DCT

2:25-cv-00637

HyperCore Systems LLC v. Harman Intl Industries Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00637, E.D. Tex., 06/16/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant 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 soundbars and automotive infotainment systems infringe patents related to methods for coordinating actions across multiple electronic devices and for efficiently managing power in multi-processor systems.
  • Technical Context: The patents address core architectural challenges in modern electronics, where managing actions and power across multiple grouped processors is essential for performance, scalability, and reliability.
  • 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 U.S. Patent No. 7,392,329 Priority Date
2005-06-22 U.S. Patent No. 7,464,280 Priority Date
2008-06-24 U.S. Patent No. 7,392,329 Issued
2008-12-09 U.S. Patent No. 7,464,280 Issued
2025-06-16 Complaint Filed

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

U.S. Patent No. 7,392,329

  • Patent Identification: 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. (Compl. ¶9).

The Invention Explained

  • Problem Addressed: In computer systems where multiple devices (e.g., processors) are grouped into a common module, the system’s Operating System (OS) is often unaware of this physical grouping. This creates a challenge when an action initiated for a single device, such as deconfiguration due to a suspected fault, should ideally be applied to all devices within the same module for serviceability and stability. (’329 Patent, col. 2:31-54).
  • The Patented Solution: The invention proposes using a common "status block," a dedicated region of memory, for each multi-device module. When an initiator like the OS performs an action on a single device, it writes information to this common status block. System firmware then reads this information and automatically applies the action to all devices in the module, making the process seamless to the OS, which remains unaware of the device grouping. (’329 Patent, Abstract; col. 4:5-18).
  • Technical Importance: This architecture provides a standardized way for an OS to manage complex modular hardware, enhancing system scalability and serviceability without requiring custom OS modifications for each new hardware configuration. (Compl. ¶12; ’329 Patent, col. 3:1-7).

Key Claims at a Glance

  • The complaint identifies independent claim 14 as exemplary. (Compl. ¶19).
  • The essential elements of system claim 14 include:
    • a plurality of devices;
    • means for storing status information for said plurality of devices;
    • means for initiating an action for altering the status of a portion of the devices, which involves writing information to the storing means; and
    • means for applying the action to other devices in the plurality based on the stored information, where this means for applying comprises firmware. (’329 Patent, col. 17:6-19).
  • The complaint states it "reserves the right to modify this description" based on discovery. (Compl. ¶19).

U.S. Patent No. 7,464,280

  • Patent Identification: U.S. Patent No. 7,464,280, "Power module for a plurality of processors," issued December 9, 2008. (Compl. ¶13).

The Invention Explained

  • Problem Addressed: Providing regulated power to multiple processors within a single electronic device is technically difficult and costly, particularly due to the high cost and limited physical space on a printed circuit board (PCB). (’280 Patent, col. 1:8-14).
  • The Patented Solution: The patent describes a single "multi-processor power module" designed to serve a plurality of processors. This module consolidates certain power regulation components while replicating others for each processor it serves. This architecture allows the module to dynamically respond to the independent power demands of each processor from a shared, space-efficient unit, rather than requiring a fully separate power module for each processor. (’280 Patent, Abstract; col. 2:50-54).
  • Technical Importance: This integrated approach to power delivery enables more compact, cost-effective, and efficient designs for multi-processor systems, which are prevalent in dense electronics. (Compl. ¶16; ’280 Patent, col. 4:35-42).

Key Claims at a Glance

  • The complaint identifies independent claim 10 as exemplary. (Compl. ¶24).
  • The essential elements of electronic device claim 10 include:
    • a plurality of processors;
    • a multi-processor power module coupled to the processors that detects power demand from each and provides a shared regulated power based on that demand; and
    • a component power module that couples to and regulates power for other components in the device. (’280 Patent, col. 9:51-10:7).
  • The complaint states it "reserves the right to modify this description" based on discovery. (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

  • The complaint accuses the "JBL Bar 300 soundbar" of infringing the ’329 and ’280 patents, and the "Harman MGU21A Infotainment System" of infringing the ’280 Patent, along with other "substantially similar products." (Compl. ¶18, ¶23).

Functionality and Market Context

  • The complaint broadly identifies the accused products as "soundbars, infotainment systems, and other products with efficient processing." (Compl. ¶8). It does not provide specific details regarding the internal architecture or operation of the accused products' processing or power management systems. The complaint alleges that Defendant derives substantial revenue from its activities in the district. (Compl. ¶6).

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits 3 and 4 but does not attach them. (Compl. ¶19, ¶24). In their absence, the infringement theory is based on the complaint's narrative allegations.

The complaint alleges that the '329 Accused Products, such as the JBL Bar 300, infringe claim 14 of the ’329 Patent by incorporating a system for applying an action initiated for a portion of a plurality of devices to all such devices. (Compl. ¶12, ¶18-19). Similarly, it alleges the ’280 Accused Products, including the JBL Bar 300 and Harman MGU21A Infotainment System, infringe claim 10 of the ’280 Patent by containing a multi-processor power module for efficient power regulation. (Compl. ¶16, ¶23-24). The complaint does not, however, provide specific factual allegations that map the functionality of the accused products to the individual elements of the asserted claims. No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Questions: The central issue will be whether discovery uncovers evidence that the accused products' internal architectures perform the functions required by the claims. For the ’329 Patent, does the JBL Bar 300 utilize a "means for storing status information" (such as a status block) and a firmware-based "means for applying" an action across multiple devices? For the ’280 Patent, do the accused products contain both a "multi-processor power module" that shares power and a separate "component power module" as architected in claim 10?
    • Scope Questions: The interpretation of the means-plus-function limitations in claim 14 of the ’329 Patent will be critical. The dispute may focus on defining the corresponding structure disclosed in the specification (e.g., firmware accessing a status block in NVRAM) and determining if the accused products contain an equivalent structure. (’329 Patent, col. 7:15-26, col. 9:30-36).

V. Key Claim Terms for Construction

For the ’329 Patent (Claim 14):

  • The Term: "means for applying said action ... comprising firmware"
  • Context and Importance: As a means-plus-function element, the scope of this term is limited to the corresponding structures disclosed in the specification and their equivalents. The core of the infringement dispute for this element will be identifying the corresponding structure in the patent and comparing it to the accused products.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The function is "applying said action for altering status ... to other ones of said plurality of devices." (’329 Patent, col. 17:14-16). The specification discloses firmware as the structure, which could be argued to cover any firmware-driven process that accomplishes this function.
    • Evidence for a Narrower Interpretation: A party could argue the corresponding structure is not just "firmware" in general, but the specific process described, such as firmware that, upon system reset, accesses the status block and rebuilds an ACPI device tree to exclude certain devices. (’329 Patent, col. 13:11-20).

For the ’280 Patent (Claim 10):

  • The Term: "multi-processor power module"
  • Context and Importance: The definition of this term is central to the infringement analysis for the ’280 Patent. Practitioners may focus on this term because its construction will determine whether the power architecture in Harman's products falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the component functionally as a module "dedicated to the power needs of multiple processors." (’280 Patent, col. 4:44-46). This could support an interpretation covering any integrated power regulation system serving multiple processors.
    • Evidence for a Narrower Interpretation: The patent figures consistently show a single, discrete physical module (e.g., item 104 in FIG. 1) that is separate from the processors. (’280 Patent, FIGs. 1, 2, 3). Language discussing the benefits of a "single mount" and reducing components may further support a narrower construction limited to a unitary, physically distinct module. (’280 Patent, col. 4:55-56).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendant induces infringement of both patents by "actively and knowingly" encouraging others (including customers and partners) through the provision of "instructions, manuals, advertisements, [and] marketing materials" that direct the use of the accused products in an infringing manner. (Compl. ¶20, ¶25).
  • Willful Infringement: While the complaint does not explicitly use the word "willful," it alleges Defendant acted "knowingly" to induce infringement and includes a prayer for relief requesting that damages be "trebled as provided by 35 U.S.C. § 284." (Compl. ¶20, ¶25, p. 6). This request for enhanced damages suggests an allegation of egregious infringement.

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

  1. Evidentiary Proof: Given the complaint's lack of technical specifics, a primary hurdle for the plaintiff will be one of evidentiary proof: can discovery reveal that the accused soundbars and infotainment systems possess the specific internal architectures recited in the patent claims, such as the "status block" system of the ’329 patent and the dual "multi-processor" and "component" power module structure of the ’280 patent?
  2. Claim Construction: The case will likely involve significant disputes over claim scope. A key legal question for the ’329 patent is the structural scope of its means-plus-function claims, while a key question for the ’280 patent will be one of definitional scope: does the term "multi-processor power module" require a single, physically discrete unit as depicted in the patent’s embodiments, or can it be construed to cover a more functionally integrated but physically distributed power system?