Helix Microinnovations LLC v. Lumileds Holding BV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Helix Microinnovations LLC (Delaware)
  • Defendant: Lumileds Holding B.V. (The Netherlands)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00565, E.D. Tex., 05/21/2025
• Venue Allegations: Venue is asserted based on the Defendant being a foreign corporation and having allegedly committed acts of patent infringement that caused harm within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s fabrication of certain semiconductor products infringes a patent related to methods for manufacturing Chip-on-Board modules.
• Technical Context: The technology relates to semiconductor manufacturing, specifically processes for mounting unpackaged semiconductor die onto printed circuit boards to create functional electronic modules in a cost-effective manner.
• Key Procedural History: The complaint alleges that Plaintiff is the assignee of the patent-in-suit, possessing all rights to enforce it. No other procedural events, such as prior litigation or administrative proceedings involving the patent, are mentioned in the complaint.

Case Timeline

Date	Event
2002-02-26	’550 Patent Priority Date
2007-07-03	’550 Patent Issue Date
2025-05-21	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

• Issued: July 3, 2007

The Invention Explained

• Problem Addressed: The patent describes an ongoing need for cost-effective semiconductor manufacturing, particularly methods that can utilize "less-than-perfect" or partially-defective semiconductor die that might otherwise be discarded. (’550 Patent, col. 2:13-18). It also notes that standard high-temperature "burn-in" testing can cause failures due to differing thermal expansion rates between the semiconductor die and the circuit board. (’550 Patent, col. 2:7-12).
• The Patented Solution: The invention is a method for fabricating "Chip-on-Board" (COB) modules using "selectively settable materials," such as UV-curable adhesives. The process involves mounting an unpackaged die onto a printed circuit board (PCB) and then hardening a ring of the material around the die's periphery to secure it in place. (’550 Patent, col. 4:12-20). A key aspect is that the material under the die can remain liquid to act as a physical and thermal buffer, while a second layer of settable material is applied over the first to "capture" and protect the delicate bonding wires that electrically connect the die to the PCB. (’550 Patent, col. 4:42-55, col. 7:15-32).
• Technical Importance: This method was designed to improve the manufacturing yield and lower the cost of electronic modules by enabling the use of unpackaged die and facilitating adjustments and repairs during the fabrication process. (’550 Patent, col. 2:33-38).

Key Claims at a Glance

• The complaint asserts infringement of exemplary method claims without specifying claim numbers (Compl. ¶11). Independent claim 1 is a representative method claim.
• Independent Claim 1 requires:
  • A method of fabricating Chip-on-Board logic modules using selectively settable materials, comprising:
  • mounting an unpackaged die using a first layer of selectively-settable material;
  • hardening a ring of said first layer of selectively-settable material around a periphery of said unpackaged die;
  • covering said first layer with a second layer of selectively-settable material; and
  • capturing bonding wires connecting the die to a printed circuit board in said second layer.
• The complaint alleges infringement literally or under the doctrine of equivalents and does not foreclose asserting other claims. (Compl. ¶11).

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 provided as Exhibit 2. (Compl. ¶11, ¶13). As this exhibit was not attached to the publicly filed complaint, the specific instrumentalities remain unidentified.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the Accused Products' specific functionality, features, or market position. It alleges only that the products "practice the technology claimed by the '550 Patent." (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint references but does not include its claim chart exhibit (Compl. ¶13, ¶14). The infringement theory is therefore summarized from the complaint's narrative allegations.

The complaint alleges that Defendant directly infringes one or more method claims of the ’550 Patent by making, using, offering to sell, or importing the "Exemplary Defendant Products" (Compl. ¶11). The infringement is alleged to occur through Defendant's manufacturing processes for these products. The complaint further alleges that infringement occurs when Defendant’s employees "internally test and use" the accused products (Compl. ¶12). The core of the allegation is that the accused manufacturing process satisfies all elements of the asserted claims (Compl. ¶13). No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: Given the claims' focus on a multi-layer material process, a central question may be whether Defendant's manufacturing method involves distinct "first" and "second" layers of material as required by claim 1, or if it uses a single application of an encapsulant. The definition of "capturing" bonding wires within the second layer, as distinct from merely covering them, could also become a point of dispute.
• Technical Questions: An evidentiary question for discovery will be to determine the specific materials and steps used in Defendant's COB fabrication. The analysis will require evidence of whether Defendant's process includes hardening only a "ring" of material around the die while leaving other portions less cured, a key feature described in the patent. (’550 Patent, col. 4:26-34).

V. Key Claim Terms for Construction

"selectively settable material" (from Claim 1)

Context and Importance: This term is foundational to the claimed invention. Its construction will be critical to determining infringement, as it defines the substance used in the patented method. Practitioners may focus on this term because its scope will dictate whether conventional manufacturing encapsulants or adhesives fall within the claims, or if it is limited to materials with more specialized properties.

Intrinsic Evidence for Interpretation:

• Evidence for a Broader Interpretation: The term itself is not explicitly defined. A party could argue it encompasses any material whose hardening can be controlled in a selective location or manner.
• Evidence for a Narrower Interpretation: The specification repeatedly provides "UV material" and "UV-curable" liquids as the primary examples. (’550 Patent, col. 4:2-3, col. 11:6-10). The detailed description explains that the material allows a ring to be hardened while the portion under the die remains liquid as a "thermal and physical buffer," suggesting a material with specific partial-curing capabilities. (’550 Patent, col. 4:26-34, col. 11:1-5).

"capturing bonding wires ... in said second layer" (from Claim 1)

Context and Importance: This term defines the final step of securing the electrical connections. The dispute will likely center on whether "capturing" requires a specific action of physical entrapment, as opposed to simply overmolding or covering the wires with a protective coating.

Intrinsic Evidence for Interpretation:

• Evidence for a Broader Interpretation: An argument could be made that any process that results in the wires being encased within the second material layer meets the "capturing" limitation.
• Evidence for a Narrower Interpretation: The specification describes a specific sequence: "The wires may be captured by carefully placing the wires within the second ring while the selectively settable material is still manageable and then hardening the ring." (’550 Patent, col. 4:48-52). This language, along with dependent claim 3's teaching of "placing only a part of each of the bonding wires" in the material, suggests an intentional, physical placement process rather than simple encapsulation. (’550 Patent, col. 10:65-67).

VI. Other Allegations

Indirect Infringement

The complaint does not plead a count for indirect infringement. Count 1 is limited to "Direct Infringement." (Compl. ¶11).

Willful Infringement

The complaint does not use the term "willful." However, in its prayer for relief, it requests that the case be "declared exceptional within the meaning of 35 U.S.C. § 285" and seeks an award of attorneys' fees. (Compl. ¶ E.i.). This request is not supported by any specific factual allegations in the complaint regarding pre-suit knowledge or egregious conduct by the Defendant.

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

The complaint's sparse factual allegations frame a dispute that will depend heavily on evidence uncovered during discovery. The key questions that will likely define the case are:

1. A primary issue will be one of evidentiary proof: Can the Plaintiff demonstrate that the Defendant's unidentified manufacturing process for its accused products maps onto the specific, multi-step method recited in the ’550 Patent's claims? The current complaint lacks the factual detail to assess the strength of the infringement read.

2. The case may also turn on a question of claim scope: Will the term "selectively settable material" be construed broadly to cover a wide range of industrial adhesives, or will it be limited by the specification's detailed examples to materials possessing specific properties, such as the capacity for partial UV curing to create a liquid thermal buffer? The outcome of this construction could be dispositive.