2:24-cv-00630
Helix Microinnovations LLC v. Microchip Technology Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Helix Microinnovations LLC (Delaware)
- Defendant: Microchip Technology Incorporated (Delaware)
- Plaintiff’s Counsel: Rabicoff Law LLC
- Case Identification: 2:24-cv-00630, E.D. Tex., 08/04/2024
- Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Texas and having committed acts of patent infringement in the district.
- Core Dispute: Plaintiff alleges that Defendant’s fabrication methods infringe a patent related to methods for manufacturing Chip-on-Board electronic modules.
- Technical Context: The technology addresses cost-effective semiconductor manufacturing by enabling the use of unpackaged and potentially partially-defective semiconductor die to create functional memory modules.
- Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. No other procedural history, such as prior litigation or administrative proceedings, is mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2002-02-26 | '550 Patent Priority Date |
| 2003-02-20 | '550 Patent Application Filing Date |
| 2007-07-03 | '550 Patent Issue Date |
| 2024-08-04 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,238,550 - “Methods and apparatus for fabricating Chip-on-Board modules”
The Invention Explained
- Problem Addressed: The patent’s background section notes that increasingly dense semiconductor manufacturing processes result in a higher number of "less-than-perfect" chips, creating a need for methods to utilize these partially-defective parts to avoid waste (ʼ550 Patent, col. 2:10-18). Additionally, standard testing procedures like "burn-in" can cause failures due to stress from the different thermal expansion coefficients of the silicon chip and the printed circuit board (PCB). (ʼ550 Patent, col. 2:7-12).
- The Patented Solution: The invention describes a fabrication method for Chip-on-Board (COB) modules that mounts an unpackaged die to a PCB using "selectively settable liquids," such as UV-curable adhesives ('550 Patent, col. 3:62-65). The process involves hardening a ring of this material around the die to secure its position, while material between the die and the PCB can remain liquid to act as a physical and thermal buffer ('550 Patent, col. 4:26-33; Fig. 4b). A second layer of this material can then be applied over the first to capture and protect the fragile bonding wires that connect the die to the PCB. ('550 Patent, col. 4:42-51).
- Technical Importance: This method provides a way to create low-cost electronic modules by salvaging partially-defective semiconductor die and improves manufacturing yield by mitigating thermal stress during testing. ('550 Patent, col. 2:14-20).
Key Claims at a Glance
- The complaint alleges infringement of "one or more claims" and refers to "exemplary method claims," but does not specify which claims are asserted, instead incorporating them by reference from an exhibit not attached to the filed complaint (Compl. ¶11, ¶13). Independent method claim 1 is presented here as a representative example.
- Independent Claim 1:
- A method of fabricating Chip-on-Board logic modules using selectively settable materials, said method comprising:
- mounting unpackaged die using a first layer of selectively-settable material;
- hardening a ring of said first layer of selectively-settable material around a periphery said unpackaged die;
- covering said first layer of selectively-settable material with a second layer of selectively-settable material; and
- capturing bonding wires connecting said unpackaged die to a printed circuit board in said second layer of selectively-settable material.
III. The Accused Instrumentality
Product Identification
The complaint does not identify any accused products or methods by name. It refers generally to "Defendant products identified in the charts incorporated into this Count" via an external exhibit that was not filed with the complaint. (Compl. ¶11, ¶13).
Functionality and Market Context
The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.
IV. Analysis of Infringement Allegations
The complaint’s substantive infringement allegations are contained entirely within "charts of Exhibit 2," which was not provided with the complaint document (Compl. ¶13-14). The narrative states only that the "Exemplary Defendant Products practice the technology claimed by the '550 Patent" and that they "satisfy all elements of the Exemplary '550 Patent Claims." (Compl. ¶13). Due to the lack of specific factual allegations or an accompanying claim chart, a detailed infringement analysis is not possible from the complaint as filed.
No probative visual evidence provided in complaint.
Identified Points of Contention
Based on the language of representative Claim 1 and the general nature of the technology, the infringement analysis, once developed, may raise several questions:
- Scope Questions: A central question will concern the scope of "selectively settable material." The analysis may explore whether this term is limited to the UV-curable adhesives described in the patent's embodiments or if it can be construed to read on other common industrial materials like thermal epoxies or single-stage encapsulants.
- Technical Questions: The claim recites a multi-step process involving a "first layer," a "second layer," and the "capturing" of wires within that second layer. A factual question will be what evidence exists that the accused manufacturing process includes these discrete, sequential steps, particularly the application of a distinct second layer for the purpose of capturing wires, as opposed to a single-step encapsulation process.
V. Key Claim Terms for Construction
The Term: "selectively settable material"
- Context and Importance: This term appears in the preamble and body of Claim 1 and is fundamental to the claimed method. The outcome of the case may depend on whether Defendant’s process uses materials that fall within the patent's definition of this term.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The term itself is broad and not explicitly defined or limited in the claims. The specification refers generally to "adhesives" ('550 Patent, col. 3:64), which could support a construction that is not limited to a single type.
- Evidence for a Narrower Interpretation: The specification heavily features "UV material" and "UV-curable" liquids as the operative example, describing a process where different light wavelengths can produce different levels of hardness ('550 Patent, col. 4:2-11). This repeated emphasis on a specific class of materials could be used to argue for a narrower construction limited to materials with such properties.
The Term: "capturing bonding wires ... in said second layer of selectively-settable material"
- Context and Importance: This limitation describes the final step of securing the fragile electrical connections. Practitioners may focus on this term because infringement will depend on whether the accused process involves a distinct structure and step corresponding to this limitation.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: An argument could be made that any process that results in the bonding wires being embedded in a protective material meets the "capturing" limitation, regardless of the number of layers or steps.
- Evidence for a Narrower Interpretation: The claim structure itself suggests a sequence: "covering said first layer ... with a second layer" and then "capturing ... in said second layer". This syntax, combined with specification passages describing the addition of a "second ring (or layer) ... on top of the first ring" to "capture the wires" ('550 Patent, col. 4:42-51), supports an interpretation requiring a distinct, second application of material for the specific purpose of securing the wires.
VI. Other Allegations
- Willful Infringement: The complaint does not include a formal count for willful infringement or plead any specific facts regarding pre- or post-suit knowledge of the patent. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285. (Compl. ¶E(i)).
VII. Analyst’s Conclusion: Key Questions for the Case
Procedural Sufficiency: A threshold issue is whether the complaint, which outsources all specific allegations of infringement to an un-filed external exhibit, satisfies the federal pleading standards established by Twombly and Iqbal. The court may first need to address whether the Defendant has been given fair notice of the specific products and infringement theories at issue.
Claim Scope: The case will likely turn on the construction of key claim terms. A core issue will be one of definitional scope: can the term "capturing bonding wires ... in said second layer" be construed to cover a single-step encapsulation process, or is it limited to the distinct two-layer, multi-step method detailed in the patent’s embodiments?
Evidentiary Mapping: Assuming the case proceeds, a key evidentiary question will be one of process equivalence: what evidence can Plaintiff produce to show that Defendant’s semiconductor fabrication process performs the discrete, sequential steps of hardening a "first layer" ring and then applying a "second layer" to capture wires, as required by the claim language?