DCT

8:19-cv-01902

Nagui Mankaruse v. Intel Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 8:19-cv-01902, C.D. Cal., 11/22/2019
  • Venue Allegations: Venue is based on Defendants' residence in California and the commission of infringing acts and business operations within the judicial district.
  • Core Dispute: Plaintiff alleges that Defendants' CPU coolers, which are required for the operation of high-power processors, infringe a patent related to modular, heat-pipe-based cooling technology.
  • Technical Context: The technology addresses thermal management for high-power electronic components, a critical engineering challenge for maintaining performance and reliability in modern computer systems.
  • Key Procedural History: The complaint details a lengthy history between the parties, including a 2004 non-disclosure agreement, technology disclosures in 2004 and 2007, and a prior state court action for trade secret misappropriation filed by the Plaintiff against Defendants, which was dismissed on statute of limitations grounds. It also references a 2010 patent infringement lawsuit involving the same patent, filed by Plaintiff's predecessor-in-interest against third-party resellers of products containing Intel components.

Case Timeline

Date Event
1999-06-29 U.S. Patent 6,411,512 Priority Date
2002-06-25 U.S. Patent 6,411,512 Issue Date
2004-06-08 Corporate Non-Disclosure Agreement (CNDA) signed between Plaintiff and Intel
2010-04-01 Prior patent action (ATI v. Resellers) filed involving the '512 Patent
2011-06-01 Prior patent action (ATI v. Resellers) dismissed
2012-04-01 Plaintiff allegedly contacts Intel regarding infringement of the '512 Patent
2015-02-03 Plaintiff purchases an allegedly infringing Intel CPU cooler
2016-10-31 Plaintiff files a related state court action against Defendants
2019-11-22 Amended Complaint Filing Date

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

U.S. Patent No. 6,411,512 - High Performance Cold Plate

Issued June 25, 2002

The Invention Explained

  • Problem Addressed: The patent's background describes conventional liquid-cooling systems ("cold plates") for electronics as being costly and complex to manufacture, often involving intricate machining and vacuum brazing processes that limit production throughput and reliability (U.S. Patent No. 6,411,512, col. 1:43-2:24). These systems struggled to meet the cooling demands of increasingly high-power electronic components (U.S. Patent No. 6,411,512, col. 1:22-29).
  • The Patented Solution: The invention proposes a modular and cost-effective cold plate built from three primary components: a thermally conductive base to contact the heat source, a "heat pipe thermal plane" or individual heat pipes to spread heat efficiently, and one or two compact heat exchangers to transfer the heat to a cooling fluid. The patent teaches that these three pre-manufactured modules are bonded together to form the final assembly, simplifying production and reducing cost ('512 Patent, Abstract; col. 2:32-49; FIG. 6).
  • Technical Importance: This modular design using high-efficiency heat pipes was intended to provide a scalable, reliable, and more manufacturable solution for thermal management as processor power dissipation continued to rise ('512 Patent, col. 2:16-24).

Key Claims at a Glance

  • The complaint asserts infringement of claims 1 through 10 (Compl. ¶41). The independent claims are 1, 5, and 6.
  • Independent Claim 1: A cold plate assembly comprising (1) a heat pipe assembly with at least one heat pipe for circulating a first fluid to carry heat from a circuit board, and (2) at least one compact heat exchanger thermally connected to the heat pipe assembly for circulating a second fluid to carry heat away from the heat pipe assembly.
  • Independent Claim 5: A cold plate assembly comprising (1) a thermally conductive base with recesses for electrical components, (2) a heat pipe assembly constructed as a thermal plane connected to the base, and (3) a compact heat exchanger with a defined inlet and outlet for a second fluid.
  • Independent Claim 6: A combination of a circuit board assembly with electronic components and a cold plate assembly, where the cold plate assembly includes (1) a heat pipe assembly thermally connected to the electronic components, and (2) a compact heat exchanger connected to the heat pipe assembly.

Note: The complaint also alleges infringement of "CA Patent 2,389,458," the Canadian counterpart to the '512 Patent, and often refers to them jointly (e.g., "'512 & '458 claim 1'") (Compl. ¶14). The complaint also contains an apparent scrivener's error, referencing "US PATENT 2,389,458," which is an unrelated 1945 patent for a "Controlling Relay" (Compl. p. 1).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products as "Delta CPU Cooler" and other CPU coolers manufactured, sold, or used by Defendants, including those sold with an "Intel Logo" (Compl. ¶¶10, 23, 28). These are allegedly required for the proper functioning of Intel's high-speed CPUs that dissipate more than 25 watts of heat (Compl. ¶41).

Functionality and Market Context

  • The accused coolers are alleged to be two-phase cooling devices that use heat pipes to transfer thermal energy from a CPU to a heat exchanger, from which it is dissipated (Compl. ¶¶30, 58). The complaint alleges that Intel forces computer manufacturers and end-users to use these coolers for their high-speed CPUs, thereby creating a market for the allegedly infringing products (Compl. ¶¶10, 26). The complaint includes several photos of an Intel-branded stock CPU cooler mounted on a motherboard as an exemplary infringing product (Compl. Attachment 1, Fig. 3, p. 45). This visual evidence depicts a cooler with a fan mounted atop a fin stack, with copper heat pipes emerging from the base.

IV. Analysis of Infringement Allegations

The complaint provides a comparative analysis table mapping claim elements to the accused product features (Compl. ¶14).

U.S. Patent No. 6,411,512 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A cold plate assembly for cooling a circuit board assembly... The accused product is identified as a "Cold Plate Assembly (CPU Cooler)" (Compl. p. 8, Table 1). ¶14 col. 1:9-14
a heat pipe assembly including at least one heat pipe adapted for internally circulating a first thermally conductive fluid for carrying heat dissipated from electrical components of a circuit board; The "Intel CPU Cooler, of at least one heat pipe with internal thermally conductive fluid," is alleged to meet this limitation. The heat pipe assembly is described as being "thermally engaged to electronic components with higher heat dissipation needed assisted cooling (CPU)" (Compl. p. 8, Table 1). ¶14 col. 4:30-35
and at least one compact heat exchanger engaging and thermally connected to said heat pipe assembly, said heat exchanger adapted for internally circulating a second thermally conductive fluid and for carrying heat dissipated from said heat pipe assembly. The accused product has "at least one heat exchanger thermally connected to heat pipe assembly." This is further described as a "Heat Exchanger... thermally engaged to said Heat Pipe Assembly" which includes "passing thermally conductive fluid through its extended surface" (Compl. p. 8, Table 1). ¶14 col. 4:56-62

Identified Points of Contention

  • Scope Questions: The complaint's infringement theory raises the question of whether a standard air-cooled heat sink with a fan falls within the scope of a "compact heat exchanger" that "internally circulat[es] a second thermally conductive fluid." A court may need to determine if ambient air blown by a fan constitutes an "internally circulating" fluid as required by the claim, or if the claim is limited to systems with enclosed fluid paths, as suggested by the patent's discussion of "inlet" and "outlet" quick disconnects (Compl. p. 8, Table 1; '512 Patent, FIG. 1).
  • Technical Questions: A primary technical question is whether the accused Intel coolers, depicted as integrated units (Compl. Attachment 1, p. 45), are constructed from the three distinct, bonded "modules" (base, heat pipe assembly, heat exchanger) that form a central part of the patented solution ('512 Patent, col. 2:35-49). The complaint does not provide specific evidence that the accused coolers are assembled in this modular fashion.

V. Key Claim Terms for Construction

The Term: "compact heat exchanger"

  • Context and Importance: The definition of this term is central to the infringement analysis. The dispute may turn on whether a fin-stack-and-fan assembly, which uses ambient air as a coolant, qualifies as a "compact heat exchanger" that "internally circulat[es]" a fluid. Practitioners may focus on this term because its construction could either limit the claims to enclosed liquid-cooling systems or broaden them to cover common air coolers.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to cooling via a "liquid or air cooled cold wall" ('512 Patent, col. 3:13-14) and describes heat exchangers of "laminated or finned construction" ('512 Patent, col. 4:60-61), which could be read to encompass air-cooled fin stacks.
    • Evidence for a Narrower Interpretation: Dependent claim 3 and independent claim 5 recite an "inlet for receiving" and an "outlet for emitting" the second fluid. This language, along with figures showing "quick disconnect" ports (FIG. 1, items 4 & 5), may support a narrower construction requiring a contained fluid circuit, more typical of liquid cooling.

The Term: "heat pipe assembly"

  • Context and Importance: This term's construction will determine if the claims require a specific structure beyond simply having heat pipes. The patent emphasizes a "modular" approach, and the "heat pipe assembly" is described as one of three core modules ('512 Patent, col. 2:35-42).
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The language of claim 1 is broad, requiring only "a heat pipe assembly including at least one heat pipe," which could arguably cover any cooler containing one or more heat pipes.
    • Evidence for a Narrower Interpretation: The specification describes a preferred embodiment of the heat pipe assembly as a "thermal plane utilizing embedded copper/water heat pipes sandwiched between two outer aluminum plates" ('512 Patent, col. 4:30-33). This could support a narrower definition requiring a specific laminated structure, as distinct from a solid base into which heat pipes are merely pressed.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Intel induces infringement by requiring manufacturers and users of its high-power CPUs to use the accused coolers (Compl. ¶¶10, 26). Knowledge is alleged based on a 2004 CNDA and direct technology disclosures made by Plaintiff to Intel in 2004 and 2007 (Compl. ¶¶42, 65.b).
  • Willful Infringement: Willfulness allegations are predicated on pre-suit knowledge stemming from the same 2004 and 2007 interactions (Compl. ¶26(c)). The complaint alleges that Intel knew of the patented technology but proceeded with infringing conduct, and it explicitly invokes the doctrine of "willful blindness" (Compl. ¶13.ii, ¶48).

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

  1. A threshold issue will be one of timeliness: can the Plaintiff's claims survive a motion to dismiss based on the statute of limitations, given the complaint's acknowledgment of a prior 2010 lawsuit on the same patent and communications with Intel regarding infringement in 2012?
  2. A core issue will be one of claim construction: can the term "compact heat exchanger" with its "internally circulating" fluid limitation be construed broadly enough to cover the fan-and-fin-stack design of the accused air coolers, or do the patent's specification and prosecution history limit it to enclosed, likely liquid-based, systems?
  3. A key evidentiary question will be one of structural infringement: does the accused Intel CPU cooler embody the distinct three-part modular assembly (base, heat pipe assembly, heat exchanger) that is a foundational concept of the '512 patent, or is its integrated construction fundamentally different from what was claimed?