DCT

2:22-cv-00482

Network System Tech LLC v. Texas Instruments Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:22-cv-00482, E.D. Tex., 12/19/2022
  • Venue Allegations: Venue is alleged against Texas Instruments and Ford based on their regular and established places of business within the Eastern District of Texas. Venue against Volkswagen AG and Audi AG is based on their status as foreign entities under the alien-venue rule.
  • Core Dispute: Plaintiff alleges that Defendants’ System-on-a-Chip (SoC) products, particularly those manufactured by Texas Instruments and incorporated into automotive systems by Ford and Volkswagen, infringe six patents related to on-chip network communication architectures and data management methods.
  • Technical Context: The lawsuit concerns Network-on-Chip (NoC) technology, which provides the communication backbone for complex SoCs that integrate multiple processors, memories, and functional units onto a single semiconductor die.
  • Key Procedural History: The asserted patents originated with Philips Semiconductors. According to disclaimers filed with the USPTO, all asserted claims of U.S. Patent No. 7,373,449 except for claims 2, 5, and 7-9 have been disclaimed. Additionally, claim 6 of U.S. Patent No. 8,086,800 has been disclaimed. Such disclaimers permanently remove the specified claims from the patent's scope.

Case Timeline

Date Event
2002-10-08 Priority Date for ’818, ’449, and ’9893 Patents
2004-03-17 Priority Date for ’052 Patent
2004-05-18 Priority Date for ’800 Patent
2005-04-21 Priority Date for ’2893 Patent
2008-04-29 U.S. Patent No. 7,366,818 Issues
2008-05-13 U.S. Patent No. 7,373,449 Issues
2009-09-22 U.S. Patent No. 7,594,052 Issues
2010-08-03 U.S. Patent No. 7,769,893 Issues
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

U.S. Patent No. 7,366,818 - “INTEGRATED CIRCUIT COMPRISING A PLURALITY OF PROCESSING MODULES AND A NETWORK AND METHOD FOR EXCHANGING DATA USING SAME”

The Invention Explained

  • Problem Addressed: As System-on-Chip (SoC) designs grow more complex, traditional bus-based communication becomes a bottleneck. The patent background describes the shift to Network-on-Chip (NoC) architectures, which introduces new challenges, such as managing transaction completion and flow control without the high cost of conventional end-to-end flow control mechanisms. (’818 Patent, col. 4:1-12; col. 5:8-13).
  • The Patented Solution: The invention proposes an integrated circuit where the interface between processing modules and the on-chip network includes a "dropping means." This mechanism allows for the selective dropping of data in certain cases, with the interface controlling the process to manage transaction completion, thereby providing an alternative to more resource-intensive flow control schemes. (’818 Patent, Abstract; col. 6:22-44).
  • Technical Importance: This approach suggests a method to balance performance and resource cost in NoC design by enabling more granular control over data handling and transaction finality. (Compl. ¶23).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶125).
  • The essential elements of claim 1 include:
    • An integrated circuit with multiple processing modules on the same chip.
    • A network-on-chip providing a connection between the modules for transactions.
    • At least one "dropping means" for dropping data exchanged between modules.
    • At least one "interface means" for managing the module-to-network interface.
    • The interface means itself comprises a "first dropping means."
    • The transaction completion can be controlled by the interface means through the dropping of data.
  • The complaint reserves the right to assert other claims. (Compl. ¶125).

U.S. Patent No. 7,373,449 - “APPARATUS AND METHOD FOR COMMUNICATING IN AN INTEGRATED CIRCUIT”

The Invention Explained

  • Problem Addressed: In complex SoCs with diverse processing modules, efficiently allocating network resources like communication channels is critical. The patent background describes the need for flexible connection properties to avoid over-dimensioning network resources and to adapt to the actual communication requirements of different modules. (’449 Patent, col. 3:1-11; col. 7:26-34).
  • The Patented Solution: The invention discloses a method where a "communication manager" and a "resource manager" are used to establish connections. A first module requests a connection with desired properties; the communication manager forwards this to the resource manager, which determines if a target connection with those properties is available and responds accordingly, allowing for dynamic and efficient resource allocation. (’449 Patent, Abstract; col. 7:40-67).
  • Technical Importance: This system provides a mechanism for dynamic resource management in NoCs, enabling more efficient use of on-chip network infrastructure by tailoring connections to specific transactional needs. (Compl. ¶35).

Key Claims at a Glance

  • The complaint asserts independent claim 10. (Compl. ¶150).
  • The essential elements of method claim 10 include:
    • Exchanging messages between modules in an integrated circuit over connections via a network.
    • 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 if a target connection with the desired properties is available.
    • The resource manager responding with the availability to the communication manager.
    • Establishing the connection based on the available properties.
  • The complaint reserves the right to assert other claims. (Compl. ¶150).

U.S. Patent No. 7,594,052 - “INTEGRATED CIRCUIT AND METHOD OF COMMUNICATION SERVICE MAPPING”

  • Technology Synopsis: The patent describes a method for mapping a requested communication service to a specific connection within an SoC. It uses a "communication service identification" (such as a communication thread or an address range) to map a service request with specific properties to a network connection that has a corresponding set of properties. (Compl. ¶46; ’052 Patent, Abstract).
  • Asserted Claims: Independent claim 6 is asserted. (Compl. ¶175).
  • Accused Features: The accused SoCs are alleged to offer differentiated intermodular communication services by mapping requested services to connections based on their properties. (Compl. ¶46).

U.S. Patent No. 7,769,893 - “INTEGRATED CIRCUIT AND METHOD FOR ESTABLISHING TRANSACTIONS”

  • Technology Synopsis: The patent covers SoCs that use an "address translation unit" within a network interface for address mapping. This unit combines information about the location of a receiving module within the network and information about a particular location within that module into a single address, which is then used to route the message. (Compl. ¶58; ’9893 Patent, Abstract).
  • Asserted Claims: Independent claim 4 is asserted. (Compl. ¶200).
  • Accused Features: The accused SoCs are alleged to use an address translation unit for address mapping that determines both the location of a receiving module and a specific location within it. (Compl. ¶58).

U.S. Patent No. 8,072,893 - “INTEGRATED CIRCUIT WITH DATA COMMUNICATION NETWORK AND IC DESIGN METHOD”

  • Technology Synopsis: This patent addresses communication speed and synchronization in NoCs by introducing a calculated delay. It describes a method where, if a communication channel's transfer delay exceeds a threshold, a number of data storage elements are inserted to introduce a delay correlated to the data packet size, thereby managing synchronization. (Compl. ¶70; ’2893 Patent, Abstract).
  • Asserted Claims: Independent claims 1 and 10 are asserted. (Compl. ¶¶71, 225).
  • Accused Features: The accused SoCs are alleged to improve data communication speed and synchronization through the use of packetized data and the introduction of a delay on communication channels. (Compl. ¶70).

U.S. Patent No. 8,086,800 - “INTEGRATED CIRCUIT AND METHOD FOR BUFFERING TO OPTIMIZE BURST LENGTH IN NETWORKS ON CHIPS”

  • Technology Synopsis: The patent describes a method for optimizing data transfers in NoCs by buffering data at both the requesting (master) and responding (slave) modules. Each module's network interface contains a "wrapper" that buffers data into an "optimal amount" before transferring it over the interconnect, improving efficiency. (Compl. ¶82; ’800 Patent, Abstract).
  • Asserted Claims: Independent claim 10 is asserted. (Compl. ¶250).
  • Accused Features: The accused SoCs are alleged to employ data buffering at both master and slave modules, where a network interface wrapper buffers data into optimal amounts for transfer. (Compl. ¶82).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are primarily System-on-a-Chip (SoC) products manufactured by Defendant Texas Instruments (TI), which allegedly incorporate "Arteris interconnect technology and/or a derivative thereof." (Compl. ¶95). The complaint identifies a list of "TI Accused Products" in a table, which includes the TI Jacinto, OMAP, TDA, and DRA processor families, as well as TI SimpleLink processors. (Compl. ¶97). This table provides a clear, non-limiting list of the accused TI components. (Compl. ¶97). Downstream products from Defendants Ford and Volkswagen that incorporate these TI SoCs are also accused, such as Ford’s SYNC3 infotainment system and Volkswagen’s MIB 3 infotainment system. (Compl. ¶¶105, 114).

Functionality and Market Context

The accused SoCs are described as complex integrated circuits that incorporate multiple processors and functional units onto a single chip for use in consumer electronics and automotive systems, such as advanced driver assistance systems (ADAS) and vehicle infotainment. (Compl. ¶92). The complaint alleges that the interconnect technology within these SoCs is a dominant factor in determining their performance, size, and cost. (Compl. ¶93). The complaint further alleges that Ford and Volkswagen are customers of TI's automotive SoCs. (Compl. ¶95, n.11).

IV. Analysis of Infringement Allegations

The complaint references external exhibits for detailed claim comparisons, which were not provided with the complaint document. (Compl. ¶100, ¶109, ¶118). The narrative infringement theory is therefore summarized below in prose.

’818 Patent Infringement Theory

The complaint alleges that the accused SoCs infringe claim 1 of the ’818 Patent because they contain an interface with "a dropping means for dropping data exchanged by two modules" and where this interface "can control the dropping of data and therefore completion of message transactions." (Compl. ¶22). This functionality is tied to the alleged use of Arteris interconnect technology in the accused TI SoCs. (Compl. ¶95).

’449 Patent Infringement Theory

The complaint alleges that the accused SoCs infringe claim 10 of the ’449 Patent because they have "a resource manager that manages network resources by determining whether the resources (i.e., communication channels and connection properties) are available." (Compl. ¶34). This alleged functionality is also linked to the Arteris interconnect technology purportedly used in the accused TI products. (Compl. ¶95).

Identified Points of Contention

  • Technical Questions: A primary factual question for the court will be whether the accused "Arteris interconnect technology" in the TI SoCs actually operates in the manner required by the claims. For the ’818 Patent, this raises the question of whether the technology includes a specific "dropping means" controllable by an interface to manage transaction completion, as distinct from general packet loss. For the ’449 Patent, a key question is whether the accused technology employs distinct "communication manager" and "resource manager" entities that perform the claimed steps of requesting, forwarding, determining availability, and responding to establish a connection.
  • Scope Questions: The infringement analysis may depend on the construction of key claim terms. For instance, the scope of "dropping means" in the ’818 Patent will be critical. The analysis will question whether this term should be limited to the specific error-messaging and transaction-control schemes described in the patent, or if it can be read more broadly to cover other forms of data management in a NoC. Similarly, for the ’449 Patent, the definitions of "resource manager" and "communication manager" will be central to determining if the accused SoCs meet these limitations.

V. Key Claim Terms for Construction

"dropping means" (’818 Patent, claim 1)

Context and Importance

This term is central to the inventive concept of the ’818 Patent. Its construction will determine whether the accused SoCs, which may handle data loss or flow control in various ways, perform the specific function claimed. Practitioners may focus on whether this term requires the generation of specific status or error messages upon dropping data, as described in the specification, or if it can encompass any mechanism for discarding data within a network interface.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: Claim 1 itself broadly recites "at least one dropping means (DM) for dropping data." The specification also refers to the invention being based on the general "idea to allow the dropping of data in certain cases." (’818 Patent, col. 6:33-34).
  • Evidence for a Narrower Interpretation: The detailed description repeatedly links the "dropping means" to a system that creates and sends an "error message" if data is dropped, ensuring the source is informed. (’818 Patent, col. 6:50-54). Embodiments describe the dropping manager returning specific status messages like "FAIL/ERROR" or "REQLOST," which suggests a more complex function than simply discarding data. (’818 Patent, col. 9:5-24).

"resource manager" (’449 Patent, claim 10)

Context and Importance

Claim 10 recites a multi-step process involving both a "communication manager" and a "resource manager." The definition of "resource manager" and its distinction from the "communication manager" will be critical. The dispute may turn on whether the accused SoCs have a single, monolithic control unit or if their architecture can be mapped to these two distinct, interacting logical entities as claimed.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent abstract describes the invention at a high level without strictly defining the structural separation of the managers, focusing on the functional steps of managing resources and connections. (’449 Patent, Abstract). This may support an argument that the terms refer to logical functions that could be performed by a single hardware block.
  • Evidence for a Narrower Interpretation: The patent’s Figure 3 explicitly depicts the "Communication Manager (CM)" and "Resource Manager (RM)" as separate blocks within the network. (’449 Patent, FIG. 3). The detailed description explains a clear sequence where the CM "forwards the request" to the RM, which "determines whether the requested connection...is available," suggesting distinct roles and a potential structural or at least clear functional separation. (’449 Patent, col. 7:40-52).

VI. Other Allegations

Indirect Infringement

The complaint alleges that TI induces infringement by providing customers like Ford and Volkswagen with products, support, data sheets, manuals, and guides that instruct them on how to use the accused SoCs in an infringing manner. (Compl. ¶¶126-127, 151-152). Contributory infringement is also alleged, on the basis that the TI Accused Products are especially made for infringing use and are not staple articles of commerce suitable for substantial non-infringing use. (Compl. ¶¶128, 153).

Willful Infringement

Willfulness allegations are based on both pre- and post-suit knowledge. The complaint alleges that due to the prominence of Philips Semiconductors in the industry, Defendants "monitored patenting activity" and "were aware of" the asserted patents "around the time [they] issued or...published" between 2006-2012. (Compl. ¶¶28-29, 31, 39-41, 43). The complaint also states that "Plaintiff notified" Defendants of their infringement, which would establish knowledge at least as of the date of the complaint. (Compl. ¶¶130, 138, 146).

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

  1. Technical Mapping: A central evidentiary question will be one of functional correspondence: does the accused "Arteris interconnect technology" operate in a way that maps onto the specific claimed functions? For example, does it contain a "dropping means" that actively manages transaction completion via error messaging as described in the ’818 patent, or a distinct "resource manager" that determines connection availability in response to a forwarded request from a "communication manager" as required by the ’449 patent?
  2. Definitional Scope: The case may turn on a question of claim construction: how broadly will terms like "dropping means" and "resource manager" be defined? The court's interpretation will determine whether these terms cover the general concepts of data packet management and resource allocation in a NoC, or if they are limited to the specific architectures and multi-step methods disclosed in the patents' specifications.
  3. State of Mind for Willfulness: A key legal and factual question will be the basis for pre-suit knowledge. The allegation that Defendants knew of these patents for over a decade based on general industry monitoring, rather than specific notice, may face scrutiny. The strength of the willfulness claim could depend on what evidence emerges regarding whether Defendants actually considered these specific patents during their product development.