DCT

2:25-cv-00382

HyperCore Systems LLC v. LG Electronics Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00382, E.D. Tex., 04/10/2025
  • Venue Allegations: Venue for LG-Korea is based on its status as a foreign corporation. Venue for LG-USA is based on allegations that it maintains a regular and established place of business in the Eastern District of Texas and has committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s televisions and laptops, which feature multi-processor systems, infringe patents related to coordinating actions across multiple devices and efficiently regulating power for them.
  • Technical Context: The technology concerns hardware and firmware architectures for managing and powering multi-device modules, such as multi-core processors, which are fundamental to the design of modern consumer electronics.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
2003-03-28 ’329 Patent Priority Date
2005-06-22 ’280 Patent Priority Date
2008-06-24 U.S. Patent No. 7,392,329 Issued
2008-12-09 U.S. Patent No. 7,464,280 Issued
2025-04-10 Complaint Filing Date

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

U.S. Patent No. 7,392,329 - System and method for applying an action initiated for a portion of a plurality of devices to all of the plurality of devices

Issued June 24, 2008

The Invention Explained

  • Problem Addressed: The patent addresses a challenge in computer systems where multiple devices (e.g., processors) are grouped into a common module. The operating system (OS) is often unaware of this grouping and treats each device as independent. This creates a problem when an action initiated by the OS for one device (e.g., deconfiguring it due to an error) must, for hardware or serviceability reasons, be applied to all devices in the module (’329 Patent, col. 2:29-54).
  • The Patented Solution: The invention proposes a "status block," a shared memory structure for the module. When an initiator (like the OS) triggers an action for any single device, information is written to this common status block. System firmware then reads this status block and automatically applies the action to all other devices in the module, making the process transparent to the OS, which does not need to know about the device grouping (’329 Patent, Abstract; col. 3:34-39).
  • Technical Importance: This method allows systems to comply with industry standards (like ACPI) that give the OS control over device configuration, while still supporting complex, proprietary hardware groupings in multi-device modules (’329 Patent, col. 3:1-25).

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶21).
  • The essential elements of claim 14, a system claim written in means-plus-function format, are:
    • a plurality of devices;
    • means for storing status information for said plurality of devices;
    • means for initiating an action for altering status of a portion of said plurality of devices, wherein said altering writes said status information to the storing means; and
    • means for applying said action for altering status of said portion of said plurality of devices to other ones of said plurality of devices...based at least in part on said status information...said means for applying said action comprising firmware in said system.
  • The complaint reserves the right to modify its infringement description pending discovery (Compl. ¶21).

U.S. Patent No. 7,464,280 - Power module for a plurality of processors

Issued December 9, 2008

The Invention Explained

  • Problem Addressed: In electronic devices with multiple processors, providing regulated power to each processor is costly and complex, particularly due to the limited space available on printed circuit boards (PCBs) (’280 Patent, col. 1:8-14).
  • The Patented Solution: The patent describes a dedicated "multi-processor power module" that serves a plurality of processors from a single unit. The module is designed with a hybrid architecture, using non-replicated components (e.g., a single input stage and control logic) that are shared, and replicated components (e.g., switching and output stages) for each processor. This approach is designed to handle the independent and dynamic power demands of each processor while saving PCB space and reducing component redundancy (’280 Patent, Abstract; Fig. 5).
  • Technical Importance: This architecture enables more compact, cost-effective, and efficient power delivery systems for multi-processor electronics by consolidating hardware that would otherwise be duplicated for each processor (’280 Patent, col. 4:35-51).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶26).
  • The essential elements of claim 10, an electronic device claim, are:
    • a plurality of processors;
    • a multi-processor power module that couples to the plurality of processors, detects a demand from each...and provides a regulated power based on the demand, the regulated power being shared by the plurality of processors; and
    • a component power module that couples to components other than the plurality of processors and that regulates power to the components.
  • The complaint reserves the right to modify its infringement descriptions pending discovery (Compl. ¶26).

III. The Accused Instrumentality

Product Identification

The complaint accuses the LG OLED G4, LG OLED C4, and LG OLED B4 televisions of infringing both the ’329 and ’280 patents. The LG Gram Book 15U50T-G.ARS2U1 laptop is accused of infringing the ’280 Patent (Compl. ¶20, ¶25).

Functionality and Market Context

The complaint alleges that these products infringe by "making, using, selling, or offering for sale...products with efficient processing claimed in the Patents-in-Suit" (Compl. ¶10). It asserts that the accused LG TVs contain systems that infringe claim 14 of the ’329 Patent and that both the TVs and the accused laptop contain systems that infringe claim 10 of the ’280 Patent (Compl. ¶21, ¶26). The complaint does not provide specific technical details on the operation of the accused products, instead referencing claim chart exhibits that were not included with the complaint document (Compl. ¶21, ¶26). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart Exhibits C, D, and E to detail its infringement allegations, but these exhibits were not provided. The narrative infringement theory is summarized below.

  • ’329 Patent Infringement Allegations: The complaint alleges that the accused LG televisions infringe at least claim 14 (Compl. ¶20-21). The infringement theory appears to be that the processors in the televisions constitute a "plurality of devices." It is alleged that these products contain the claimed "means for storing" status information, "means for initiating" an action, and "means for applying" that action across the devices via firmware. This suggests an allegation that when the television's OS initiates an action for a single processor core, a shared status mechanism causes firmware to apply that action to other cores in the same module (Compl. ¶14).
  • ’280 Patent Infringement Allegations: The complaint alleges that the accused LG televisions and laptop infringe at least claim 10 (Compl. ¶25-26). The infringement theory appears to focus on the power architecture of these devices. Plaintiff alleges the products contain a "multi-processor power module" that regulates and provides shared power to their multiple processors, as well as a separate "component power module" that powers other system components. This structure is alleged to meet the elements of claim 10 (Compl. ¶18).
  • Identified Points of Contention:
    • ’329 Patent (Means-Plus-Function): Claim 14 is composed entirely of means-plus-function limitations. A central dispute will be whether the accused products contain structures that are structurally equivalent to the specific "status block" architecture and associated firmware disclosed in the ’329 Patent specification for performing the claimed functions.
    • ’280 Patent (Structural Demarcation): The infringement analysis may turn on whether the accused products' power circuitry can be physically and functionally demarcated into the two distinct modules required by claim 10: a "multi-processor power module" and a separate "component power module." The question is whether the accused devices employ such a partitioned architecture or a more integrated power system.

V. Key Claim Terms for Construction

  • Term: "means for storing status information for said plurality of devices" (’329 Patent, Claim 14)

    • Context and Importance: As a means-plus-function limitation, the construction of this term will define the required structure for infringement. Practitioners may focus on this term because the outcome of the infringement analysis for claim 14 depends entirely on identifying an equivalent structure in the accused device.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the function being performed by a "region of memory" or a "status structure," which could be implemented in "non-volatile memory (e.g., NVRAM)" (’329 Patent, col. 4:5-8, 4:20-22). This language could support an argument that any shared memory location used for status flags is within the scope.
      • Evidence for a Narrower Interpretation: The patent discloses a specific corresponding structure: a "status block" (102A/102B) with a detailed 32-bit layout shown in Figure 2, which includes fields for a signature, device-specific status, and a single bit to indicate if the entire module is deconfigured (’329 Patent, Fig. 2; col. 9:11-10:26). This disclosure could support a narrower construction limited to this specific bit-mapped structure or a close structural equivalent.

  • Term: "multi-processor power module" (’280 Patent, Claim 10)

    • Context and Importance: The definition of this term is critical for determining if the accused products have the claimed two-part power architecture. Practitioners may focus on this term because infringement hinges on whether the power circuitry in the accused products constitutes a single, identifiable module that is separate from the "component power module."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the module's function as providing power to multiple processors and being "configured to handle the dynamic power needs of both" (’280 Patent, col. 2:5-7, 2:50-52). This could support a construction covering any power regulation circuitry that is logically dedicated to multiple processors.
      • Evidence for a Narrower Interpretation: The specification repeatedly depicts the "multi-processor power module" as a discrete physical component (104, 304) mounted on a PCB, positioned to achieve "space reduction" and "mount reductions" by eliminating redundant parts from separate uni-processor modules (’280 Patent, Figs. 1, 3; col. 4:35-51). This could support a construction requiring a physically distinct, consolidated package that provides specific layout efficiencies.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents, asserting that LG encourages infringement by providing customers and partners with the accused products along with "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" (Compl. ¶22, ¶27).
  • Willful Infringement: The complaint includes a prayer for a finding of willful infringement and enhanced damages (Compl., Prayer for Relief ¶C, E). However, the body of the complaint does not plead specific facts suggesting pre-suit knowledge of the patents-in-suit, such as prior correspondence or citation of the patents in other contexts.

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

The resolution of this case may depend on the court’s determination of the following key questions:

  1. A central issue for the ’329 patent will be one of structural equivalence: Do the accused LG televisions utilize a hardware and firmware system that is structurally equivalent to the specific "status block" memory map and associated firmware routines disclosed in the patent, or do they achieve cross-device coordination through a structurally different mechanism?

  2. For the ’280 patent, the dispute may turn on a question of physical demarcation: Does the claim term "multi-processor power module" require a physically distinct and consolidated hardware unit as shown in the patent’s embodiments, and if so, do the accused LG products incorporate such a discrete module, or do they use a more integrated power system that does not align with the claim's two-part architectural requirement?