Long Hua, a Taiwanese company that develops and manufactures electronic components for computers, smartphones, and the like, accuses Michigan company A123 of infringing two patents, U.S. 7,803,484 and 8,034,480, relating to lithium ion secondary (rechargeable) batteries. The patents specifically relate to the rates of discharge at low and high power demands. Long Hua asserts that A123 battery cells that are incorporated into the ALM® 12V7 batteries of NEC Energy Solutions and in Jaguar and Land Rover batteries. Despite asserting knowledge of the patents only to the date of filing of the complaint, Long Hua asserts willfulness. Personal jurisdiction over A123 is based on its having two places of business in the state, one each on Waltham and Hopkinton. The case is before Judge Stearns.