This case was last updated from PACER on 10/16/2021 at 10:27:33 (UTC).

Charge Fusion Technologies, LLC v. Tesla, Inc.

Case Summary

On October 15, 2021, Charge Fusion Technologies, LLC (“Charge Fusion” or “Plaintiff”), represented by Bradley David Liddle of Carter Arnett PLLC, filed an intellectual property lawsuit against Tesla, Incorporated (“Tesla” or “Defendant”), seeking preliminary and permanent injunctive relief and damages along with prejudgement and post-judgement interests among other relief for the alleged infringement of the United States Patents owned by Plaintiff. This case was filed in the United States District Court in the Western District of Texas. 


Plaintiff filed this complaint for the alleged infringement of the United States Patent No. 9,853,488 (the “’488 Patent”), United States Patent No. 10,819,135 (the “’135 Patent”) and United States Patent No. 10,998,753 (the “’753 Patent”) (collectively, “Patents-in-suit”) owned by Plaintiff.


In the complaint, Plaintiff alleged that, “Defendant, individually and collectively as a common business enterprise and without authorization or license from Charge Fusion, has been and is directly infringing the ’488 Patent, either literally or equivalently, as infringement is defined by 35 U.S.C. § 271, including through making, using, importing, selling, and offering for sale electric cars and charging stations that infringe one or more claims of the ’488 Patent. Tesla, individually and collectively as a common business enterprise, develops, designs, manufactures, sells, and distributes electric cars and charging stations that infringe one or more claims of the ’488 Patent.”


Similar allegations with respect to direct infringement have been made by Plaintiff with reference to the infringement of other Patents-in-suit. 


Plaintiff further alleged that, “Tesla has induced and are knowingly inducing their dealers, customers, and end-users to directly infringe the claims of the ’488 Patent, with the specific intent to induce acts constituting infringement, and knowing that the induced acts constitute patent infringement, either literally or equivalently.”


Plaintiff also alleged that, “Tesla has knowingly contributed to direct infringement by their customers by having imported, sold, and offered for sale, and knowingly importing, selling, and offering to sell within the United States products covered by the claims of ’488 Patent, including, but not limited to, the Accused Tesla Cars and the associated charging stations which are not suitable for substantial non-infringing use and which are especially made or especially adapted for use by its customers in an infringement of the asserted patent.”


There are three claims for relief laid down by Plaintiff, one for the infringement of each of the Patents-in-suit.

In the prayer for relief, Plaintiff has requested the court for preliminary and permanent injunctive relief and declaratory relief along with an award for damages adequate to compensate Charge Fusion for the patent infringement that has occurred, together with prejudgment and post-judgment interest and costs, and an ongoing royalty for continued infringement, award reasonable attorneys’ fees and any other relief the court deems just and proper.


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Case Details Parties Documents Dockets


Case Details

  • Case Number:


  • Filing Date:


  • Case Status:

    Pending - Other Pending

  • Case Type:

    Intellectual Property - Patent


Party Details


Charge Fusion Technologies, LLC


Tesla, Inc.

Attorney/Law Firm Details

Plaintiff Attorney

Bradley David Liddle

Attorney at Carter Arnett PLLC

8150 N Central Expressway, Suite 500

Dallas, TX 75206


Court Documents


1 #1

Exhibit A

1 #2

Exhibit B

1 #3

Exhibit C



Docket Entries

  • 10/15/2021
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  • Docket(#2) JS44 (Civil Cover Sheet) submitted by Charge Fusion Technologies, LLC. (Liddle, Bradley) (Entered: 10/15/2021)

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  • 10/15/2021
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  • Docket(#1) COMPLAINT for Patent Infringement ( Filing fee $ 402 receipt number 0542-15341454). No Summons requested at this time, filed by Charge Fusion Technologies, LLC. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)(Liddle, Bradley) (Entered: 10/15/2021)

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