InnoMemory LLC v. Alliance Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: Alliance Bank (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00106, E.D. Tex., 02/01/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district, has committed alleged acts of infringement in the district, and has caused harm to Plaintiff in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for reducing power consumption in memory devices during refresh operations.
• Technical Context: The technology concerns power-saving techniques in dynamic random-access memory (DRAM), a critical component in many electronic devices, where reducing standby power consumption is important for battery life.
• Key Procedural History: The patent-in-suit is a continuation of a prior application that issued as U.S. Patent No. 6,618,314. No other prior litigation or administrative proceedings are mentioned in the complaint.

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"

• Patent Identification: 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 “’960 Patent”).

The Invention Explained

• Problem Addressed: In conventional memory devices, especially DRAM, all memory cells are refreshed periodically to prevent data loss, even when the device is in a low-power standby mode. This process activates support circuitry for the entire memory array, consuming significant power, which is a drawback for battery-powered devices like mobile phones (’960 Patent, col. 1:26-35, 2:25-30).
• The Patented Solution: The invention proposes a method to reduce this power consumption by dividing the memory array into multiple sections. The system can selectively refresh only certain sections of the memory array that contain data needing to be retained, while leaving the support circuits for other sections inactive (’960 Patent, Abstract; col. 2:50-54). This is achieved by using control signals, generated in response to a programmable address, to enable or disable the "periphery array circuits" for each section independently (’960 Patent, col. 2:34-44).
• Technical Importance: This approach allows for a more granular control of power usage in standby modes, a critical feature for the growing mobile device market which requires long battery life (’960 Patent, col. 1:31-35).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, instead referring to "Exemplary '960 Patent Claims" detailed in an external exhibit not provided with the complaint (Compl. ¶13). Analysis of independent claim 1, as a representative method claim, is provided below.
• Essential elements of Independent Claim 1 include:
  • A method for reducing power consumption during background operations in a memory array with a plurality of sections.
  • Controlling the background operations in each section in response to one or more control signals.
  • Generating the control signals 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 the periphery array circuits of the sections.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products. It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2 (Compl. ¶11, 13). Exhibit 2 was not provided with the filed complaint document.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. It alleges only that the unidentified products practice the technology claimed by the ’960 Patent (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint’s infringement allegations are contained entirely within claim charts in Exhibit 2, which was not included with the public filing (Compl. ¶13-14). The complaint alleges that Defendant directly infringes by making, using, offering to sell, selling, or importing the "Exemplary Defendant Products" (Compl. ¶11). It further alleges infringement occurs through internal testing and use of these products by Defendant's employees (Compl. ¶12). Without the claim charts, a detailed analysis comparing claim elements to accused functionality is not possible.

No probative visual evidence provided in complaint.

Identified Points of Contention

Based on the language of representative Claim 1 and the nature of the technology, the infringement analysis may raise several questions:

• Scope Question: A dispute may arise over the definition of "background operations." The defendant could argue this term should be limited to the "refresh operations" emphasized in the patent's title and background, while the plaintiff might argue it covers a broader set of housekeeping functions, such as parity checking, as suggested by other claims (’960 Patent, Claim 4).
• Technical Question: The infringement case may turn on whether the accused products utilize a "programmable address signal" to select which memory sections to activate. The parties may dispute what level of user or system-level control is required to meet the "programmable" limitation.
• Evidentiary Question: A central question for the court will be what evidence demonstrates that the accused products’ internal circuitry, particularly the "periphery array circuits," are selectively activated "independently of any other section" in a manner that maps onto the claim limitations.

V. Key Claim Terms for Construction

"background operations"

• Context and Importance: This term appears in the preamble of Claim 1 and defines the context of the entire method. Its construction is critical because it determines whether the patent is limited to memory refresh or covers other power-consuming maintenance tasks. Practitioners may focus on this term because its scope will directly dictate the range of accused activities that could be found to infringe.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification states the invention provides a method for reducing power during "background operations, such as memory cell refresh operations" (’960 Patent, col. 2:47-49), which suggests refreshing is an example, not an exclusive definition. Dependent claim 4 explicitly recites that the "background operations comprise parity checking," which supports the view that the term in Claim 1 is broader than refresh alone (’960 Patent, col. 11:58-60).
  • Evidence for a Narrower Interpretation: The patent's title, background, and detailed description heavily focus on "refresh operations" as the primary problem and solution (’960 Patent, Title; col. 1:12-14). A defendant may argue that the patent’s disclosure does not provide sufficient written description to support a scope beyond memory refresh and that the term should be construed as such.

"programmable address signal"

• Context and Importance: This term in Claim 1 is the mechanism that generates the control signals for selective refresh. The definition of "programmable" is key to infringement, as it will determine what kind of system architecture meets this limitation.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not appear to explicitly define "programmable." A party could argue for a broad meaning encompassing any signal that can be set or altered, for example by loading a value into a register to designate which memory blocks should be active. The specification discusses using a "register 138" to store a "refresh block address" which controls which sections are refreshed, supporting an interpretation that programmability is achieved by writing to a register (’960 Patent, col. 4:55-65).
  • Evidence for a Narrower Interpretation: A party could argue "programmable" implies a higher level of dynamic, software-based control than merely setting a hardware register. The specification's reference to a "refresh address register" could be used to argue that the term is limited to the specific register-based embodiments disclosed and does not cover other methods of selecting memory sections.

VI. Other Allegations

Willful Infringement

The complaint does not make any factual allegations to support a claim for willful infringement, such as pre-suit knowledge of the patent. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285 for an award of attorneys' fees but does not explicitly request enhanced damages for willful infringement under § 284 (Compl. p. 4, ¶E.i).

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

Given the sparse, notice-pleading nature of the complaint, the litigation will likely center on the following fundamental questions that must be developed during discovery and claim construction:

• A core issue will be one of definitional scope: Can the term "background operations", which is central to the claimed method, be construed broadly to include functions beyond the memory "refresh operations" that are the primary focus of the patent's disclosure? The answer will substantially broaden or narrow the field of potentially infringing activities.
• A key evidentiary question will be one of technical implementation: As discovery proceeds, the plaintiff will bear the burden of demonstrating how the specific, unidentified "Exemplary Defendant Products" actually implement the claimed invention. The case will hinge on whether evidence shows these products use a "programmable address signal" to selectively and independently activate "periphery array circuits" as claimed.
• A foundational question will be one of infringement evidence: The complaint's reliance on an external, unprovided exhibit for all substantive infringement allegations (Compl. ¶13-14) leaves open the fundamental question of what specific features of what specific products are alleged to infringe the ’960 Patent.