InnoMemory LLC v. Winbond Electronics Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: Winbond Electronics Corporation (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:24-cv-00497, E.D. Tex., 07/08/2024
• Venue Allegations: Venue is alleged to be proper because the Defendant is a foreign corporation that has committed acts of patent infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s memory devices infringe a patent related to methods for reducing power consumption during memory refresh operations.
• Technical Context: The technology concerns power-saving techniques in dynamic random-access memory (DRAM), which is critical for extending battery life in mobile and portable electronic devices.
• Key Procedural History: The asserted patent is a continuation of a prior application that issued as U.S. Patent No. 6,618,314. The complaint states that Plaintiff is the assignee of the patent-in-suit.

Case Timeline

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

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

• The Invention Explained:
  • Problem Addressed: The patent describes that conventional dynamic semiconductor memory devices must periodically refresh their memory cells to prevent data loss due to electrical leakage (Compl. ¶9; ’960 Patent, col. 1:17-25). In standby or reduced power modes, this constant refresh of the entire memory array consumes significant power, which is detrimental for battery-powered devices like portable telephones, even if only a portion of the memory contains data that needs to be retained (’960 Patent, col. 2:31-48). A specific drawback noted is that conventional methods activate the support circuits for all quadrants of a memory array, even when only a subset of the array requires refreshing (’960 Patent, col. 2:25-30).
  • The Patented Solution: The invention proposes an architecture where a memory array is divided into multiple sections (e.g., quadrants), and the background operations, such as refresh, can be controlled for each section independently (’960 Patent, Abstract). This is achieved by using specific control signals (e.g., REF0-REF3 in Fig. 3) to enable the "periphery array circuits" (support circuitry) only for the sections being refreshed, while leaving the circuitry for other sections inactive (’960 Patent, col. 2:50-55; col. 6:3-17). This selective activation, based on a programmable address, reduces overall power consumption during standby modes.
  • Technical Importance: This selective refresh capability addresses a key demand in the growing market for mobile electronics by providing a method to lower standby power consumption and thereby extend battery life (’960 Patent, col. 2:31-38).
• Key Claims at a Glance:
  • The complaint does not specify which claims are asserted, referring only to "Exemplary '960 Patent Claims" in an external exhibit (Compl. ¶11, 13). Independent claim 1 is representative of the patented method.
  • Independent Claim 1 (Method):
    • Controlling background operations in each of a plurality of memory array sections in response to one or more control signals.
    • The control signals are generated in response to a "programmable address signal."
    • The background operations can be enabled simultaneously in two or more sections, independently of any other section.
    • Presenting the control signals and decoded address signals to one or more "periphery array circuits" of the sections.

III. The Accused Instrumentality

Product Identification

• The complaint does not identify any specific accused products by name. It refers generally to "Defendant products identified in the charts incorporated into this Count" and "Exemplary Defendant Products" (Compl. ¶11, 13).

Functionality and Market Context

• The complaint does not provide any description of the functionality, operation, or market context of the accused products. It alleges only that the products "practice the technology claimed by the '960 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references claim charts in an "Exhibit 2" but does not attach or include them (Compl. ¶13-14). The complaint’s narrative theory of infringement is limited to the conclusory statement that "the Exemplary Defendant Products incorporated in these charts satisfy all elements of the Exemplary '960 Patent Claims" (Compl. ¶13). No specific facts are alleged in the complaint body to map accused product functionality to the claim elements. Therefore, a claim chart summary cannot be constructed from the provided documents.

No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Evidentiary Question: The primary threshold question will be whether Plaintiff can produce sufficient evidence to support its bare allegations, given the lack of specific product identification and infringement details in the complaint.
  • Scope Question: A dispute may arise over the scope of "background operations." While the patent focuses on "refresh operations," the claims are not so limited, and the specification also mentions "parity checking" as a possible background operation (’960 Patent, col. 8:22-24; Claim 4). The breadth of this term could be a point of contention.
  • Technical Question: A central technical question will be whether the accused products' power-saving modes function in the manner required by the claims. Specifically, the court will need to determine if the accused products use a "programmable address signal" to generate control signals that independently enable or disable the "periphery array circuits" for distinct sections of a memory array.

V. Key Claim Terms for Construction

The complaint does not provide sufficient detail for analysis of how specific claim terms apply to the accused products. However, based on the patent's language, the construction of the following terms will likely be critical.

• The Term: "programmable address signal" (Claim 1)

  • Context and Importance: This term is foundational to the claim, as it is the basis for generating the control signals that enable selective refresh. The outcome of the infringement analysis may depend on whether the signal used in the accused devices to select memory sections for low-power operations qualifies as "programmable."
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification refers to a "refresh address register" that is programmed with the portion of the memory array to be refreshed (’960 Patent, col. 2:63-65). Plaintiff may argue this suggests any signal originating from a configurable register that designates a memory block meets the definition.
    • Evidence for a Narrower Interpretation: The detailed description shows a "refresh block address" (AR1) being loaded into a register (138) to generate a "REF_BLK" signal, which in turn is used to control the refresh operation (’960 Patent, Fig. 3; col. 4:55-68). Defendant may argue the term is limited to this specific implementation of an externally loaded address, rather than an internally generated one.

• The Term: "periphery array circuits" (Claim 1)

  • Context and Importance: The claims require that these specific circuits be controlled. Defining what constitutes a "periphery array circuit" is therefore essential to determining whether the accused products meet this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is not explicitly defined. Plaintiff may argue it should be given its plain and ordinary meaning, covering any support circuitry associated with the memory array sections.
    • Evidence for a Narrower Interpretation: The specification provides an exemplary list of what these circuits comprise: "sense amplifiers, column multiplexer circuits, equalization circuits, and wordline driver circuits" (’960 Patent, col. 11:63-65). Defendant may argue the term should be limited to the circuits explicitly disclosed or those of the same class.

VI. Other Allegations

• Indirect Infringement: The complaint does not allege indirect infringement.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. However, the prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which would allow for an award of attorney fees (Compl., Prayer for Relief ¶E.i). The complaint does not allege any facts regarding Defendant's knowledge of the patent.

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

1. Evidentiary Sufficiency: A threshold issue stems from the complaint's lack of specificity. A key question is whether the Plaintiff's conclusory allegations, which refer to unnamed products and unprovided claim charts, can survive a motion to dismiss for failure to state a plausible claim for relief.

2. Claim Scope and Technical Infringement: Should the case proceed, a central issue will be one of technical mechanics: do the accused memory devices practice the specific power-saving method of the ’960 Patent? This will require the court to first construe the scope of key terms like "programmable address signal", and then to resolve the factual question of whether the accused products' circuitry independently controls discrete memory sections using such a signal, as opposed to using a different power-saving technique.