Heritage IP LLC v. Leviton Mfg Co

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Heritage IP LLC (Texas)
  • Defendant: Leviton Manufacturing Company (Delaware)
  • Plaintiff’s Counsel: Loaknauth Law, P.C.
• Case Identification: 2:22-cv-05869, E.D.N.Y., 09/30/2022
• Venue Allegations: Venue is alleged to be proper because Defendant maintains a place of business in the Eastern District of New York and has committed the alleged acts of infringement within the district.
• Core Dispute: Plaintiff alleges that Defendant’s DDE06-BLZ product infringes a patent related to programmable low-voltage reset circuits for electronic chips that use multiple power supplies.
• Technical Context: The technology addresses the need for reliable reset mechanisms in complex integrated circuits, such as microcontrollers, which must operate with multiple, different voltage levels to interface with various components.
• 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
2004-03-24	’200 Patent Priority Date
2007-05-22	’200 Patent Issue Date
2022-09-30	Complaint Filing Date

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

• Patent Identification: U.S. Patent No. 7,221,200, "Programmable Low Voltage Reset Apparatus for Multi-VDD Chips," issued May 22, 2007.

The Invention Explained

• Problem Addressed: The patent’s background section describes the limitations of conventional reset circuits, which are typically designed for a single power supply voltage (Vdd). Such circuits are inadequate for modern chips that use multiple, different power supply levels, as they cannot monitor for a voltage drop across more than one supply. (’200 Patent, col. 1:46-51). This creates a need for a reset system that can be adapted to various voltage levels and can trigger a reset when any one of several different power supplies fails. (’200 Patent, col. 1:51-54).
• The Patented Solution: The invention proposes a reset apparatus that is "programmable." It includes a programmable reference voltage generator and a "reset selector" that can be configured to monitor a specific power supply. (’200 Patent, Abstract). This allows a user to decide which power supply drop will trigger a reset and to set the specific voltage threshold for that trigger, providing flexibility for chips operating in complex, multi-voltage environments. (’200 Patent, col. 4:16-24). The system can be configured via firmware after power-up, allowing it to adapt to the specific needs of an application. (’200 Patent, col. 4:36-44).
• Technical Importance: This approach provided a flexible and integrated solution for ensuring data integrity and preventing network disruptions in devices with multiple power domains, which was critical as microcontrollers became more complex. (’200 Patent, col. 5:1-19).

Key Claims at a Glance

• The complaint asserts infringement of "at least one or more claims" without specifying them (Compl. ¶19). Independent claim 1 is representative:
• Independent Claim 1:
  • a programmable reference voltage generator for generating a programmable reference voltage according to a power supply voltage;
  • a low voltage signal generator coupled to the programmable reference voltage generator, the low voltage signal generator for generating a low voltage signal when the power supply voltage decreases below the programmable reference voltage; and
  • a reset selector coupled to the low voltage signal generator for selectively passing the low voltage signal as a reset signal in response to a reset selector control signal.

III. The Accused Instrumentality

• Product Identification: The complaint identifies at least "Leviton's DDE06-BLZ" as an Accused Product (Compl. ¶2).
• Functionality and Market Context: The complaint alleges that the Accused Product infringes by "implementing, without authorization, Heritage's proprietary technologies" (Compl. ¶2). It further states that the infringing nature of the product is "set forth in Exhibit B" (Compl. ¶19). As Exhibit B was not filed with the complaint, the public docket does not provide specific details on the technical functionality of the accused DDE06-BLZ product or its market context beyond the general allegation of infringement. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the Accused Products infringe one or more claims of the ’200 Patent, with the specific infringement theory detailed in an Exhibit B that is referenced but not included with the complaint (Compl. ¶19). The complaint itself does not contain a claim chart or specific allegations mapping claim elements to product features. Therefore, a detailed analysis of the infringement allegations is not possible from the complaint alone.

• Identified Points of Contention:
  • Evidentiary Question: The primary issue raised by the complaint is evidentiary. Without the referenced Exhibit B or an amended complaint, it is unclear which specific components or software routines within the Leviton DDE06-BLZ product are alleged to perform the functions of the "programmable reference voltage generator" and "reset selector" recited in the claims.
  • Technical Question: Once the infringement theory is detailed, a key technical question will be whether the accused circuitry operates in the manner required by the claims. For example, analysis will focus on whether the accused device allows for its reset voltage threshold to be programmed and whether it features a distinct "selector" for choosing which low-voltage signal triggers a system reset.

V. Key Claim Terms for Construction

The Term: "programmable reference voltage generator"

• Context and Importance: This term is foundational to the invention's core concept of adaptability. The definition of "programmable" will be critical. Practitioners may focus on this term because if it is construed narrowly to require user-level firmware control, it could be a significant hurdle for the plaintiff; a broader construction covering hardware-level configuration would favor a wider claim scope.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain language of claim 1 does not specify the means of programming, suggesting any method of setting or adjusting the reference voltage could suffice (’200 Patent, col. 6:1-3).
  • Evidence for a Narrower Interpretation: The specification repeatedly describes programming being performed by a "user" via "firmware" writing to a "configuration register" after power-up (’200 Patent, col. 4:18-20, 4:36-39). Figure 3 explicitly shows a "Register 70" for this purpose, which could support an argument that "programmable" implies software or firmware control, not just a fixed or hardware-set configuration.

The Term: "reset selector"

• Context and Importance: This term defines the mechanism for choosing which power supply fault triggers a reset. Its construction will determine what type of circuitry meets this limitation. The dispute may center on whether a simple logical gate combining signals constitutes a "selector," or if a more complex, configurable component is required.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: Claim 1 functionally defines the term as a component that "selectively pass[es] the low voltage signal as a reset signal" (’200 Patent, col. 6:4-7). This broad functional language could encompass any circuit that achieves this result.
  • Evidence for a Narrower Interpretation: The preferred embodiment describes a specific implementation using a multiplexer controlled by a flip-flop, which is itself set by a "power on reset (POR) signal" and can be configured by a user (’200 Patent, col. 3:6-12; Fig. 2). A party could argue that "selector" should be construed to require this ability to be configured, particularly after the initial power-up sequence.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides "instructions to enable and facilitate" direct infringement by its end-user customers (Compl. ¶23). It also alleges contributory infringement, asserting that the Accused Products are "specially designed to infringe," contain software components that are not staple articles of commerce, and have no substantial non-infringing uses (Compl. ¶24).
• Willful Infringement: Willfulness is alleged based on Defendant having knowledge of the ’200 Patent "at least as early as of the date of the filing of the Complaint" (Compl. ¶20). The complaint further alleges that Defendant "knew or should have known" of the patent or "deliberately took steps to avoid learning of those facts," suggesting a theory of willful blindness (Compl. ¶21).

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

1. An Evidentiary Question: The immediate central issue is the lack of a detailed infringement theory in the complaint itself. The viability of the case hinges on the specific allegations to be provided in the referenced (but unattached) Exhibit B or subsequent pleadings, which must articulate precisely how the accused Leviton DDE06-BLZ product is alleged to meet each limitation of the asserted patent claims.

2. A Claim Construction Question: A core legal issue will be one of definitional scope: how will the court construe the term "programmable"? The case may turn on whether the term is interpreted broadly to include any form of adjustability, or narrowly to require the specific user-controlled, firmware-based programmability that is emphasized in the patent's detailed description.

3. A Functional Question: Assuming the claim construction is resolved, a key factual question will be whether the accused product’s reset circuitry performs the specific function of the claimed "reset selector". The dispute will likely focus on whether the product merely combines multiple fault signals or if it includes a mechanism that "selectively" passes one signal over another in response to a "control signal," as required by the claim language.