Wiesblatt Licensing LLC v. Lenovo United States Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wiesblatt Licensing LLC (Texas)
  • Defendant: Lenovo (United States), Inc. (Delaware)
  • Plaintiff’s Counsel: Chong Law Firm PA
• Case Identification: 1:21-cv-01524, D. Del., 10/27/2021
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is a Delaware corporation and has allegedly committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that certain unspecified Lenovo products infringe a patent related to power-efficient data transfer in electronic circuits that use variable power supplies and analog clocking signals.
• Technical Context: The technology addresses challenges in reducing power consumption and signal noise in complex electronics by dynamically adjusting operating voltage and using analog signals for clocking and data transfer.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 8,396,112, titled "Circuitry and method for transferring data, and circuitry and method utilizing clock pulses," issued on March 12, 2013 (the "’112 Patent").

The Invention Explained

• Problem Addressed: The patent identifies two primary technical problems. First, in electronic systems that use a variable power supply to conserve energy, it is "difficult to consistently convert... multi-value analog signals into multi-value digital signals because the power supply voltage changes" (’112 Patent, col. 1:32-36). Second, transmitting high-frequency digital clock pulses to many circuits can create "high-harmonic noise" and cause the pulse waveform to "deteriorate" (’112 Patent, col. 1:39-42).
• The Patented Solution: The invention proposes a system where the threshold voltages required for analog-to-digital (A/D) conversion are themselves generated from the variable power supply (’112 Patent, col. 1:63-col. 2:3). This ensures that the reference voltages for data conversion scale with the supply voltage, maintaining accuracy. To solve the clocking problem, the system transmits a lower-frequency analog clock signal (e.g., a sine wave) and uses local generators within different circuit blocks (e.g., a CPU or memory) to create the necessary high-frequency digital clock pulses locally, reducing noise and signal integrity issues associated with long-distance transmission of sharp digital pulses (’112 Patent, col. 2:35-48; Fig. 1).
• Technical Importance: This approach allows for the implementation of dynamic voltage scaling to reduce power consumption without compromising the integrity of data transfer between different components of an electronic device (’112 Patent, col. 1:28-31).

Key Claims at a Glance

• The complaint does not specify which claims of the ’112 Patent it asserts, referring only to the "Exemplary '112 Patent Claims" (Compl. ¶11). Independent claim 1 is representative of the data transfer technology.
• Independent Claim 1 recites a circuitry for transferring data, comprising:
  • a variable power supply voltage generator for generating a variable power supply voltage;
  • a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal;
  • a receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal; and
  • a threshold voltage generator for generating threshold voltages used for the A/D conversion from the variable power supply voltage or a signal proportional to it.
• The complaint reserves the right to assert other claims, which could include independent claim 7, directed to the analog clocking technology (Compl. ¶11).

III. The Accused Instrumentality

The complaint identifies the accused instrumentalities as "Exemplary Defendant Products" detailed in an "Exhibit 2" (Compl. ¶11, ¶13). This exhibit was not attached to the publicly filed complaint. Consequently, the complaint does not provide sufficient detail for analysis of the specific accused products or their functionality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement by incorporating by reference claim charts from a non-proffered Exhibit 2 (Compl. ¶13, ¶14). The pleading does not contain a narrative infringement theory within its body, stating only that the charts demonstrate that the "Exemplary Defendant Products" practice the technology claimed by the ’112 Patent and "satisfy all elements of the Exemplary ’112 Patent Claims" (Compl. ¶13). Without access to the referenced charts or a more detailed narrative, a substantive analysis of the specific infringement allegations is not possible.

V. Key Claim Terms for Construction

Because the complaint lacks a specific infringement theory, analysis of key terms is predictive. Based on the technology, disputes may arise over the following terms from independent claim 1:

• The Term: "variable power supply voltage"

  • Context and Importance: This term is foundational to the patent's problem-solution narrative. The scope of "variable" will be critical. Practitioners may focus on this term to determine if the accused products' power management systems fall within the claim's scope, or if they operate in a manner that is merely non-static but not "variable" in the way contemplated by the patent.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The background section frames the context as reducing power consumption, a general goal achieved by varying voltage, suggesting any non-fixed power supply could qualify (’112 Patent, col. 1:28-31).
    • Evidence for a Narrower Interpretation: An opposing argument could be that the term implies a specific linkage to system operations, such as the variable clock signal (VCLK) described in the embodiment shown in FIG. 2, where the voltage level and clock frequency are coupled (’112 Patent, col. 4:28-32, col. 5:45-51).

• The Term: "multi-value analog signal"

  • Context and Importance: This term distinguishes the claimed invention from conventional binary digital data transfer. The definition will determine whether the accused data transfer method infringes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: A party might argue the term encompasses any analog signal that is not strictly binary, representing more than two states.
    • Evidence for a Narrower Interpretation: The specification provides a more specific boundary, stating the signals are those "having a multi-value signal level of three or higher" (’112 Patent, col. 4:50-52). This language could be used to argue that the term requires at least three intentionally defined signal levels, excluding systems that might have intermediate voltages due to noise or signal transitions rather than design.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege indirect infringement. The single count is for "Direct Infringement" (Compl. ¶11).
• Willful Infringement: The complaint does not allege willful infringement or provide any factual basis for pre- or post-suit knowledge of the patent.

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

The minimalism of the complaint frames the initial phase of the dispute. The case will likely turn on the following fundamental questions:

1. Evidentiary Sufficiency: A threshold issue will be whether the complaint, which asserts infringement entirely through a non-proffered exhibit, provides sufficient factual matter to state a plausible claim for relief under the Twombly/Iqbal pleading standard, a question that may be raised in a motion to dismiss.
2. Technical Application: Assuming the case proceeds and infringement contentions are detailed, a central technical question will be whether the accused products actually generate A/D conversion threshold voltages from a variable power supply as claimed, or if they employ a different, non-infringing architecture for power management and data conversion.
3. Definitional Scope: A key legal question will concern the scope of "multi-value analog signal". The dispute may focus on whether signals within the accused products are intentionally designed with three or more levels as taught by the patent, or if they are fundamentally binary signals whose waveform characteristics are incidental.