DCT

2:25-cv-00787

Induction Devices LLC v. Brand House Collective Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00787, E.D. Tex., 08/13/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant, a Tennessee corporation, maintains a place of business in Frisco, Texas, and regularly conducts business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s branded contactless consumer credit cards infringe five U.S. patents related to various semiconductor circuit technologies, including circuit reset logic, signal multiplexing, secure memory subsystems, asynchronous communication, and digital signal processing.
  • Technical Context: The patents-in-suit relate to foundational circuit design and system-on-a-chip architecture, technologies that are fundamental to the operation of complex integrated circuits used in modern electronics such as secure 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
2005-06-01 ’145 Patent Priority Date
2006-01-26 ’926 Patent Priority Date
2006-12-21 ’885 Patent Priority Date
2007-03-09 ’543 Patent Priority Date
2007-04-17 ’628 Patent Priority Date
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
2025-08-13 Complaint Filed

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 dilemma in semiconductor design: resetting a synchronous circuit (like RAM) with a signal that is asynchronous to the system clock can cause data loss, but in the event of a critical failure (e.g., a CPU malfunction), an immediate asynchronous reset is necessary to re-initialize the entire system and prevent further error. (’926 Patent, col. 1:37-60).
  • 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 a synchronous circuit, such as a CPU, to determine if it is "operating normally or abnormally." (’926 Patent, Abstract; col. 1:61-2:6). If the CPU is operating normally, the invention generates a reset signal that is synchronous with the system clock, preserving data. If abnormal operation is detected (e.g., the CPU fails to send a periodic "clear signal"), it generates an asynchronous reset signal to immediately initialize all circuits. (’926 Patent, col. 4:34-45, 6:58-7:6).
  • Technical Importance: This selective reset capability enhances overall circuit reliability by allowing for safe, data-preserving resets during normal operation while enabling a robust, fail-safe recovery mechanism for abnormal conditions. (Compl. ¶11).

Key Claims at a Glance

  • The complaint asserts independent claim 1. (Compl. ¶32).
  • Claim 1 requires:
    • A reset signal generation circuit for a synchronous circuit.
    • An operation detection circuit for detecting whether the synchronous circuit is operating normally or abnormally and for generating an operation detection signal.
    • A signal control circuit for generating a first reset signal based on a system reset signal, the clock signal, and the operation detection signal.
    • The signal control circuit generates a first reset signal that is synchronous to the clock signal when the synchronous circuit is operating normally.
    • The signal control circuit generates the first reset signal that is asynchronous to the clock signal when the synchronous circuit is operating abnormally.
  • 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 Mar. 1, 2011)

The Invention Explained

  • Problem Addressed: According to the complaint, prior art methods for minimizing timing delays and jitter in high-speed synchronous systems often involved using multiplexers to select between multiple clock signals (e.g., from different phase-locked loops). However, these multiplexer designs themselves could introduce undesirable "crosstalk and power supply noise," degrading clock signal integrity. (Compl. ¶16).
  • The Patented Solution: The complaint alleges the patent teaches an improved multiplexer circuit architecture. This solution involves distributing logic gates across separate power domains and using a logic block to supply a static control signal, ensuring only one signal path is active at any given time. This design allegedly eliminates crosstalk and power supply noise at the logic gate inputs. (Compl. ¶15, ¶17).
  • Technical Importance: This approach is alleged to overcome disadvantages of prior designs, improving the overall performance and reliability of clock networks in synchronous systems. (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts independent claim 10. (Compl. ¶42).
  • Claim 10 of the patent depends on claim 1 and recites:
    • An arrangement with a transponder and a metal component, where an aerial for the transponder is formed by a recess in the metal component, with a cover and a cavity at least partially filled with a dielectric material. (’145 Patent, cl. 1).
    • The recess in the metal component has the form of a ring segment. (’145 Patent, cl. 10).
  • Plaintiff reserves the right to assert additional claims. (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 is directed to a memory module that integrates a security processor, non-volatile memory, and a near-field communication (NFC) component onto a single subsystem. This tight integration is intended to create a secure execution environment for storing and processing NFC transaction data, with the security processor enforcing access rights to different memory partitions to ensure data integrity. (Compl. ¶21-22).
  • Asserted Claims: Independent claims 1 and 3 are asserted. (Compl. ¶52).
  • Accused Features: The "branded contactless consumer credit cards" are accused of containing the claimed memory module. (Compl. ¶52).

U.S. Patent No. 8,370,543 - "Busy Detection Logic for Asynchronous Communication Port" (Issued Feb. 5, 2013)

  • Technology Synopsis: The patent addresses the challenge of synchronizing communication between components operating in independent clock domains (e.g., a fast processor and a slower memory device). The invention provides systems and methods to manage device resource access information across these domains without requiring high-speed clocks or imposing minimum pulse-width requirements on control signals, thereby reducing complexity and power consumption. (Compl. ¶25-27).
  • Asserted Claims: Independent claim 16 is asserted. (Compl. ¶62).
  • Accused Features: The "branded contactless consumer credit cards" are accused of using the claimed busy detection logic. (Compl. ¶62).

U.S. Patent No. 8,543,628 - "Method and System of Digital Signal Processing" (Issued Sep. 24, 2013)

  • Technology Synopsis: The patent describes a programmable and dynamically reconfigurable system-on-a-chip for digital signal processing. In the system, instruction sets from a microcontroller configure a controller and an address-calculation device, which in turn select filter-coefficients that a data path device uses to perform digital filtering on incoming data. This architecture is designed to improve resource efficiency and scalability. (Compl. ¶29-30).
  • Asserted Claims: Independent claim 1 is asserted. (Compl. ¶72).
  • Accused Features: The "branded contactless consumer credit cards" are accused of containing the claimed programmable system. (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

The Accused Instrumentalities are "branded contactless consumer credit cards" that Defendant provides, supports, and distributes. (Compl. ¶32, ¶42, ¶52, ¶62, ¶72).

Functionality and Market Context

The complaint alleges that these contactless credit cards are used by Defendant's partners, clients, and end users throughout the United States. (Compl. ¶34). The core of the infringement allegations is that the integrated circuits within these cards contain the technologies recited in the patents-in-suit, and that use of the cards constitutes direct infringement, which Defendant induces. (Compl. ¶32, ¶34). The complaint does not provide further technical details about the specific operation or components of the accused cards. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not publicly filed with the pleading; therefore, the infringement allegations are summarized below in prose based on the complaint's narrative.

  • ’926 Patent Infringement Allegations: Plaintiff alleges that the accused credit cards contain circuitry that performs the functions of claim 1. The narrative theory is that these cards include a reset generation circuit that monitors the operational status of an onboard synchronous circuit (e.g., a processor) and, based on whether the operation is normal or abnormal, selectively generates either a synchronous or an asynchronous reset signal to enhance reliability. (Compl. ¶10-12, ¶33).
  • ’145 Patent Infringement Allegations: Plaintiff alleges that the accused credit cards infringe claim 10 by incorporating an improved multiplexer circuit. The complaint's theory is that these cards use multiplexers with features such as distributed power domains and single-path activation to reduce signal jitter, consistent with the technology described by Plaintiff. (Compl. ¶15-17, ¶43).
  • Identified Points of Contention:
    • Technical Questions (’926 Patent): A central question will be what evidence Plaintiff can adduce to show that the accused credit cards contain a circuit that performs the specific two-mode (synchronous/asynchronous) reset function triggered by a detected "abnormal" operation, as required by claim 1. The complaint does not specify how the accused products allegedly perform this function.
    • Fundamental Mismatch (’145 Patent): A threshold issue for the ’145 patent is a significant apparent mismatch between the technology described in the complaint and the language of the asserted claim. The complaint's infringement theory is based on a multiplexer circuit that reduces jitter (Compl. ¶15-17), but asserted claim 10 recites a physical antenna structure comprising a "recess in the metal component" that "has the form of a ring segment." (’145 Patent, cl. 10). This raises the question of whether the complaint's allegations related to signal multiplexing can plausibly map onto the structural limitations of the asserted antenna claim.
    • Scope Questions (All Patents): For all asserted patents, a recurring question may be whether the systems described in the patent specifications (e.g., general system LSI, digital signal processors) can be read to cover the specific, application-focused integrated circuits found in contactless credit cards.

V. Key Claim Terms for Construction

  • For the ’926 Patent:
    • The Term: "operating... abnormally"
    • Context and Importance: This term is the trigger that dictates whether the claimed circuit generates a synchronous or an asynchronous reset signal. Its construction is therefore critical to determining infringement, as it defines the condition under which a key function of the claim must be performed.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The background section uses general language, stating the CPU may "operate erroneously." (’926 Patent, col. 1:32). This could support a construction covering a wide range of fault states.
      • Evidence for a Narrower Interpretation: A specific embodiment describes abnormal operation as the failure of a CPU to provide a "clear signal" to a detection circuit at an "appropriate interval." (’926 Patent, col. 4:39-42). This may be used to argue for a narrower definition tied to this disclosed example.
  • For the ’145 Patent:
    • The Term: "recess in the metal component... in the form of a ring segment"
    • Context and Importance: Practitioners may focus on this term because, despite the complaint's narrative about multiplexer circuits, this structural limitation is what is actually claimed in asserted claim 10. The infringement analysis for this claim will depend entirely on whether the accused cards contain this physical structure.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent figures depict various arc-like and U-shaped recesses, not just complete rings. (e.g., ’145 Patent, Fig. 4). This could support an argument that any curved or annular slot or indentation in a metal layer qualifies.
      • Evidence for a Narrower Interpretation: The term "ring segment" itself suggests a piece of a ring. A party could argue the term requires a specific geometry and function as an antenna, and that incidental manufacturing features do not meet this limitation. The patent also describes the recess as forming an "aerial." (’145 Patent, col. 2:17-20).

VI. Other Allegations

  • Indirect Infringement: Plaintiff alleges induced infringement for all five patents. The basis for inducement is Defendant’s alleged "advertising and distributing the Accused Instrumentalities and providing instruction materials, training, and services" to its partners, customers, and end users, who are the alleged direct infringers. (Compl. ¶37, ¶47, ¶57, ¶67, ¶77).
  • Willful Infringement: Willfulness is alleged based on Defendant’s continued inducement of infringement after receiving notice of the patents and its alleged infringement via the filing and service of the complaint. (Compl. ¶35, ¶38, ¶45, ¶48).

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

  1. A threshold issue will be one of pleading coherence for the ’145 patent: can the complaint's infringement allegations, which are based entirely on a signal multiplexing technology, state a plausible claim for infringement of a patent claim directed to the physical structure of an antenna?
  2. A primary evidentiary question for all asserted patents will be one of technical specificity: what discovery evidence will Plaintiff present to demonstrate that the internal, proprietary circuitry of mass-produced contactless credit cards practices the specific and distinct functions recited in each of the five asserted patents, from selective reset logic to reconfigurable digital signal processing?
  3. Should the case proceed, a key legal battle will be over claim construction. For the ’926 patent, the dispute may center on the definition of "operating abnormally." For the ’145 patent, the focus will be on the physical meaning of a "recess... in the form of a ring segment." For the remaining patents, the scope of terms like "security processor" (’885 patent) and "reconfigurable" controller (’628 patent) will likely be central to the infringement and validity analyses.