DCT

5:23-cv-00570

Telefonaktiebolaget LM Ericsson v. Lenovo United States Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:23-cv-00570, E.D.N.C., 10/11/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of North Carolina because Defendants Lenovo USA and Motorola maintain offices and employees in the district, have committed acts of infringement there, and have previously argued for the propriety of this venue in other patent litigation.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile phones, tablets, and laptop computers infringe five patents covering a range of technologies, including semiconductor inductor design, on-chip filter arrangements, secure video delivery methods, and camera user interface controls.
  • Technical Context: The asserted patents relate to foundational hardware and software technologies that are critical to the performance, efficiency, and user experience of modern mobile and computing devices.
  • Key Procedural History: The complaint does not mention any prior litigation between the parties, Inter Partes Review (IPR) proceedings involving the asserted patents, or specific licensing history.

Case Timeline

Date Event
2004-03-03 U.S. Patent No. 7,151,430 Priority Date
2006-12-19 U.S. Patent No. 7,151,430 Issued
2008-09-05 U.S. Patent No. 10,972,654 Priority Date
2011-06-23 U.S. Patent No. 9,313,178 Priority Date
2011-06-23 U.S. Patent No. 11,122,313 Priority Date
2011-07-21 U.S. Patent No. 9,509,273 Priority Date
2016-04-12 U.S. Patent No. 9,313,178 Issued
2016-11-29 U.S. Patent No. 9,509,273 Issued
2021-04-06 U.S. Patent No. 10,972,654 Issued
2021-09-14 U.S. Patent No. 11,122,313 Issued
2023-10-11 Complaint Filed

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

U.S. Patent No. 7,151,430 - “Method of and Inductor Layout for Reduced VCO Coupling”

  • Issued: December 19, 2006

The Invention Explained

  • Problem Addressed: As electronic components are packed more densely onto a single semiconductor chip, radio frequency (RF) components like voltage-controlled oscillators (VCOs) can interfere with each other through electromagnetic (EM) coupling, which can degrade performance by creating spurious signals (’430 Patent, col. 1:25-40).
  • The Patented Solution: The patent discloses designing inductors—a key component of VCOs—with specific symmetrical shapes, such as a "figure-8" or "four-leaf clover." This geometry causes the magnetic fields generated by different loops within the same inductor to flow in opposing directions, largely canceling each other out at a distance and thereby reducing the mutual EM coupling between adjacent components (’430 Patent, Abstract; col. 2:6-12).
  • Technical Importance: This approach addresses a fundamental physics-based challenge in RF integrated circuit design, allowing for greater component density and miniaturization without sacrificing signal integrity.

Key Claims at a Glance

  • The complaint asserts independent method claim 11 by way of example (Compl. ¶28).
  • Claim 11 requires:
    • Forming a first inductor with a shape that is substantially symmetrical (including a first loop and an identical second loop arranged to cancel magnetic fields).
    • Connecting two closely spaced terminals to the first loop to supply current.
    • Positioning a second inductor at a predetermined distance from the first, such that the mutual EM coupling between them is reduced.
  • The complaint reserves the right to assert other claims (Compl. ¶26).

U.S. Patent No. 9,509,273 - “Transformer Filter Arrangement”

  • Issued: November 29, 2016

The Invention Explained

  • Problem Addressed: Radio front-end circuits in cellular devices traditionally require numerous, relatively expensive, and physically separate "off-chip" filters (like SAW filters) to isolate desired signals for different frequency bands. This increases the cost and size of the device (’273 Patent, col. 1:11-23).
  • The Patented Solution: The invention describes a transformer filter that can be integrated directly onto a semiconductor chip. The transformer's windings are divided into segments, with small reactive circuits (containing inductors) placed in series between them. Critically, these inductors are physically located inside the area enclosed by the transformer's main windings, creating a compact, area-saving layout that provides on-chip filtering to suppress unwanted harmonic frequencies (’273 Patent, Abstract; col. 9:36-49).
  • Technical Importance: This integrated design helps eliminate the need for external filter components, reducing manufacturing cost and physical footprint, which are critical goals for mobile device engineering.

Key Claims at a Glance

  • The complaint asserts independent apparatus claim 7 by way of example (Compl. ¶32).
  • Claim 7 requires a radio communication apparatus comprising a transformer filter arrangement, which includes:
    • A transformer with first and second windings that enclose an area.
    • At least one reactive sub-circuit with at least one inductor.
    • The first winding is divided into multiple segments.
    • A reactive sub-circuit is connected in series between two of the winding segments.
    • At least one inductor of that sub-circuit is "located in said area" enclosed by the windings.
    • The arrangement is tuned to pass a fundamental frequency and suppress at least one harmonic frequency.
  • The complaint reserves the right to assert other claims (Compl. ¶31).

U.S. Patent No. 9,313,178 - “Method and System for Secure Over-the-Top Live Video Delivery”

  • Issued: April 12, 2016
  • Technology Synopsis: The patent describes a system for securely delivering live streaming video over public networks (Over-the-Top, or OTT). To prevent a single compromised key from exposing an entire stream, the invention uses a series of rotating encryption keys with defined lifespans. The system provides a mechanism for client devices to be notified of upcoming key changes and securely retrieve the next key in the series, ensuring uninterrupted and secure playback (’178 Patent, Abstract).
  • Asserted Claims: Independent method claim 1 is asserted by example (Compl. ¶36).
  • Accused Features: The methods used by the Motorola Edge (2022) for handling secure video streaming are alleged to infringe (Compl. ¶35).

U.S. Patent No. 11,122,313 - “Method and System for Secure Over-the-Top Live Video Delivery”

  • Issued: September 14, 2021
  • Technology Synopsis: As a continuation of the same family as the ’178 Patent, this invention also details a method for secure OTT live video delivery using key rotation. It focuses on the client-side process, including receiving key identifiers and expiration times, detecting key rotation boundaries in the content stream, and requesting new keys from a license server before the current key expires to facilitate seamless decryption (’313 Patent, Abstract).
  • Asserted Claims: Independent method claim 1 is asserted by example (Compl. ¶40).
  • Accused Features: The methods used by the Motorola Edge (2022) for secure video stream playback are alleged to infringe (Compl. ¶39).

U.S. Patent No. 10,972,654 - “Controlling Image Capturing Setting of Camera Based On Direction Objected Is Dragged Along Touch Screen”

  • Issued: April 6, 2021
  • Technology Synopsis: The patent discloses a user interface method for controlling a camera setting (e.g., focus, brightness) on a mobile device. The system displays a control object on the touch screen; when a user drags this object in a first direction, the corresponding setting's value is increased, and when dragged in a second direction, it is decreased. This provides an intuitive, touch-based way to adjust camera parameters (’654 Patent, Abstract; Claim 1).
  • Asserted Claims: Independent apparatus claim 1 is asserted by example (Compl. ¶44).
  • Accused Features: The camera application on the Motorola moto g STYLUS 5G is alleged to infringe, presumably through its user interface for adjusting settings like focus or exposure (Compl. ¶43).

III. The Accused Instrumentality

Product Identification

  • The complaint broadly accuses Lenovo's "phones, tablets, laptop computers (including Chromebooks), and similar products and services" (Compl. ¶13). Specific representative products named are the Motorola Edge XT2205-1, Motorola Edge Plus XT2201-3, Motorola Edge (2022), and Motorola moto g STYLUS 5G (Compl. ¶26, 31, 35, 39, 43).

Functionality and Market Context

  • The complaint alleges that these products incorporate and use the technologies covered by the asserted patents (Compl. ¶13). It identifies specific products as infringing specific patents but does not provide detailed technical descriptions of how the accused products operate. The complaint also does not provide specific allegations regarding the commercial importance or market positioning of the accused products.

Visual Evidence

  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not publicly filed with the initial pleading (Compl. ¶28, 32). Therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

  • '430 Patent Infringement Allegations

    • The infringement theory for the ’430 Patent is based on the manufacture and design of semiconductor components within the accused products, such as the Motorola Edge XT2205-1 (Compl. ¶26-27). The complaint alleges that these products are made by a process that infringes claim 11, which would involve forming on-chip inductors with the claimed "substantially symmetrical" layout to reduce electromagnetic interference (Compl. ¶28). The core of this allegation rests on the physical design of the microelectronics inside the devices.
    • Identified Points of Contention:
      • Evidentiary Question: A central issue will be evidentiary. The allegations concern nanometer-scale structures on a semiconductor die. The plaintiff may need to present evidence from reverse engineering or internal design documents obtained in discovery to show that the inductors in the accused products actually have the specific symmetrical shape and EM-field-canceling properties required by the claims.
      • Scope Question: The dispute may turn on the meaning of "substantially symmetrical." The parties may contest whether this requires near-perfect geometric identity between inductor loops, as depicted in the patent's figures, or if it can be satisfied by a functional outcome of field cancellation, even with some geometric asymmetry.

  • '273 Patent Infringement Allegations

    • The infringement theory for the ’273 Patent targets the on-chip RF filtering architecture in products like the Motorola Edge Plus XT2201-3 (Compl. ¶31). The complaint alleges these products contain the claimed transformer filter arrangement, where inductors that form a part of a reactive filter are physically placed inside the area enclosed by the transformer's own windings to save space and provide harmonic suppression (Compl. ¶32).
    • Identified Points of Contention:
      • Technical Question: Infringement will depend on the actual physical layout of the RF front-end chips in the accused products. Does a transformer arrangement exist where an inductor from a series-connected sub-circuit is physically "located in said area" as required by the claim?
      • Functional Question: Beyond the structural layout, what evidence shows that the accused arrangement is "tuned... to suppress signals at least at one interfering frequency," as the claim requires? This raises a question of whether the accused circuit performs the specific filtering function claimed, or if it operates differently.

V. Key Claim Terms for Construction

  • For the '430 Patent (Claim 11):

    • The Term: "substantially symmetrical"
    • Context and Importance: This term defines the required shape of the inductor loops. Its construction is critical because infringement depends on whether the physical layout of an accused inductor meets this qualitative standard. Practitioners may focus on this term because its ambiguity creates a clear point of dispute between a structural and a functional interpretation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification emphasizes the functional purpose: "a magnetic field emanating therefrom tends to cancel a magnetic field emanating from the first loop" (’430 Patent, col. 2:10-12). This focus on the outcome of cancellation could support an interpretation where any shape achieving this functional goal is "substantially symmetrical."
      • Evidence for a Narrower Interpretation: The patent’s figures depict highly regular, geometrically precise shapes, such as a perfect "figure-8" (Fig. 2) and "four-leaf clover" (Fig. 10). These specific embodiments could be used to argue for a narrower definition tied to these ideal geometries.

  • For the '273 Patent (Claim 7):

    • The Term: "located in said area"
    • Context and Importance: This is a purely structural limitation that dictates the physical placement of the filter's inductor relative to the transformer's windings. The infringement case for this patent hinges on this physical arrangement. Practitioners may focus on this term because it presents a factual question that can potentially be resolved with clear evidence from chip imaging.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent’s stated purpose is to achieve an "area saving layout" (’273 Patent, col. 9:36-37). An argument could be made that any layout achieving this purpose, even with partial overlap, satisfies the "located in" requirement.
      • Evidence for a Narrower Interpretation: The patent's own figures provide strong evidence for a literal, physical containment requirement. Figure 10 unambiguously shows inductors (200a, 200b) placed entirely within the inner border (310) of the transformer winding (110), which strongly supports a narrow interpretation of complete physical placement inside the defined area.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement, such as knowledge or intent based on user manuals or other documentation.
  • Willful Infringement: The complaint does not explicitly allege willful infringement or reference pre-suit knowledge of the patents. It does, however, request a declaration that the case is "exceptional" under 35 U.S.C. § 285, which relates to an award of attorneys' fees and can be predicated on a finding of willful infringement or litigation misconduct (Compl., Prayer for Relief ¶(d)).

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

  • A central issue for the hardware-level patents ('430, '273) will be one of evidence and proof. Can the plaintiff, through discovery and technical analysis, demonstrate that the internal, nanometer-scale structures of the defendants' commercial chips literally meet the specific layout and placement limitations of the claims, such as the "substantially symmetrical" inductor shape ('430) and the inductor being "located in said area" ('273)?
  • The case will also present a question of definitional scope during claim construction. Will key structural terms be interpreted narrowly based on the patent's specific drawings, or more broadly based on their stated functional purpose? For example, is "substantially symmetrical" ('430 Patent) a matter of geometric precision or functional field cancellation?
  • A key strategic question concerns the breadth of the asserted technologies. The complaint joins claims on low-level chip design ('430, '273), systemic video encryption protocols ('178, '313), and user-facing software features ('654). The court will have to determine if these disparate inventions can be efficiently litigated and valued as a single cohesive case or if the dispute will effectively fragment into multiple, distinct sub-cases.