DCT

1:00-cv-11544

Speedline Tech v. Nordson Corp

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:00-cv-11544, D. Mass., 10/10/2000
  • Venue Allegations: Venue is alleged to be proper based on Defendant Nordson conducting business within the District of Massachusetts.
  • Core Dispute: This is a declaratory judgment action where Plaintiff Speedline, a manufacturer of liquid dispensing systems, seeks a court declaration that its products do not infringe Defendant Nordson's patent and/or that Nordson's patent is invalid.
  • Technical Context: The technology relates to automated systems for precisely dispensing viscous materials, such as epoxy, in the high-volume manufacturing of semiconductor devices.
  • Key Procedural History: The complaint states that a case or controversy exists because Nordson has asserted that certain of Speedline's "XYFLEX" machines infringe one or more claims of the patent-in-suit.

Case Timeline

Date Event
1995-10-13 '682 Patent Priority Date
1999-05-25 '682 Patent Issue Date
2000-10-10 Amended Complaint for Declaratory Judgment Filed

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

U.S. Patent No. 5,906,682 - "Flip Chip Underfill System and Method"

  • Issued: May 25, 1999

The Invention Explained

  • Problem Addressed: In the high-precision manufacturing of circuit boards, particularly in "flip chip" applications, dispensing an exact amount of protective epoxy is critical. The patent identifies a key problem: the viscosity of the epoxy changes over time as it begins to cure, which alters its flow rate from the dispenser and makes it difficult to consistently apply the correct amount ('682 Patent, col. 2:46-54). Applying too little epoxy can lead to corrosion and component failure, while too much can interfere with other components on the board ('682 Patent, col. 2:32-41).
  • The Patented Solution: The invention is an automated dispensing system that actively compensates for changes in material viscosity. It incorporates a "weigh scale" located near the substrate. Periodically, the system dispenses a small test amount of the viscous material onto the scale, measures its weight, and calculates the current flow rate. A "closed loop control means" (e.g., a computer) uses this real-time flow rate to adjust operating parameters—such as the movement speed of the dispensing head over the circuit board—to ensure the desired amount of material is dispensed despite any changes in viscosity ('682 Patent, Abstract; col. 3:15-28). The system is illustrated in the block diagram of Figure 5, which shows the interrelation of the computer, weigh scale, and motion control components ('682 Patent, Fig. 5).
  • Technical Importance: This closed-loop feedback mechanism allows for highly accurate, automated dispensing in a mass-production environment by providing a way to dynamically account for and correct a critical process variable (viscosity change) that previously compromised manufacturing precision and yield ('682 Patent, col. 3:1-5).

Key Claims at a Glance

  • The complaint does not specify which claims Nordson has asserted, stating only that infringement of "one or more claims" has been alleged (Compl. ¶7). Independent claim 1 is representative of the core technology.
  • The essential elements of independent claim 1 include:
    • a dispensing element;
    • a viscous material reservoir;
    • a metering device coupled between the reservoir and the dispensing element for metering a variable amount of the viscous material;
    • positioner means for moving the dispensing element adjacent a surface of the substrate;
    • a "weigh scale" positioned and arranged adjacent the substrate for receiving a metered amount of the viscous material from the dispensing element and producing signals representative of a weight of the material dispensed during a predetermined time interval; and
    • "closed loop control means" for calculating a flow rate based on the signals from the weigh scale and for adjusting a speed of movement of the positioner means... to cause the dispensing element to dispense a desired amount of the material based on the calculated flow rate.
  • The complaint seeks a declaration of non-infringement as to the entire '682 patent (Compl., Prayer for Relief (b)).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are liquid dispensing systems manufactured and sold by Speedline under the trademark XYFLEX (Compl. ¶6).

Functionality and Market Context

The complaint describes the accused products only as "liquid dispensing systems" and does not provide technical details regarding their method of operation (Compl. ¶6). The complaint makes a specific denial that Speedline has "manufactured, used or sold any ovens which infringe the '682 patent," which may suggest that substrate heating capabilities are a potential area of dispute (Compl. ¶9).

IV. Analysis of Infringement Allegations

The complaint, being an action for declaratory judgment of non-infringement, does not contain detailed infringement allegations from the patent holder. Plaintiff Speedline makes a general assertion that its XYFLEX machines "do not include all of the elements of any claim of the '682 patent" (Compl. ¶9). As such, a detailed claim chart mapping alleged infringing functionality to claim elements cannot be constructed from the provided complaint.

  • Identified Points of Contention: Based on the patent's claims and the sparse allegations, the dispute may center on the following questions:
    • Technical Question: A foundational issue will be whether the accused XYFLEX systems employ a "weigh scale", or a structurally equivalent component, to receive a test dispense of material and generate weight-based signals for process control, as required by independent claims 1 and 11. The presence and function of this calibration feature is a cornerstone of the patented invention. The block diagram in Figure 5 of the '682 Patent illustrates the claimed relationship between the computer (30), the weigh scale (52), the positioner (32), and the metering valve (25) (Compl. Ex. A, '682 Patent, Fig. 5).
    • Technical Question: If the XYFLEX systems do use a weight-based feedback mechanism, a further question is whether they use that data to perform the specific function claimed. For instance, does the system's controller adjust the "speed of movement of the positioner means" as required by claim 1, or does it adjust the "rate of delivery of the metering device" as required by claim 11? The specific method of adjustment is a distinguishing feature between the independent claims.
    • Scope Question: Speedline’s specific denial regarding "ovens" (Compl. ¶9) suggests a possible dispute over heating elements. Claim 3, which depends from claim 1, adds a "non-contact heater means" for maintaining the substrate temperature. The dispute may involve whether this feature is present in the XYFLEX systems and whether Nordson's infringement allegations extend to dependent claims that require it.

V. Key Claim Terms for Construction

  • The Term: "closed loop control means"

    • Context and Importance: This term appears in claim 1 and is drafted in means-plus-function format. Its construction is governed by 35 U.S.C. § 112, ¶ 6 (pre-AIA) and is critical to defining the "intelligence" of the system. The scope of this term will determine what kind of controller and software configuration falls within the patent's monopoly.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The function is recited as "calculating a flow rate based on the signals from the weigh scale and for adjusting a speed of movement of the positioner means" ('682 Patent, col. 10:41-45). A party might argue that any computerized controller programmed to perform this specific algorithm is equivalent.
      • Evidence for a Narrower Interpretation: The corresponding structure disclosed in the specification is the "system computer 30" ('682 Patent, col. 6:12-18), which is described as a potentially "commercially available extended industry standard architecture ('EISA') personal computer" ('682 Patent, col. 6:45-49). A party could argue the term is limited to this specific computer architecture and its direct software equivalents, as depicted in Figure 5, which performs the claimed function.

  • The Term: "weigh scale"

    • Context and Importance: This is the key hardware component of the claimed feedback loop. Whether the accused XYFLEX systems contain a "weigh scale" will be a primary factual question in the infringement analysis.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term is used functionally in the claims to mean a device for "receiving a metered amount of the viscous material...and producing signals representative of a weight" ('682 Patent, col. 10:33-38). This language could support an interpretation covering any device that measures mass or weight to provide feedback for the control loop.
      • Evidence for a Narrower Interpretation: The specification discloses a specific, high-precision embodiment: a "Model No. DI-100 analytical weigh scale commercially available from Denver Instruments" that "utilizes digital circuitry for highly accurate measurements of minute weights" ('682 Patent, col. 6:1-8). An argument could be made that the term should be construed to require a similar analytical-grade calibration instrument, rather than any general-purpose weight sensor.

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

  • A central evidentiary question will be one of technical operation: Do the accused XYFLEX systems in fact incorporate the core inventive concept of the '682 patent—a closed feedback loop that uses a "weigh scale" to measure a test dispense, calculate a real-time flow rate, and dynamically adjust dispensing parameters to compensate for viscosity changes? The outcome may depend on detailed evidence of the process control mechanisms within the XYFLEX machines.
  • A key legal question will concern claim construction: The dispute will likely involve the scope of the means-plus-function term "closed loop control means". The court’s determination of the corresponding structure disclosed in the specification—the "system computer 30" and its associated programming—and whether the controller in the XYFLEX system is structurally equivalent will be critical to the infringement analysis.
  • The viability of the invalidity defense presents a third major question: Speedline alleges the '682 patent is invalid for anticipation, obviousness, and lack of enablement/written description (Compl. ¶8). This raises the question of whether the claimed combination of a weigh-scale feedback loop with an automated dispensing system was already known or would have been obvious to a person of ordinary skill in the art at the time of the invention.