DCT
2:22-cv-00373
Wiesblatt Licensing LLC v. MacNica Americas Inc
Key Events
Amended Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wiesblatt Licensing LLC (Texas)
- Defendant: Sony Group Corporation (Japan)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: Wiesblatt Licensing LLC v. Sony Group Corporation, 2:22-cv-00373, E.D. Tex., 02/03/2023
- Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas based on Defendant’s business activities in the state, its placement of products into the stream of commerce, and the “alien venue rule” applicable to foreign corporations.
- Core Dispute: Plaintiff alleges that Defendant’s Xperia smartphones infringe a patent related to power-efficient circuitry for transferring data using variable power supply voltages.
- Technical Context: The technology addresses power consumption in electronic devices by adjusting circuit operating voltages, a critical feature for extending battery life in mobile devices like smartphones.
- Key Procedural History: The complaint notes the inventor, Kesatoshi Takeuchi, is named on 674 U.S. patents originally assigned to Seiko Epson Corporation and that the patent-in-suit has been cited by patents issued to other industry participants.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Earliest Priority Date for U.S. Patent No. 8,396,112 |
| 2013-03-12 | U.S. Patent No. 8,396,112 Issued |
| 2023-02-03 | Plaintiff Files First Amended Complaint for Infringement |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,396,112 - "Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses"
- Patent Identification: U.S. Patent No. 8,396,112, "Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses," issued March 12, 2013.
The Invention Explained
- Problem Addressed: In systems that vary power supply voltage to save power, it becomes difficult to consistently convert multi-value analog data signals back into digital signals, because the reference voltages used for the conversion do not track the power supply changes. (’112 Patent, col. 1:30-34).
- The Patented Solution: The invention proposes a data transfer circuitry where the threshold voltages used for analog-to-digital (A/D) conversion are themselves generated from the variable power supply voltage. (’112 Patent, Abstract; col. 2:1-4). By making the reference level for data interpretation dependent on the overall supply voltage, the system can reliably decode analog signals even as the operating voltage fluctuates, thereby enabling both power savings and accurate data transfer. (’112 Patent, col. 2:4-9).
- Technical Importance: This approach allows for the use of power-saving variable voltage schemes without sacrificing the integrity of data communication between internal components, a key challenge in designing battery-powered electronics. (’112 Patent, col. 1:26-29).
Key Claims at a Glance
- The complaint asserts infringement of at least Claim 1. (Compl. ¶30).
- Independent Claim 1 requires:
- A variable power supply voltage generator for generating a variable power supply voltage.
- A transmitting circuit operative at the variable power supply voltage for generating and transmitting a multi-value analog signal.
- A receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal.
- A threshold voltage generator for generating threshold voltages used for the A/D conversion, where the threshold voltages are generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage.
- The complaint does not explicitly reserve the right to assert dependent claims, but the prayer for relief is broad. (Compl. ¶42).
III. The Accused Instrumentality
Product Identification
- The "Accused Instrumentalities" are identified as a "plurality of electronics with circuitry for transferring data," exemplified by the Sony Xperia 5 smartphone, including any augmentations or different versions of the platform. (Compl. ¶25).
Functionality and Market Context
- The complaint alleges the accused smartphones contain circuitry for data transmission between a host processor and memory, such as LPDDR5 RAM. (Compl. ¶30(i)). This circuitry is alleged to use a Power Management Integrated Circuit (PMIC) to generate variable power supply voltages (e.g., VDDQ, VDD2) that change from a minimum to a maximum value. (Compl. ¶30(ii)). The complaint provides a screenshot of the Sony webpage for the "Xperia 5 III" as a representative accused product. (Compl. ¶25, Figure 1).
- The complaint alleges Defendant generates substantial revenues from these products in the United States and Texas through various sales channels. (Compl. ¶¶5, 8, 12).
IV. Analysis of Infringement Allegations
’112 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a variable power supply voltage generator for generating a variable power supply voltage | The accused products provide a variable power supply voltage generator, such as a PMIC, for generating a variable power supply voltage (e.g., VDDQ and/or VDD2) that ranges from a minimum to maximum value. | ¶30(ii) | col. 2:56-58 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal to other circuits | The accused products provide a transmitting circuit that operates at the variable power supply voltage and generates a multi-value analog signal for transmission to other circuits, such as a receiver. | ¶30(iii) | col. 2:58-61 |
| a receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal | The accused products provide a receiving circuit that operates at the variable power supply voltage, receives the multi-value analog signal, and performs A/D conversion, utilizing a Decision Feedback Equalizer (DFE) system. | ¶30(iv) | col. 2:61-64 |
| a threshold voltage generator for generating threshold voltages used for the A/D conversion...the threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage | The accused products provide a threshold voltage generator that generates threshold voltages (e.g., VrefDQ) for A/D conversion. These threshold voltages are alleged to be generated from the variable power supply voltage (e.g., VDDQ), with VrefDQ varying with VDDQ. | ¶30(v) | col. 2:64-col. 3:4 |
- Identified Points of Contention:
- Technical Question: A central factual question is whether the accused Xperia smartphones' threshold voltage generator functions as alleged. The complaint asserts that a reference voltage (VrefDQ) used for A/D conversion "is derived from VDDQ such that it is generated from the variable power supply voltage VDDQ." (Compl. ¶30(v)). The case may turn on evidence demonstrating this specific relationship in the accused products' PMIC and memory interface circuits.
- Scope Question: The claim requires threshold voltages to be generated "from the variable power supply voltage or from a signal having a voltage value proportional to" it. The dispute may focus on what degree of correlation or what specific circuit implementation meets the "proportional to" requirement, as distinct from other methods of generating reference voltages that may be merely correlated with, but not directly generated from, the supply voltage.
V. Key Claim Terms for Construction
- The Term: "a signal having a voltage value proportional to the variable power supply voltage"
- Context and Importance: This term is critical because it defines the required link between the system's operating voltage and the reference voltage used for A/D conversion. The infringement analysis for the fourth element of Claim 1 hinges on whether the accused device's reference voltage (allegedly VrefDQ) is "proportional to" its supply voltage (allegedly VDDQ). Practitioners may focus on this term because modern power management systems can be complex, and the nature of the relationship between various voltage rails may not be a simple, direct proportion.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification describes the concept generally, stating that threshold voltages may be generated from "a voltage that changes in proportion to the variable power supply voltage Vvar." (’112 Patent, col. 9:37-39). This more general language could support an interpretation that does not require a specific circuit topology.
- Evidence for a Narrower Interpretation: The patent’s specific embodiments illustrate direct and simple proportional relationships. For example, Figure 5B shows a resistive voltage divider generating threshold voltages directly from a peak voltage Ep, which is itself proportional to the main supply voltage Vvar. (’112 Patent, Fig. 5B; col. 6:52-57). A party could argue that "proportional to" should be limited to such direct, linear relationships as explicitly disclosed in the preferred embodiments.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement of infringement under 35 U.S.C. § 271(b), asserting that Defendant's advertising and provision of the accused products encourages an infringing use. (Compl. ¶¶35-38). The allegations are not tied to specific documents like user manuals but to general commercial activities.
- Willful Infringement: The complaint alleges willfulness based on knowledge obtained from the service of the complaint in the litigation. (Compl. ¶34). It also alleges that Defendant was "willfully blind to the patent rights of Plaintiff" prior to the suit, asserting a practice of not performing patent clearance reviews before launching products. (Compl. ¶39).
VII. Analyst’s Conclusion: Key Questions for the Case
The resolution of this dispute may depend on the court’s determination of the following key questions:
A central evidentiary question will be one of technical operation: Can Plaintiff produce evidence to show that the reference voltage (VrefDQ) used for A/D conversion in the accused Sony Xperia smartphones is, in fact, "generated from" or "proportional to" the variable supply voltage (VDDQ) as alleged, or does it operate via a different, non-infringing mechanism?
A core issue will be one of definitional scope: How will the court construe the term "proportional to"? Will it be given a broad meaning covering any correlated voltage relationship, or will it be narrowed to the more direct, linear generation methods, such as a voltage divider, that are explicitly depicted in the patent's embodiments? The outcome of this construction could be dispositive of infringement.