Modulus Systems LLC v. Murata Electronics North America Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Modulus Systems LLC (Delaware)
  • Defendant: Murata Electronics North America, Inc. (Texas)
  • Plaintiff’s Counsel: Kent & Risley LLC
• Case Identification: 2:23-cv-00220, E.D. Tex., 05/18/2023
• Venue Allegations: Venue is alleged to be proper in the Eastern District of Texas because Defendant is a resident of the district, has a regular and established place of business there, and has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s radio frequency modules infringe a patent related to the physical layout and component configuration of such modules.
• Technical Context: The lawsuit concerns the design of compact radio frequency (RF) modules, which are fundamental components in a vast range of wireless devices, from mobile phones to industrial sensors.
• Key Procedural History: The complaint notes that Plaintiff is the assignee of the patent-in-suit. No other procedural history, such as prior litigation or post-grant proceedings, is mentioned.

Case Timeline

Date	Event
2008-09-11	’573 Patent Priority Date
2013-12-17	’573 Patent Issue Date
2023-05-18	Complaint Filing Date

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

U.S. Patent No. 8,610,573 - "Radio Frequency Module and Methods of Transmitting/Receiving Data"

• Patent Identification: U.S. Patent No. 8,610,573, "Radio Frequency Module and Methods of Transmitting/Receiving Data," issued December 17, 2013.

The Invention Explained

• Problem Addressed: The patent’s background section states that prior art RF modules were often limited in how small they could be made, as placing antennas and filtering components in close proximity could reduce performance (’573 Patent, col. 1:26-34). It also notes the problem of RF interference from widely used technologies like Wi-Fi, which operate in the same 2.4 GHz frequency band (’573 Patent, col. 1:40-44).
• The Patented Solution: The invention is a radio frequency module with a specific physical architecture designed for compact size and improved performance. It claims a printed circuit board on which a transceiver, a matching/filtering network, and a chip antenna are placed in a particular arrangement, which the patent describes as a "generally U-shape configuration" (’573 Patent, col. 2:15-18). This assembly is partially enclosed by a radio frequency shield that is coupled to a ground plane to protect the components from interference and prevent undesirable feedback (’573 Patent, col. 4:6-10, 25-29).
• Technical Importance: The claimed design seeks to provide a compact, integrated, and surface-mountable RF module that overcomes the performance degradation typically associated with miniaturizing wireless components, addressing a key challenge driven by consumer demand for smaller electronic devices (’573 Patent, col. 1:26-30).

Key Claims at a Glance

• The complaint alleges infringement of "one or more claims," including an "Exemplary '573 Patent Claim" identified in an exhibit not provided with the complaint (Compl. ¶11). The patent contains two independent claims, 1 and 11.
• Independent Claim 1, a representative apparatus claim, requires:
  • A base member including a printed circuit board.
  • A transceiver assembly located on the board, which includes a transceiver and a matching/filtering network.
  • A ground plane on the board's surface surrounding a substantial portion of the transceiver assembly.
  • A radio frequency shield electrically coupled to the ground plane and covering a substantial portion of the transceiver assembly.
  • A chip antenna located on the board's surface outside of the shield and extending "generally parallel" with the matching/filtering network.
  • A radio feed point connecting the antenna and network, where the antenna, network, and feed point together form a "generally U-shape configuration."
• The complaint does not specify if dependent claims are asserted but reserves the right to do so.

III. The Accused Instrumentality

Product Identification

• The complaint does not name specific accused products. It refers to them as the "Exemplary Defendant Products" identified in a chart (Exhibit B) that was incorporated by reference but not attached to the filed complaint (Compl. ¶11).

Functionality and Market Context

• The complaint does not provide any description of the accused products' technical functionality or market position, other than to allege that they "practice the technology claimed by the '573 patent" (Compl. ¶15).

IV. Analysis of Infringement Allegations

The complaint references an infringement claim chart in Exhibit B, which was not provided. The complaint’s narrative alleges that Defendant directly infringes "at least the exemplary claim of the '573 patent" by making, using, offering to sell, selling, and/or importing the "Exemplary Defendant Products" (Compl. ¶11). The complaint asserts that these products "satisfy all elements of the Exemplary '573 Patent Claim" (Compl. ¶15). Without the claim chart, a detailed element-by-element analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Given the structural nature of the patent's claims, the infringement analysis will likely focus on the physical construction of the accused modules.
  • Scope Questions: A central question will be whether the physical layout of components in the accused products constitutes the "generally U-shape configuration" required by Claim 1. The definition of this relational term will be critical.
  • Technical Questions: A key factual question is whether the accused products contain a distinct "radio frequency shield" that covers a "substantial portion" of the transceiver assembly and is "electrically coupled to the ground plane" in the manner claimed. The analysis will depend on a physical inspection and electrical testing of the accused products.

V. Key Claim Terms for Construction

• The Term: "forming a generally U-shape configuration"

• Context and Importance: This term describes the spatial relationship between the chip antenna, the matching/filtering network, and the radio feed point. It is a core limitation of the asserted apparatus claim, and infringement will hinge on whether the layout of Defendant’s products meets this geometric constraint. Practitioners may focus on this term because it is qualitative ("generally") and its scope is not explicitly defined by angular or dimensional measurements.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The use of the word "generally" suggests the shape is not required to be a perfect, geometrically precise "U" and could encompass a variety of non-linear layouts (’573 Patent, col. 12:59).
  • Evidence for a Narrower Interpretation: The specification consistently describes a specific arrangement where the "chip antenna...extends generally parallel with the matching/filtering network," and a "radio feed point extends between" them (’573 Patent, col. 2:12-18). This, along with Figure 3, could be used to argue that the "U-shape" requires two substantially parallel component lines connected at one end.

• The Term: "radio frequency shield"

• Context and Importance: The presence, placement, and function of the shield are essential elements of Claim 1. The dispute may turn on what type of component qualifies as a "shield" and whether it covers a "substantial portion" of the specified assembly.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not restrict the shield's material or construction beyond being a "radio frequency shield" that is "electrically coupled to the ground plane" (’573 Patent, col. 12:42-45).
  • Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment: a metal shield (22) with downward-extending tabs (52) that are received in holes (54) on the PCB and soldered to the ground plane (24) for alignment and strength (’573 Patent, col. 4:25-36). A party could argue this detailed disclosure limits the scope of the term to a similar structure.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials inducing end users and others to use its products in the customary and intended manner that infringes the '573 patent" (Compl. ¶14).
• Willful Infringement: The complaint does not use the term "willful." However, it alleges that service of the complaint provides Defendant with "actual knowledge" and that Defendant's continued infringing activities despite this knowledge are ongoing (Compl. ¶12, 13). This forms a basis for a claim of post-suit willful infringement.

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

• A core issue will be one of definitional scope: can the phrase "generally U-shape configuration," which describes a specific physical layout of three distinct components (antenna, network, feed point), be construed to read on the component architecture within Defendant's accused RF modules?
• A second central issue will be structural equivalence: does the accused product contain a component that meets the claim limitations of a "radio frequency shield," specifically one that is "electrically coupled to the ground plane" and covers a "substantial portion" of the transceiver assembly as defined by the patent?
• An overarching evidentiary question will be what proof Plaintiff offers to demonstrate that Defendant's mass-produced, internal electronic components possess the specific, multi-element structural arrangement claimed in the ’573 Patent, an allegation that the complaint currently supports only by incorporating a missing exhibit.