DCT
2:22-cv-00374
Wiesblatt Licensing LLC v. Sony Group Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wiesblatt Licensing LLC (Texas)
- Defendant: Sony Group Corporation (Japan) and Sony Group, LLC (Delaware)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:22-cv-00374, E.D. Tex., 09/27/2022
- Venue Allegations: Venue is alleged to be proper based on Defendant Sony Group, LLC maintaining a regular and established business presence in the district, and based on Defendant Sony Group Corporation being subject to personal jurisdiction and having regularly conducted business in the district.
- Core Dispute: Plaintiff alleges that Defendant’s Xperia smartphone products infringe a patent related to circuitry that manages data transfer in systems with a variable power supply.
- Technical Context: The technology addresses the challenge of reducing power consumption in electronic devices by varying supply voltage, while ensuring data can be reliably transferred and processed.
- Key Procedural History: The complaint notes that the patent-in-suit was originally assigned to Seiko Epson Corporation and has been cited during the prosecution of patents issued to other technology companies. The complaint also highlights that the patent claims were allowed over extensive prior art by three different patent examiners.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Earliest Priority Date for U.S. Patent 8,396,112 |
| 2013-03-12 | U.S. Patent 8,396,112 Issues |
| 2022-09-27 | Complaint Filed |
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,” issued March 12, 2013
The Invention Explained
- Problem Addressed: The patent’s background section describes the technical challenge of reliably converting multi-value analog data signals back into digital signals within a device that uses a variable power supply. As the supply voltage changes to conserve power, it can disrupt the reference points needed for accurate analog-to-digital (A/D) conversion, and transmitting high-frequency clock signals can create electronic noise. (’112 Patent, col. 1:29-42).
- The Patented Solution: The invention describes a system where both transmitting and receiving circuits operate using a variable power supply voltage. To solve the conversion problem, a “threshold voltage generator” creates the reference voltages needed for A/D conversion by deriving them directly from the variable power supply itself. This ensures that as the main system voltage fluctuates, the reference voltages for data conversion adjust proportionally, maintaining signal integrity. (’112 Patent, Abstract; col. 2:1-9; Fig. 1).
- Technical Importance: This design aims to enable power-saving techniques, like dynamic voltage scaling, without compromising the reliability of high-speed data transfer between components such as a CPU and memory. (’112 Patent, col. 1:26-29).
Key Claims at a Glance
- The complaint asserts independent Claim 1. (Compl. ¶27).
- The essential elements of Claim 1 are:
- 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 analog signal and performing A/D conversion to re-generate a digital signal; and
- A threshold voltage generator that generates threshold voltages for the A/D conversion, where these threshold voltages are generated from the variable power supply voltage or a signal proportional to it.
- The complaint alleges infringement of "the claims" of the patent, suggesting a potential future assertion of other claims. (Compl. ¶32).
III. The Accused Instrumentality
Product Identification
- The accused products are electronics with data transfer circuitry, with the complaint specifically identifying the Sony "Xperia 5 smartphone" as an exemplary instrumentality. (Compl. ¶22).
Functionality and Market Context
- The complaint alleges that the accused smartphones incorporate circuitry for transferring data between a host processor and memory, such as LPDDR5 RAM. (Compl. ¶27(i)). It further alleges these devices contain a Power Management Integrated Circuit (PMIC) that functions as a variable power supply voltage generator, a transmitter, a receiver utilizing a Decision Feedback Equalizer (DFE) for A/D conversion, and a threshold voltage generator. (Compl. ¶27). Figure 1 in the complaint displays a screenshot from Defendant's website for the "Xperia 5 III" smartphone. (Compl. Fig. 1, p. 6). The complaint does not contain allegations regarding the product's specific market positioning beyond its general availability for sale.
IV. Analysis of Infringement Allegations
8,396,112 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 allegedly provide a variable power supply voltage generator (identified as a PMIC) for generating a variable power supply voltage (identified as VDDQ and/or VDD2). | ¶27(ii) | col. 4:25-30 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal...; | The accused products allegedly provide a transmitting circuit operative at the variable power supply voltage, which generates and transmits a multi-value analog signal to other circuits. | ¶27(iii) | col. 4:34-36 |
| 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 allegedly provide a receiving circuit that operates at the variable power supply voltage, receives the multi-value analog signal, and performs A/D conversion using a DFE system to generate digital signals. | ¶27(iv) | col. 4:49-51 |
| 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 allegedly provide a threshold voltage generator that creates threshold voltages (identified as VrefDQ) for A/D conversion, with these voltages being generated from the variable power supply voltage (identified as VDDQ). | ¶27(v) | col. 2:1-9 |
- Identified Points of Contention:
- Technical Questions: The complaint maps claim elements to standardized components (e.g., PMIC, LPDDR5, DFE). A central question will be whether these components, in their actual operation within the Xperia smartphone, perform the specific functions as claimed. For instance, what evidence demonstrates that the VrefDQ signal in the LPDDR5 interface is used as the "threshold voltage" for "A/D conversion" in the manner required by the claim, and is it "generated from" the variable supply voltage VDDQ in the patented way?
- Scope Questions: The dispute may raise questions about the scope of the phrase "generated from the variable power supply voltage or from a signal having a voltage value proportional to" it. The complaint alleges VrefDQ is "usually ½ of VDDQ," which suggests proportionality. (Compl. ¶27(v)). The court may need to determine how direct this relationship must be and whether the accused implementation falls within that scope.
V. Key Claim Terms for Construction
- The Term: "threshold voltage generator"
- Context and Importance: This term describes a functional element, not necessarily a single, discrete component. Its construction is critical because the invention's novelty is tied to how these adaptive threshold voltages are created and used. The infringement analysis for this element will likely depend heavily on its construed meaning.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language itself defines the term functionally, requiring that it "generat[e] threshold voltages... from the variable power supply voltage or from a signal having a voltage value proportional to" it. (’112 Patent, cl. 1). This functional definition does not specify a particular circuit structure, which may support an interpretation that covers any circuit achieving the stated result.
- Evidence for a Narrower Interpretation: The specification discloses specific embodiments, such as a generator (156) comprising a "peak voltage filter" (158) and a "voltage distribution circuit" (159), which is illustrated as a resistor ladder. (’112 Patent, Figs. 5A-5B; col. 7:45-55). This may support an argument that the term should be construed more narrowly to require a structure analogous to those explicitly described, rather than any circuit that happens to produce a proportional voltage.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement, stating that Defendant has knowledge of the patent and performs acts that it "knew or should have known would induce actual infringements." (Compl. ¶33). The complaint also points to "advertising an infringing use" as an active step of inducement. (Compl. ¶35).
- Willful Infringement: The willfulness claim is based on alleged post-suit knowledge arising from the filing and service of the complaint. (Compl. ¶31). It is also alleged on a theory of willful blindness, based on Defendant’s purported "practice of not performing a review of the patent rights of others... prior to launching products." (Compl. ¶36).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of technical implementation: Can the plaintiff provide sufficient evidence to show that the standard components identified in the accused Xperia smartphone (e.g., PMIC, LPDDR5 memory controller) operate together to meet the specific functional requirements of Claim 1, particularly regarding how the threshold voltages for A/D conversion are generated and used?
- The outcome may also depend on a core issue of claim scope: Will the term "threshold voltage generator" be construed broadly based on its function, as recited in the claim, or will its meaning be narrowed by the specific filter and resistor-ladder embodiments detailed in the patent’s specification?