DCT

3:17-cv-04691

NHK Spring Co Ltd v. Intri Plex Tech Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:17-cv-04691, N.D. Cal., 08/14/2017
  • Venue Allegations: Venue is alleged based on certain defendants being incorporated in, having a regular place of business in, or committing alleged acts of infringement within the Northern District of California.
  • Core Dispute: Plaintiff alleges that Defendants' base plates for hard disk drive suspensions infringe a patent related to improving the mechanical stability and vibrational characteristics of the suspension assembly.
  • Technical Context: The technology concerns the precise mounting of read/write head suspensions in hard disk drives (HDDs), where minimizing vibration is critical to achieving high data density and operational reliability.
  • Key Procedural History: The complaint alleges that Defendants have had actual knowledge of the patent-in-suit since at least August 2, 2016, based on a patent list Plaintiff sent to them, which may be relevant to the allegations of willful infringement.

Case Timeline

Date Event
2008-04-21 '415 Patent Priority Date
2012-01-10 U.S. Patent No. 8,094,415 Issued
2016-08-02 Alleged date of Defendants' knowledge of the '415 patent
2017-08-14 Complaint Filing Date

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

U.S. Patent No. 8,094,415 - "Disk Drive Suspension"

The Invention Explained

  • Problem Addressed: The patent's background section describes how, in conventional hard disk drives, minor warping or distortion of a suspension's base plate can cause it to unstably contact the actuator arm to which it is mounted, leading to undesirable vibrations that reduce performance ('415 Patent, col. 1:49-57).
  • The Patented Solution: The invention proposes a base plate design featuring a central mounting boss and multiple small, distinct "projections" on its mounting surface. These projections are designed to create a stable, multi-point contact with the actuator arm, ensuring the base plate is "steadily fixed" even if the larger flat surfaces are not perfectly aligned, thereby improving the assembly's vibrational characteristics ('415 Patent, Abstract; col. 2:1-17). Figure 5 illustrates how these projections (e.g., 72) are designed to contact the suspension support portion (50) of the actuator arm ('415 Patent, Fig. 5).
  • Technical Importance: This approach addresses the need for extremely high mechanical precision in HDD assemblies, where stable positioning of the read/write head is essential for reliable data access at increasing storage densities ('415 Patent, col. 1:36-41).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 (Compl. ¶26).
  • The essential elements of independent Claim 1 include:
    • A disk drive suspension comprising a base plate, a load beam, and a flexure with a slider.
    • The base plate itself includes a mounting surface, a boss portion for insertion into a hole in an actuator arm, a "first region" closer to the slider, and a "second region" more remote from the slider.
    • A "pair of first projections" is located within the first region, and a "pair of second projections" is located within the second region, with both pairs projecting toward the actuator arm's suspension support portion.
    • The assembly is configured such that when the boss portion is fixed into the actuator arm, the projections make contact with the suspension support portion.

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "base plates for disk drive suspensions" manufactured and supplied by the Defendants (Compl. ¶¶ 20-21). The complaint identifies a specific end-product incorporating these components: the Western Digital "WD30EZRZ 3TB SATA 6.0Gb/s 64MB 3.5" HDD Caviar" (the "WD product") (Compl. ¶24).

Functionality and Market Context

The accused base plates are components fixed to the actuator arm within HDD products to hold the read/write head assembly (Compl. ¶27). The complaint alleges the Defendants advertise these components as enabling the magnetic recording head to be "reliably attach[ed]... with an attitude and position for optimum assembly performance" (Compl. ¶33). A graphic included in the complaint, allegedly from a Defendant's marketing materials, depicts the multi-stage manufacturing process for an "HDD Swage Mount," including steps like "PRECISION FORMING" and "DEBURR & POLISH" (Compl. p. 7).

IV. Analysis of Infringement Allegations

'415 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a base plate fixed to a suspension support portion of an actuator arm of a disk drive; a load beam attached to the base plate; and a flexure located along the load beam and provided with a slider on a distal end portion thereof... The accused base plate is allegedly fixed to an actuator arm's suspension support portion and attached to a load beam and flexure with a slider in end-products such as the WD product. ¶27 col. 3:20-28
the base plate including a mounting surface opposed to the suspension support portion, a boss portion which is inserted into a hole in the suspension support portion... The accused base plate is alleged to include a mounting surface facing the actuator arm and a boss portion that is inserted into a hole in the suspension support portion. ¶28 col. 3:47-52
a first region situated on a side of the mounting surface closer to the slider with respect to a center of the boss portion, a second region situated on a side of the mounting surface more remote from the slider... The accused base plate allegedly has a first region on the side of the mounting surface closer to the slider and a second region on the side farther from the slider. ¶29 col. 3:62-65
a pair of first projections formed individually on one and the other transverse sides... of the mounting surface within the first region... and a pair of second projections formed individually on one and the other transverse sides... of the mounting surface within the second region... The accused base plate is alleged to have a pair of first areas that form projections on two corners of a first region, and a pair of second areas that form projections on two corners of a second region. ¶29 col. 4:7-21
...projecting toward the suspension support portion... The plurality of alleged projection areas on the accused base plate are said to "project towards the suspension support portion." ¶30 col. 5:29-37
the boss portion being fixed to the actuator arm in such a manner that the boss portion is inserted into the hole of the actuator arm and that the projections are in contact with the suspension support portion. In the infringing HDD products, the alleged projection areas on the base plate "contact the suspension support portion when the boss portion is inserted into a hole of, and fixed to, the actuator arm." ¶31 col. 4:40-51

Identified Points of Contention

  • Technical Question: A central factual question is whether the accused base plates physically embody the structures recited in the claims. The complaint alleges the existence of "projections" (Compl. ¶29), but the case will depend on evidentiary findings regarding the actual topography of the accused components and whether any raised features function as claimed.
  • Scope Questions: The dispute may center on the definition of "projections." For instance, does the term, as used in the patent, require a specific method of formation (such as the "coining" described in the specification at col. 4:29-31), a minimum height, or a particular shape, or does it more broadly cover any set of raised contact points that provide a stabilizing function?

V. Key Claim Terms for Construction

  • The Term: "projections"
  • Context and Importance: This term is the central feature of the asserted independent claim, representing the purported point of novelty over the prior art. The outcome of the infringement analysis will heavily depend on how this term is construed. Practitioners may focus on this term because it distinguishes the patented solution from a simple flat mounting surface.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 itself describes the elements as "projections formed individually... and projecting toward the suspension support portion" ('415 Patent, col. 5:29-37). The claim language does not specify a method of formation, material, or exact dimensions, which may support a construction not limited to the specific examples in the specification.
    • Evidence for a Narrower Interpretation: The specification provides a detailed embodiment where the projections are formed by "coining" ('415 Patent, col. 4:29-31) and have an example height of 5 µm ('415 Patent, col. 4:24-25). A party could argue that these specifics from the preferred embodiment should inform and limit the scope of the term "projections."

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement, stating that Defendants supply the base plates with knowledge of the '415 patent and the specific intent that their customers will incorporate them into infringing HDDs (Compl. ¶¶ 32-33). This intent is allegedly evidenced by Defendants' own advertising, which promotes the precise performance of their base plates (Compl. ¶33). The complaint also pleads contributory infringement, alleging the base plates are especially made for this infringing use and are not staple articles of commerce suitable for substantial non-infringing uses (Compl. ¶34).

Willful Infringement

Willfulness is alleged based on Defendants' purported actual knowledge of the '415 patent since at least August 2, 2016, following receipt of a patent list from the Plaintiff (Compl. ¶22; Prayer for Relief ¶E).

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

  • A core issue will be one of structural correspondence: does discovery and expert analysis reveal that Defendants' accused base plates physically possess the "pair of first projections" and "pair of second projections" located in the distinct spatial regions as required by Claim 1?
  • The case will also likely involve a key question of definitional scope: will the term "projections" be construed broadly to encompass any raised features that provide a stable contact, or will it be limited by the patent’s specific examples, such as the "coining" manufacturing process or the exemplary dimensions described in the preferred embodiment?