1:25-cv-01580
Helix Microinnovations LLC v. Luminus Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Helix Microinnovations LLC (Delaware)
- Defendant: Luminus, Inc. (Delaware)
- Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
- Case Identification: 1:25-cv-01580, D. Del., 12/31/2025
- Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant, a Delaware corporation, has an established place of business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s manufacturing processes for semiconductor modules infringe a patent related to methods for fabricating Chip-on-Board modules.
- Technical Context: The dispute concerns manufacturing techniques for mounting and connecting unpackaged semiconductor die (chips) directly onto a printed circuit board, a cost-sensitive and technically challenging area of electronics assembly.
- Key Procedural History: The complaint does not reference any prior litigation, licensing history, or post-grant proceedings involving the patent-in-suit.
Case Timeline
| Date | Event |
|---|---|
| 2002-02-26 | ’550 Patent Priority Date |
| 2003-02-20 | ’550 Patent Application Filing Date |
| 2007-07-03 | ’550 Patent Issue Date |
| 2025-12-31 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
Patent Identification: U.S. Patent No. 7,238,550, Methods and apparatus for fabricating Chip-on-Board modules, issued July 3, 2007 (’550 Patent).
The Invention Explained:
- Problem Addressed: The patent describes a need for low-cost methods of producing semiconductor devices, particularly by utilizing "less-than-perfect" or partially-defective semiconductor die to reduce waste (ʻ550 Patent, col. 2:13-18). A further technical challenge is that high-heat testing processes ("burn-in" tests) can cause failures due to the different thermal expansion rates of the semiconductor chip and the circuit board it is mounted on (ʻ550 Patent, col. 2:7-12).
- The Patented Solution: The patent discloses a method for mounting an unpackaged semiconductor die onto a printed circuit board (PCB) using "selectively settable" materials, such as UV-curable liquids (ʻ550 Patent, Abstract). The process involves applying a first layer of this material, hardening a ring of it around the die to hold it in place, and then applying a second layer to "capture" the delicate bonding wires that connect the die to the PCB (ʻ550 Patent, col. 4:11-55). Crucially, some of the material between the die and the PCB can remain liquid, serving as a physical and thermal buffer to absorb stress during testing and operation (ʻ550 Patent, col. 11:1-4).
- Technical Importance: This multi-stage hardening process provided a method to securely mount and protect unpackaged die while mitigating thermal stress, potentially improving manufacturing yields and enabling the use of lower-cost components (ʻ550 Patent, col. 3:49-54).
Key Claims at a Glance:
- The complaint asserts infringement of "exemplary method claims" without specifying claim numbers (Compl. ¶11). Independent claim 1 is representative of the core method.
- 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 identify any accused products or processes by name (Compl. ¶¶11, 13). It refers to "Exemplary Defendant Products" that are detailed in "charts incorporated into this Count below" via Exhibit 2 (Compl. ¶¶11, 13). Exhibit 2 was not filed with the complaint.
Functionality and Market Context: The complaint alleges that Defendant directly infringes by "making, using, offering to sell, selling and/or importing" the accused products (Compl. ¶11). It further alleges that Defendant’s employees "internally test and use these Exemplary Products" (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the accused products' specific functionality or market context.
IV. Analysis of Infringement Allegations
The complaint references claim charts in an unprovided "Exhibit 2" and alleges that these charts demonstrate that the "Exemplary Defendant Products practice the technology claimed by the '550 Patent" (Compl. ¶13). No specific factual allegations mapping the accused processes to the claim elements are included in the body of the complaint. The infringement theory is based entirely on the incorporation by reference of these charts (Compl. ¶14).
No probative visual evidence provided in complaint.
- Identified Points of Contention: Given the lack of specific allegations, any infringement analysis will depend on facts developed during discovery. However, the claim language itself suggests potential areas of dispute:
- Scope Questions: The complaint's focus on "method claims" raises the question of whether Defendant performs all the required steps in the specified order (Compl. ¶11). The dispute may turn on whether Defendant's manufacturing process includes distinct steps of hardening a peripheral ring, covering it with a second layer, and then "capturing" wires within that second layer.
- Technical Questions: A central technical question will be whether the materials used in Defendant’s process qualify as "selectively settable material" as understood in the patent. A further question is whether Defendant’s process for protecting bonding wires constitutes "capturing" them in a second layer of material, as opposed to merely coating them.
V. Key Claim Terms for Construction
The Term: "selectively settable material" (Claim 1)
Context and Importance: This term is foundational to all asserted method claims. Its construction will determine what types of manufacturing processes fall within the patent's scope. A narrow construction could limit the claims to the specific UV-curable adhesives disclosed, while a broader construction could encompass other multi-stage hardening compounds.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims use the general term "selectively settable material" without further limitation. Dependent claim 6 explicitly narrows the material to "UV-settable materials," which, under the doctrine of claim differentiation, suggests the independent claim term is broader and not limited to just UV-settable types ('550 Patent, col. 11:7-9).
- Evidence for a Narrower Interpretation: The specification primarily describes the material as "UV material, i.e., material hardened by exposure to certain wavelengths of light" and specifically references "adhesives made by Dymax Corporation" ('550 Patent, col. 4:2-4, col. 3:64-66). An accused infringer may argue that the term should be limited to these disclosed embodiments.
The Term: "capturing bonding wires... in said second layer" (Claim 1)
Context and Importance: This term defines the specific mechanism for protecting the delicate wires connecting the chip to the board. Whether Defendant’s process meets this limitation will be a critical infringement question. Practitioners may focus on this term because the method of wire protection is a key point of novelty.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term "capturing" is not explicitly defined and could be argued to cover any process where the second layer secures the wires, even if they are not fully embedded.
- Evidence for a Narrower Interpretation: The specification describes this step as "placing part of the bonding wires (415) within the second layer of selectively settable material (416) and hardening the second layer" ('550 Patent, col. 8:35-39; Fig. 4b). This language, along with the accompanying figure, suggests a process where the wires are physically trapped or embedded within the material, not merely coated by it.
VI. Other Allegations
Indirect Infringement: The complaint does not contain allegations of induced or contributory infringement. It alleges only direct infringement (Compl. ¶11).
Willful Infringement: The complaint does not explicitly allege willful infringement. However, the prayer for relief requests that the case "be declared exceptional within the meaning of 35 U.S.C. § 285" (Compl., Prayer ¶E.i). Such a request is often predicated on allegations of willful infringement or litigation misconduct, but the complaint provides no factual basis, such as pre-suit knowledge of the patent, to support this claim.
VII. Analyst’s Conclusion: Key Questions for the Case
- Evidentiary Sufficiency: A threshold issue is the complaint's lack of factual detail. The case will depend entirely on evidence produced in discovery to identify the specific accused manufacturing processes and compare them to the patent's claims, as the complaint itself provides no basis for this analysis.
- Definitional Scope: The dispute will likely involve a significant claim construction battle over the meaning of "selectively settable material." The outcome will determine whether the patent is limited to the UV-cured adhesives of the 2002-2003 era or can read on a wider range of modern manufacturing compounds.
- Functional Equivalence: A core infringement question will be one of mechanical operation: does the accused process for protecting bonding wires perform the specific function of "capturing" them within a distinct second material layer, or does it use a technically different method, such as a single-application encapsulation, that falls outside the claimed steps?