DCT
2:25-cv-00147
Chip Packaging Tech LLC v. Infineon Tech AG
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Chip Packaging Technologies, LLC (Texas)
- Defendant: Infineon Technologies AG (Germany)
- Plaintiff’s Counsel: Blue Peak Law Group LLP; Miller Fair Henry, PLLC
- Case Identification: 2:25-cv-00147, E.D. Tex., 02/06/2025
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a foreign corporation not resident in the United States and therefore may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that Defendant’s semiconductor products, and the methods used to manufacture them, infringe five U.S. patents related to semiconductor packaging technologies.
- Technical Context: The lawsuit concerns innovations in semiconductor packaging, a critical field for protecting integrated circuits and managing their electrical and thermal performance in compact electronic devices.
- Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history concerning the asserted patents; it does allege compliance with statutory marking requirements.
Case Timeline
| Date | Event |
|---|---|
| 2007-07-23 | ’611 Patent Priority Date |
| 2010-02-12 | ’713 Patent Priority Date |
| 2012-09-04 | ’611 Patent Issue Date |
| 2013-03-12 | ’713 Patent Issue Date |
| 2014-07-02 | ’299 Patent Priority Date |
| 2014-07-18 | ’351 Patent Priority Date |
| 2015-08-23 | ’646 Patent Priority Date |
| 2016-02-16 | ’299 Patent Issue Date |
| 2016-03-29 | ’646 Patent Issue Date |
| 2017-06-20 | ’351 Patent Issue Date |
| 2025-01-27 | Availability of Accused Products confirmed via distributor websites |
| 2025-02-06 | Complaint Filing Date |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 9,263,299 - “Exposed Die Clip Bond Power Package”
- Issued: Feb. 16, 2016
The Invention Explained
- Problem Addressed: The patent describes the need for semiconductor power packages with minimal on-state resistance (Rpson) and enhanced thermal performance, which is challenging to achieve in increasingly compact devices (ʼ299 Patent, col. 1:47-54).
- The Patented Solution: The invention is a method for packaging a device die by first mounting it onto a temporary carrier. A pre-formed lead frame, composed of clips, is then attached directly to the die's top-side bond pads using solder paste. After reflowing the solder, the entire assembly is encapsulated, creating a package where the die's underside and the lead frame's lower surfaces are exposed and coplanar, allowing for improved thermal dissipation and a lower-profile connection to a circuit board (ʼ299 Patent, Abstract; col. 2:1-8).
- Technical Importance: This "clip bond" process aims to create a more direct and robust electrical and thermal path compared to traditional wire bonding, reducing resistance and improving heat management in high-power applications (ʼ299 Patent, col. 1:52-58).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶38).
- Essential elements of claim 1, a method, include:
- Mounting a plurality of back-ground, solderable active device die onto a temporary carrier.
- Dispensing a solder paste onto the bond pads of the die.
- Attaching a lead frame to the temporary carrier, wherein upper lead frame portions contact the solder paste and lower portions contact the carrier.
- Reflowing the solder to connect the upper lead frame portions to the bond pads.
- The complaint alleges infringement of "one or more claims," preserving the right to assert others (Compl. ¶37).
U.S. Patent No. 9,299,646 - “Lead Frame With Power And Ground Bars”
- Issued: Mar. 29, 2016
The Invention Explained
- Problem Addressed: The patent’s background explains that in conventional semiconductor packages, bond wires carrying sensitive I/O signals often must pass over or near a power bar, creating a risk of noise coupling and signal interference (ʼ646 Patent, col. 1:15-21).
- The Patented Solution: The invention discloses a lead frame architecture that incorporates a specially configured ground bar to shield the signal leads from the power bar. The ground bar is designed with two portions: one placed between the signal leads and the power bar, and another between the power bar and the semiconductor die, effectively isolating the power bar to improve noise immunity (ʼ646 Patent, Abstract; col. 3:41-51). Figure 2 of the patent illustrates this arrangement.
- Technical Importance: This design provides a structural solution to a common signal integrity problem, allowing for more reliable performance in complex integrated circuits where high-power and sensitive I/O signals coexist in close proximity (ʼ646 Patent, col. 1:22-26).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶60).
- Essential elements of claim 1, a device, include:
- A semiconductor die with first (signal) and second (power) contact pads.
- A package casing covering the die.
- A plurality of signal leads connected to the first contact pads.
- A power bar connected to the second contact pad, located between the signal leads and the die.
- An electrically grounded ground bar with a first portion between the signal leads and the power bar, and a second portion between the power bar and the die.
- The complaint alleges infringement of "one or more claims" (Compl. ¶59).
U.S. Patent No. 8,258,611 - “Leadframe Structure For Electronic Packages”
- Issued: Sep. 4, 2012
- Technology Synopsis: The patent addresses the problem of delamination of the molding compound from the leadframe, which can cause bondwire breakage (ʼ611 Patent, col. 1:26-46). The solution is a leadframe structure with a "barrier area"—a narrow metallic track connecting the die-pad to a bonding area—that is configured to halt the propagation of delamination that starts near the die ('611 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶82).
- Accused Features: The complaint accuses various Infineon products, such as the CoolGaN Integrated Power Stage and MOTIX Microcontroller, of incorporating infringing "delamination barrier structures" (Compl. ¶80, ¶83-86). The allegations are supported by annotated X-ray images purporting to show these structures (Compl. p. 44-47).
U.S. Patent No. 9,685,351 - “Wire Bond Mold Lock Method And Structure”
- Issued: June 20, 2017
- Technology Synopsis: The patent seeks to solve the problem of mold compound delamination by creating better mechanical adhesion to the lead frame ('351 Patent, col. 1:28-40). The invention is a method of forming "positive mold lock structures," such as dummy wire bond loops or stud bumps, that protrude laterally above the lead frame's surface to create a mechanical interlock when the molding compound is applied ('351 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶98).
- Accused Features: The complaint alleges that the manufacturing process for the Infineon AUDO MAX MCU, among other products, includes forming these infringing mold lock structures on the lead frame (Compl. ¶96, ¶99).
U.S. Patent No. 8,394,713 - “Method Of Improving Adhesion Of Bond Pad Over Pad Metallization With A Neighboring Passivation Layer By Depositing A Palladium Layer”
- Issued: Mar. 12, 2013
- Technology Synopsis: This patent addresses poor adhesion between a nickel layer on a bond pad and the adjacent passivation layer, which can create a space that leads to corrosion ('713 Patent, col. 2:49-56). The claimed method involves using an isotropic etchant to widen this space and then depositing a palladium layer that fills the gap, thereby creating a robust, corrosion-resistant connection between the nickel, the bond pad, and the passivation layer ('713 Patent, Abstract).
- Asserted Claims: Independent claim 1 is asserted (Compl. ¶115).
- Accused Features: The Infineon CoolGaN product line is accused of being manufactured using this patented method for forming over-pad metallization (Compl. ¶113, ¶116).
III. The Accused Instrumentality
Product Identification
- The complaint names several families of Infineon semiconductor products, including the OPTIREG Buck Regulator, PROFET Smart High-Side Power Switch, CoolGaN Integrated Power Stage, TC1782 AUDO MAX Microcontroller, TLF51801 OPTIREG Asynchronous DC/DC Step-Down Converter, and TLE9872 Motix 32-bit Microcontroller (Compl. ¶29).
Functionality and Market Context
- The accused products are integrated circuits and power management components used in various sectors, including automotive and telecommunications infrastructure (Compl. p. 6, 9). The complaint provides evidence from distributor websites, such as Digi-Key and Mouser, to allege that these products are actively marketed, sold, and available for purchase within the United States (Compl. ¶29, p. 6-21). For example, a screenshot shows the "Infineon 32-bit MCU TriCore Package" and its corresponding datasheet, which details its technical features (Compl. p. 31).
IV. Analysis of Infringement Allegations
’299 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| mounting a plurality of active device die, into predetermined positions, onto a temporary carrier... | The complaint alleges, based on X-ray and cross-section images, that the accused products are manufactured by mounting an active die onto a carrier/substrate. An X-ray image of an accused Infineon Buck Regulator package is presented as evidence of this step. | ¶41 | col. 4:5-12 |
| ...each said active device die having bond pads... | Images of a partially delayered package are provided to show the presence of bond pads on the active die. | ¶42 | col. 2:19-21 |
| ...each of said active device die having a solderable conductive surface on its underside; and having been subjected to back-grinding... | A cross-section image with energy-dispersive X-ray maps is used to allege the presence of a solderable copper (Cu) and lead/tin/silver (Pb, Sn, Ag) backside metallization on a silicon (Si) die. | ¶43 | col. 3:32-41 |
| dispensing a solder paste onto the bond pads on the plurality active device die; | A cross-section image is annotated to show what is alleged to be solder paste on the die bond pad, connecting it to the upper lead frame. | ¶44 | col. 4:36-40 |
| attaching a lead frame to the temporary carrier...wherein upper lead frame portions contact the solder paste present on the bond pads and lower lead frame portions contact the temporary carrier; | The complaint uses X-ray, cross-section, and delayered package images to allege that a lead frame is attached such that its upper parts contact the solder on the bond pads and its lower parts contact the carrier. | ¶45-47 | col. 4:35-50 |
| reflowing the solder so that a connection is made between the upper lead frame portions and the bond pads... | A final cross-section image is presented to show the completed solder connection between the upper lead frame and the die bond pad after the alleged reflow process. | ¶48 | col. 2:5-8 |
- Identified Points of Contention:
- Evidentiary Questions: The complaint alleges infringement of a method claim based on reverse engineering of a finished product. A central question will be whether the structural evidence presented (e.g., cross-sections, X-rays) is sufficient to prove that the accused products were manufactured using the specific sequence of steps required by claim 1, such as mounting on a "temporary carrier" before lead frame attachment.
- Scope Questions: The definition of "temporary carrier" may be contested. Defendant could argue that its manufacturing process, if different from the specific thermal-release tape embodiment described in the patent (ʼ299 Patent, col. 4:10-17), does not meet this limitation.
’646 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a semiconductor die having a plurality of first contact pads and at least one second contact pad... | An overlay image combining a die photo with a lead frame X-ray of the accused TriCore package is used to identify the semiconductor die and its contact pads. | ¶63 | col. 2:40-42 |
| a package casing that covers the semiconductor die; | The complaint points to the overall structure in the product photographs and X-rays as the package casing. | ¶64 | col. 2:35-39 |
| a plurality of signal leads spaced apart from the semiconductor die...electrically connected to a respective one of the first contact pads; | The annotated overlay image purports to show signal leads connected to the die's first contact pads. | ¶65 | col. 2:51-58 |
| a power bar extending at least partially in an area between the embedded portions of the plurality of signal leads and the semiconductor die... | The complaint identifies a structure in the X-ray overlay as the "power bar" and alleges it meets the claimed spatial arrangement. | ¶66-67 | col. 3:5-24 |
| a ground bar that is electrically grounded and extends at least partially in said area, the ground bar having a first portion disposed between...the signal leads and the...power bar, and a second portion disposed between the...power bar and the semiconductor die. | The complaint identifies a separate structure in the X-ray overlay as the "ground bar" and alleges it is positioned to shield the signal leads from the power bar as claimed. | ¶68-70 | col. 3:41-51 |
- Identified Points of Contention:
- Scope Questions: The infringement analysis will likely focus on the construction of "power bar" and "ground bar." A key question is whether the structures identified in the accused product's X-ray meet the specific spatial and structural definitions of the claims, particularly the two-part shielding structure of the "ground bar."
- Technical Questions: A factual dispute may arise over whether the structures identified by Plaintiff as the "power bar" and "ground bar" actually function as claimed. For example, the complaint alleges the ground bar is "electrically grounded," which will require evidence beyond the structural layout shown in the X-rays.
V. Key Claim Terms for Construction
For the ’299 Patent
- The Term: "temporary carrier"
- Context and Importance: This term is foundational to the claimed method, which requires mounting the die onto this carrier before attaching the lead frame. The defendant may argue its process uses a substrate or fixture that does not meet the patent's definition of a "temporary carrier," thus avoiding infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claims do not restrict the term to a specific material. The specification mentions both a "carrier tape stretched in a carrier ring apparatus" and a "carrier tape attached to a support plate," suggesting the term is not limited to a single configuration (ʼ299 Patent, col. 8:46-49).
- Evidence for a Narrower Interpretation: The detailed description of an embodiment repeatedly references a specific brand of thermal release tape ("REVALPHA® tape") (ʼ299 Patent, col. 4:10-17). A defendant may argue this focus limits the term to an adhesive tape that is removed via a specific mechanism.
For the ’646 Patent
- The Term: "ground bar"
- Context and Importance: The novelty of the '646 patent rests on the specific two-part structure of the "ground bar" that shields signal leads from the power bar. Whether the accused device contains a structure that meets this detailed definition will be dispositive for infringement.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language defines the term functionally and by its location relative to other components: a first portion between the signal leads and power bar, and a second portion between the power bar and the die (ʼ646 Patent, col. 5:20-25). Plaintiff will likely argue that any structure meeting these spatial requirements infringes, regardless of its exact shape.
- Evidence for a Narrower Interpretation: The embodiment shown in Figure 2 of the patent depicts the ground bar as a continuous, generally U-shaped structure with distinct portions. A defendant could argue that fragmented, non-continuous, or differently shaped conductive elements in its product do not constitute a "bar" as disclosed in the patent's preferred embodiment.
VI. Other Allegations
- Indirect Infringement: For all asserted patents, the complaint alleges induced infringement. The primary factual basis alleged is that Infineon contracts with third-party manufacturers to make the accused products and provides these products to customers and end-users, thereby intentionally causing their direct infringement (e.g., Compl. ¶51-52, ¶73-74).
- Willful Infringement: The willfulness allegations are based on knowledge "at least as of the date of this Complaint," indicating a claim for post-suit willfulness. The complaint also pleads willful blindness in the alternative, alleging that Defendant acted with a high probability that others were infringing but remained willfully blind to that fact (e.g., Compl. ¶52, ¶74).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue for the method patents ('299, '351, '713) will be one of evidence and inference: Can Plaintiff prove, through reverse engineering of finished products, that Defendant’s manufacturing process necessarily includes the specific sequence of steps and material transformations required by the asserted method claims?
- A core question for the apparatus patents ('646, '611) will be one of claim scope and construction: Can the terms "ground bar" ('646 patent) and "barrier area" ('611 patent), which are depicted with specific geometries in the patent embodiments, be construed broadly enough to read on the corresponding structures that Plaintiff has identified in the accused Infineon products through X-ray and cross-sectional analysis?
- The case relies heavily on the interpretation of the visual evidence provided in the complaint. A key battleground will be whether the annotated X-rays and microscopy images accurately depict the claimed features and functions, or if there is a fundamental mismatch in technical operation and structure between what the patents claim and what the accused products actually are.