3:25-cv-00110
QuickLogic Corp v. Flex Loading Tech LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: QuickLogic Corporation (Delaware)
- Defendant: Flex Loading Technologies, LLC (Delaware) and QuickFlex, Inc. (Delaware)
- Plaintiff’s Counsel: Baker Botts L.L.P.
- Case Identification: 5:25-cv-00110, N.D. Cal., 01/03/2025
- Venue Allegations: Plaintiff QuickLogic alleges venue is proper in the Northern District of California because it is a resident of the district, the Defendants are subject to personal jurisdiction in the district based on prior business activities and targeted cease-and-desist correspondence, and the alleged acts giving rise to the dispute took place in the district.
- Core Dispute: Plaintiff seeks a declaratory judgment that its products do not infringe a patent owned by Defendants related to methods for managing reconfigurable computing resources.
- Technical Context: The technology concerns the efficient allocation of hardware resources in Field Programmable Gate Arrays (FPGAs), which are semiconductor devices with programmable logic circuits used in a wide range of electronic systems.
- Key Procedural History: The action was precipitated by a December 4, 2024, demand letter from Defendant Flex Loading Technologies to Plaintiff QuickLogic, which alleged infringement of the patent-in-suit and included a draft complaint. QuickLogic filed this declaratory judgment action in response, seeking to pre-emptively establish non-infringement and select the venue.
Case Timeline
| Date | Event |
|---|---|
| 2009-08-18 | U.S. Patent No. 8,176,212 Priority Date |
| 2012-05-08 | U.S. Patent No. 8,176,212 Issued |
| 2023-07-28 | Defendant Flex Loading Technologies, LLC formed |
| 2024-12-04 | Defendants send notice letter and draft complaint to Plaintiff |
| 2025-01-03 | Complaint for Declaratory Judgment filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,176,212 - "Method and system for hierarchical and joinable behavior containers for reconfigurable computing"
The Invention Explained
- Problem Addressed: The patent addresses the inefficiency of using reconfigurable computing resources like FPGAs when hardware tasks (or "behaviors") of widely varying sizes must be loaded and run. Conventional methods often use pre-determined, fixed-size regions for this "partial reconfiguration," which can lead to wasted resources when a small task occupies a large, fixed region, or an inability to run large tasks at all (’212 Patent, col. 7:15-24, col. 9:40-46).
- The Patented Solution: The invention proposes a system for managing reconfigurable resources through "behavior containers" that are both hierarchical and joinable. This allows a logic manager to dynamically create containers of different sizes by either breaking down large regions into smaller nested ones or joining adjacent smaller regions to form a larger one, thereby creating a better "fit" for the specific hardware behavior being loaded (’212 Patent, col. 7:37-45, Fig. 5). This flexible sizing is intended to improve the overall efficiency and utilization of the FPGA fabric (’212 Patent, col. 7:45-55).
- Technical Importance: This approach provided a more dynamic and fine-grained method for managing FPGA resources compared to the static partitioning common at the time, enabling more powerful and flexible use of partial reconfiguration technology (’212 Patent, col. 7:50-58).
Key Claims at a Glance
- The complaint asserts non-infringement of independent claim 1 (Compl. ¶33).
- The essential elements of independent claim 1 are:
- defining a configuration of hierarchical behavior container regions on said reconfigurable computer resource according to allowable electrical boundary limitations of said reconfigurable computer resource;
- selecting a hierarchical behavior container on said reconfigurable computer resource to load said hardware behavior according to a hierarchical process wherein said hardware behavior is loaded into the smallest hierarchical behavior container available in a configuration of hierarchical behavior container regions on said reconfigurable computer resource; and
- loading said hardware behavior into said selected hierarchical behavior container.
- The complaint seeks a declaration of non-infringement for "any claim of the '212 Patent" (Compl. ¶34).
III. The Accused Instrumentality
Product Identification
The complaint identifies the "QuickLogic Aurora Software Tool Suite" as the primary accused product, along with other current or legacy products that use or are used in combination with the suite (Compl. ¶24).
Functionality and Market Context
The complaint describes the Aurora Software Tool Suite as a tool used in connection with FPGAs (Compl. ¶24, ¶37). The complaint includes a screenshot, allegedly from the Defendants' draft complaint, which states that a "netlist generated by Mentor Graphics Precision is imported in Aurora, through which the designer runs the implementation flow" using tools like a Logic Optimizer, Placer, and Router. This screenshot depicts the accused product's role as part of a larger implementation workflow for FPGAs (Compl. p. 10; Ex. 3). The complaint does not provide further detail on the product's market context.
IV. Analysis of Infringement Allegations
The complaint is for a declaratory judgment of non-infringement. The following table summarizes the infringement theory that Plaintiff QuickLogic attributes to the Defendants (based on a draft complaint) and against which QuickLogic argues.
’212 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality (as attributed to Defendants) | Complaint Citation | Patent Citation |
|---|---|---|---|
| defining a configuration of hierarchical behavior container regions on said reconfigurable computer resource according to allowable electrical boundary limitations of said reconfigurable computer resource | This step is allegedly met by "netlist creation." The complaint alleges that this function is performed not by QuickLogic's product but by a third-party tool, Mentor Graphics Precision. A screenshot from the draft complaint shows this asserted equivalence (Compl. p. 10). | ¶¶36-37 | col. 12:62-col. 13:1 |
| selecting a hierarchical behavior container on said reconfigurable computer resource to load said hardware behavior according to a hierarchical process wherein said hardware behavior is loaded into the smallest hierarchical behavior container available... | The complaint denies that the Accused Products perform this function but does not detail the specific functionality that Defendants allege meets this limitation. | ¶38 | col. 13:2-8 |
| loading said hardware behavior into said selected hierarchical behavior container | The complaint asserts that the "Aurora Software Tool Suite does not load hardware behavior into hierarchical behavior containers." It does not specify the functionality that Defendants allege meets this limitation. | ¶39 | col. 13:9-11 |
- Identified Points of Contention:
- Scope Questions: The core dispute appears to hinge on whether the term "defining a configuration" can be met by the act of "netlist creation" as allegedly asserted by Defendants (Compl. ¶36). A screenshot from Defendants' draft complaint shows an allegation that QuickLogic "defines a configuration (here, netlist creation)" (Compl. p. 10; Ex. 3).
- Technical Questions: A primary issue is whether QuickLogic's Aurora software itself performs the claimed steps. The complaint contends that the "defining" step (i.e., netlist creation) is performed by a third-party Mentor Graphics tool, not the accused product (Compl. ¶37). This raises the question of whether a single actor performs all steps of the claimed method, a prerequisite for direct infringement. The complaint also raises factual questions about whether the accused products perform the "selecting" and "loading" steps as required by the claim (Compl. ¶¶38-39).
V. Key Claim Terms for Construction
The Term: "defining a configuration of hierarchical behavior container regions"
Context and Importance: This term is central because QuickLogic alleges that the corresponding function ("netlist creation") is performed by a third-party tool, not its own software (Compl. ¶37). The case may turn on whether "defining" requires direct action by the accused infringer or if facilitating an action by another tool is sufficient, and whether "netlist creation" is functionally equivalent to "defining a configuration" as taught in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not explicitly define the term. Parties arguing for a broader scope may point to the general description of a "reconfigurable logic manager" that "manages" the resource, potentially suggesting that overseeing a process involving multiple tools could fall within the claim's scope (’212 Patent, col. 8:46-48).
- Evidence for a Narrower Interpretation: The detailed description of the process suggests an integrated system where a single "reconfigurable logic manager" makes determinations and controls the loading process (’212 Patent, col. 7:56-62, col. 8:60-64). The use of the active verb "defining" in a method claim may support an interpretation that the same entity must perform the action.
The Term: "loaded into the smallest hierarchical behavior container available"
Context and Importance: Practitioners may focus on this term because QuickLogic specifically denies that its products perform this function (Compl. ¶38). The outcome of this element will depend on both the technical evidence of how the Aurora tool suite operates and the legal construction of "smallest" and "available."
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "smallest... available" could be interpreted relatively, meaning the smallest among a set of possible options that meets the size requirement, without necessarily being the absolute smallest possible configuration on the entire device.
- Evidence for a Narrower Interpretation: The patent describes a specific hierarchical decision process that begins at the "leaf" level (the smallest containers) and works its way up, suggesting a rigorous search for the most granular, best-fit container (’212 Patent, Fig. 5; col. 11:46-54). This could support a narrower construction requiring a specific, optimized selection process.
VI. Other Allegations
- Indirect Infringement: The complaint is a declaratory judgment action for non-infringement and thus does not contain allegations of infringement against QuickLogic. However, the complaint's argument that a third-party tool performs a key step (Compl. ¶37) suggests that a central defense to any future infringement claim by Defendants will be the lack of a single actor performing all claim steps, which is required for direct infringement and is a predicate for finding indirect infringement.
- Willful Infringement: The complaint does not contain allegations of willful infringement.
VII. Analyst’s Conclusion: Key Questions for the Case
This declaratory judgment action appears to center on three fundamental questions for the court:
A central issue will be one of divided infringement: can Flex Loading establish that QuickLogic is liable for infringement when, as QuickLogic alleges, a key step of the claimed method ("defining a configuration") is performed by a third-party software tool from Mentor Graphics? This will require an analysis of whether QuickLogic directs or controls its users to perform the complete claimed method.
A second issue is one of definitional scope: does the term "defining a configuration," as used in the context of creating hierarchical regions on an FPGA, read on the function of "netlist creation" performed by an electronic design automation tool?
Finally, the case presents an evidentiary question of technical operation: beyond the "defining" step, does the QuickLogic Aurora Software Tool Suite, as a factual matter, perform the claimed steps of "selecting" the "smallest hierarchical behavior container available" and "loading" hardware behavior into it, as QuickLogic denies?