DCT
2:25-cv-00778
Induction Devices LLC v. Williams Sonoma Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Induction Devices LLC (Texas)
- Defendant: Williams-Sonoma, Inc. (Delaware)
- Plaintiff’s Counsel: SHEA | BEATY PLLC
- Case Identification: 2:25-cv-00778, E.D. Tex., 08/08/2025
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Williams-Sonoma maintains regular and established places of business (retail stores) within the district.
- Core Dispute: Plaintiff alleges that Defendant’s provision and support of branded contactless consumer credit cards induces infringement of five patents related to fundamental semiconductor circuit design and secure transaction technologies.
- Technical Context: The patents-in-suit cover a range of semiconductor technologies, including system reset circuits, low-jitter signal multiplexing, secure memory for near-field communication (NFC), and reconfigurable digital signal processors, which are foundational to modern integrated circuits used in devices like contactless payment cards.
- Key Procedural History: The complaint notes that U.S. Patent No. 7,899,145 was previously litigated in the Western District of Texas, but those cases were resolved before any substantive matters were addressed.
Case Timeline
| Date | Event |
|---|---|
| 2006-01-26 | Priority Date for U.S. Patent No. 7,449,926 |
| 2006-12-21 | Priority Date for U.S. Patent No. 8,190,885 |
| 2007-03-09 | Priority Date for U.S. Patent No. 8,370,543 |
| 2007-04-17 | Priority Date for U.S. Patent No. 8,543,628 |
| 2008-11-11 | U.S. Patent No. 7,449,926 Issued |
| 2011-03-01 | U.S. Patent No. 7,899,145 Issued |
| 2012-05-29 | U.S. Patent No. 8,190,885 Issued |
| 2013-02-05 | U.S. Patent No. 8,370,543 Issued |
| 2013-09-24 | U.S. Patent No. 8,543,628 Issued |
| 2021-01-01 | Prior Litigations involving the '145 Patent mentioned (approx. year) |
| 2025-08-08 | 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 November 11, 2008
The Invention Explained
- Problem Addressed: The patent’s background section describes the challenge of resetting synchronous circuits, such as a RAM, within a larger system like a semiconductor device. An asynchronous reset during normal operation can lead to the loss of stored data, while a synchronous reset may not be sufficient to recover the system from an abnormal state, such as an erroneous CPU operation (’926 Patent, col. 1:37-46).
- The Patented Solution: The invention is a reset signal generation circuit that intelligently selects the type of reset to perform. It generates a data-preserving synchronous reset when the system CPU is operating normally, but triggers an immediate, system-wide asynchronous reset when the CPU is operating abnormally, ensuring a full initialization to recover from a fault condition (Compl. ¶11; ’926 Patent, col. 6:58-7:6).
- Technical Importance: This selective reset capability enhances the reliability of a semiconductor device by enabling it to handle different operational states appropriately—preserving data when possible while ensuring a robust recovery from critical failures (Compl. ¶11).
Key Claims at a Glance
- The complaint asserts independent claim 1 (Compl. ¶32).
- The essential elements of claim 1 are:
- An operation detection circuit for detecting whether the synchronous circuit is operating normally or abnormally and generating a corresponding detection signal.
- A signal control circuit that receives the detection signal and a system reset signal.
- The signal control circuit generates a synchronous reset signal when the detection signal indicates normal operation.
- The signal control circuit generates an asynchronous reset signal when the detection signal indicates abnormal operation.
- Plaintiff reserves the right to assert additional claims (Compl. ¶33).
U.S. Patent No. 7,899,145 - Circuit, System, and Method for Multiplexing Signals with Reduced Jitter
Issued March 1, 2011
The Invention Explained
- Problem Addressed: The complaint explains that prior art multiplexers, used to select between different clock signals (e.g., from PLL/DLLs) in synchronous systems, introduced undesirable crosstalk and power supply noise, which degraded system performance and reliability (Compl. ¶16).
- The Patented Solution: The invention, as described in the complaint, is an improved multiplexer circuit that uses a logic block to ensure only one signal is active at any given time, thereby eliminating crosstalk. The patent also teaches arranging the logic gates in separate power domains to further isolate the inputs from noise (Compl. ¶17).
- Technical Importance: This design reduces jitter and noise in critical clocking paths, enhancing the performance and reliability of high-speed synchronous systems (Compl. ¶16).
Key Claims at a Glance
- The complaint asserts at least independent claim 10 (Compl. ¶42).
- The complaint does not provide the text of asserted independent claim 10, precluding a detailed breakdown of its elements. The infringement allegations are detailed in Exhibit B-1, which was not provided with the complaint (Compl. ¶43).
U.S. Patent No. 8,190,885 - Non-Volatile Memory Sub-System Integrated with Security for Storing Near Field Transactions
Issued May 29, 2012
- Technology Synopsis: The patent describes a memory module that tightly integrates a security processor, non-volatile memory, and a near-field communication (NFC) component. This architecture creates a secure execution environment for NFC transactions, enables the creation of memory partitions with individualized access rights, and allows for the secure logging of transaction data (Compl. ¶¶21-22).
- Asserted Claims: At least independent claims 1 and 3 are asserted (Compl. ¶52).
- Accused Features: The complaint alleges that the provision and support of branded contactless consumer credit cards, which contain integrated circuits for secure NFC transactions, induces infringement of this patent (Compl. ¶52).
U.S. Patent No. 8,370,543 - Busy Detection Logic for Asynchronous Communication Port
Issued February 5, 2013
- Technology Synopsis: The patent discloses a system for synchronizing information between two independent time domains (e.g., a fast processor and a slow memory device) without the limitations of prior art designs, such as requiring high-speed clocks or minimum pulse widths for control signals. This invention allows for improved performance and less complex designs for systems with asynchronous components (’543 Patent, Abstract; Compl. ¶¶25-27).
- Asserted Claims: At least independent claim 16 is asserted (Compl. ¶62).
- Accused Features: The accused features are the branded contactless consumer credit cards, which allegedly contain chips that must manage communication between internal components operating in different clock domains (Compl. ¶62).
U.S. Patent No. 8,543,628 - Method and System of Digital Signal Processing
Issued September 24, 2013
- Technology Synopsis: The patent is directed to a dynamically reconfigurable digital signal processing (DSP) system on a chip. In this system, a microcontroller can load instruction sets that configure a controller and an address-calculation device; these components then direct a data path device to perform specific DSP operations (e.g., digital filtering) on incoming data. This architecture enables resource efficiency, scalability, and dynamic reconfiguration (Compl. ¶¶29-30).
- Asserted Claims: At least independent claim 1 is asserted (Compl. ¶72).
- Accused Features: The accused features are the branded contactless consumer credit cards, which allegedly incorporate reconfigurable DSPs to process signals for communication and transactions (Compl. ¶72).
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities are "branded contactless consumer credit cards" that Defendant Williams-Sonoma provides and supports for use by its partners, customers, and end users (Compl. ¶32).
Functionality and Market Context
- The complaint does not describe the specific technical operation of the accused cards. Instead, it alleges that the integrated circuits (chips) within these cards contain the circuitry and systems covered by the patents-in-suit. The core of the infringement allegation is that the use of these cards by consumers for contactless transactions constitutes direct infringement, which is induced by the Defendant's marketing and provision of the cards (Compl. ¶¶32, 34, 37). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references preliminary infringement claim charts as exhibits for each asserted patent but does not include them with the public filing. The analysis below is based on the claim language and the narrative allegations.
'926 Patent Infringement Allegations
The complaint alleges that the use of the Accused Instrumentalities directly infringes claim 1, with a detailed analysis provided in the unattached Exhibit A-1 (Compl. ¶33). The theory is that the chips within the cards contain circuits performing the claimed selective reset functions.
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an operation detection circuit for detecting whether the synchronous circuit is operating normally or abnormally... | The complaint alleges the accused cards' chips contain an operation detection circuit that monitors the processor state. | ¶33 | col. 2:2-4 |
| a signal control circuit... for generating the first reset signal based on a system reset signal, the clock signal, and the operation detection signal | The complaint alleges the accused cards' chips contain a signal control circuit to generate a reset signal. | ¶33 | col. 2:4-7 |
| wherein the signal control circuit generates the first reset signal that is synchronous... when the synchronous circuit is operating normally... | The complaint's theory requires that the accused chips generate a synchronous reset during normal operations (e.g., a standard transaction). | ¶33 | col. 6:58-7:1 |
| wherein the signal control circuit generates the first reset signal that is asynchronous... when the synchronous circuit is operating abnormally. | The complaint's theory requires that the accused chips generate an asynchronous reset during abnormal operations (e.g., a transaction failure or fault). | ¶33 | col. 7:1-6 |
'145 Patent Infringement Allegations
The complaint asserts claim 10 but provides neither the claim text nor the referenced claim chart exhibit (Exhibit B-1) (Compl. ¶¶42-43). The infringement theory, based on the complaint's narrative, is that multiplexer circuits within the accused cards' chips employ the patented techniques to reduce jitter and signal noise by ensuring only one signal path is active at a time and by arranging logic gates in separate power domains (Compl. ¶¶16-17).
- Identified Points of Contention:
- Technical Matching: A primary question for the '926 patent is whether the error-handling or power-cycling modes in a standard payment card chip constitute the specific "normal" versus "abnormal" operation states that trigger distinct synchronous and asynchronous resets as claimed. The patent describes "abnormal" operation in the context of initializing "all the synchronous circuits including the CPU" ('926 Patent, col. 7:4-6), which may present a scope question relative to the functionality of a payment chip.
- Evidentiary Basis: For all asserted patents, the infringement case hinges on the specific, internal design of the semiconductor chips used in the accused credit cards. The complaint's allegations are made "on information and belief," and a central point of contention will be whether discovery reveals that these chips, which may be commodity parts, actually practice the specific and nuanced inventions claimed.
V. Key Claim Terms for Construction
For the '926 Patent
- The Term: "operating abnormally"
- Context and Importance: This term is dispositive for the second half of the infringement allegation for claim 1. Whether the accused device infringes depends on whether it generates an asynchronous reset in response to a condition that falls within the scope of "operating abnormally." Practitioners may focus on this term because its definition will determine whether routine error states in a payment chip can be equated to the more severe fault conditions potentially envisioned by the patent.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent does not provide an explicit definition of the term, which may leave room for a broader construction that encompasses a range of non-standard operational states.
- Evidence for a Narrower Interpretation: The specification provides a specific example of the consequence of abnormal operation: "all the synchronous circuits including the CPU 11 are immediately initialized" ('926 Patent, col. 7:4-6). This language, suggesting a complete and immediate system-wide reset, could support a narrower construction limited to catastrophic failures rather than routine transaction errors.
For the '145 Patent
The complaint does not provide the text of asserted independent claim 10, precluding an analysis of key terms for construction.
VI. Other Allegations
- Indirect Infringement: The complaint's sole cause of action is for induced infringement under 35 U.S.C. § 271(b) for all five patents. Plaintiff alleges that Defendant, by "advertising and distributing the Accused Instrumentalities and providing instruction materials, training, and services," knowingly and intentionally encourages direct infringement by its customers and partners who use the contactless cards (Compl. ¶¶32, 36-37).
- Willful Infringement: Willfulness is alleged for all asserted patents. The claim is based on alleged knowledge of the patents and the infringing nature of the accused activities "at least as early as the filing of this Complaint" (Compl. ¶35). The allegations assert that any continued inducement after receiving notice via the complaint is willful (Compl. ¶¶36, 38).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of inducement and intent: can Plaintiff demonstrate that Williams-Sonoma, a retailer, possessed the requisite specific intent to encourage infringement of these specific semiconductor circuit patents merely by providing co-branded contactless credit cards to its customers, particularly when it is not the manufacturer of the cards or the chips within them?
- A key evidentiary question will be one of technical implementation: will discovery of the designs of the semiconductor chips inside the "branded contactless consumer credit cards" reveal the specific, and in some cases unconventional, circuit architectures required by the patent claims, or will they show more common, non-infringing designs?
- A critical legal question for the '926 patent will be one of definitional scope: can the claim term "operating abnormally," which the patent links to an immediate, full-system initialization, be construed broadly enough to read on the routine error handling modes or transaction failures that occur in a standard contactless payment chip?