Helix Microinnovations LLC v. Penguin Solutions Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Helix Microinnovations LLC (Delaware)
  • Defendant: Penguin Solutions, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01581, D. Del., 12/31/2025
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant is incorporated in Delaware and has an established place of business in the District.
• Core Dispute: Plaintiff alleges that Defendant’s manufacturing processes for certain semiconductor products infringe a patent related to methods for fabricating Chip-on-Board modules.
• Technical Context: The dispute concerns manufacturing techniques for semiconductor memory modules, specifically methods that allow for the use of unpackaged semiconductor die to reduce costs.
• Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date	Event
2002-02-26	’550 Patent Priority Date
2007-07-03	U.S. Patent No. 7,238,550 Issues
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

The Invention Explained

• Problem Addressed: The patent addresses the need for low-cost methods of producing semiconductor devices, particularly by enabling the use of unpackaged and "less-than-perfect" semiconductor die that might otherwise be wasted (ʼ550 Patent, col. 1:46-54). It also notes that traditional high-heat testing processes can cause failures due to differing thermal expansion rates between the semiconductor chip and the printed circuit board (PCB) base (’550 Patent, col. 2:7-12).
• The Patented Solution: The invention describes a method for mounting an unpackaged die onto a PCB using "selectively settable liquids," such as UV-curable adhesives (’550 Patent, col. 3:62-65). A first layer of this material is used to tack the die to the board; a ring of this material around the die's periphery is hardened, while the material directly under the die may remain liquid to act as a physical and thermal buffer (’550 Patent, col. 11:1-5). A second layer of material is then applied over the first to "capture" the delicate bonding wires that electrically connect the die to the PCB, securing them in place and protecting them from damage or shorting (’550 Patent, col. 4:42-55).
• Technical Importance: This multi-step process using selectively hardened materials was designed to improve yields and reduce costs in Chip-on-Board manufacturing by providing a more controlled and protective method for handling unpackaged die and their associated bonding wires (’550 Patent, col. 1:55-65).

Key Claims at a Glance

• The complaint asserts infringement of at least the "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, 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.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

• The complaint refers to "Exemplary Defendant Products" without providing specific product names or model numbers (Compl. ¶11).

Functionality and Market Context

• The complaint alleges that the accused products "practice the technology claimed by the '550 Patent" but provides no specific details regarding their functionality, features, or manufacturing processes (Compl. ¶13). All substantive allegations are incorporated by reference from an "Exhibit 2," which was not filed with the complaint (Compl. ¶13-14). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are made by incorporating by reference a set of claim charts in "Exhibit 2" (Compl. ¶13). As this exhibit was not provided with the complaint, a detailed element-by-element analysis is not possible. The complaint’s narrative theory is that the "Exemplary Defendant Products" are fabricated using a process that satisfies all elements of the asserted claims (Compl. ¶13).

• Identified Points of Contention: Given the method claimed in the ’550 Patent, the infringement analysis will likely raise several technical and evidentiary questions:
  • Evidentiary Questions: What evidence will be presented to show that Defendant's manufacturing process for its Chip-on-Board modules involves the specific sequence of steps recited in Claim 1? Specifically, does the process use two distinct layers of settable material where the second layer is used for the express purpose of "capturing" bonding wires?
  • Scope Questions: Does the Defendant's manufacturing process, which may use modern encapsulants or epoxies, fall within the scope of the term "capturing bonding wires... in said second layer of selectively-settable material"? This raises the question of whether simply covering wires with a protective coating is the same as the patent’s more active process of placing and securing them within a manageable, then hardened, material.

V. Key Claim Terms for Construction

"selectively-settable material" (Claim 1)

• Context and Importance: This term defines the universe of materials whose use in the claimed process could be infringing. Its construction will determine whether the claims are limited to specific types of adhesives (e.g., UV-curable) or cover a broader range of modern industrial encapsulants and epoxies.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, not limiting the material to a specific chemical composition or setting mechanism. The specification refers to "selectively settable liquids, such as adhesives" generally, suggesting adhesives are an example, not a limitation (’550 Patent, col. 3:64-65).
  • Evidence for a Narrower Interpretation: The primary embodiment described throughout the specification uses "UV material, i.e., material hardened by exposure to certain wavelengths of light" (’550 Patent, col. 4:2-4). A defendant may argue that the invention is defined by this specific type of material, which allows for the differential curing (liquid underneath, solid ring on periphery) that the patent describes as a key feature.

"capturing bonding wires ... in said second layer" (Claim 1)

• Context and Importance: This term is central to the novelty of the claimed method. The definition of "capturing" will be a focal point of the infringement dispute. Practitioners may focus on this term because it distinguishes the invention from simply coating or encapsulating wires for protection.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: A plaintiff may argue "capturing" simply means to secure or encase the wires within the second layer, regardless of the precise physical mechanism.
  • Evidence for a Narrower Interpretation: The specification describes a specific process where wires are "carefully plac[ed]... within the second ring while the selectively settable material is still manageable and then hardening the ring" (’550 Patent, col. 4:47-50). This language may support an interpretation that "capturing" requires the affirmative step of positioning the wires within a soft or liquid material before it is hardened, rather than simply applying a coating over already-fixed wires.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of induced or contributory infringement. The sole count is for direct infringement (Compl. ¶11).
• Willful Infringement: The complaint contains no factual allegations to support a claim of willful infringement, such as pre-suit knowledge of the patent. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285, but the complaint body does not plead the predicate facts for such a finding (Compl., Prayer for Relief, E.i.).

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

The resolution of this dispute, based on the complaint, will likely depend on the answers to two central questions:

1. A primary question will be evidentiary: As the complaint’s substantive allegations rely on an unfiled exhibit, the case will turn on what discovery reveals about Defendant’s actual manufacturing processes. Can Plaintiff produce evidence that Defendant’s methods map onto the specific multi-step, two-layer material application and wire-capturing process recited in the patent’s claims?

2. A core issue will be one of claim scope: How will the court construe the term "capturing bonding wires"? The case may hinge on whether this term is interpreted narrowly to require the specific process of placing wires into a manageable material before hardening, as described in the patent's preferred embodiment, or broadly enough to read on more conventional methods of applying a general protective encapsulation over the chip and wires.