DCT

2:22-cv-00481

Network System Tech LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-00481, E.D. Tex., 12/19/2022
  • Venue Allegations: Venue is alleged as proper for the domestic Samsung entities based on their regular and established places of business within the Eastern District of Texas. For the foreign defendants (Samsung Electronics Co., Ltd., Lenovo, and OnePlus), venue is asserted under the alien-venue statute.
  • Core Dispute: Plaintiff alleges that Defendants’ system-on-a-chip (SoC) products, which are incorporated into a wide range of consumer electronics, infringe six patents related to technologies for managing communication and data exchange within an integrated circuit.
  • Technical Context: The technology at issue is Network-on-Chip (NoC), an architecture for managing communication between processors, memory, and other functional blocks on a single complex semiconductor chip.
  • Key Procedural History: The complaint alleges that the asserted patents originated from research and development at Philips Semiconductors. To support allegations of pre-suit knowledge and willfulness, the complaint repeatedly asserts that the patents-in-suit were cited during the prosecution of patent applications later assigned to or prosecuted by Samsung.

Case Timeline

Date Event
2002-10-08 Earliest Priority Date (’818, ’449, '9893 Patents)
2004-03-17 Earliest Priority Date (’052 Patent)
2004-05-18 Earliest Priority Date (’800 Patent)
2005-04-21 Earliest Priority Date ('2893 Patent)
2006-05-16 Filing Date of Samsung U.S. Patent Application 11/434,188
2006-08-31 Filing Date of Samsung U.S. Patent Application 11/513,021
2007-01-11 Filing Date of Samsung U.S. Patent Application 11/652,010
2008-04-29 U.S. Patent No. 7,366,818 Issues
2008-05-13 U.S. Patent No. 7,373,449 Issues
2009-01-27 Alleged date of Samsung's actual knowledge of '449 Patent
2009-09-22 U.S. Patent No. 7,594,052 Issues
2010-03-01 Filing Date of Samsung U.S. Patent Application 12/659,218
2010-08-03 U.S. Patent No. 7,769,893 Issues
2011-02-22 Alleged date of Samsung's actual knowledge of '9893 Patent
2011-04-15 Alleged date of Samsung's actual knowledge of '052 Patent
2011-12-06 U.S. Patent No. 8,072,893 Issues
2011-12-27 U.S. Patent No. 8,086,800 Issues
2022-12-19 Complaint Filed

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

  • Patent Identification: U.S. Patent No. 7366818, "INTEGRATED CIRCUIT COMPRISING A PLURALITY OF PROCESSING MODULES AND A NETWORK AND METHOD FOR EXCHANGING DATA USING SAME," Issued April 29, 2008.

  • The Invention Explained:

    • Problem Addressed: The patent's background describes that as on-chip systems become more complex, traditional communication methods like buses become bottlenecks, and ensuring that data transactions are completed without expensive end-to-end flow control becomes a challenge (’818 Patent, col. 1:17-40, col. 5:7-13).
    • The Patented Solution: The invention proposes a system where an "interface means" sits between a processing module and the on-chip network. This interface includes a "dropping means" that can selectively drop data to manage data flow and control transaction completion, providing a lower-cost alternative to a fully guaranteed, non-dropping network connection (’818 Patent, Abstract; col. 6:30-44).
    • Technical Importance: This approach provided a method for managing data transactions in complex SoCs that could be less resource-intensive than implementing full end-to-end flow control for all communications (Compl. ¶27).

  • Key Claims at a Glance:

    • The complaint asserts independent claim 1 (Compl. ¶181).
    • Essential elements of claim 1 include:
      • An integrated circuit comprising a plurality of processing modules on the same chip and a network-on-chip for communication.
      • The connection supports transactions with outgoing and return messages.
      • The integrated circuit comprises at least one "dropping means (DM)" for dropping data.
      • At least one "interface means" manages the interface between a module and the network.
      • The interface means itself comprises a first "dropping means (DM)".
      • The dropping of data and transaction completion can be controlled by the interface means.
    • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

  • Patent Identification: U.S. Patent No. 7373449, "APPARATUS AND METHOD FOR COMMUNICATING IN AN INTEGRATED CIRCUIT," Issued May 13, 2008.

  • The Invention Explained:

    • Problem Addressed: As SoCs grew more complex, different communication tasks required different service levels (e.g., high-throughput for video vs. low-latency for control), making a single, uniform network connection inefficient (’449 Patent, col. 7:25-32).
    • The Patented Solution: The patent describes a system for establishing tailored on-chip connections. A module requests a connection with "desired connection properties" from a "communication manager." This manager forwards the request to a "resource manager," which determines if network resources are available to support those properties and, if so, establishes the customized connection (’449 Patent, Abstract; col. 7:39-55).
    • Technical Importance: This invention enabled more efficient use of on-chip network resources by creating connections with specific, configurable properties tailored to the application's needs (Compl. ¶39).

  • Key Claims at a Glance:

    • The complaint asserts independent claim 10 (Compl. ¶206).
    • Essential steps of method claim 10 include:
      • A first module issuing a request for a connection with desired connection properties to a communication manager.
      • The communication manager forwarding the request to a resource manager.
      • The resource manager determining whether a target connection with the desired properties is available.
      • The resource manager responding with the availability of the target connection.
      • Establishing the target connection based on the available properties.
    • The complaint does not explicitly reserve the right to assert dependent claims for this patent.

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 7594052, "INTEGRATED CIRCUIT AND METHOD OF COMMUNICATION SERVICE MAPPING," Issued September 22, 2009 (Compl. ¶58).
    • Technology Synopsis: The patent describes a method for offering differentiated communication services within an SoC. It discloses mapping a requested service, which is identified by specific properties and an identifier (like a communication thread or memory address range), to a specific on-chip connection that has a corresponding set of properties (Compl. ¶60-61).
    • Asserted Claims: Independent claim 6 is asserted (Compl. ¶231).
    • Accused Features: The complaint accuses SoCs that offer differentiated intermodular communication services based on connections with corresponding properties (Compl. ¶60).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 7769893, "INTEGRATED CIRCUIT AND METHOD FOR ESTABLISHING TRANSACTIONS," Issued August 3, 2010 (Compl. ¶81).
    • Technology Synopsis: The patent addresses address mapping in SoCs. It describes a method where an "address translation unit," part of a network interface, takes a message request containing two separate pieces of information (one for the target module's location, one for the location within that module) and arranges them into a single address to determine the routing and final destination (Compl. ¶¶83-84).
    • Asserted Claims: Independent claim 4 is asserted (Compl. ¶256).
    • Accused Features: The complaint targets SoCs that use an address translation unit for address mapping to determine both the location of a receiving module and a location within that module (Compl. ¶83).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8072893, "INTEGRATED CIRCUIT WITH DATA COMMUNICATION NETWORK AND IC DESIGN METHOD," Issued December 6, 2011 (Compl. ¶102).
    • Technology Synopsis: The patent describes a technique to improve data communication speed and synchronization in an SoC. The method involves identifying a communication channel with a data transfer delay exceeding a threshold and then introducing a calculated delay (a multiple of the data packet size, N) onto that channel to maintain synchronization across the network (Compl. ¶¶104-105).
    • Asserted Claims: Independent claims 1 and 10 are asserted (Compl. ¶¶281-282).
    • Accused Features: The complaint targets SoCs that use packetized data and introduce a correlated delay on a communication channel for synchronization purposes (Compl. ¶104).

  • Multi-Patent Capsule:

    • Patent Identification: U.S. Patent No. 8086800, "INTEGRATED CIRCUIT AND METHOD FOR BUFFERING TO OPTIMIZE BURST LENGTH IN NETWORKS ON CHIPS," Issued December 27, 2011 (Compl. ¶123).
    • Technology Synopsis: This patent relates to optimizing data transfers in SoCs. The invention uses "wrappers" at both the requesting (master) and responding (slave) modules' network interfaces. These wrappers buffer data until an "optimal amount" is accumulated before transferring it across the interconnect as a single, efficient burst (Compl. ¶¶125-126).
    • Asserted Claims: Independent claim 10 is asserted (Compl. ¶311).
    • Accused Features: The complaint targets SoCs that employ data buffering at both master and slave modules to buffer data into optimal amounts for transfer (Compl. ¶125).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are broadly defined as system-on-a-chip (SoC) products, including Qualcomm Snapdragon SoCs and Samsung Exynos SoCs, as well as the end-user electronic devices that incorporate them (Compl. ¶¶21, 147). The complaint lists numerous product lines from Samsung, Lenovo, and OnePlus, such as Samsung's Galaxy phones and tablets, Lenovo's ThinkPad laptops and Motorola phones, and various OnePlus smartphone models (Compl. ¶¶152, 161, 170). The complaint includes a table listing Samsung Accused Products, including Exynos processors and devices containing them (Compl. ¶152).
  • Functionality and Market Context: The complaint alleges that the accused SoCs incorporate Arteris interconnect technology or a derivative thereof, which functions as a network-on-chip (NoC) to manage communication between the various processing cores, memory, and other functional blocks on the chip (Compl. ¶¶145, 148, 150). The complaint asserts that this interconnect efficiency is a "dominant factor in determining overall SoC system performance, size, and cost" for the widely used consumer electronics that contain these SoCs (Compl. ¶¶144-145).

IV. Analysis of Infringement Allegations

The complaint does not contain claim charts in its body but incorporates them by reference as exhibits that were not provided for this analysis. The infringement theories are therefore summarized from the complaint's narrative allegations.

'818 Patent Infringement Allegations

The complaint's infringement theory appears to map the functionality of the Arteris interconnect technology within the accused SoCs to the elements of claim 1 (Compl. ¶181). It alleges that the interface between processing modules and the on-chip network in the accused products performs the function of the claimed "interface means." The core of the allegation suggests that the methods used by this technology to manage network traffic and potential data overflow, such as flow control or throttling, constitute the claimed "dropping means" that controls transaction completion (Compl. ¶26).

'449 Patent Infringement Allegations

The complaint alleges that the accused SoCs practice the patented method for establishing connections with specific properties (Compl. ¶206). The infringement theory posits that the Arteris interconnect technology includes a system for managing network resources that corresponds to the claimed method. This system allegedly allows different modules on the SoC to request and establish connections with particular characteristics (e.g., quality of service, bandwidth), which is alleged to map to the claimed steps of a module issuing a request to a "communication manager," which then interacts with a "resource manager" to allocate network resources and establish the connection (Compl. ¶38-39).

Identified Points of Contention

  • Scope Questions: For the ’818 Patent, a primary question of scope may be whether network management techniques like back-pressure or flow control, which temporarily halt data transmission rather than discard it, fall within the meaning of the term "dropping means." For the ’449 Patent, a key question will be whether the accused SoCs' integrated resource management architecture can be mapped onto the distinct "communication manager" and "resource manager" entities recited in the claim.
  • Technical Questions: What evidence does the complaint provide that the accused products' alleged "dropping means" is controlled by the "interface means" to manage "transaction completion" as required by claim 1 of the ’818 Patent? What specific components in the accused SoCs are alleged to perform the distinct roles of the "communication manager" and "resource manager" as recited in the steps of claim 10 of the ’449 Patent?

V. Key Claim Terms for Construction

  • The Term: "dropping means" (’818 Patent, claim 1)
  • Context and Importance: This term appears to be central to the inventive concept of the ’818 Patent. The outcome of the infringement analysis for this patent may depend on whether the accused products' mechanisms for handling network congestion, which may include throttling or applying back-pressure, are construed to be a "dropping means."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the invention as being "based on the idea to allow the dropping of data in certain cases" (’818 Patent, col. 6:36-38), suggesting a functional definition. The term "means" also invokes analysis under 35 U.S.C. § 112(f), which could tie the term to the corresponding structure in the specification but also allow for equivalents.
    • Evidence for a Narrower Interpretation: The detailed embodiments describe a specific "dropping manager DM" that responds to buffer overflow by creating and sending an "error message" such as "REQLOST" or "RETLOST" (’818 Patent, col. 6:50-51, col. 9:18-24). A defendant may argue that the term should be limited to an apparatus that actively discards data packets and generates a corresponding loss-specific status message, as opposed to a mechanism that merely pauses transmission.
  • The Term: "resource manager" (’449 Patent, claim 10)
  • Context and Importance: Claim 10 recites a multi-step method involving distinct actors: a "communication manager" and a "resource manager." The definition of "resource manager" is critical, as infringement requires showing that the accused method involves an entity with this role that is separate from, and receives a forwarded request from, the "communication manager."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the resource manager's function as "managing the resources of the network N" (’449 Patent, col. 7:38-39). This functional language could support an argument that any component or process that allocates network bandwidth, buffer space, or other resources qualifies as the "resource manager."
    • Evidence for a Narrower Interpretation: The specification describes a specific sequence where the communication manager (CM) "forwards the request" to the resource manager (RM), which then "determines whether the requested connection... is available, and responds" to the CM (’449 Patent, col. 7:42-50). A defendant could argue this language requires a distinct architectural component that performs this specific determination-and-response function, and that a more integrated system that does not separate these roles would not meet this limitation.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that all Defendants induce infringement by marketing and selling the accused products and by providing technical documentation, data sheets, and user manuals that allegedly instruct customers and end-users on how to use the products in an infringing manner (Compl. ¶¶157-158, 166-167, 175-176). The complaint also alleges contributory infringement, stating the accused products are especially made or adapted for practicing the inventions and are not staple articles of commerce (Compl. ¶¶159, 168, 177).
  • Willful Infringement: Willfulness is alleged based on Defendants' alleged knowledge of the asserted patents prior to the lawsuit. The complaint asserts this knowledge arises from the patents having been cited during the prosecution of Defendants' (specifically Samsung's) own patent applications (Compl. ¶¶43-44, 52, 65-67, 75, 88-89, 96, 109-110, 117, 129-130, 137). The complaint alleges specific dates of knowledge for several patents based on these prosecution histories and further alleges that infringement continued despite this knowledge.

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

  • A core issue will be one of technical and definitional scope: Can the functionalities of modern SoC interconnects, which often rely on complex flow control and quality-of-service protocols, be construed to meet the specific claim terms of the asserted patents, such as the "dropping means" of the ’818 patent or the distinct "resource manager" of the ’449 patent?
  • A second key issue will be one of architectural mapping: Does the accused Arteris interconnect technology, as implemented in Defendants' SoCs, possess the discrete, interacting components and perform the specific sequences of steps recited in the asserted method claims (e.g., ’449, ’800 patents), or is there a fundamental mismatch between the claimed methods and the actual operation of the accused systems?
  • A central factual question for willfulness and damages will be the impact of prosecution history citations: What level of corporate knowledge and intent can Plaintiff establish based on the allegation that the asserted patents were cited as prior art during the prosecution of Defendants' own patent applications, and how might that influence a finding of willful infringement for conduct that occurred years before this lawsuit was filed?