DCT

2:25-cv-00393

HyperCore Systems LLC v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00393, E.D. Tex., 04/15/2025
  • Venue Allegations: Venue is alleged to be proper as to Samsung Electronics Co., Ltd. because it is a foreign corporation. Venue is alleged to be proper as to Samsung Electronics America, Inc. based on its regular and established place of business within the district (Plano, Texas) and alleged acts of infringement committed in the district.
  • Core Dispute: Plaintiff alleges that a wide range of Defendant’s electronic products, including smartphones, televisions, and laptops, infringes patents related to coordinated device management and multi-processor power regulation.
  • Technical Context: The patents address foundational challenges in modern multi-component electronic systems: managing actions across grouped devices like multi-core CPUs, and efficiently delivering power to them.
  • Key Procedural History: The complaint does not mention 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 Issues
2008-12-09 U.S. Patent No. 7,464,280 Issues
2025-04-15 Complaint Filed

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 describes a problem in computer systems where multiple devices (e.g., processors) are grouped into a "multi-device module." An operating system (OS) may need to perform an action on one device (e.g., deconfigure it due to an error) but is typically unaware of the grouping. The hardware, however, may require that if one device in a module is deconfigured, all devices in that module must be deconfigured (Compl. Ex. A, col. 1:29-51).
  • The Patented Solution: The invention proposes a system where an initiator (like an OS) can trigger an action for a single device, and that action is automatically applied to all devices within the same module (Compl. ¶15; Compl. Ex. A, col. 3:34-39). This is achieved using a "status block," a shared memory region for the module. When an action is initiated for one device, information is written to this status block, which then serves as a trigger for system firmware to apply the same action to all other devices in the module (Compl. Ex. A, Abstract; col. 4:4-20). This mechanism allows the OS to remain "transparent" to the underlying hardware groupings (Compl. Ex. A, col. 3:1-5).
  • Technical Importance: This approach decouples the OS from the specific hardware architecture, allowing new multi-device modules to be implemented without requiring corresponding changes to the OS (Compl. Ex. A, col. 3:1-5).

Key Claims at a Glance

  • The complaint specifically identifies independent claim 14 as being infringed (Compl. ¶22).
  • The essential elements of independent claim 14, a means-plus-function claim, are:
    • A plurality of devices;
    • Means for storing status information for the plurality of devices;
    • Means for an initiator to alter the status for a portion of the devices, which writes to the storing means; and
    • Means for applying the action to other devices based on the information written to the storing means, with the application performed by firmware.
  • The complaint notes that its infringement example is non-limiting, which may suggest the right to assert other claims is reserved (Compl. ¶22).

U.S. Patent No. 7,464,280 - “Power module for a plurality of processors”, Issued December 9, 2008

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty and cost of regulating power for multiple processors in an electronic device, particularly given the limited space on a printed circuit board (PCB) (Compl. ¶19; Compl. Ex. B, col. 1:7-14).
  • The Patented Solution: The invention describes a single "multi-processor power module" designed to serve multiple processors. The module contains "replicated components" for each processor, along with "control logic" that detects power demand from each processor and directs the replicated components to provide regulated power, which is then shared among the processors (Compl. Ex. B, Abstract). This consolidated design aims to reduce physical space, mounting hardware, and redundant components compared to using separate power modules for each processor (Compl. Ex. B, col. 4:35-51).
  • Technical Importance: The invention offers a way to improve power-delivery efficiency and reduce manufacturing costs and PCB footprint in multi-processor systems, such as servers or high-performance computers (Compl. ¶19; Compl. Ex. B, col. 4:35-66).

Key Claims at a Glance

  • The complaint specifically identifies independent claim 10 as being infringed (Compl. ¶27).
  • The essential elements of independent claim 10 are:
    • A plurality of processors;
    • A multi-processor power module that couples to the processors, detects demand from each, and provides a shared regulated power based on that demand; and
    • A separate component power module for components other than the plurality of processors.
  • The complaint notes that its infringement example is non-limiting, which may suggest the right to assert other claims is reserved (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses a broad range of Samsung products, including but not limited to the Galaxy S23, S24, and S25 smartphones; S series OLED TVs; Galaxy Watch 7 and Ultra smartwatches; Galaxy Book4 and Book5 laptops; and Galaxy Tab S9 and S10 tablets (Compl. ¶¶21, 26).

Functionality and Market Context

  • The complaint alleges these products contain "efficient processing" capabilities that infringe the patents-in-suit (Compl. ¶11). The allegations for the '329 Patent focus on systems where an action for one part of a device group is applied to the whole group (Compl. ¶¶15, 22). The allegations for the '280 Patent focus on the products' use of power management systems for multiple processors (Compl. ¶¶19, 27).
  • The complaint does not provide specific technical details on the operation of the accused products' processors or power management units, instead referring to forthcoming exemplary claim charts in Exhibits C and D, which were not attached to the publicly filed complaint (Compl. ¶¶22, 27).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits C and D, but these exhibits were not provided with the filed document. The infringement theory is therefore based on the narrative allegations in the complaint.

’329 Patent Infringement Allegations

The complaint alleges that the accused products, such as the Samsung Galaxy S23 smartphone, infringe claim 14 of the '329 Patent (Compl. ¶22). The narrative theory suggests that these products contain systems with multiple processing devices (e.g., multi-core CPUs). When an action (such as deconfiguration) is initiated for one of these devices, the product's architecture allegedly uses a mechanism equivalent to the claimed "status block" to automatically apply that action to other devices in the same functional group, using firmware as required by the claim (Compl. ¶¶15, 22). No probative visual evidence provided in complaint.

’280 Patent Infringement Allegations

The complaint alleges that the same range of accused products infringes claim 10 of the '280 Patent (Compl. ¶27). The infringement theory posits that these products contain a power architecture that functions as the claimed "multi-processor power module." This module is alleged to regulate and share power among a plurality of processors (e.g., cores) based on their individual demands, and operates alongside a separate power module for other system components, thereby meeting the limitations of claim 10 (Compl. ¶¶19, 27). No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central question for the '329 Patent will be whether the accused products' methods for coordinating actions across processor cores meet the specific "means for storing" and "means for applying" limitations of claim 14, which recites firmware as the applying means. For the '280 Patent, a question is whether modern, highly integrated Power Management Integrated Circuits (PMICs) in Samsung's devices can be characterized as a "multi-processor power module" with "replicated components" that is distinct from a "component power module" as claimed.
    • Technical Questions: A key factual dispute for the '329 Patent will be identifying a structure in the accused products that functions as the claimed "status block." For the '280 Patent, discovery will likely focus on whether the power delivery architecture for the processors is sufficiently "replicated" and "shared" in the manner described by the patent specification.

V. Key Claim Terms for Construction

  • Term: "status block" (from '329 Patent, specification context for claim 14)

    • Context and Importance: Claim 14 is a means-plus-function claim, and the "means for storing status information" is described in the specification as a "status block." The definition of this term is critical, as infringement will depend on whether Samsung's architecture contains an analogous structure. Practitioners may focus on this term to determine if it is limited to a specific type of memory structure or can be read more broadly to cover any form of shared state information.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent summary describes it as a "means for storing status information," which could suggest a functional rather than structural definition (Compl. Ex. A, col. 2:63-64).
      • Evidence for a Narrower Interpretation: The detailed description shows the status block as a specific "32-bit structure" in memory with defined fields for a signature, device status, and a deconfigured flag, which could support a narrower construction (Compl. Ex. A, col. 9:11-12; Fig. 2).

  • Term: "replicated components" (from '280 Patent, claim 1)

    • Context and Importance: This term from independent claim 1 (on which asserted claim 10 depends via other claims not asserted here, but which provides context) is central to the '280 Patent's infringement theory. The case may turn on whether the components within Samsung's power management systems are considered "replicated" for each processor.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent's goal of reducing redundancy might suggest that "replicated" does not require full, identical duplication, but rather the replication of key power-delivery stages (Compl. Ex. B, col. 4:41-51). Figure 5 shows replicated "switching stages" and "output stages" but a non-replicated "input stage" and "control logic," supporting an interpretation of partial replication (Compl. Ex. B, Fig. 5).
      • Evidence for a Narrower Interpretation: Defendant may argue that "replicated at least for each of the plurality of processors" implies a one-to-one correspondence of specific hardware units for each processor, which may not be present in a highly integrated PMIC.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. It asserts that Samsung knowingly encourages infringement by providing the accused products along with "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" that direct end-users and others to operate the products in an infringing manner (Compl. ¶¶23, 28).
  • Willful Infringement: The complaint makes a conclusory allegation that infringement has been willful, but does not plead specific facts regarding pre-suit knowledge of the patents (Compl. ¶¶24, 29; Prayer for Relief ¶C). The filing of the complaint itself establishes post-suit knowledge.

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

  1. A question of structural equivalence: For the '329 patent, can Plaintiff demonstrate that Samsung's devices, which manage coordinated tasks across processor cores, contain a specific, identifiable memory structure that performs the function of the claimed "status block" as described in the patent's detailed embodiments?
  2. A question of architectural characterization: For the '280 patent, does the integrated power management architecture in Samsung’s diverse products—from watches to TVs—map onto the patent's model of a "multi-processor power module" with "replicated components" and a separate "component power module," or does the technology represent a fundamentally different, more integrated design approach?
  3. An evidentiary question of functionality: Given the breadth of accused products, a central issue will be whether Plaintiff can provide evidence that the software and hardware in each distinct product line actually operate in the specific manner required to meet the functional limitations of the asserted means-plus-function claims.