InnoMemory LLC v. Citizens State Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: Citizens State Bank (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00152, E.D. Tex., 03/04/2024
• Venue Allegations: Venue is alleged as proper because the Defendant, Citizens State Bank, maintains an established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant infringes two U.S. patents related to power-saving methods and architectures in random access memory (RAM) devices.
• Technical Context: The patents address technologies for reducing power consumption in computer memory, a critical design consideration for performance and battery life in modern electronic devices.
• Key Procedural History: The complaint does not allege any significant procedural history, such as prior litigation involving the patents-in-suit or pre-suit correspondence between the parties.

Case Timeline

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

U.S. Patent No. 6,240,046 - "Integrated circuit random access memory capable of reading either one or more than one data word in a single clock cycle," Issued May 29, 2001

The Invention Explained

• Problem Addressed: The patent's background describes an "unfilled need for memory devices with low power consumption characteristics," noting that many prior art memory systems waste power by retrieving multiple data words when only one is needed for a given read request (’046 Patent, col. 2:1-15).
• The Patented Solution: The invention is a random access memory circuit that can operate in different modes to conserve power. The system can retrieve a single data word from its memory array in one clock cycle for random read requests, or it can retrieve more than one data word in a single cycle for sequential "burst" requests, which is more power-efficient for that access pattern (’046 Patent, Abstract). This dual-mode capability allows the memory to tailor its power consumption to the type of data access being performed, reducing the average power usage (’046 Patent, col. 3:5-20).
• Technical Importance: This approach provided a flexible method for power management in RAM, a technology of increasing importance for battery-powered and portable computing devices of the era.

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims of the '046 Patent" but does not identify specific claims in the body of the complaint, instead referring to an external exhibit not provided for this analysis (Compl. ¶12).

U.S. Patent No. 7,057,960 - "Method and architecture for reducing the power consumption for memory devices in refresh operations," Issued June 6, 2006

The Invention Explained

• Problem Addressed: The patent addresses power consumption during standby modes in devices using dynamic random access memories (DRAMs). It notes that conventional devices refresh all memory cells, which is inefficient and wastes power in applications where only a portion of the memory contains data that needs to be retained (’960 Patent, col. 1:40-52).
• The Patented Solution: The invention proposes a method and architecture where the memory array is divided into multiple sections (e.g., quadrants). The system includes control circuitry that can perform background operations, such as the power-intensive refresh process, on only a selected subset of these sections while leaving the support circuits for other sections inactive (’960 Patent, Abstract; col. 2:36-44). This "partial array" refresh capability allows the device to significantly reduce its standby power consumption (’960 Patent, col. 2:9-14).
• Technical Importance: This invention describes a technique for partial-array self-refresh, a feature that became crucial for extending battery life in mobile phones and other portable electronics.

Key Claims at a Glance

• The complaint asserts infringement of "one or more claims of the '960 Patent" but does not identify specific claims in the body of the complaint, instead referring to an external exhibit not provided for this analysis (Compl. ¶18).

III. The Accused Instrumentality

• Product Identification: The complaint does not identify any specific accused product, system, method, or service by name (Compl. ¶¶1-23). It refers generally to "Exemplary Defendant Products" that are allegedly identified in Exhibits 3 and 4, which were incorporated by reference but not provided for this analysis (Compl. ¶12, ¶18).
• Functionality and Market Context: The complaint does not describe the functionality of any accused instrumentality. Given that the Defendant is a financial institution, the nature of the alleged infringement raises the question of whether the accused instrumentalities are off-the-shelf computer systems, custom-developed software, or other technologies used in the course of its business operations (Compl. ¶3). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges direct infringement of the ’046 and ’960 Patents but incorporates its substantive technical allegations by reference to Exhibits 3 and 4, which were not provided for this analysis (Compl. ¶14, ¶20). Therefore, a detailed claim chart summary and an identification of potential points of contention cannot be constructed.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail, such as asserted claims or a specific infringement theory, to identify key claim terms for construction.

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of induced or contributory infringement. The infringement counts are explicitly limited to "Direct Infringement" (Compl. ¶12, ¶18).
• Willful Infringement: The complaint does not contain factual allegations to support a claim of willful infringement, such as allegations of pre-suit knowledge of the patents-in-suit. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285, but the body of the complaint does not plead a basis for such a finding (Compl. p. 5).

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

The complaint, as filed, presents foundational questions due to its reliance on external exhibits for its core allegations. The central issues for the case will likely be:

• Identification of the Accused Instrumentality: A primary question will be to identify the specific products, systems, or methods utilized by a financial institution that are alleged to practice the patented memory architecture and operation technologies. The basis for alleging that a bank infringes patents directed to the design of semiconductor memory chips will be a central focus.
• Articulation of the Infringement Theory: With no asserted claims or technical comparisons present in the complaint itself, a key question is the specific technical theory of how the unidentified "Exemplary Defendant Products" are alleged to meet the limitations of claims from the patents-in-suit.