Anker 

products, infringe at least claims 1-7, 9, 10, and 14 of the ’696 Patent, literally and/or under the 

doctrine of equivalents.

88. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo

is a wireless charger, and therefore is operable to transfer power to an inductive power receiver.

https://www.anker.com/products/b2599?variant=42519665016982.

89. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo,

has a platform for supporting an inductive power receiver. For example, the Anker 737 MagGo 

has platforms for several different devices, including for example, an iPhone, Apple Watch, or 

Airpods. 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 24 of 51 PageID #: 24
25

https://www.anker.com/products/b2599?variant=42519665016982.

90. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo, 

incorporates at least one primary coil. For example, on information and belief, the Anker 737 

MagGo is Qi-compliant and follows the recommended A11a transmitter design, which requires at 

least one primary coil in the power transmitter. See, e.g., Qi Reference Designs at 66-67. In 

accordance therewith, the Anker 737 MagGo incorporates at least one primary coil for inductively 

transferring power, for example, to a mobile device.

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 25 of 51 PageID #: 25
26

91. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo, 

includes an alignment mechanism configured to facilitate alignment between the primary inductive 

outlet and the inductive power receiver such that an inductive couple is formed between the 

primary inductive coil and a secondary inductive coil of the inductive power receiver. For example, 

the Anker 737 MagGo incorporates a MagSafe module to facilitate alignment between the primary 

coil of the Anker 737 MagGo with a secondary coil in an compatible device, like an iPhone. 

https://www.anker.com/products/b2599?variant=42519665016982.

92. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo, 

is configured such that the inductive couple formed with a secondary device has a characteristic 

resonant frequency. For example, on information and belief, the Anker 737 is Qi-compliant, and 

accordingly has a characteristic frequency when coupled with a secondary device. For example, in 

accordance with reference design A11a, the Anker 737 MagGo, on information and belief, 

incorporates at least a characteristic resonant frequency (e.g., about 100 kHz). See, e.g., Qi 

Reference Design at 69.

93. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo, 

includes a driving circuit wired to the primary inductive coil, where the driving circuit includes a 

switching unit configured and operable to provide an oscillating driving voltage across the primary 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 26 of 51 PageID #: 26
27

inductive coil such that a secondary voltage is induced in the secondary inductive coil. For example, 

on information and belief, the Anker 737 MagGo is Qi standard-compliant, and therefore

incorporates a driving circuit—for example, a full-bridge inverter—wired to the primary inductive 

coil. The full-bridge inverter has a switching unit configured and operable to provide an oscillating 

driving voltage across the primary inductive coil such that a secondary voltage is induced in the 

secondary inductive coil. For example, on information and belief, the applied driving voltage is 

sufficient to charge a phone in about one hour (e.g., 47 minutes for iPhone 14 Pro Max). On 

information and belief, the inverter oscillates at an operating frequency and incorporates a 

switching unit to provide the oscillating voltage. 

https://www.anker.com/products/b2599?variant=42519665016982#.

94. Each of the ’696 Accused Products, including for example, the Anker 737 MagGo, 

includes a driving circuit (e.g., full-bridge inverter) that has a switching unit configured and 

operable to provide an oscillating driving voltage at a transmission frequency that is substantially 

different from the characteristic resonant frequency of the inductive couple. For example, the Qi 

Standard discloses an operating frequency that is substantially different from the resonant 

frequency of 100 kHz.

95. The foregoing features and capabilities of the Anker 737 MagGo, and Defendant’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Defendant’s direct infringement by satisfying every element of at least 

claims 1-7, 9, 10, and 14 of the ’696 Patent, under 35 U.S.C. § 271(a). 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 27 of 51 PageID #: 27
28

96. Defendant has indirectly infringed at least claims 1-7, 9, 10, and 14 of the ’696

Patent in this judicial district and elsewhere in the United States by, among other things, actively 

inducing the use, offering for sale, selling, or importation of at least the ’696 Accused Products. 

Defendant’s customers who purchase devices and components thereof and operate such devices 

and components in accordance with Defendant’s instructions directly infringe one or more claims 

of the ’696 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at 

least user guides, such as those for the Anker 737 MagGo located at the following website: 

https://www.anker.com/products/b2599?variant=42519665016982. Defendant is therefore liable 

for infringement of the ’696 Patent pursuant to 35 U.S.C. § 271(b). 

97. Defendant has indirectly infringed at least claims 1-7, 9, 10, and 14 of the ’696

Patent by, among other things, contributing to the direct infringement of others, including 

customers of the ’696 Accused Products by making, offering to sell, or selling, in the United States, 

or importing a component of a patented process, constituting a material part of the invention, 

knowing the same to be especially made or especially adapted for use in infringement of the ’696

Patent, and not a staple article or commodity of commerce suitable for substantial non-infringing 

use.

98. For example, the ’696 Accused Products include at least one component to 

inductively transmit power and ensure alignment with a secondary device. This is a component of 

a patented machine, manufacture, or combination, or an apparatus for use in practicing a patented 

process. Furthermore, such component is a material part of the invention and upon information 

and belief is not a staple article or commodity of commerce suitable for substantial non-infringing 

use. Thus, Defendant is liable for infringement of the ’696 Patent pursuant to 35 U.S.C. § 271(c).

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 28 of 51 PageID #: 28
29

99. Defendant has been on notice of the ’696 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 1-7, 9, 10, and 14 of the ’696 Patent. 

100. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’696 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’696 Patent, and that the ’696 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’696 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’461 Patent. 

101. Powermat has been damaged by Defendant’s infringement of the ’696 Patent. 

COUNT 4 – INFRINGEMENT OF U.S. PATENT NO. 8,981,598

102. Powermat incorporates paragraphs 1-101 above by reference.

103. The ’598 Patent is directed to an inductive power outlet for transmitting power to 

one or more inductive power receivers. For example, the ’598 Patent discloses an inductive power 

outlet that includes a trigger sensor for detecting a release signal indicating proximity of an 

inductive power receiver, and a signal detector operable to detect instruction signals from the 

inductive power receiver concurrently with power transfer. The release signal triggers the outlet 

to generate an activation signal detectable by the power receiver. The signal detector may be 

operable to detect an identification signal sent by the power receiver and to initiate driving of the 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 29 of 51 PageID #: 29
30

primary inductor such that the power receiver draws power from the outlet for a limited time 

duration and to stop driving if no instruction signal is received during the limited time duration. 

104. Defendant has directly infringed one or more claims of the ’598 Patent in this 

district and elsewhere in Texas, including at least claims 1-3 and 5 literally and/or under the 

doctrine of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its 

wireless charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 

737 MagGo Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic 

Wireless Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-

in-1 Stand), 533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 

Wireless Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 

Magnetic Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic 

Battery (MagGo), 521 Magnetic Battery (PowerCore 5K), and 533 Wireless Power Bank 

(PowerCore 10K) (collectively, “the ’598 Accused Products”). Powermat reserves the right to 

discover and pursue any additional infringing devices that incorporate infringing functionalities. 

For the avoidance of doubt, the ’598 Accused Products are identified to describe the Defendant’s 

infringement and in no way limit the discovery and infringement allegations against Defendant 

concerning other devices that incorporate the same or reasonably similar functionalities. 

105. At least some of the asserted claims of the ’598 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 313 Pad as complying with the Qi Standard. In 

addition, Anker has indicated the Anker 313 Pad as comporting with the Qi Standard’s A11a power 

transmitter design. As such, the Anker 313 Pad, and all materially similar Anker products, infringe 

at least claims 1-3 and 5 of the ’598 Patent, literally and/or under the doctrine of equivalents.

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 30 of 51 PageID #: 30
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106. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, is 

an inductive power outlet for transmitting power to at least one inductive power receiver. For 

example, the Anker 313 Pad is a wireless charger that includes an inductive coil (or primary unit 

coil) for transmitting power wirelessly to power receiver in a compatible device (e.g., iPhone) that 

is operable to receive power wirelessly. See, e.g.,

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

107. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, 

includes at least one primary inductor wired to a power supply, where the primary inductor is for 

forming an inductive couple with at least one secondary inductive coil associated with the 

inductive power receiver. 

 

Id.

108. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, 

includes at least one driver configured to provide an oscillating voltage across said primary 

inductor. On information and belief, the Anker 313 Pad follows the Qi Specification’s A11a 

transmitter design. In accordance with this design, the Anker 313 Pad incorporates a driver, e.g., 

a full-bridge inverter, to drive the primary coil with an AC waveform oscillating at a high 

frequency.

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 31 of 51 PageID #: 31
32

109. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, 

includes a trigger sensor configured to detect a release signal indicating proximity of an inductive 

power receiver. For example, the Anker 313 Pad incorporates an electronic circuit operating as a 

trigger sensor for detecting whether an object is placed on or near the charging surface and to 

activate power transmission when a secondary device is detected. On information and belief, the 

Anker 313 is configured to detect whether the secondary side apparatus is present as opposed to a 

foreign object, in accordance with the Qi Standard.

110. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, 

includes a signal detector operable to detect instruction signals from said inductive power receiver 

concurrently with power transfer. For example, during a power transfer phase in which the Anker 

313 Pad transfers power to a secondary unit coupled with the primary coil, the Anker 313 Pad 

regulates the transmission of power to the secondary unit in response to a regulation signal (e.g. a 

Control Error Packet) received from the secondary unit concurrently with power transfer by 

modulation of the current in the primary coil.

111. Each of the ’598 Accused Products, including for example, the Anker 313 Pad, is 

configured to detect a release signal which triggers the inductive power outlet to generate an 

activation signal detectable by the inductive power receiver. For example, following a selection 

phase in which the Anker 313 Pad detects the presence of an object coupled with the primary coil, 

the Anker 313 Pad performs a digital ping operating as an activation signal to confirm the presence 

of a secondary unit by detecting the reception of a confirmation signal (e.g., a Signal Strength 

Packet) indicating that a secondary device is coupled with the primary coil.

112. The Anker 313 Pad includes a signal detector that is operable to detect an 

identification signal sent by the inductive power receiver to the inductive power outlet and to start 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 32 of 51 PageID #: 32
33

the inductive power outlet driving the primary inductor such that the inductive power receiver 

draws power therefrom for a limited time duration and to stop driving the oscillating voltage if no 

instruction signal is received during that limited time duration. For example, in accordance with 

the Qi Standard, during an identification and configuration phase, the Anker 313 Pad is configured 

to detect an identification signal received from the secondary unit. The Anker 313 Pad applies a 

power signal in accordance with its Operating Point as defined in the A11a reference design to 

allow the power receiver to draw power so as to communicate with the Anker 313 Pad concurrently 

with power transfer. The Anker 313 Pad maintains the initial power transfer for a limited time 

suitable to receive a Signal Strength Packet, and a sequence of packets expected during the 

identification and configuration phase, including at least an Identification Packet. The limited time 

duration, for example, is a timeout period after which the Anker 313 Pad removes the power signal.

The Anker 313 Pad stops driving the oscillating voltage if no Signal Strength Packet, Identification 

Packet, or first Control Error Packet is received within the timeout period.

113. The foregoing features and capabilities of the Anker 313 Pad, and Anker’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Anker’s direct infringement by satisfying every element of at least 

claims 1-3 and 5 of the ’598 Patent, under 35 U.S.C. § 271(a).

114. Defendant has indirectly infringed at least claims 1-3 and 5 of the ’598 Patent in 

this judicial district and elsewhere in the United States by, among other things, actively inducing 

the use, offering for sale, selling, or importation of at least the ’598 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’598 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 33 of 51 PageID #: 33
34

user guides, such as those for the Anker 313 Pad located at the following website: 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

Defendant is therefore liable for infringement of the ’598 Patent pursuant to 35 U.S.C. § 271(b). 

115. Defendant has indirectly infringed at least claims 1-3 and 5 of the ’598 Patent by, 

among other things, contributing to the direct infringement of others, including customers of 

the ’598 Accused Products by making, offering to sell, or selling, in the United States, or importing 

a component of a patented process, constituting a material part of the invention, knowing the same 

to be especially made or especially adapted for use in infringement of the ’598 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

116. For example, the ’598 Accused Products include at least one component to 

inductively transmit power to an inductive power receiver, and to drive a voltage to enable the 

power receiver to draw power therefrom and stop such driving if no instruction signal is received. 

This is a component of a patented machine, manufacture, or combination, or an apparatus for use 

in practicing a patented process. Furthermore, such component is a material part of the invention 

and upon information and belief is not a staple article or commodity of commerce suitable for 

substantial non-infringing use. Thus, Defendant is liable for infringement of the ’598 Patent 

pursuant to 35 U.S.C. § 271(c).

117. Defendant has been on notice of the ’598 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 1-3 and 5 of the ’598 Patent. 

118. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’598 Patent, which has been duly issued by the 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 34 of 51 PageID #: 34
35

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’598 Patent, and that the ’598 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’598 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’598 Patent. 

119. Powermat has been damaged by Defendant’s infringement of the ’598 Patent. 

COUNT 5 – INFRINGEMENT OF U.S. PATENT NO. 9,006,937

120. Powermat incorporates paragraphs 1-119 above by reference.

121. The ’937 Patent is directed to a system and method for controlling the wireless 

transmission of power over an inductive coil-to-coil coupling. For example, the ’937 Patent 

discloses an inductive power outlet that includes a primary inductive coil for forming an inductive 

couple with a secondary coil in a power receiver, a signal receiver for receiving feedback signals 

from the receiver, a driver for providing an oscillating driving voltage to the primary coil according 

to instruction signals received concurrent with inductive power transfer between the coils, where 

the driver maintains the same power level when a perpetuation signal is received.

122. Defendant has directly infringed one or more claims of the ’937 Patent in this 

district and elsewhere in Texas, including at least claims 8-12 literally and/or under the doctrine 

of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its wireless 

charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 737 MagGo 

Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic Wireless 

Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-in-1 Stand), 

Case 5:23-cv-00052 Document 1 Filed 06/05/23 Page 35 of 51 PageID #: 35
36

533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 Wireless 

Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 Magnetic 

Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic Battery 

(MagGo), 521 Magnetic Battery (PowerCore 5K), and 533 Wireless Power Bank (PowerCore 10K) 

(collectively, “the ’937 Accused Products”). Powermat reserves the right to discover and pursue 

any additional infringing devices that incorporate infringing functionalities. For the avoidance of 

doubt, the ’937 Accused Products are identified to describe the Defendant’s infringement and in 

no way limit the discovery and infringement allegations against Defendant concerning other 

devices that incorporate the same or reasonably similar functionalities. 

123. At least some of the asserted claims of the ’937 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 313 Pad as complying with the Qi Standard. In 

addition, Anker has indicated the Anker 313 Pad as comporting with the Qi Standard’s A11a power 

transmitter design. As such, the Anker 313 Pad, and all materially similar Anker products, infringe 

at least claims 8-12 of the ’937 Patent, literally and/or under the doctrine of equivalents.

124. Each of the ’937 Accused Products, including for example, the Anker 313 Pad, is

an inductive power outlet operable to transfer power to an electric load via at least one inductive 

power receiver. For example, the Anker 313 Pad is a wireless charger that includes an inductive 

coil (or primary unit coil) for transmitting power wirelessly to power receiver in a compatible 

device (e.g., iPhone) that is operable to receive power wirelessly. See 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy. The 

Anker 313 Pad therefore includes at least one primary inductive coil for forming an inductive 

couple with at least one secondary inductive coil (e.g., in an iPhone) associated with the at least 

one inductive power receiver.

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125. Each of the ’937 Accused Products, including for example, the Anker 313 Pad, 

includes a signal receiver for receiving feedback signals from the inductive power receiver. For 

example, on information and belief, the Anker 313 Pad incorporates one or more circuit 

components (e.g., capacitors, resistors, and diodes) and a controller to receive signals transmitted 

via modulation to the primary coil.

126. Additionally, on information and belief, the Anker 313 Pad incorporates a 

Communications & Control Unit, in accordance with the Qi A11a Reference Design, for receiving 

and decoding feedback signals from a power receiver. For example, on information and belief, as 

per the Qi Standard, the Anker 313 Pad is configured to confirm the presence of a secondary unit 

by detecting the reception of a confirmation signal.

127. Each of the ’937 Accused Products, including for example, the Anker 313 Pad, 

includes a driver operable to provide an oscillating driving voltage to the primary inductive coil 

according to instruction signals received concurrently with inductive power transfer between the 

primary and secondary inductive coils. For example, on information and belief, in accordance with 

Qi Reference Design A11a, the Anker 313 Pad incorporates a driver such as a full-bridge inverter 

to drive the primary coil with an AC waveform oscillating at a high frequency. Further in 

accordance with the Qi Standard, the Anker 313 Pad adjusts its operating power in accordance 

with instruction signals received via modulation. 

128. The driver in each of the ’937 Accused Products, including for example, the Anker 

313 Pad, is operable to continue driving the primary inductive coil at the same power level when 

a perpetuation signal is received. For example, on information and belief, as per the Qi Standard, 

the Anker 313 Pad is configured to maintain the same power level if the received Control Error 

Packet has a value of zero. Specifically, the Anker 313 Pad does not adjust its operating power if 

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it receives a zero value for the Control Error Packet because a Control Error Value of zero indicates 

that the actual Control Point of the power receiver is the desired Control Point.

129. The foregoing features and capabilities of the Anker 313 Pad, and Anker’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Anker’s direct infringement by satisfying every element of at least 

claims 8-12 of the ’937 Patent, under 35 U.S.C. § 271(a).

130. Defendant has indirectly infringed at least claims 8-12 of the ’937 Patent in this 

judicial district and elsewhere in the United States by, among other things, actively inducing the 

use, offering for sale, selling, or importation of at least the ’937 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’937 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

user guides, such as those for the Anker 313 Pad located at the following website: 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

Defendant is therefore liable for infringement of the ’937 Patent pursuant to 35 U.S.C. § 271(b). 

131. Defendant has indirectly infringed at least claims 8-12 of the ’937 Patent by, among 

other things, contributing to the direct infringement of others, including customers of the ’937 

Accused Products by making, offering to sell, or selling, in the United States, or importing a 

component of a patented process, constituting a material part of the invention, knowing the same 

to be especially made or especially adapted for use in infringement of the ’937 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

132. For example, the ’937 Accused Products include at least one component to control 

the wireless transmission of power. This is a component of a patented machine, manufacture, or 

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combination, or an apparatus for use in practicing a patented process. Furthermore, such 

component is a material part of the invention and upon information and belief is not a staple article 

or commodity of commerce suitable for substantial non-infringing use. Thus, Defendant is liable 

for infringement of the ’937 Patent pursuant to 35 U.S.C. § 271(c).

133. Defendant has been on notice of the ’937 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 8-12 of the ’937 Patent. 

134. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’937 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’937 Patent, and that the ’937 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’937 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’937 Patent. 

135. Powermat has been damaged by Defendant’s infringement of the ’937 Patent. 

COUNT 6 – INFRINGEMENT OF U.S. PATENT NO. 9,083,204

136. Powermat incorporates paragraphs 1-135 above by reference.

137. The ’204 Patent is directed to an inductive power transfer system in which power 

is controlled by adjusting transmission frequency. For example, the ’204 Patent discloses an 

inductive power outlet that includes a driver for producing a driving voltage that oscillates at a 

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non-resonant transmission frequency substantially different from the characteristic resonant 

frequency of the inductive couple, and for increasing or decreasing power by increasing or 

decreasing the non-resonant transmission frequency based on detected first and second signals.

138. Defendant has directly infringed one or more claims of the ’204 Patent in this 

district and elsewhere in Texas, including at least claims 1-5 and 8 literally and/or under the 

doctrine of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its 

wireless charging products, including at least the Anker 747 3-in-1 Cube with MagSafe, Anker 

737 MagGo Charger (3-in-1 Station), 613 Magnetic Wireless Charger (MagGo), 623 Magnetic 

Wireless Charger (MagGo), 633 Magnetic Wireless Charger (MagGo), 544 Wireless Charger (4-

in-1 Stand), 533 Magnetic Wireless Charger (3-in-1 Stand), 313 Wireless Charger (Stand), 315 

Wireless Charger (Pad), 313 Wireless Charger (Pad), 335 Wireless Charger (3-in-1 Station), 622 

Magnetic Battery (MagGo), 633 Magnetic Battery, 621 Magnetic Battery (MagGo), 622 Magnetic 

Battery (MagGo), 521 Magnetic Battery (PowerCore 5K), and 533 Wireless Power Bank 

(PowerCore 10K) (collectively, “the ’204 Accused Products”). Powermat reserves the right to 

discover and pursue any additional infringing devices that incorporate infringing functionalities. 

For the avoidance of doubt, the ’204 Accused Products are identified to describe the Defendant’s 

infringement and in no way limit the discovery and infringement allegations against Defendant 

concerning other devices that incorporate the same or reasonably similar functionalities. 

139. At least some of the asserted claims of the ’204 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 737 MagGo as complying with the Qi Standard. 

In addition, Anker has indicated the Anker 737 MagGo as comporting with the Qi Standard’s A11a 

power transmitter design. As such, the Anker 737 MagGo, and all materially similar Anker 

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products, infringe at least claims 1-5 and 8 of the ’204 Patent, literally and/or under the doctrine 

of equivalents.

140. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo,

is a wireless charger, and therefore operable to transfer power to an inductive power receiver as 

part of an inductive power system 

(https://www.anker.com/products/b2599?variant=42519665016982).

141. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

is a wireless charger, and therefore operates as an inductive power outlet to transfer power to an 

inductive power receiver as part of an inductive power system. On information and belief, the 

Anker 737 follows the Qi Standard’s recommended A11a transmitter design. In accordance with 

reference design A11a, the Anker 737 MagGo incorporates at least one primary coil wired to a 

power supply via a driver.

142. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

is configured to form an inductive couple having a characteristic resonant frequency with at least 

one secondary inductive coil wired to an electric load. The Anker 737 MagGo is Qi Standardcompliant. Thus, it has a characteristic frequency when coupled with a secondary device. On 

information and belief, the Anker 737 follows the recommended A11a transmitter design. In 

accordance with reference design A11a, the Anker 737 MagGo incorporates at least a 

characteristic resonant frequency. 

143. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

is configured to couple and transmit power to a secondary inductive coil associated with an 

inductive power receiver such as a phone, a watch, or wireless ear buds. The driver in the Anker 

737 MagGo is configured to provide a driving voltage across said primary inductive coil. On 

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information and belief, the Anker 737 MagGo follows the recommended A11a transmitter design. 

In accordance with reference design A11a, the Anker 737 MagGo incorporates a driver, e.g. an 

inverter that provides a driving voltage across the primary inductive coil.

144. The driver in each of the ’204 Accused Products, including for example, the Anker 

737 MagGo, is Qi Standard-compliant and configured to provide a driving voltage oscillating at a 

non-resonant transmission frequency substantially different from the characteristic resonant 

frequency of the inductive couple. The driving circuit (e.g., full-bridge inverter) has a switching 

unit configured and operable to provide an oscillating driving voltage at an operating frequency in 

the range 110 - 148 kHz. For example, the operating frequency is about 146 kHz during Digital 

Ping. 

145. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

incorporates a signal detector adapted to detect a first signal and a second signal. For example, the 

Anker 737 MagGo incorporates detection circuitry including for example a current sensing unit 

which in conjunction with the primary coil is adapted to detect signals like Control Error Packet 

received from a power receiver. In addition, the Anker 737 incorporates a Communications & 

Control Unit adapted to receive and decode messages e.g. Control Error Packets received from the 

power receiver and perform power control algorithms in response to the decoded messages.

146. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

is configured to provide less power by increasing said non-resonant transmission frequency by an 

incremental value when said first signal is detected by the detector. For example, a positive value 

of the Control Error Packet causes the Anker 737 MagGo to increase voltage / decrease 

transmission frequency. For example, the Anker 737 MagGo uses a lower operating frequency to 

transfer a higher amount of power. For example, the Anker 737 MagGo uses a PID algorithm to 

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determine an incremental value by which to increase the non-resonant operating frequency starting 

from an initial operating frequency, e.g. starting from 146 kHz.

147. Each of the ’204 Accused Products, including for example, the Anker 737 MagGo, 

is configured to provide more power by decreasing said non-resonant transmission frequency by 

an incremental value when said second signal is detected by the detector. For example a negative 

value of the Control Error Packet causes the Anker 737 MagGo to decrease voltage/increase 

transmission frequency. For example, the Anker 737 MagGo uses a higher operating frequency to 

transfer a lower amount of power. For example, the Anker 737 MagGo uses a PID algorithm to 

determine an incremental value by which to decrease the non-resonant operating frequency starting 

from an initial operating frequency, e.g. starting from 146 kHz.

148. The foregoing features and capabilities of the Anker 737 MagGo, and Anker’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Anker’s direct infringement by satisfying every element of at least 

claims 1-5 and 8 of the ’204 Patent, under 35 U.S.C. § 271(a).

149. Defendant has indirectly infringed at least claims 1-5 and 8 of the ’204 Patent in 

this judicial district and elsewhere in the United States by, among other things, actively inducing 

the use, offering for sale, selling, or importation of at least the ’204 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’204 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

user guides, such as those for the Anker 737 MagGo located at the following website: 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

Defendant is therefore liable for infringement of the ’204 Patent pursuant to 35 U.S.C. § 271(b). 

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150. Defendant has indirectly infringed at least claims 1-5 and 8 of the ’204 Patent by, 

among other things, contributing to the direct infringement of others, including customers of 

the ’204 Accused Products by making, offering to sell, or selling, in the United States, or importing 

a component of a patented process, constituting a material part of the invention, knowing the same 

to be especially made or especially adapted for use in infringement of the ’204 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

151. For example, the ’204 Accused Products include at least one component to 

magnetically couple with a pinless power plug and inductively transmit power thereto. This is a 

component of a patented machine, manufacture, or combination, or an apparatus for use in 

practicing a patented process. Furthermore, such component is a material part of the invention and 

upon information and belief is not a staple article or commodity of commerce suitable for 

substantial non-infringing use. Thus, Defendant is liable for infringement of the ’204 Patent 

pursuant to 35 U.S.C. § 271(c).

152. Defendant has been on notice of the ’204 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 1-5 and 8 of the ’204 Patent. 

153. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’204 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’204 Patent, and that the ’204 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

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of the ’204 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’204 Patent. 

154. Powermat has been damaged by Defendant’s infringement of the ’204 Patent. 

COUNT 7 – INFRINGEMENT OF U.S. PATENT NO. 8,049,370

155. Powermat incorporates paragraphs 1-154 above by reference.

156. The ’370 Patent is directed to an inductive power transmission platform containing 

multiple inductive coils. For example, the ’370 Patent discloses an inductive power transmission 

platform that includes at least one cluster of primary inductors for coupling with a secondary 

inductor, a common driver connected to each primary inductor in the cluster via an individual 

power switch, where the power switch is operable to disconnect the primary inductor from the 

common driver only after the driver is deactivated, such that no current passes through the switch 

prior to the switch being opened.

157. Defendant has directly infringed one or more claims of the ’370 Patent in this 

district and elsewhere in Texas, including at least claims 1, 7, 8, 11 literally and/or under the 

doctrine of equivalents, by or through its sale, offer for sale, manufacture, use, or import of its 

wireless charging products, including at least the 544 Wireless Charger (4-in-1 Stand), 533 

Wireless Charger (3-in-1 Stand), 335 Wireless Charger (3-in-1 Station), 313 Wireless Charger 

(Stand), and PowerWave 3-in-1 Station with Watch Charging Holder (collectively, “the ’370

Accused Products”). Powermat reserves the right to discover and pursue any additional infringing 

devices that incorporate infringing functionalities. For the avoidance of doubt, the ’370 Accused 

Products are identified to describe the Defendant’s infringement and in no way limit the discovery 

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and infringement allegations against Defendant concerning other devices that incorporate the same 

or reasonably similar functionalities. 

158. At least some of the asserted claims of the ’370 Patent are essential to practicing 

the Qi Standard. Anker has indicated the Anker 313 Wireless Charger (Stand) (“Anker 313 Stand”) 

as complying with the Qi Standard. In addition, Anker has indicated the Anker 313 Stand as 

comporting with the Qi Standard’s A28a power transmitter design. As such, the Anker 313 Stand, 

and all materially similar Anker products, infringe at least claims 1, 7, 8, and 11 of the ’370 Patent, 

literally and/or under the doctrine of equivalents.

159. Each of the Accused ’370 Products, including for example, the Anker 313 Stand,

is an inductive power transmission platform. See, e.g., Anker’s website and technical specifications 

(https://www.anker.com/products/a2524?variant=37438027137174&ref=collectionBuy). For 

example, the Anker 313 Stand is a wireless charger for transmitting wireless power to e.g., a mobile 

device (i.e., iPhone).

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https://www.anker.com/products/a2524?variant=37438027137174&ref=collectionBuy. 

160. Each of the Accused ’370 Products, including for example, the Anker 313 Stand, 

includes at least one cluster of primary inductors configured to couple with at least one secondary 

inductor wired to an electrical load. For example, the Anker 313 Stand includes at least one cluster 

of primary inductors configured to couple with at least one secondary inductor wired to an 

electrical load (e.g., a secondary inductor wired to a battery within an iPhone).

.

https://www.anker.com/products/a2524?variant=37438027137174&ref=collectionBuy.

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161. Each of the Accused ’370 Products, including for example, the Anker 313 Stand, 

also includes a common driver connected to each primary inductor of the cluster by way of an 

individual power switch. For example, on information and belief, the Anker 313 Stand is Qicompliant and follows the Qi Standard’s recommended A28a transmitter design. In accordance 

with this design, the Anker 313 Stand incorporates a driver (e.g., a full-bridge inverter) to drive 

the primary coils with an AC waveform oscillating at a high frequency. This common driver 

provides an oscillating voltage to at least one cluster of primary inductors.

162. Each of the Accused ’370 Products, including for example, the Anker 313 Stand, 

also includes a power switch that is operable to disconnect the primary inductor from the common 

driver only after the driver is deactivated, such that no current passes through the switch prior to 

the switch being opened. For example, the Anker 313 Stand performs at least one method to 

determine if a foreign object is detected and to terminate the power transfer to a mobile device if 

a foreign object is present. 

163. The foregoing features and capabilities of the ’370 Accused Products, and Anker’s 

description and/or demonstration thereof, including in user manuals and advertising, and in view 

of the Qi Standard, reflect Anker’s direct infringement by satisfying every element of at least 

claims 1, 7, 8, 11 of the ’370 Patent, under 35 U.S.C. § 271(a).

164. Defendant has indirectly infringed at least claims 1, 7, 8, 11 of the ’370 Patent in 

this judicial district and elsewhere in the United States by, among other things, actively inducing 

the use, offering for sale, selling, or importation of at least the ’370 Accused Products. Defendant’s 

customers who purchase devices and components thereof and operate such devices and 

components in accordance with Defendant’s instructions directly infringe one or more claims of 

the ’370 Patent in violation of 35 U.S.C. § 271. Defendant instructs its customers through at least 

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49

user guides, such as those for the Anker 313 Stand located at the following website: 

https://www.anker.com/products/a2503?variant=39295736283286&ref=collectionBuy.

Defendant is therefore liable for infringement of the ’370 Patent pursuant to 35 U.S.C. § 271(b). 

165. Defendant has indirectly infringed at least claims 1, 7, 8, 11 of the ’370 Patent by, 

among other things, contributing to the direct infringement of others, including customers of 

the ’370 Accused Products by making, offering to sell, or selling, in the United States, or importing 

a component of a patented process, constituting a material part of the invention, knowing the same 

to be especially made or especially adapted for use in infringement of the ’370 Patent, and not a 

staple article or commodity of commerce suitable for substantial non-infringing use.

166. For example, the ’370 Accused Products include at least one component to 

magnetically couple with a pinless power plug and inductively transmit power thereto. This is a 

component of a patented machine, manufacture, or combination, or an apparatus for use in 

practicing a patented process. Furthermore, such component is a material part of the invention and 

upon information and belief is not a staple article or commodity of commerce suitable for 

substantial non-infringing use. Thus, Defendant is liable for infringement of the ’370 Patent 

pursuant to 35 U.S.C. § 271(c).

167. Defendant has been on notice of the ’370 Patent since at least November 11, 2018. 

By the time of trial, Defendant will thus have known and intended (since receiving such notice), 

that its continued actions would actively induce and contribute to actual infringement of at least 

claims 1, 7, 8, 11 of the ’370 Patent. 

168. Defendant undertook and continues its infringing actions despite an objectively 

high likelihood that such activities infringed the ’370 Patent, which has been duly issued by the 

USPTO, and is presumed valid. For example, since at least November 11, 2018, Defendant has 

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been aware of an objectively high likelihood that its actions constituted and continue to constitute 

infringement of the ’370 Patent, and that the ’370 Patent is valid. On information and belief, 

Defendant could not reasonably, subjectively believe that its actions do not constitute infringement 

of the ’370 Patent, particularly in light of the standard compliance, nor could it reasonably, 

subjectively believe that the patent is invalid. Despite that knowledge and subjective belief, and 

the objectively high likelihood that its actions constitute infringement, Defendant has continued 

its infringing activities. As such, Defendant willfully infringes the ’370 Patent. 

169. Powermat has been damaged by Defendant’s infringement of the ’370 Patent. 

DAMAGES

As a result of Defendants’ acts of infringement, Powermat has suffered actual and 

consequential damages. To the fullest extent permitted by law, Powermat seeks recovery of 

damages at least in the form of reasonable royalties.

JURY DEMAND

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands a trial by 

jury on all issues triable as such.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment for itself and against Defendant as follows:

A. An adjudication that Defendant has infringed U.S. Patent Nos. 8,283,812; 8,626,461;

9,048,696; 8,981,598; 9,006,937; 9,083,204; and 8,049,370.

B. An award of damages to be paid by Defendant adequate to compensate Plaintiff for 

Defendant’s past infringement of the Asserted Patents, and any continuing or future 

infringement through the date such judgment is entered, including interest, costs, expenses 

and an accounting of all infringing acts including, but not limited to, those acts not 

presented at trial;

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C. A determination of a per-unit RAND royalty rate to be applied to all acts of infringement, 

including after the date judgment is entered; 

D. A declaration that this case is exceptional under 35 U.S.C. § 285, and an award of Plaintiff’s

reasonable attorneys’ fees; and

E. An award to Plaintiff of such further relief at law or in equity as the Court deems just and 

proper.

Dated: June 5, 2023

Of counsel:

Jamie B. Beaber

Kfir B. Levy

William J. Barrow

Baldine Paul

MAYER BROWN LLP

1999 K Street, N.W.

Washington D.C. 20006

(202) 263-3000

jbeaber@mayerbrown.com

klevy@mayerbrown.com

wbarrow@mayerbrown.com

bpaul@mayerbrown.com

Respectfully submitted,

/s/Geoffrey Culbertson

Geoffrey Culbertson

Tx. Bar No. 24045732

Kelly B. Tidwell

Tx. Bar No. 20020580

PATTON, TIDWELL & 

CULBERTSON, LLP

2800 Texas Boulevard (75503)

P.O. Box 5398

Texarkana, TX 75505-5398

(P) 903-792-7080

(F) 903-792-8233

gpc@texarkanalaw.com

kbt@texarkanalaw.com

Counsel for Plaintiff Powermat Technologies 

Ltd.

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