Helix Microinnovations LLC v. Microchip Technology Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Helix Microinnovations LLC (Delaware)
  • Defendant: Microchip Technology Incorporated (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:24-cv-00962, D. Del., 08/21/2024
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware and maintains an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products, fabricated using certain manufacturing methods, infringe a patent related to the fabrication of Chip-on-Board semiconductor modules.
• Technical Context: The technology concerns methods for manufacturing electronic modules by mounting unpackaged semiconductor die directly onto a printed circuit board, a process known as Chip-on-Board (COB), intended to reduce costs and improve manufacturing yields.
• Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other significant procedural events.

Case Timeline

Date	Event
2002-02-26	Priority Date for U.S. Patent No. 7,238,550
2007-07-03	U.S. Patent No. 7,238,550 Issued
2024-08-21	Complaint Filed

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

U.S. Patent No. 7,238,550 - "Methods and apparatus for fabricating Chip-on-Board modules"

• Patent Identification: U.S. Patent No. 7,238,550, "Methods and apparatus for fabricating Chip-on-Board modules", issued July 3, 2007.

The Invention Explained

• Problem Addressed: The patent describes the ongoing need for lower-cost semiconductor devices, particularly memory modules. It notes that conventional manufacturing can be wasteful when semiconductor devices are only "partially-defective." Furthermore, standard assembly processes can cause failures due to stress from differing thermal expansion coefficients between the semiconductor chip and the circuit board. (’550 Patent, col. 2:13-20).
• The Patented Solution: The invention proposes an improved method for fabricating Chip-on-Board modules, including those using partially-defective chips. The method involves mounting an unpackaged die onto a printed circuit board (PCB) using "selectively settable liquids," such as UV-curable adhesives. A first application of this material can be partially cured to tack the die in place, while a second layer can be applied over the bonding wires to "capture" and protect them before a final hardening step. This multi-stage process is described as facilitating repositioning, testing, and securing fragile components. (’550 Patent, Abstract; col. 4:12-20, col. 7:32-45).
• Technical Importance: The described method aims to improve the yield and lower the cost of producing semiconductor modules by enabling the use of less-than-perfect die and providing a more robust assembly process for delicate, unpackaged components. (’550 Patent, col. 2:46-54).

Key Claims at a Glance

• The complaint alleges infringement of "exemplary method claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is a representative method claim.
• Independent Claim 1:
  • A method of fabricating Chip-on-Board logic modules using selectively settable materials, comprising:
  • mounting unpackaged die using a first layer of selectively-settable material;
  • hardening a ring of said first layer of selectively-settable material around a periphery said unpackaged die;
  • covering said first layer of selectively-settable material with a second layer of selectively-settable material; and
  • capturing bonding wires connecting said unpackaged die to a printed circuit board in said second layer of selectively-settable material.

III. The Accused Instrumentality

Product Identification

• The complaint does not specifically name any accused products. It refers to "the Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). These charts are referenced as "Exhibit 2," which was not filed with the complaint.

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products or processes. It alleges that Defendant infringes by "making, using, offering to sell, selling and/or importing" the "Exemplary Defendant Products" (Compl. ¶11).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in "charts comparing the Exemplary '550 Patent Claims to the Exemplary Defendant Products," which are contained in an unfiled Exhibit 2 (Compl. ¶13). As the charts are not provided, a detailed element-by-element analysis is not possible.

The complaint’s narrative theory of infringement is that the "Exemplary Defendant Products" practice the technology claimed by the ’550 Patent and "satisfy all elements of the Exemplary '550 Patent Claims" (Compl. ¶13). The infringement is alleged to be direct, occurring literally or under the doctrine of equivalents (Compl. ¶11). The complaint further alleges direct infringement through internal use, stating that Defendant’s "employees internally test and use these Exemplary Products" (Compl. ¶12).

No probative visual evidence provided in complaint.

• Identified Points of Contention: Lacking specific details about the accused instrumentality, any analysis is preliminary. However, based on the asserted claims, key disputes may involve:
  • Procedural Questions: A primary question will be identifying the specific products and manufacturing processes accused of infringement, which are not detailed in the complaint itself.
  • Technical Questions: A factual dispute may arise over whether Defendant's manufacturing process includes distinct first and second layers of material as claimed, and whether its process performs the specific function of "capturing bonding wires" within a settable material prior to final hardening.
  • Scope Questions: The definition of "selectively-settable material" and what constitutes "capturing" the bonding wires will be central. The analysis will question whether Defendant's materials and assembly steps fall within the scope of these terms as defined by the patent.

V. Key Claim Terms for Construction

• The Term: "selectively-settable material" (from Claim 1)

• Context and Importance: This term is the core technical component of the claimed invention. Its definition will determine whether the materials used in Defendant’s process meet this limitation. Practitioners may focus on whether this term is limited to the specific examples in the patent or covers a broader class of industrial adhesives.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims use the general term "selectively-settable material" without further limitation, suggesting any material that can be hardened in a controlled manner could be covered (’550 Patent, col. 10:50).
  • Evidence for a Narrower Interpretation: The specification repeatedly uses "UV material" and "UV-curable liquids" as the primary example, and describes a specific hardening process based on different wavelengths of light. A defendant may argue the term should be construed in light of these specific embodiments. (’550 Patent, col. 4:1-11, col. 11:8-9).

• The Term: "capturing bonding wires" (from Claim 1)

• Context and Importance: This is the key functional step for protecting the delicate wires. The dispute will likely center on how this "capturing" is achieved. The case may turn on whether Defendant’s process of securing wires is equivalent to the patent’s specific description of enveloping them in a liquid material that is subsequently hardened.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The term itself is functional and could be argued to cover any process that secures the wires within a material, not just the specific one shown.
  • Evidence for a Narrower Interpretation: The specification describes a specific sequence: placing wires "within the second ring while the selectively settable material is still manageable and then hardening the ring" (’550 Patent, col. 4:49-52). The detailed description further explains this is done by covering a first layer with a second layer and placing the wires inside the second layer (’550 Patent, col. 7:32-41). This could support a narrower construction requiring a multi-layer liquid application process.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain specific allegations of induced or contributory infringement. The focus is on Defendant’s own acts of direct infringement (Compl. ¶11, ¶12).
• Willful Infringement: The complaint does not use the term "willful." However, in the prayer for relief, it requests a judgment that the "case be declared exceptional within the meaning of 35 U.S.C. § 285" (Compl. p. 4, ¶E.i). The complaint does not plead any specific facts regarding pre-suit knowledge or egregious conduct that would typically support such a finding.

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

1. An Evidentiary Question of Process: The central threshold issue is factual: What are the specific "Exemplary Defendant Products," and what are the precise steps and materials used in their manufacturing process? Without this information, which is referenced but absent from the complaint, any analysis of infringement remains speculative.

2. A Definitional Question of Claim Scope: The case will likely depend on the construction of key claim terms. A core issue will be whether Defendant’s method of securing bonding wires constitutes "capturing" them within a "second layer of selectively-settable material" as the patent requires, or if it utilizes a technically distinct process that falls outside the claim’s scope.

3. A Question of Pleading Sufficiency: Given the complaint’s reliance on an unfiled exhibit to identify the accused products and provide the basis for infringement, an early issue may be whether the pleading meets the plausibility standards required by Federal Rule of Civil Procedure 8, as interpreted by the Supreme Court in Iqbal and Twombly.