DCT
5:25-cv-00110
QuickLogic Corp v. Flex Loading Tech LLC
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: QuickLogic Corporation (Delaware, with a principal place of business in California)
- Defendant: Flex Loading Technologies, LLC (Delaware) and QuickFlex, Inc. (Delaware, with a principal place of business in Virginia)
- Plaintiff’s Counsel: Baker Botts L.L.P.
- Case Identification: 5:25-cv-00110, N.D. Cal., 01/03/2025
- Venue Allegations: Plaintiff QuickLogic asserts that venue is proper under the general venue statute because Defendants are subject to personal jurisdiction in the Northern District of California, stemming from activities including a founder’s presentations at trade shows in the district and the sending of the notice letter that prompted this lawsuit into the district.
- Core Dispute: Plaintiff QuickLogic seeks a declaratory judgment that its software products do not infringe a patent held by Defendants related to methods for managing reconfigurable computing resources, following receipt of a cease-and-desist letter and draft infringement complaint from Defendants.
- Technical Context: The technology concerns the efficient allocation of hardware resources on Field-Programmable Gate Arrays (FPGAs), which are semiconductor devices with configurable logic blocks that are crucial in high-performance and specialized computing applications.
- Key Procedural History: This action for declaratory judgment was precipitated by a December 4, 2024, notice letter from Defendant Flex Loading Technologies to Plaintiff QuickLogic, which alleged infringement of the patent-in-suit and included a draft complaint. This communication is asserted as the basis for the "actual controversy" required for the court to have jurisdiction over the declaratory judgment action.
Case Timeline
| Date | Event |
|---|---|
| 2009-08-18 | ’212 Patent Priority Date |
| 2012-05-08 | ’212 Patent Issue Date |
| 2023-07-28 | Flex Loading Technologies, LLC formed |
| 2024-12-04 | Defendants send notice letter 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 inefficient use of reconfigurable computing resources like FPGAs that arises from "partial dynamic reconfiguration." This process often involves pre-allocating fixed-size regions for hardware tasks. When a small hardware task ("behavior") is loaded into a large, pre-determined region, the excess capacity in that region is wasted, leading to "inefficient use of the partially reconfigurable regions." (’212 Patent, col. 7:15-24).
- The Patented Solution: The invention provides a system for the "flexible sizing of behavior containers" on a reconfigurable device by using "hierarchically nested as well as joinable and separable containers." (’212 Patent, Abstract). A software "reconfigurable logic manager" dynamically determines the best allocation of these containers, joining smaller adjacent containers to create a larger space for a demanding task, or separating a larger space into smaller containers as needed, thereby improving resource utilization. (’212 Patent, col. 7:56-62, col. 8:45-50).
- Technical Importance: This method of dynamic and flexible resource allocation was intended to improve the "flexibility and computational effectiveness" of FPGAs, allowing for more powerful and fine-grained control over how hardware resources are used in real-time. (’212 Patent, col. 7:51-58).
Key Claims at a Glance
- The complaint’s first claim for relief focuses on Independent Claim 1 of the ’212 Patent (Compl. ¶¶ 33-36).
- The essential elements of Independent Claim 1 include:
- A method for flexible loading of a hardware behavior on a reconfigurable computer resource.
- "defining" a configuration of hierarchical behavior container regions on the resource according to its allowable electrical boundary limitations.
- "selecting" a hierarchical behavior container to load the hardware behavior according to a hierarchical process.
- Wherein the hardware behavior is loaded into the "smallest" hierarchical behavior container available.
- "loading" the hardware behavior into the selected container.
- The complaint seeks a declaration of non-infringement of "any claim of the Asserted Patent," reserving the right to address other claims (Compl. ¶¶ 6, 34).
III. The Accused Instrumentality
Product Identification
The complaint identifies the primary accused instrumentality as the "QuickLogic Aurora Software Tool Suite." It also includes a broad catch-all for other current and legacy products that use or are combined with the Aurora suite (Compl. ¶ 24).
Functionality and Market Context
The Aurora Software Tool Suite is used to implement designs on QuickLogic's eFPGA (embedded Field-Programmable Gate Array) hardware (Compl. ¶ 37, Ex. 3). According to the complaint, a key function in this process is "netlist creation," which defines the hardware configuration. QuickLogic alleges that this function is not performed by its Aurora suite, but rather by a third-party tool, Mentor Graphics Precision, and that the resulting netlist is then "imported in Aurora" for subsequent implementation steps (Compl. ¶¶ 37, p.10).
IV. Analysis of Infringement Allegations
As this is a declaratory judgment action, the following chart summarizes Plaintiff QuickLogic's asserted grounds for non-infringement, based on allegations it attributes to the Defendants' draft complaint (Compl. Ex. 3).
’212 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| defining a configuration of hierarchical behavior container regions on said reconfigurable computer resource according to allowable electrical boundary limitations... | This element is allegedly met by "netlist creation." QuickLogic alleges this step is performed by a third-party tool, Mentor Graphics Precision, not by the Accused Products. The screenshot from the Defendants' draft complaint shows that "The netlist generated by Mentor Graphics Precision is imported in Aurora." | ¶¶ 36-37, p. 10 | col. 12:65-13:5 |
| 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... | QuickLogic alleges the Accused Products do not perform this step because they cannot show that the hardware behavior is loaded into the "smallest hierarchical behavior container available." | ¶ 38 | col. 13:1-7 |
| loading said hardware behavior into said selected hierarchical behavior container. | QuickLogic alleges its "Aurora Software Tool Suite does not load hardware behavior into hierarchical behavior containers." | ¶ 39, p. 11 | col. 13:8-12 |
Identified Points of Contention
- Scope Questions: A central issue is whether the act of "importing" a pre-defined netlist, as shown in the visual evidence cited by the complaint (Compl. ¶37, p.10), can satisfy the claim limitation of "defining a configuration." This raises the question of whether "defining" requires the initial creation of the configuration based on electrical limitations, an act QuickLogic attributes to a third party.
- Technical Questions: The complaint raises factual questions about the operation of the Aurora tool suite. What evidence can be produced to show that the accused software performs the specific hierarchical selection process required by the claim, particularly the step of loading a behavior into the "smallest... available" container? QuickLogic's denial suggests a potential mismatch between the allocation algorithm claimed in the patent and the one used in its software (Compl. ¶ 38).
V. Key Claim Terms for Construction
"defining a configuration of hierarchical behavior container regions"
- Context and Importance: This term is critical because QuickLogic’s primary non-infringement argument is that this step is performed by a third party’s "netlist creation" tool, not its own product (Compl. ¶¶ 36-37). The construction of "defining" will determine whether merely importing and processing a configuration created by another tool falls within the scope of the claim.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification states the "reconfigurable logic manager" is responsible for "making dynamic determinations of the best current allocation" based on workload (col. 7:56-62). This could support an interpretation where "defining" encompasses the entire management process, including the use of configurations generated by external tools as part of that process.
- Evidence for a Narrower Interpretation: The claim requires defining the configuration "according to allowable electrical boundary limitations" (col. 13:4-5). The patent explains that these boundaries are delineated by physical "BUS MACRO" structures to ensure electrical safety (col. 10:1-7). This could support a narrower reading where "defining" requires the act of creating the layout with direct consideration of these physical hardware constraints, not merely importing a completed layout.
"smallest hierarchical behavior container available"
- Context and Importance: QuickLogic specifically denies that its products load behavior into the "smallest" container available (Compl. ¶ 38). The interpretation of this phrase will be central to determining if the allocation logic of the Accused Products infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes selecting the "most appropriate region" based on "best fit" (col. 8:4-7), which could be argued to be more flexible than a strict "smallest" rule and might encompass other optimization factors besides pure size.
- Evidence for a Narrower Interpretation: The claim language is specific. Further, the process described in relation to Figure 5 involves a search for an "unoccupied and large enough" node, and considers joining adjacent nodes if a single one is not large enough (col. 10:45-11:3). This suggests a search for a minimally sufficient space, lending support to a literal interpretation of "smallest... available."
VI. Other Allegations
Indirect Infringement
The complaint seeks a declaration of non-infringement "directly or indirectly" (Compl. ¶ 34). QuickLogic’s defense that a third party (Mentor Graphics) performs a key claimed step raises the question of indirect infringement. Defendants would need to show that QuickLogic actively induces its customers or partners to combine the Aurora suite with the Mentor Graphics tool in a way that infringes the patent. The allegation that Mentor Graphics' tool is "enhanced to support QuickLogic's... architectures" could be used as evidence of an intent to induce infringement (Compl. ¶ 37, p. 10).
Willful Infringement
While no allegation of willfulness has been made against QuickLogic in a formal complaint, the December 4, 2024, notice letter establishes that QuickLogic has had knowledge of the patent-in-suit since at least that date (Compl. ¶ 2). This pre-suit notice could form the basis for a future claim of willful infringement by the Defendants if infringement is ultimately found.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of liability for divided actions: Can QuickLogic be held liable for direct infringement when it alleges a necessary claim step—"defining a configuration"—is performed by a separate, third-party software tool? The case may turn on whether QuickLogic directs or controls the performance of that step, or alternatively, whether it can be held liable for inducing infringement by its customers who use the tools in combination.
- A second key issue will be one of claim scope: The dispute will likely focus on the proper construction of key terms. Can "defining a configuration" be satisfied by importing a netlist created by another program, and does the accused software’s allocation method meet the specific requirement of selecting the "smallest hierarchical behavior container available"?
- Finally, the case presents a fundamental evidentiary question of technical operation: Beyond legal interpretations, the parties appear to dispute what the Accused Products actually do. Resolving the factual discrepancy between the patent’s claimed "selecting" and "loading" processes and the actual functionality of the QuickLogic Aurora Software Tool Suite will be critical.