DCT

2:07-cv-00497

SynQor Inc v. Artesyn Tech Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:07-cv-00497, E.D. Tex., 11/13/2007
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants conduct systematic and continuous business in the district and make, use, sell, or import the accused products within the district, targeting customers who are reasonably expected to sell products containing the accused technology into the district.
  • Core Dispute: Plaintiff alleges that Defendants’ DC/DC power converters, specifically bus converters and point-of-load converters used in intermediate bus architecture power supply systems, infringe three patents related to high-efficiency power conversion technology.
  • Technical Context: The technology at issue involves DC-DC power converters, which are fundamental components in modern electronics for efficiently converting direct current from one voltage level to another, particularly in the telecommunications and computing industries.
  • Key Procedural History: The patents-in-suit claim priority to an application filed in 1997 and have undergone extensive prosecution, including multiple continuations and divisional applications, suggesting a mature and strategically developed patent portfolio. The provided patent documents also include multiple reexamination certificates, indicating that the patents have been subject to post-grant validity challenges at the USPTO.

Case Timeline

Date Event
1997-01-24 Earliest Priority Date for '190, '021, and '034 Patents
2006-07-04 U.S. Patent No. 7,072,190 Issued
2007-09-11 U.S. Patent No. 7,269,034 Issued
2007-09-18 U.S. Patent No. 7,272,021 Issued
2007-11-13 Complaint Filed

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

U.S. Patent No. 7,072,190 - "High Efficiency Power Converter"

  • Patent Identification: U.S. Patent No. 7,072,190, "High Efficiency Power Converter", issued July 4, 2006 (Compl. ¶20; ’190 Patent, cover).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies energy dissipation and inefficiency in conventional switching power converters as a primary technical challenge. Specifically, it notes the conduction loss from diodes used for rectification and the difficulties in implementing more efficient "synchronous rectifiers" (transistors) in high-frequency converters, including providing properly timed control signals and minimizing switching losses ('190 Patent, col. 1:36-62).
  • The Patented Solution: The invention claims a power converter architecture comprising a "non-regulating isolation stage" followed by separate "non-isolating regulation stages." The isolation stage uses a unique topology with plural controlled rectifiers (e.g., MOSFETs) whose control signals are cross-coupled from opposite secondary transformer windings. This design aims to simplify control and "nearly losslessly" recover energy from parasitic circuit elements during switching transitions, thereby increasing overall efficiency ('190 Patent, Abstract; col. 2:4-18; Fig. 3).
  • Technical Importance: This approach sought to significantly improve the efficiency of DC-DC converters, a key factor in reducing waste heat, physical size, and cost for densely packed electronics used in the computing and telecommunications markets ('190 Patent, col. 1:26-35).

Key Claims at a Glance

  • The complaint does not specify which claims of the '190 patent are asserted, stating only that accused products "are used to practice the claims of the '190 patent" (Compl. ¶25).
  • A representative independent claim, Claim 1, includes the following essential elements:
    • A DC power source;
    • A non-regulating isolation stage comprising a primary transformer winding circuit and a secondary transformer winding circuit, where the secondary circuit has "plural controlled rectifiers" (each with a parallel uncontrolled rectifier) that are turned on and off in synchronization with the primary winding's voltage waveform, which has a "fixed duty cycle" and short transition times; and
    • A plurality of "non-isolating regulation stages" that receive the output from the isolation stage and regulate it, while the fixed duty cycle of the isolation stage is maintained.

U.S. Patent No. 7,272,021 - "Power Converter with Isolated and Regulation Stages"

  • Patent Identification: U.S. Patent No. 7,272,021, "Power Converter with Isolated and Regulation Stages", issued September 18, 2007 (Compl. ¶21; ’021 Patent, cover).

The Invention Explained

  • Problem Addressed: The patent addresses the need for efficient power conversion in systems using an "Intermediate Bus Architecture" (IBA). A key challenge in such systems is maintaining safe and stable operation during non-standard conditions, such as device startup or a short-circuit, which may require reducing the converter's duty cycle and introducing "freewheeling periods" that interrupt continuous power flow ('021 Patent, col. 2:20-24).
  • The Patented Solution: The invention describes a power converter system with a "normally non-regulating isolation stage" designed for "substantially uninterrupted flow of power" during normal operation. This highly efficient isolation stage is followed by one or more separate, non-isolating regulation stages. A control circuit manages the duty cycle, reducing it from its normal-operation state only to handle conditions like startup or current limiting, thereby ensuring both high efficiency and robust protection ('021 Patent, Abstract; col. 2:5-19).
  • Technical Importance: This architecture enables a modular and efficient power distribution system where a single, optimized bus converter can supply an intermediate voltage to multiple local point-of-load (POL) regulators, a design that became prevalent in complex digital systems ('021 Patent, Fig. 5; col. 2:45-51).

Key Claims at a Glance

  • The complaint does not specify which claims of the '021 patent are asserted (Compl. ¶30).
  • A representative independent claim, Claim 1, includes the following essential elements:
    • A "normally non-regulating isolation stage" comprising primary and secondary winding circuits with controlled rectifiers, providing a "normally non-regulated output";
    • A control circuit that controls the duty cycle of the primary winding to cause "substantially uninterrupted flow of power" during "normal operation"; and
    • A plurality of "non-isolating regulation stages" that receive the non-regulated output and perform final regulation.

U.S. Patent No. 7,269,034 - "High Efficiency Power Converter"

  • Patent Identification: U.S. Patent No. 7,269,034, "High Efficiency Power Converter", issued September 11, 2007 (Compl. ¶22; '034 Patent, cover).
  • Technology Synopsis: The '034 patent discloses a DC-DC converter system having an "isolation/semi-regulation" stage that provides a semi-regulated output whose voltage drops as current flow increases. This output is then fed to plural non-isolating switching regulators for final voltage control. The system features a control circuit that senses a voltage within the primary winding circuit, enabling a feedback mechanism that does not need to cross the galvanic isolation barrier ('034 Patent, Abstract; Claim 1).
  • Asserted Claims: The complaint does not specify which claims are asserted (Compl. ¶35). Independent claims include 1 and 21.
  • Accused Features: The complaint alleges that "semi-regulated bus converters and/or POLs used in intermediate bus architecture power supply systems" infringe the patent (Compl. ¶34).

III. The Accused Instrumentality

Product Identification

The complaint accuses broad categories of products, including "unregulated and semi-regulated bus converters" and "non-isolated point of load converters ('POLs')" (Compl. ¶5, ¶17). These components are alleged to be used within "intermediate bus architecture power supply systems" (Compl. ¶5). No specific product models are identified.

Functionality and Market Context

Based on the allegations, the accused products are components within a distributed power architecture. The bus converters are alleged to perform an initial DC-DC conversion to an intermediate voltage, and the POL converters perform a subsequent conversion to a final voltage required by a load, such as a microprocessor. The complaint states these products are sold to "computer and telecommunications equipment manufacturers" (Compl. ¶17).

IV. Analysis of Infringement Allegations

The complaint provides only conclusory allegations of infringement and does not contain specific factual assertions that map elements of the patent claims to features of the accused products. For example, the complaint states that the defendants infringe but does not explain how any particular product meets any specific claim limitation (Compl. ¶¶ 24, 29, 34). This form of notice pleading, while common at the time of filing, does not provide sufficient detail for a formal claim-chart analysis. No probative visual evidence provided in complaint.

Identified Points of Contention

  • Scope Questions: A primary point of contention will likely revolve around the characterization of the accused products. The infringement analysis for the '190 and '021 patents will depend on whether the accused bus converters are properly classified as "non-regulating" or "normally non-regulating." Defendants may argue that their products perform some degree of regulation at all times, placing them outside the literal scope of claims that require a functional separation between the isolation and regulation stages.
  • Technical Questions: A key technical question for the '190 patent is whether the accused converters utilize the claimed "cross-coupled" control scheme for their synchronous rectifiers or employ an alternative control method. For the '021 patent, a factual dispute may arise over whether the accused products are designed for "substantially uninterrupted flow of power" during "normal operation," as the claim requires, or if their standard operation involves periodic interruptions not contemplated by the patent.

V. Key Claim Terms for Construction

The Term: "non-regulating isolation stage" ('190 Patent, Claim 1)

  • Context and Importance: This term is foundational to the claimed two-stage architecture in the '190 patent. The viability of the infringement claim depends on whether the accused bus converters meet this definition. Practitioners may focus on this term because Defendants will likely argue their products are not "non-regulating."
  • Intrinsic Evidence for a Broader Interpretation: The specification distinguishes this stage functionally from a "regulation stage" (e.g., '190 Patent, Fig. 1), and its purpose is described as providing the "isolation and/or step-down (or step-up) function" ('190 Patent, col. 4:38-39). A party could argue the term means the stage's primary purpose is not regulation, and it does not preclude incidental voltage variations.
  • Intrinsic Evidence for a Narrower Interpretation: The claim recites that the separate "regulation stages" are what perform the act of "regulating a regulation stage output" ('190 Patent, col. 18:40-41). A party could argue that if the isolation stage performs any active regulation, it cannot be considered "non-regulating."

The Term: "substantially uninterrupted flow of power" ('021 Patent, Claim 1)

  • Context and Importance: This phrase defines the required mode of "normal operation" for the claimed isolation stage, distinguishing it from non-normal operation where "freewheeling periods" are introduced. The infringement question will turn on whether the accused products operate in this manner.
  • Intrinsic Evidence for a Broader Interpretation: The use of the word "substantially" suggests that minor, inherent interruptions, such as those occurring during brief switching transitions, do not remove a device from the claim's scope. The patent contrasts this state with the deliberate introduction of "freewheeling periods" during startup or short-circuits ('021 Patent, col. 2:20-24).
  • Intrinsic Evidence for a Narrower Interpretation: A party could argue that any operational mode that does not involve a 100% duty cycle inherently includes interruptions in power flow. An accused infringer might contend that its products' normal operation includes periodic "off" times for other control purposes, and that these regular interruptions are sufficient to fall outside the meaning of "substantially uninterrupted."

VI. Other Allegations

Indirect Infringement

The complaint includes boilerplate allegations of active inducement and contributory infringement (e.g., Compl. ¶¶ 24-25, 29-30). It alleges that the accused products are "especially made or adapted for use in an infringement" and are not "staple articles or commodities of commerce suitable for substantial non-infringing uses" (Compl. ¶25). The complaint does not, however, allege specific facts to support the knowledge and intent elements required for such claims.

Willful Infringement

Willfulness is alleged in a single conclusory paragraph, stating that "On information and belief, Defendants' infringement of the patents-in-suit has been and/or will continue to be willful and deliberate" (Compl. ¶107). The complaint provides no factual basis for this allegation, such as evidence of pre-suit knowledge of the patents.

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

  • A central issue will be one of definitional scope: can the terms "non-regulating" ('190 patent) and "normally non-regulating" ('021 patent) be construed to cover the accused commercial bus converters? The case will likely depend on whether these terms are interpreted to mean a complete absence of regulation in the isolation stage or merely that regulation is not its primary, intended function.
  • A key evidentiary question will be one of operational correspondence: assuming a favorable claim construction, what evidence will show that the accused products actually operate in the specific manner required by the claims? The conclusory nature of the complaint leaves the technical details of the accused products—such as their rectifier control schemes and power-flow characteristics during normal operation—as entirely open questions to be resolved through discovery and expert testimony.