DCT

2:25-cv-00765

Induction Devices LLC v. Dick's Sporting Goods Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00765, E.D. Tex., 08/05/2025
  • Venue Allegations: Venue is based on Defendant allegedly having a place of business in the district and selling accused products within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s branded contactless consumer credit cards infringe five patents related to fundamental semiconductor circuit design, signal processing, and secure communications.
  • Technical Context: The patents cover foundational technologies for complex systems-on-a-chip, including circuit reset logic, signal multiplexing, secure memory for NFC transactions, asynchronous communication, and digital signal processing.
  • Key Procedural History: The complaint notes that U.S. Patent No. 7,889,145 was previously litigated in the Western District of Texas, but those cases were resolved before any substantive matters were addressed.

Case Timeline

Date Event
2005-06-01 Earliest Priority Date for ’145 Patent
2006-01-26 Priority Date for ’926 Patent
2006-12-21 Priority Date for ’885 Patent
2007-03-09 Earliest Priority Date for ’543 Patent
2007-04-17 Priority Date for ’628 Patent
2008-11-11 ’926 Patent Issued
2011-03-01 ’145 Patent Issued
2012-05-29 ’885 Patent Issued
2013-02-05 ’543 Patent Issued
2013-09-24 ’628 Patent Issued
2021-XX-XX Prior Litigation involving ’145 Patent filed
2025-08-05 Complaint Filing Date

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

U.S. Patent No. 7,449,926 - Circuit for Asynchronously Resetting Synchronous Circuit (Issued Nov. 11, 2008)

The Invention Explained

  • Problem Addressed: The patent describes a challenge in synchronous circuits, such as those using RAM, where an asynchronous reset during normal operation could cause data loss. However, when a circuit operates abnormally (e.g., a CPU crash), an immediate, asynchronous reset is required to initialize the entire system. (’926 Patent, col. 2:36-50).
  • The Patented Solution: The invention is a reset signal generation circuit that intelligently chooses the type of reset signal to generate. It includes an "operation detection circuit" that monitors the state of a synchronous circuit like a CPU. If the CPU is operating normally, the invention generates a synchronous reset signal, which preserves data integrity. If the CPU is operating abnormally, it generates an asynchronous reset signal to force an immediate system-wide initialization. (’926 Patent, col. 6:58-7:6).
  • Technical Importance: This adaptive reset mechanism improves the overall reliability of complex semiconductor devices by safely handling routine resets without data loss while providing a robust failure recovery method for abnormal operating conditions. (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent Claim 1. (Compl. ¶32).
  • Essential elements of Claim 1 include:
    • An operation detection circuit for detecting whether the synchronous circuit is operating normally or abnormally.
    • A signal control circuit that generates a first reset signal.
    • The signal control circuit generates a synchronous reset signal when the synchronous circuit is operating normally.
    • The signal control circuit generates an asynchronous reset signal when the synchronous circuit is operating abnormally.

U.S. Patent No. 7,889,145 - Arrangement with a Transponder and a Metal Element (Issued Mar. 1, 2011)

The Invention Explained

  • Problem Addressed: The complaint alleges that this patent addresses problems of timing delays and jitter in synchronous systems. (Compl. ¶16). The specification of the ’145 Patent itself, however, addresses a different problem: the detrimental effect that metal components have on the function of nearby RFID transponders by absorbing electromagnetic energy. (’145 Patent, col. 1:49-58).
  • The Patented Solution: The complaint describes a solution involving multiplexer circuits that reduce jitter by deactivating signals and using separate power domains. (Compl. ¶17). In contrast, the solution described in the ’145 Patent is to form an antenna for an RFID transponder by creating a recess or breakthrough directly in the proximate metal component, thereby improving communication despite the metal's presence. (’145 Patent, Abstract; col. 2:14-24).
  • Technical Importance: Integrating an antenna structure directly into a metal object allows for the effective use of RFID technology on metal products or containers, which would otherwise shield the transponder and prevent communication. (’145 Patent, col. 1:59-2:4).

Key Claims at a Glance

  • The complaint asserts at least Claim 10. (Compl. ¶42).
  • Claim 10 is dependent on Claim 1. The asserted claim tree requires:
    • An arrangement with a transponder and an allocated metal component.
    • An aerial (antenna) for the transponder formed by means of a recess in the metal component.
    • The recess in the metal component has the form of a ring segment.

Multi-Patent Capsule: U.S. Patent No. 8,190,885

  • Patent Identification: U.S. Patent No. 8,190,885, "Non-Volatile Memory Sub-System Integrated with Security for Storing Near Field Transactions", issued May 29, 2012. (Compl. ¶19).
  • Technology Synopsis: The patent is directed to a memory module that integrates non-volatile memory, a security processor, and a near field communication (NFC) component. This integration creates a secure execution environment to store and process NFC transaction data, preventing unauthorized access and ensuring data integrity. (Compl. ¶21-22; ’885 Patent, Abstract).
  • Asserted Claims: Independent claims 1 and 3 are asserted. (Compl. ¶52).
  • Accused Features: The accused features are the systems within the branded contactless consumer credit cards that are alleged to provide an integrated and secure memory environment for NFC transactions. (Compl. ¶52).

Multi-Patent Capsule: U.S. Patent No. 8,370,543

  • Patent Identification: U.S. Patent No. 8,370,543, "Busy Detection Logic for Asynchronous Communication Port", issued Feb. 5, 2013. (Compl. ¶23).
  • Technology Synopsis: The patent addresses the problem of synchronizing access to a shared resource (e.g., memory) between different parts of a circuit that operate in independent time domains. The invention provides logic for synchronizing this access information without requiring high-speed clocks or restrictive signal pulse widths, thereby improving design efficiency and reducing power consumption. (Compl. ¶25-27; ’543 Patent, col. 2:9-19).
  • Asserted Claims: The complaint asserts at least independent claim 16 (via inducement) and notes that an exhibit shows direct infringement of independent claim 1. (Compl. ¶62-63).
  • Accused Features: The accused features are the internal circuits within the contactless credit cards that allegedly manage communication and resource access between asynchronous components. (Compl. ¶62).

Multi-Patent Capsule: U.S. Patent No. 8,543,628

  • Patent Identification: U.S. Patent No. 8,543,628, "Method and System of Digital Signal Processing", issued Sep. 24, 2013. (Compl. ¶28).
  • Technology Synopsis: The patent describes a programmable and dynamically reconfigurable system for digital signal processing. Instruction sets from a microcontroller configure a controller and an address-calculation device, which in turn direct a data path device to perform digital filtering on incoming data using specified coefficients. (Compl. ¶29; ’628 Patent, Abstract).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶72).
  • Accused Features: The accused features are the digital signal processing systems within the contactless credit cards that are alleged to be dynamically reconfigurable. (Compl. ¶72).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the "Accused Instrumentalities" as "branded contactless consumer credit cards" that Defendant provides, supports, advertises, and distributes. (Compl. ¶32, ¶37, ¶42).
  • Functionality and Market Context: The complaint does not provide specific technical details on the operation of the accused cards. Based on the patents-in-suit, the infringement allegations target the underlying semiconductor chips that power the cards. The allegedly infringing functionalities include the chips’ internal circuits for reset management, signal multiplexing, secure NFC transaction handling, asynchronous communications between internal blocks, and digital signal processing. The complaint alleges these cards are marketed and used throughout the United States. (Compl. ¶34). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that detailed infringement analyses are set forth in exhibits (e.g., Exhibit A-1, B-1), which were not attached to the publicly filed complaint. The analysis below is based on the narrative infringement theories presented in the body of the complaint.

’926 Patent Infringement Allegations

The complaint alleges that Defendant induces infringement of at least Claim 1 by providing contactless credit cards to its partners, customers, and end users, whose use of the cards constitutes direct infringement. (Compl. ¶32, ¶34). The infringement theory posits that the semiconductor chips within these cards contain synchronous circuits that are reset using a mechanism that meets the limitations of Claim 1, including a circuit that detects the operational state of the system to select between a synchronous and an asynchronous reset. (Compl. ¶33, ¶10-11).

  • Identified Points of Contention:
    • Technical Question: What evidence will show that the reset circuits in the accused cards perform the specific function of detecting a CPU's operational state (normal vs. abnormal) to select a reset type, as required by the claim?
    • Scope Question: A central question for the court may be whether the accused devices, which likely employ some form of power-on-reset or external reset logic, practice the specific "operation detection" and dual-mode (synchronous/asynchronous) generation claimed in the ’926 Patent.

’145 Patent Infringement Allegations

The complaint alleges inducement of infringement of at least Claim 10 of the ’145 Patent. (Compl. ¶42). The narrative describes the patent as relating to multiplexer circuits that reduce jitter, and implies the accused cards infringe by containing such circuitry. (Compl. ¶15-17). However, the actual ’145 patent and its claims relate to forming an antenna for an RFID transponder out of a recess in a metal object. (see Section II, supra). Claim 10, the asserted dependent claim, specifically requires that this recess has "the form of a ring segment."

  • Identified Points of Contention:
    • Fundamental Discrepancy: The primary point of contention is the stark mismatch between the technology described and accused in the complaint's text (signal multiplexing circuits) and the technology actually claimed in the asserted ’145 Patent (antennas formed in metal).
    • Technical Question: A key question for the court will be how a "contactless consumer credit card" can infringe a claim requiring a "recess in [a] metal component" that forms an antenna, a structure seemingly unrelated to the alleged product. This discrepancy raises significant questions about the viability of this infringement count as pleaded.

V. Key Claim Terms for Construction

For the ’926 Patent:

  • The Term: "an operation detection circuit for detecting whether the synchronous circuit is operating normally or abnormally" (from Claim 1).
  • Context and Importance: This term is the central inventive concept of the patent. Infringement hinges on whether the accused devices perform this specific type of detection. Practitioners may focus on this term because its construction will determine whether a standard "watchdog" timer or other simple reset circuit falls within the claim scope.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification states the circuit "generates an operation detection signal OC showing the detection result," which could support a construction covering any circuit that outputs a signal indicative of CPU health. (’926 Patent, col. 4:15-17).
    • Evidence for a Narrower Interpretation: The primary embodiment describes the circuit as an up-counter periodically cleared by the CPU; failure to clear it indicates an abnormal state. (’926 Patent, col. 4:17-33). This specific implementation may be used to argue for a narrower construction limited to such a "watchdog timer" mechanism.

For the ’145 Patent:

Given the fundamental discrepancy noted in Sections II and IV, traditional claim construction analysis is secondary to resolving the mismatch. However, based on the asserted claim:

  • The Term: "recess in the metal component" (from Claim 1, on which asserted Claim 10 depends).
  • Context and Importance: This term defines the physical structure of the claimed antenna. The infringement analysis depends entirely on identifying such a structure in an accused product.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification shows the recess can be a simple "breakthrough" or slot. (’145 Patent, Fig. 3, col. 3:41-43).
    • Evidence for a Narrower Interpretation: The specification also discloses more complex arrangements, such as a recess within a lowered zone or one filled with dielectric material, which might be used to argue the term requires more than a simple hole. (’145 Patent, Fig. 5, col. 5:40-44). The asserted dependent claim 10 further narrows this to a "ring segment," severely limiting its scope.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all five patents. The factual basis asserted is Defendant's provision of the Accused Instrumentalities to third-party users (customers, partners, etc.), supported by actions such as advertising, distributing, and providing instruction materials. (Compl. ¶37, ¶47, ¶57, ¶67, ¶77).
  • Willful Infringement: Willfulness is alleged for all five patents. The complaint alleges that Defendant had knowledge of the patents and infringement "at least as early as the filing of this Complaint," and that any induced infringement occurring after this date is willful. (Compl. ¶35, ¶38, ¶45, ¶48). This pleading frames willfulness based on post-suit conduct.

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

  • A central issue for the case will be one of fundamental pleading sufficiency, particularly for the '145 patent. The court will have to address the stark contradiction between the signal multiplexing technology described in the complaint's narrative and the antenna technology actually claimed in the asserted '145 patent.
  • A key evidentiary question will be one of technical proof. As the complaint makes "information and belief" allegations about the internal architecture of semiconductor chips without providing the referenced claim charts, the case will depend on whether discovery can uncover evidence that the accused credit cards practice the specific, and often nuanced, functionalities required by the claims, such as the '926 patent's normal-versus-abnormal operational state detection.
  • Finally, the case will present a question of induced infringement. Since infringement is alleged to be committed by end-users of credit cards, the plaintiff will face the challenge of proving that the defendant, by merely providing the cards, possessed the specific intent required by 35 U.S.C. § 271(b) to cause those users to operate the cards' internal, invisible circuitry in a manner that infringes the asserted patents.