In Black Oak Group Inc. d/b/a Carmet Scientific v. JOLT Charge, Inc., No. 3:26-cv-10576 (N.D. Cal. filed Sep. 16, 2026), Carmet alleges federal jurisdiction under 28 U.S.C. §§ 1331 and 1338(a) after JOLT alleged infringement under 35 U.S.C. § 271(a) and threatened damages, enhancement, and attorneys' fees.

The commercial sequence

Carmet says that on December 5, 2025, it bought Volta charging stations, BTC charging components, and related equipment from Equilon Enterprises LLC d/b/a Shell Oil Products US under a purchase and sale agreement. After quantity adjustments, Carmet received about 771 Volta stations and 888 BTC products. Separately, JOLT announced a deal to acquire Volta-related assets, including patent rights, from Shell-related entities, with closing conditions and a later public statement that the IP transfer became effective January 1, 2026.

What JOLT asserted

According to the complaint, in June and July 2026 letters, JOLT's counsel identified specific accused articles and patents, demanded that Carmet pause third-party sales, and provided claim charts focused on design patents. Carmet asked Shell for its view. Shell's counsel wrote that Shell sold the equipment to Carmet before transferring IP to JOLT on January 1, 2026, and that Shell's view is that JOLT cannot prohibit Carmet from marketing or selling that specific equipment.

Patents JOLT identified

The complaint seeks declaratory relief only as to issued U.S. patents JOLT identified in its June 10, June 23, and July 7, 2026 communications: U.S. Patents 11,731,526 and 12,054,066; design patents including D844,559, D876,342 through D876,346, D883,199, D893,414, D962,159, D962,856, D967,011, D967,012, D971,830, D1,005,937, D1,005,938, D1,008,950, D1,051,045, D1,066,242, D1,068,646, D1,081,546, and D1,092,377; and reissues RE48,500, RE48,837, and RE49,540.

What Carmet wants

Carmet asks for a judgment that, if Shell's sale of an accused article was authorized by the then-holder of the relevant patent rights, those rights were exhausted as to that article and stay exhausted after later assignment to JOLT. Carmet does not seek a declaration that it may manufacture or reconstruct new patented articles from separate components. It seeks declaratory and other non-monetary relief, not damages.

Practice pointers

  • Identify who owned the relevant patent rights and who authorized the sale of the specific equipment.
  • Distinguish limits on a licensee's authority to sell from contractual restrictions on use or resale after an authorized sale. In its 2017 decision cited below, the Supreme Court held that an authorized sale exhausts patent rights in the item even when the seller imposes post-sale restrictions; contract remedies are a separate question.
  • Compare the sale and assignment documents with the specific articles at issue. A claim chart does not resolve whether an earlier authorized sale exhausted patent rights in those articles.

What to watch next

Watch JOLT's answer or motion practice on jurisdiction, ownership, and whether Shell's December 2025 sale was authorized. Also watch whether related Volta/JOLT patent enforcement spreads beyond this reseller dispute.