DCT

5:04-cv-04379

SanDisk Corp v. STMicroelectronics Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:04-cv-04379, N.D. Cal., 06/18/2007
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Defendant has solicited licenses and caused injury within the district, and a substantial part of the events giving rise to the action occurred there.
  • Core Dispute: Plaintiff alleges that Defendant’s flash memory products infringe a patent related to multi-state memory cell circuits and reading techniques.
  • Technical Context: The dispute centers on multi-level cell (MLC) technology for non-volatile memory, a foundational method for increasing data storage density in devices like flash drives and solid-state disks.
  • Key Procedural History: This filing is an amended complaint. The complaint details pre-suit interactions where Defendant allegedly charged Plaintiff with infringing three of Defendant's own patents. These allegations form the basis for Plaintiff’s requests for declaratory judgment of non-infringement and invalidity concerning those patents, indicating a broader, multi-faceted dispute between the parties.

Case Timeline

Date Event
1989-04-13 U.S. Patent No. 5,172,338 Priority Date
1992-12-15 U.S. Patent No. 5,172,338 Issues
2004-04-16 Defendant sends Plaintiff a letter identifying U.S. Patent Nos. 4,839,768, 5,073,816, and 6,100,581
2004-08-27 Meeting between Plaintiff and Defendant where infringement of Defendant's patents is discussed
2007-06-18 Amended Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 5172338, “Multi-State EEPROM Read and Write Circuits and Techniques,” issued December 15, 1992 (’338 Patent).
  • The Invention Explained:
    • Problem Addressed: The patent addresses the limitations of conventional EEPROM memory cells, which typically store only one bit of data in one of two states ("zero" or "one") ('338 Patent, col. 2:1-12). Storing more than one bit per cell requires partitioning the cell's operating window into multiple distinct states, which presents challenges for accurately and reliably programming and reading those states over the device's lifetime, especially when accounting for variations in temperature, voltage, and manufacturing processes ('338 Patent, col. 2:36-41).
    • The Patented Solution: The invention proposes a system for multi-state memory that uses a set of reference EEPROM cells to establish multiple, programmable threshold levels for reading and verification ('338 Patent, Abstract). Because these reference cells are identical in structure to the data-storing memory cells, they are designed to closely track and compensate for performance variations caused by aging, operating conditions, and manufacturing differences ('338 Patent, col. 2:65-3:3). The patent further describes using both "master" reference cells for the entire chip and "local" reference cells within specific memory sectors to account for localized wear from repeated program/erase cycles ('338 Patent, col. 3:9-17).
    • Technical Importance: This approach allows a memory array to store significantly more information, as its capacity increases with the number of states each cell can store ('338 Patent, col. 2:15-18).
  • Key Claims at a Glance:
    • The complaint does not identify any specific claims of the ’338 Patent that are asserted against the Defendant.

III. The Accused Instrumentality

  • Product Identification: The complaint broadly identifies the accused instrumentalities as "flash memory products" designed, manufactured, marketed, and sold by the Defendant (Compl. ¶¶2, 3). No specific product names, models, or series are identified.
  • Functionality and Market Context:
    • The complaint does not provide any technical details regarding the functionality or operation of the accused flash memory products.
    • The complaint alleges that Defendant STMicroelectronics, Inc. and its parent, STMicroelectronics NV, design, manufacture, and sell semiconductors, including flash memory products (Compl. ¶¶2, 3). No further information regarding the products' market positioning is provided.

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for analysis of infringement. It makes a general allegation that STMicro infringes the ’338 Patent but does not assert any specific claims or provide an infringement theory mapping any accused product features to claim elements (Compl. ¶8).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not assert specific claims or detail an infringement theory, and therefore offers no basis for an analysis of key claim terms.

VI. Other Allegations

  • Indirect Infringement: The complaint makes a conclusory allegation of contributory and induced infringement without providing any specific supporting facts, such as allegations related to product manuals or specific components (Compl. ¶8).
  • Willful Infringement: The complaint alleges that Defendant's infringement "has been and continues to be deliberate and willful" (Compl. ¶11). It does not, however, allege any facts to support this claim, such as pre-suit knowledge of the ’338 Patent.

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

The complaint, filed under older pleading standards, provides minimal technical or factual detail regarding its infringement claim. Consequently, the initial phase of the case will likely focus on establishing the basic contours of the dispute. The central questions are:

  • A primary procedural question will be one of claim selection and specificity: which specific claims of the ’338 Patent does SanDisk intend to assert, and which specific STMicro flash memory products are accused of infringing those claims? The answers will define the technical scope of the dispute.
  • A key evidentiary question will be one of factual basis: what is the technical evidence supporting the allegation that the yet-to-be-identified accused products practice the methods and contain the circuits required by the yet-to-be-asserted claims of the ’338 Patent?