DCT

2:25-cv-00580

HyperCore Systems LLC v. Panasonic Holdings Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00580, E.D. Tex., 05/22/2025
  • Venue Allegations: Venue is alleged to be proper for Panasonic Holdings Corporation as a foreign corporation and for Panasonic Corporation of North America based on its regular and established place of business and acts of infringement within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s line of Toughbook laptops, tablets, and automotive infotainment systems infringes two patents related to methods for managing actions and power across multiple processors or devices within a single system.
  • Technical Context: The patents address challenges in designing complex computer systems where multiple processors are grouped into modules, focusing on how the operating system can manage them and how power can be supplied efficiently without custom, costly solutions for each processor.
  • 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 Priority Date for U.S. Patent No. 7,392,329
2005-06-22 Priority Date for U.S. Patent No. 7,464,280
2008-06-24 U.S. Patent No. 7,392,329 Issued
2008-12-09 U.S. Patent No. 7,464,280 Issued
2025-05-22 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: In computer systems with multi-device modules (e.g., multi-core processors), an operating system (OS) may need to perform an action on a single device, such as deconfiguring a faulty processor core. The hardware, however, may require this action to be applied to all devices within that module. The patent notes that conventional operating systems are generally unaware of these hardware-level groupings, and requiring the OS to be aware of them would necessitate custom modifications for new hardware configurations (ʼ329 Patent, col. 2:29-54; col. 3:1-8).
  • The Patented Solution: The invention proposes using a "status block," which is a dedicated region of memory associated with a multi-device module. When an initiator like an OS performs an action on one device, it writes information to this shared status block. System firmware then reads the status block and automatically propagates the action to all other devices in the module. This mechanism allows the underlying hardware grouping to remain transparent to the OS (ʼ329 Patent, Abstract; col. 4:5-18). Figure 1 illustrates this architecture, showing the OS interacting with CPU modules via common status blocks managed by firmware.
  • Technical Importance: This approach decouples the OS from the physical hardware implementation, allowing standard, ACPI-compliant operating systems to manage modular hardware without needing to be rewritten for each new processor configuration (ʼ329 Patent, col. 3:1-8, 16-25).

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶22).
  • Claim 14 is a system claim comprising the following essential elements:
    • 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 to other devices, based on the information in the storing means, where the means for applying comprises firmware.
  • The complaint reserves the right to assert additional claims (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: Designing and implementing power regulation for multiple processors in an electronic device is costly and complex, particularly due to the dynamic power needs of each processor and the limited physical space on a printed circuit board (PCB) (ʼ280 Patent, col. 1:7-14).
  • The Patented Solution: The patent describes a single "multi-processor power module" designed to serve multiple processors. The module achieves space and cost efficiencies by combining non-replicated components (e.g., a single input stage and control logic) for less failure-prone functions with replicated components (e.g., individual switching and output stages for each processor) for more failure-prone functions. This architecture allows the module to dynamically handle the power demands of each processor without the expense and footprint of entirely separate power supplies for each one (ʼ280 Patent, Abstract; col. 2:50-55; Fig. 5).
  • Technical Importance: The invention provides a method for making multi-processor systems more compact and cost-effective by consolidating power regulation functions into a single, shared module that balances component redundancy with space savings (ʼ280 Patent, col. 4:35-52).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶27).
  • Claim 10 is a claim for an electronic device comprising:
    • a plurality of processors;
    • a multi-processor power module coupled to the processors that detects demand from each processor and provides a shared, regulated power based on that demand; and
    • a component power module that couples to and regulates power for components other than the plurality of processors.
  • The complaint reserves the right to assert additional claims (Compl. ¶27).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities include the Panasonic FZ-G2, CF-33, FZ-55, and FZ-40 Toughbook tablets and laptops, and the Panasonic 86140-OA281 Infotainment System (collectively, "the Accused Products") (Compl. ¶21, ¶26).

Functionality and Market Context

  • The complaint identifies the Accused Products as devices that incorporate "efficient processing" (Compl. ¶11). These devices, being modern tablets, laptops, and infotainment systems, inherently rely on multi-core processors and sophisticated power management systems to function. The infringement allegations center on the underlying architecture used to coordinate actions between processor cores and to regulate power delivery to them (Compl. ¶15, ¶19).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits C and D, but these exhibits were not filed with the public complaint. Therefore, a chart-based analysis is not possible. The infringement theories are summarized below in prose.

  • ’329 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe at least claim 14 of the ’329 Patent (Compl. ¶22). The core theory appears to be that the Accused Products contain a system for managing actions across multiple processor cores. When the operating system initiates an action for one core, the system allegedly uses a mechanism equivalent to the claimed "means for storing status information" (e.g., a shared register or memory location) and "means for applying said action" (e.g., system firmware) to automatically apply that action to other cores in the same processor module. This is alleged to meet the limitations of claim 14 (Compl. ¶15).

  • ’280 Patent Infringement Allegations: The complaint alleges that the Accused Products infringe at least claim 10 of the ’280 Patent (Compl. ¶27). The infringement theory suggests that the Accused Products contain an integrated "multi-processor power module" that dynamically provides shared, regulated power to a plurality of processors based on their individual demands. The complaint further alleges the products contain a separate "component power module" for other system components, thereby meeting all elements of claim 10 (Compl. ¶19).

  • No probative visual evidence provided in complaint.

  • Identified Points of Contention:

    • Scope Questions: The infringement analysis for the ’329 Patent will involve construing means-plus-function claim terms. This raises the question: does the architecture in the Accused Products for coordinating actions across processor cores contain structures that are identical or equivalent to the "status block" and "firmware" disclosed in the '329 Patent specification for performing the claimed functions? (ʼ329 Patent, col. 7:3-14, 61-65; Fig. 1).
    • Technical Questions: For the '280 Patent, a central question may be whether the Accused Products' power circuitry operates as the claimed "multi-processor power module." Specifically, what evidence does the complaint provide that the power regulation circuitry is a single, integrated module that "shares" regulated power, as opposed to a collection of co-located but functionally distinct power regulators? (ʼ280 Patent, col. 2:26-54).

V. Key Claim Terms for Construction

  • From the ’329 Patent, Claim 14:

    • The Term: "means for applying said action...comprising firmware"
    • Context and Importance: This is a means-plus-function limitation. Its scope is not limitless but is tied to the corresponding structure described in the patent's specification and its equivalents. The outcome of the infringement analysis for claim 14 will depend heavily on whether the accused system's architecture is found to be structurally equivalent to what the '329 Patent discloses for this function.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the function broadly as applying an action to "all devices of the module" in response to information in the status block (ʼ329 Patent, col. 4:13-18).
      • Evidence for a Narrower Interpretation: The specification provides a specific structural implementation: system firmware (103) that accesses the status structure (102A), particularly upon a system reset, to determine if devices are deconfigured and then rebuilds the device tree accordingly (ʼ329 Patent, col. 13:12-21). An argument could be made that the "means" is limited to this firmware-based, reset-time implementation and its direct equivalents.

  • From the ’280 Patent, Claim 10:

    • The Term: "multi-processor power module"
    • Context and Importance: This term is the central element of claim 10. How it is defined will be critical. If construed broadly, it could cover any power supply system that services multiple processors. If construed narrowly, it might be limited to the specific architecture disclosed in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is general, describing the module by its function: it "detects a demand," "provides a regulated power," and that power is "shared" (ʼ280 Patent, col. 10:1-5).
      • Evidence for a Narrower Interpretation: The detailed description and figures emphasize a particular architecture that combines non-replicated components (input stage, control logic) with replicated components (switching stages, output stages) to save space and cost (ʼ280 Patent, col. 5:55-63; Fig. 5). A defendant may argue that this disclosed structure defines and limits the scope of the term.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents. The basis for this allegation is that Panasonic provides the Accused Products along with "specifications, instructions, manuals, advertisements, marketing materials, and technical assistance" that allegedly instruct and encourage customers and end-users to operate the products in an infringing manner (Compl. ¶23, ¶28).
  • Willful Infringement: The complaint includes a prayer for a finding of willful infringement (Compl. p. 7, ¶C). The complaint itself establishes post-suit knowledge of the patents, but it does not plead specific facts to support an allegation of pre-suit knowledge or egregious conduct.

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

  1. A core issue for the ’329 patent will be one of structural equivalence. Given the use of means-plus-function claiming, the dispute may center on whether the accused Panasonic products contain an architecture that is structurally equivalent to the specific "status block" and "firmware" arrangement disclosed in the patent for coordinating actions across multiple processor cores.

  2. A key issue for the ’280 patent will be one of definitional scope. The case may turn on whether the term "multi-processor power module" is construed broadly to cover any system providing power to multiple processors, or narrowly, limited by the specification's examples to an architecture that strategically combines non-replicated and replicated components.

  3. An overarching evidentiary question will be one of technical operation. As the complaint lacks detailed technical breakdowns of the accused systems, the case will depend on evidence developed during discovery to establish how the Panasonic products' hardware and firmware actually function with respect to inter-processor coordination and power regulation.