DCT
1:24-cv-11759
Ocean Semiconductors LLC v. Analog Devices Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Ocean Semiconductor LLC (Delaware)
- Defendant: Analog Devices, Inc. (Delaware, with a principal place of business in Massachusetts)
- Plaintiff’s Counsel: Arrowood LLP; Devlin Law Firm LLC
- Case Identification: 1:24-cv-11759, D. Mass., 08/09/2024
- Venue Allegations: Venue is alleged to be proper in the District of Massachusetts because Defendant is headquartered and maintains a regular and established place of business in Wilmington, Massachusetts, within the district.
- Core Dispute: Plaintiff alleges that Defendant’s semiconductor manufacturing processes, and the resulting integrated circuits, infringe a patent related to filtering industrial metrology data to improve automated process control.
- Technical Context: The technology concerns advanced process control (APC) in semiconductor fabrication, where automated systems use measurement data to adjust manufacturing tools in real-time to maximize production yield and device quality.
- Key Procedural History: The complaint alleges that Plaintiff placed Defendant on actual notice of the patent and its alleged infringement on November 25, 2020. The complaint also references Defendant's 2021 acquisition of Maxim Integrated Products, Inc., and contractual relationships with various third-party foundries as relevant to the infringement claims.
Case Timeline
| Date | Event |
|---|---|
| 2003-05-01 | U.S. Patent Application No. 10/427,620 Filing Date ('691 Patent) |
| 2004-12-28 | U.S. Patent No. 6,836,691 Issue Date |
| 2020-11-25 | Date Plaintiff alleges it placed Defendant on actual notice of patent |
| 2021-01-01 | Approximate date of Defendant's acquisition of Maxim Integrated |
| 2024-08-09 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 6,836,691 - "Method and Apparatus for Filtering Metrology Data Based on Collection Purpose", issued December 28, 2004 (’691 Patent)
The Invention Explained
- Problem Addressed: In a semiconductor fab, metrology (measurement) data is collected for multiple reasons, such as routine process control sampling and targeted fault detection. The patent asserts that when a process controller uses data collected for a special purpose (e.g., investigating a tool malfunction) to make routine adjustments, it can introduce unwanted variability and reduce the controller's effectiveness (’691 Patent, col. 2:17-26).
- The Patented Solution: The invention proposes a method where collected metrology data is associated with "context data," which includes "collection purpose data" indicating why the measurement was taken. A process controller can then use this purpose data to "filter" the measurements it considers, for example, by excluding data gathered for fault diagnosis when performing routine process control calculations, thereby improving the stability and performance of the automated system ('691 Patent, Abstract; col. 6:21-40). The overall workflow is depicted in the patent's Figure 2 ('691 Patent, Fig. 2).
- Technical Importance: This approach provides a systematic way to segregate data from "special cause" events (like a tool fault) from "common cause" process variation, which is critical for maintaining stable and reliable automated process control in a high-volume manufacturing environment ('691 Patent, col. 6:30-40).
Key Claims at a Glance
- The complaint asserts dependent claims 4 and 5, which incorporate all limitations of independent claim 1 (Compl. ¶29).
- The essential elements of independent method claim 1 are:
- collecting metrology data related to the processing of workpieces in a plurality of tools;
- generating context data for the metrology data, the context data including collection purpose data;
- filtering the metrology data based on the collection purpose data; and
- conducting a process control activity related to one of the tools based on the filtered metrology data.
- The complaint does not explicitly reserve the right to assert other claims.
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are the manufacturing processes and systems used by Defendant and its third-party foundry partners (such as Tower Semiconductor) to manufacture a broad portfolio of semiconductor devices ("Accused Products") (Compl. ¶¶4-5, 9, 11). These instrumentalities are identified as various metrology, process control, and fault detection systems, including those from third-party suppliers like Applied Materials, KLA, and Rockwell, as well as Defendant's proprietary systems (Compl. ¶¶4-5).
Functionality and Market Context
- The complaint alleges that the accused manufacturing processes involve the collection of metrology data, which is then associated with "collection purpose data" (Compl. ¶32). This data is allegedly filtered based on its stated purpose before being used to conduct a "process control activity" on one of the manufacturing tools (Compl. ¶32). These processes are used to manufacture a wide array of commercially significant products, including amplifiers, converters, processors, and sensors, for industries such as communications, automotive, and consumer electronics (Compl. ¶¶6-7). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references, but does not include, claim chart exhibits (Compl. ¶33). The infringement theory is summarized narratively.
’691 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| collecting metrology data related to the processing of workpieces in a plurality of tools | During manufacture, "metrology data related to the processing of workpieces in a plurality of tools is collected." | ¶32 | col. 5:46-51 |
| generating context data for the metrology data, the context data including collection purpose data | "Context data for the metrology data, including collection purpose data, is collected." | ¶32 | col. 6:15-17 |
| filtering the metrology data based on the collection purpose data | "The metrology data is filtered based on the collection purpose data." | ¶32 | col. 6:21-23 |
| conducting a process control activity related to one of the tools based on the filtered metrology data | "A process control activity related to one of the tools is conducted based on the filtered metrology data." | ¶32 | col. 6:23-30 |
- Identified Points of Contention:
- Scope Questions: A central question may be whether the data identifiers used in Defendant's manufacturing systems constitute "collection purpose data" as understood in the patent. The patent provides specific examples, such as "Process Control Sampling," "Fault Detection Sampling," and "Known Defective" ('691 Patent, col. 7, Table 1). The dispute may turn on whether the accused systems' data tags map onto these or similar concepts.
- Technical Questions: The complaint alleges that the accused systems perform "filtering" based on the "collection purpose data" (Compl. ¶32). A key factual question will be what evidence demonstrates that this specific filtering step occurs. The court will need to determine if the accused systems actually segregate or exclude data based on its collection purpose before a process control activity, or if data is filtered based on other criteria not covered by the claims.
V. Key Claim Terms for Construction
The Term: "collection purpose data"
Context and Importance: This term is the central inventive concept of the patent. The outcome of the case may hinge on whether the data tags or flags used in Defendant’s manufacturing systems are construed as "collection purpose data." Practitioners may focus on this term because its definition dictates whether the core of the infringement allegation has merit.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself is general, referring simply to data indicating the "purpose" of collection. This could support an argument that any data tag distinguishing one collection reason from another (e.g., "engineering lot" vs. "production lot") falls within the claim scope.
- Evidence for a Narrower Interpretation: The specification provides an exemplary table with specific codes for distinct purposes: "Process Control Sampling," "Fault Detection Sampling," "Targeted Fault Detection," "Fault Detection—no fault identified," and "Known Defective" ('691 Patent, col. 7, Table 1). A party could argue the term should be limited to data that distinguishes between routine monitoring and fault-related investigations, consistent with the problem described in the patent's background.
The Term: "filtering"
Context and Importance: The act of "filtering" is the key action that leverages the "collection purpose data." The infringement case depends on showing that Defendant's systems perform an action that meets the definition of this term.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party might argue that any act of excluding or separating data from a data set for a subsequent calculation, based on its collection purpose, constitutes "filtering."
- Evidence for a Narrower Interpretation: The specification describes filtering as a way to "improve the performance of the process controller by removing outlier data that exhibits variation from a source other than normal process variation" ('691 Patent, col. 6:34-37). This could support a narrower construction requiring that the filtering action be specifically tied to improving a process control model by excluding data associated with special causes of variation.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement, stating that Defendant instructs and encourages its third-party foundry partners to use the patented methods to manufacture Defendant's products (Compl. ¶¶35, 42). This is allegedly accomplished by providing technical specifications and development criteria that require the use of the infringing processes to meet quality standards (Compl. ¶44).
- Willful Infringement: The complaint alleges willful infringement based on Defendant having had actual notice of the ’691 Patent and its alleged infringement since "at least as of November 25, 2020" (Compl. ¶¶28, 48).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "collection purpose data", which the patent illustrates with examples distinguishing routine sampling from fault investigation, be construed to cover the types of data identifiers allegedly used in Defendant's and its partners' manufacturing control systems?
- A key evidentiary question will be one of technical proof: as the complaint’s infringement allegations largely track the language of the claims, the case will likely turn on whether Plaintiff can produce evidence showing that the accused systems perform the specific, sequential steps of the claimed method—particularly, the act of "filtering" data explicitly "based on" its "collection purpose" before conducting a process control activity.