Robinson v. Global Semiconductor Alliance

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Kay C Robinson Jr. (Michigan), Pro Se
  • Defendant: Global Semiconductor Alliance (GSA) (Texas)
  • Plaintiff’s Counsel: Plaintiff Pro Se
• Case Identification: 2:24-cv-11786, E.D. Mich., 07/10/2024
• Venue Allegations: The complaint does not contain specific allegations regarding the basis for venue in the Eastern District of Michigan. The plaintiff resides within the district.
• Core Dispute: Plaintiff, the inventor of a patent related to fiber-optic connections within logic circuits, alleges that various unnamed semiconductor companies are using his patented technology for optical computing to run Large Language Models (LLMs), and that the defendant industry alliance is involved by funding semiconductor research.
• Technical Context: The technology concerns the use of optical components (fiber optics, LEDs, photodiodes) to replace metallic wiring for data transmission between logic gates inside an integrated circuit, aiming to increase speed and efficiency.
• Key Procedural History: The complaint does not reference prior litigation or administrative proceedings. It notes that the patent application was posted on social media in 2019 and that the patent was granted in the third quarter of 2021.

Case Timeline

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

U.S. Patent No. 11,108,397 - "Fiber-Optic Connected Logic (FOCL)"

Issued August 31, 2021

The Invention Explained

• Problem Addressed: The patent addresses the performance limitations of traditional integrated circuits where electronic switches are connected by metallic conductors. It notes that propagation delays in transistors and diodes slow down the circuit's overall function. The invention aims to increase data speeds, lower power consumption, and reduce the possibility of faulty information transmission between logic gates. (’397 Patent, col. 1:22-33).
• The Patented Solution: The patent proposes replacing metallic conductors between logic gates on a chip with fiber-optic lines. In this design, a light signal is sent through a fiber-optic line to a photodiode, which acts as a switch. When activated by light, the photodiode connects a voltage to a transistor (such as a BJT or FET), turning it on. The transistor’s output then powers a light emitting diode (LED), which transmits the resulting signal as light through another fiber-optic line to the next logic gate in the circuit. (’397 Patent, Abstract; col. 2:37-47, Fig. 1b). This creates an optoelectronic pathway for data transmission within the integrated circuit.
• Technical Importance: The described approach seeks to overcome the inherent speed and power-consumption bottlenecks of purely electronic, on-chip communication by leveraging the advantages of optical data transmission. (’397 Patent, Abstract).

Key Claims at a Glance

The complaint does not identify any specific claims being asserted. Independent claim 1 is presented below for analytical purposes.

• Independent Claim 1:
  • A logic circuit comprising a plurality of logic gates.
  • A first logic gate includes a first bipolar junction transistor (BJT) and a first photodiode attached to the first BJT’s base.
  • A second logic gate includes a second BJT and a second photodiode attached to the second BJT’s base.
  • Light through a first fiber-optic line turns on the first photodiode, which connects a positive voltage to the first BJT base.
  • A first light emitting diode (LED) is attached to the output of the first logic gate to transmit light through a second fiber-optic line to the second photodiode.
  • Fiber-optic transmission lines connect the plurality of logic gates and transmit binary information as light between them.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not identify a specific accused product, method, or service. It broadly refers to technology used by "various semiconductor manufacturing companies for the purpose of optical and photonic computing to run LLM’s" and "optical computing hardware." (Compl. p. 5, 8).

Functionality and Market Context

The complaint does not provide technical details on the operation of any accused instrumentality. It alleges that the technology is being used to run "cloud programs that the industry does make a profit from." (Compl. p. 8). The defendant, Global Semiconductor Alliance (GSA), is not accused of making or selling any products but rather of being an organization that "pools their money into several central US based companies that give out funding to various universities and organizations for semiconductor research." (Compl. p. 5).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or provide a limitation-by-limitation analysis of infringement. Instead, it presents a narrative theory that the patented invention has been "used by various semiconductor manufacturing companies for the purpose of optical and photonic computing to run LLM's." (Compl. p. 5). The core of the allegation is an inference that because the patent relates to optical logic and certain modern computing tasks use "optical computing hardware," infringement must be occurring. (Compl. p. 8). The complaint does not connect any specific feature of any existing technology to the specific elements of any asserted claim.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Identification of an Infringing Act: A primary issue will be the complaint's failure to identify any specific product, process, or service that allegedly infringes the ’397 Patent. The allegations are directed at an entire industry and a general technological field rather than a particular instrumentality.
  • Defendant's Role: The complaint alleges that the defendant, an industry alliance, facilitates infringement by funding research. (Compl. p. 5). This raises the question of whether such activity could constitute direct, induced, or contributory infringement, none of which are explicitly pleaded with supporting factual allegations.
  • Technical Mismatch: Should an accused product be identified, a likely point of contention will be whether the general field of "optical and photonic computing" necessarily practices the specific architecture required by the claims, such as using a photodiode to switch a transistor that in turn drives an LED for on-chip communication.

V. Key Claim Terms for Construction

The complaint’s lack of a specific infringement theory makes any claim construction analysis preliminary. However, based on the technology, the following terms may be central.

• The Term: "logic circuit"

• Context and Importance: This term appears in the preamble of independent claims 1 and 5 and defines the overall invention. Its scope will determine what type of device can infringe. Practitioners may focus on this term because the defendant could argue that "optical and photonic computing" hardware does not meet the specific structural requirements of the claimed "logic circuit."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The specification describes the invention as an "electronic circuit design method that incorporates fiber optic lines between individual logic gates for transmitting data." (’397 Patent, col. 1:5-7). This language could support a construction covering a wide range of devices that implement this general method.
  • Evidence for a Narrower Interpretation: The claims recite a specific combination of components: a "plurality of logic gates," transistors, photodiodes, and LEDs connected in a particular way "within the logic circuit." (’397 Patent, cl. 1). The detailed embodiments exclusively show specific gate designs (e.g., AND, OR, NOT gates in Figs. 1-7). This could support a narrower construction limited to integrated circuits containing these specific optoelectronic logic gate structures.

• The Term: "fiber-optic transmission lines for connecting the plurality of logic gates within the logic circuit"

• Context and Importance: This limitation is the core of the invention, replacing metallic interconnects with optical ones. The term "within the logic circuit" is critical, as it may distinguish the invention from other uses of fiber optics in computing, such as connecting different circuit boards or servers.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: A plaintiff might argue the term should be read broadly to cover any use of fiber optics to link logical processing units that are part of a single functional circuit, regardless of physical scale.
  • Evidence for a Narrower Interpretation: The abstract repeatedly refers to communication "within the integrated circuit" and "within the circuit chip." (’397 Patent, Abstract). This language suggests the invention is directed at on-chip optical interconnects, which could support a construction that excludes board-level, chassis-level, or network-level optical connections.

VI. Other Allegations

• Indirect Infringement: The complaint does not explicitly allege inducement or contributory infringement. The allegations that Defendant GSA provides research funding to other entities could be interpreted as a potential basis for an inducement claim, but the complaint lacks any factual allegations of Defendant's knowledge of the ’397 patent or its specific intent to cause infringing acts. (Compl. p. 5).
• Willful Infringement: The complaint does not allege willful infringement and pleads no facts suggesting the Defendant had knowledge of the ’397 patent prior to the lawsuit.

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

• Pleading Sufficiency and Identification: A threshold issue is whether the complaint can survive a motion to dismiss given its failure to identify any specific accused product or infringing act. The case will depend on the plaintiff’s ability to connect his patent’s specific claims to a tangible technology in the marketplace.
• Liability of an Industry Alliance: A central legal question is whether an industry alliance, whose alleged role is limited to funding research, can be held liable for patent infringement. The viability of the case against this specific defendant hinges on whether its alleged activities meet the legal standards for direct or indirect infringement.
• Scope of the Patented Technology: If the case proceeds, a key technical question will be one of scope: does the general and rapidly evolving field of "optical and photonic computing" for AI applications actually implement the specific optoelectronic logic gate architecture claimed in the ’397 patent, or does it rely on fundamentally different technologies?