DCT

1:25-cv-01579

Helix Microinnovations LLC v. Bridgelux Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 1:25-cv-01579, D. Del., 12/31/2025

  • Venue Allegations: Plaintiff alleges venue is proper because Defendant is incorporated in Delaware, has an established place of business in the district, and has committed alleged acts of infringement in the district.

  • Core Dispute: Plaintiff alleges that Defendant’s semiconductor products are manufactured using methods that infringe a patent related to the fabrication of Chip-on-Board modules.

  • Technical Context: The dispute centers on semiconductor packaging technology, specifically methods for mounting unpackaged semiconductor die onto printed circuit boards to create functional electronic modules at a lower cost.

  • Key Procedural History: The complaint does not mention any prior litigation, licensing history, or other procedural events relevant to the patent-in-suit.

Case Timeline

Date Event
2002-02-26 ’550 Patent Priority Date
2003-02-20 Application for ’550 Patent Filed
2007-07-03 ’550 Patent Issued
2025-12-31 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 addresses the need for lower-cost methods of producing semiconductor devices, particularly by enabling the use of unpackaged die and even "less-than-perfect" or partially defective semiconductor chips that might otherwise be discarded (’550 Patent, col. 2:13-18). A further problem identified is the risk of chip failure during "burn-in" testing due to stress from differing thermal expansion rates between the semiconductor die and the circuit board (’550 Patent, col. 2:7-11).

  • The Patented Solution: The invention discloses a method for fabricating "Chip-on-Board" (COB) modules by mounting an unpackaged semiconductor die onto a printed circuit board (PCB) using "selectively settable materials," such as UV-curable adhesives (’550 Patent, Abstract; col. 4:1-4). The process involves applying a first ring of this material to hold the die in place for alignment, then hardening it (’550 Patent, col. 4:11-18). A second layer of material can then be applied over the first to "capture" the delicate bonding wires that electrically connect the die to the PCB, securing them and preventing shorts (’550 Patent, col. 4:41-55). In some embodiments, a layer of the settable material between the die and the PCB intentionally remains liquid to serve as a thermal and physical buffer, mitigating stress from thermal expansion (’550 Patent, col. 11:1-4).

  • Technical Importance: This fabrication method aims to improve manufacturing yields and reduce costs by providing a more robust process for handling unpackaged die and securing fragile wire bonds, while also accommodating the use of imperfect components (’550 Patent, col. 3:50-54).

Key Claims at a Glance

The complaint alleges infringement of "exemplary method claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is representative of the patented method:

  • A method of fabricating Chip-on-Board logic modules using selectively settable materials, said method 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 accuses unspecified "Exemplary Defendant Products" (Compl. ¶11, ¶13).

Functionality and Market Context

  • The complaint does not describe the accused products or their functionality. It states that the products are identified in charts included as Exhibit 2, which was not filed with the complaint itself (Compl. ¶13). Therefore, the complaint does not provide sufficient detail for analysis of the accused instrumentality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from Exhibit 2, which was not provided with the complaint (Compl. ¶13, ¶14). Therefore, a detailed claim chart summary cannot be constructed from the available documents. The infringement theory is limited to a general allegation that the "Exemplary Defendant Products practice the technology claimed by the '550 Patent" (Compl. ¶13).

  • Identified Points of Contention: Based on the language of claim 1 of the ’550 Patent, the infringement analysis may raise several technical and legal questions for the court:
    • Scope Questions: The complaint alleges infringement by "Defendant products" (Compl. ¶11). As claim 1 is a method claim, a primary question will be whether Defendant itself performs all steps of the claimed manufacturing method within the United States, or whether the allegations concern products manufactured by a third party using an infringing method.
    • Technical Questions: A central evidentiary question will be whether the accused manufacturing process performs the specific, sequential steps recited in the claim. For example, what evidence demonstrates that the process involves "hardening a ring of said first layer" before "covering said first layer... with a second layer" for the purpose of "capturing bonding wires"? The discrete nature and sequence of these steps may be a focus of dispute.

V. Key Claim Terms for Construction

  • The Term: "selectively settable material"

    • Context and Importance: This term is foundational to all asserted independent claims. Its construction will determine the range of manufacturing materials and processes that fall within the patent's scope. Practitioners may focus on this term because the specification provides specific examples, raising the question of whether the claim is limited to those examples.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is broad, not limiting the material to a specific type (e.g., UV-curable). This may support an argument that the term covers any material that can be hardened in a targeted or "selective" manner.
      • Evidence for a Narrower Interpretation: The specification's detailed description heavily features "UV material" as the preferred embodiment, explaining how different light wavelengths can be used to achieve different levels of hardness (’550 Patent, col. 4:1-10). This repeated emphasis on a specific type of material could be used to argue for a narrower construction limited to materials with similar properties.

  • The Term: "capturing bonding wires ... in said second layer"

    • Context and Importance: This term defines the final, critical step of securing the electrical connections to the die. The interpretation of "capturing" will be key to determining whether an accused process that merely coats or tacks down wires, rather than physically trapping them, meets this limitation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The plain meaning of "capture" could arguably include any action by the second layer that restrains or secures the wires.
      • Evidence for a Narrower Interpretation: The specification describes placing the wires "within the second ring" and "trapping the wires" to facilitate the bonding process (’550 Patent, col. 4:48-50; col. 7:38-40). This language may support an interpretation requiring the wires to be at least partially embedded or enclosed by the material of the second layer, rather than simply being coated by it.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain allegations of indirect infringement (induced or contributory). Count 1 is explicitly titled "Direct Infringement" (Compl. ¶11).

  • Willful Infringement: The complaint does not use the term "willful." However, the prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which allows for the award of attorney's fees (Compl. p. 4, ¶E.i). The complaint does not plead any specific facts, such as pre-suit knowledge of the patent, to support this request.

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

The resolution of this case will likely depend on the answers to a few central questions for the court, which will require factual development through discovery.

  • A core issue will be one of procedural mechanics: does the accused manufacturing process employ the specific, multi-step sequence required by the claims, including the distinct application and hardening of a first material layer before a second layer is used to capture bonding wires?

  • A second key question will be one of definitional scope: can the term "selectively settable material," which is described in the patent primarily through the example of UV-curable adhesives, be construed to cover the specific materials used in the Defendant's manufacturing process?

  • Finally, a threshold evidentiary question will be one of attribution: what proof demonstrates that the Defendant performs the accused manufacturing method in the United States, as required for direct infringement of a method claim?