FrameTech LLC v. Super Micro Computer Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: FrameTech LLC (Delaware)
  • Defendant: Super Micro Computer, Inc. (Delaware)
  • Plaintiff’s Counsel: Garibian Law Offices, P.C.; Rabicoff Law LLC
• Case Identification: 1:25-cv-00900, D. Del., 07/18/2025
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant is incorporated in Delaware, has an established place of business in the district, has committed alleged acts of infringement in the district, and Plaintiff has suffered harm there.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified computer products infringe a patent related to automating the setup and configuration of mainframe computer operating systems.
• Technical Context: The technology concerns methods for discovering the configuration of an existing mainframe computer system and using that information to automate the installation and customization of a new or upgraded operating system.
• Key Procedural History: No prior litigation, IPR proceedings, or licensing history is mentioned in the complaint. The complaint asserts knowledge of infringement only as of the date of its service.

Case Timeline

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

U.S. Patent No. 7,194,737 - "System and Method for Expediting and Automating Mainframe Computer Setup," issued March 20, 2007

The Invention Explained

• Problem Addressed: The patent describes the process of upgrading a mainframe computer operating system as an "arduous task" that is highly complex, time-consuming, and dependent on a shrinking pool of skilled, aging mainframe systems programmers. (’737 Patent, col. 1:30-44, col. 2:5-17). Manually performing an "initial program load" (IPL) could take skilled technicians several days. (’737 Patent, col. 1:41-44).
• The Patented Solution: The invention provides a system, typically running on a separate client computer, that automates this process. It first performs a "discovery" process to gather "profile information" about the existing mainframe's hardware and software configuration (e.g., storage volumes, security settings, network parameters). (’737 Patent, col. 2:30-38). It then uses this information to generate and transfer a "base operating system" to the target mainframe and automatically customize it to replicate the prior environment, thereby preparing the mainframe for an automated IPL. (’737 Patent, col. 2:39-49; Fig. 3).
• Technical Importance: The invention sought to reduce the time, cost, and specialized human expertise required for mainframe maintenance and upgrades, a critical task for organizations reliant on legacy data systems. (’737 Patent, col. 4:5-9).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '737 Patent Claims" in a non-provided exhibit (Compl. ¶11). Independent claim 1 is representative of the patented method.
• Independent Claim 1:
  • automatically receiving source profile information, said source profile information representing an existing configuration of at least one of hardware and software on said mainframe computer system;
  • using a client computer system to generate a base operating system... wherein the client computer system communicates with said mainframe computer system over a communication network;
  • transferring said base operating system from said client computer system to said mainframe computer; and
  • using the client computer system to automatically customize said base operating system comprising said mainframe computer system to incorporate elements in said source profile information, wherein after said base operating system is customized, said mainframe computer system is automatically adapted for an initial program load.
• The complaint reserves the right to assert other claims, which could include dependent claims. (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

• The complaint does not name any specific accused products in its body. It refers to "Exemplary Defendant Products" that are identified in charts within Exhibit 2, which was incorporated by reference but not provided with the complaint. (Compl. ¶11, ¶16).

Functionality and Market Context

• The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It alleges only that the unspecified products "practice the technology claimed by the '737 Patent." (Compl. ¶16). Super Micro Computer, Inc. is generally known as a manufacturer of servers, server management software, and related computing hardware.

IV. Analysis of Infringement Allegations

The complaint alleges that the "Exemplary Defendant Products" infringe one or more claims of the ’737 Patent, including by satisfying all elements of the "Exemplary '737 Patent Claims." (Compl. ¶11, ¶16). The specific mapping of claim elements to accused product features is contained in claim charts in Exhibit 2, which was not provided. (Compl. ¶17). The complaint alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products and also by having its employees "internally test and use these Exemplary Products." (Compl. ¶11-12).

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question will be whether the patent’s claims, which are described in the context of legacy mainframe systems (e.g., "OS/390," "z/OS," "SYS1.LINKLIB"), can be read to cover the modern server architecture and operating systems (e.g., Linux, Windows Server) presumably used in Defendant’s products. (’737 Patent, col. 1:17-18, col. 7:37-38). The defense may argue that terms like "mainframe computer system" and "initial program load" have specific meanings in the art that do not extend to the accused products.
  • Technical Questions: It will be a point of contention whether Defendant's products perform the specific sequence of steps claimed: (1) discovering a pre-existing configuration, (2) generating a "base operating system," (3) transferring it, and (4) "automatically customiz[ing]" it to "incorporate elements" from the discovered configuration. The complaint lacks factual allegations detailing how any of Defendant's products perform this specific, multi-stage process.

V. Key Claim Terms for Construction

The Term: "mainframe computer system"

• Context and Importance: This term appears in the preamble and body of claim 1. Its construction is critical because the patent's specification is heavily rooted in the context of specific IBM mainframe environments like "System 390" and "OS/390." (’737 Patent, col. 1:17-18). The outcome of the infringement analysis may depend on whether this term is construed narrowly to mean only such legacy systems or broadly to encompass modern, high-performance servers like those sold by Defendant.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly define "mainframe computer system." Plaintiff may argue that the term should be given its plain and ordinary meaning, which could encompass any large, powerful, central computer, including modern enterprise servers.
  • Evidence for a Narrower Interpretation: The specification repeatedly and exclusively uses IBM mainframe systems as examples (e.g., "IBM System 90," "OS/390 from IBM," "z/OS"). (’737 Patent, col. 3:26-27, col. 3:37, col. 7:13). The detailed description of the problem and solution is framed entirely around mainframe-specific concepts like IPLs, PARMLIB, and SYSRES volumes, which may support a narrower construction limited to that technical environment. (’737 Patent, col. 1:38, col. 6:5, col. 8:8-10).

The Term: "automatically customize said base operating system ... to incorporate elements in said source profile information"

• Context and Importance: This step is the core of the claimed invention, where the discovered configuration is applied to the new system. Practitioners may focus on this term because the dispute will likely turn on whether the accused products perform this specific customization function, as opposed to a more generic installation or configuration process.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language is general, referring simply to "incorporat[ing] elements." Plaintiff might argue this covers any automated process where settings from a source (e.g., a template, a user profile) are applied during software installation on a new server.
  • Evidence for a Narrower Interpretation: The specification describes a highly specific process of recreating a prior environment by, for example, defining a new master catalog, restoring data sets from a dump image, creating specific members in "PARMLIB", and copying the "IODF". (’737 Patent, col. 10:49-67). A defendant could argue that "automatically customize" should be limited to this mainframe-specific process of replicating a detailed, pre-existing environment, not merely applying a standard configuration template.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant sells the accused products to customers and distributes "product literature and website materials" that instruct end users on how to use the products in an infringing manner. (Compl. ¶14-15). The factual basis for this allegation is deferred to the unprovided Exhibit 2.
• Willful Infringement: The complaint alleges willful infringement based on knowledge obtained "at least since being served by this Complaint." (Compl. ¶15). It also alleges "Actual Knowledge" based on the service of the complaint and its attached claim charts. (Compl. ¶13). This appears to be a claim for post-suit willfulness only, as no pre-suit knowledge is alleged.

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

1. A central issue will be one of technological scope: Can the patent’s claims, which are grounded in the language and architecture of 1990s/2000s-era IBM mainframes, be construed to cover the potentially different architecture and setup processes of Defendant’s modern server products?
2. A key evidentiary question will be one of infringement evidence: As the complaint’s factual allegations are contained entirely within an unprovided exhibit, a primary question is what evidence Plaintiff will produce to show that Defendant’s products actually perform the claimed method of discovering a pre-existing configuration and using it to automatically customize a new operating system for an initial program load.
3. The case may also turn on a question of claim construction: Will the term "mainframe computer system" be interpreted broadly to mean any powerful, centralized server, or will it be limited by the specification's exclusive focus on the specific IBM hardware and software environment described in the patent?