Induction Devices LLC v. Lowe's Companies Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Induction Devices LLC (Texas)
  • Defendant: Lowe's Companies, Inc. (North Carolina)
  • Plaintiff’s Counsel: SHEA | BEATY PLLC
• Case Identification: 2:25-cv-00788, E.D. Tex., 08/13/2025
• Venue Allegations: Venue is based on Defendant having a place of business in the district and regularly conducting business in Texas.
• Core Dispute: Plaintiff alleges that Defendant’s provision and support of branded contactless consumer credit cards induces infringement of five patents related to various semiconductor circuit technologies.
• Technical Context: The patents-in-suit cover diverse and fundamental aspects of semiconductor design, including circuit reset logic, signal multiplexing, secure memory integration with NFC, asynchronous communication, and digital signal processing.
• 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	’926 Patent Priority Date
2006-06-01	’145 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 Issue Date
2011-03-01	’145 Patent Issue Date
2012-05-29	’885 Patent Issue Date
2013-02-05	’543 Patent Issue Date
2013-09-24	’628 Patent Issue Date
2021-01-01	Prior litigation of ’145 patent initiated (approx. date)
2025-08-13	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 describes the challenge of resetting synchronous circuits (e.g., a CPU or RAM). An asynchronous reset is necessary to initialize a circuit immediately if it operates abnormally, but this can cause data loss in memory. A synchronous reset, timed with the system clock, is preferred for normal operations to preserve data, but it is not suitable for immediate correction of fault states (Compl. ¶10; ’926 Patent, col. 1:36-44).
• The Patented Solution: The invention is a reset signal generation circuit that can selectively produce either a synchronous or an asynchronous reset signal. This selection is based on an "operation detection signal" that determines if a CPU is functioning normally or abnormally, thereby applying the correct type of reset for the situation (Compl. ¶11; ’926 Patent, col. 6:58-7:6).
• Technical Importance: This selective reset capability enhances the reliability of semiconductor devices by using a data-preserving reset during normal procedures and an immediate, stabilizing reset during fault 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 a synchronous circuit is operating normally or abnormally and generating a corresponding signal.
  • A "signal control circuit" that receives the operation detection signal, a system reset signal, and a clock signal.
  • The signal control circuit generates a synchronous reset when the synchronous circuit operates normally.
  • The signal control circuit generates an asynchronous reset when the synchronous circuit operates abnormally.
• The complaint reserves the right to assert other 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 patent identifies that prior art techniques for multiplexing (selecting between multiple signals) in high-speed clock networks introduced undesirable timing delays, jitter, crosstalk, and power supply noise, which degraded system performance and reliability (Compl. ¶16; '145 Patent, col. 1:49-52, 2:60-63).
• The Patented Solution: The patent teaches an arrangement where an antenna for a transponder is formed by a "recess" in a metal component. The arrangement includes a cover over the recess, creating a cavity that is at least partially filled with a dielectric material, which can improve communication between the transponder and an external apparatus (Compl. ¶¶15, 17; ’145 Patent, col. 2:14-24).
• Technical Importance: This approach provides a method for integrating a transponder antenna directly into a metal object, mitigating the negative effects the metal would otherwise have on radio frequency communication (Compl. ¶17).

Key Claims at a Glance

• The complaint asserts dependent Claim 10, which relies on independent Claim 8 (Compl. ¶42).
• Essential elements of independent Claim 8 include:
  • An arrangement with a transponder and a metal component.
  • An aerial for the transponder is formed by means of a "recess" in the metal component.
  • The arrangement includes a "cover" allocated to the recess.
  • The cover and metal component enclose a "cavity."
  • The cavity is at least partially filled with a "dielectric material."
• The complaint reserves the right to assert other 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 non-volatile memory, a security processor, and a Near Field Communication (NFC) component. This integration creates a secure environment for processing and logging NFC transactions, preventing unauthorized access and allowing for the creation of memory partitions with individualized access rights (Compl. ¶¶21-22).
• Asserted Claims: Claims 1 and 3 (Compl. ¶52).
• Accused Features: The integrated secure memory and NFC functionality within branded contactless consumer credit cards are alleged to infringe (Compl. ¶52).

U.S. Patent No. 8,370,543 - "Busy Detection Logic for Asynchronous Communication Port," issued February 5, 2013

• Technology Synopsis: The patent describes systems for synchronizing resource access between devices operating in different time domains (e.g., a fast processor and a slower memory). The invention purports to achieve this without requiring high-speed clocks or imposing minimum pulse width requirements on control signals, which reduces circuit complexity and power consumption (Compl. ¶¶25-27).
• Asserted Claims: Claims 1 and 16 (Compl. ¶¶62, 63).
• Accused Features: The internal communication architecture of contactless credit cards, which must manage components operating at different clock speeds, is alleged to infringe (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 system-on-a-chip for digital signal processing. A microcontroller uses instruction sets to configure a controller and an address-calculation device, which in turn select filter-coefficients for a data path device to perform filtering on incoming digital data (Compl. ¶¶29-30).
• Asserted Claims: Claim 1 (Compl. ¶72).
• Accused Features: The digital signal processing functionalities present in the integrated circuits of contactless credit cards are alleged to infringe (Compl. ¶72).

III. The Accused Instrumentality

Product Identification

• The "Accused Instrumentalities" are identified as "branded contactless consumer credit cards" that Defendant provides, supports, advertises, and distributes (Compl. ¶¶32, 37).

Functionality and Market Context

• The complaint does not describe the specific technical operation of the accused cards. Instead, it alleges that their use by third parties, such as customers and partners, constitutes direct infringement of the asserted patents (Compl. ¶32). The infringement theory implies that these cards contain the semiconductor technologies claimed in the patents-in-suit, including advanced reset circuits, signal multiplexers, secure NFC memory modules, asynchronous communication logic, and digital signal processors (Compl. ¶¶10, 15, 21, 25, 29). The complaint alleges these cards are marketed across the country, suggesting wide commercial distribution (Compl. ¶34).

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement chart exhibits for each asserted patent (Exhibits A-1, B-1, C-1, D-1, E-1) but does not attach them (Compl. ¶¶33, 43, 53, 63, 73). The infringement allegations are therefore summarized below in prose based on the complaint's narrative. No probative visual evidence provided in complaint.

’926 Patent Infringement Allegations

The complaint alleges that Defendant induces infringement of at least Claim 1 by providing contactless credit cards to end users (Compl. ¶32). The implicit theory is that the integrated circuits within these cards contain synchronous components (e.g., a CPU) that must be reset. It is alleged that these circuits necessarily practice the claimed invention by employing an "operation detection circuit" and a "signal control circuit" to selectively generate either a synchronous or an asynchronous reset signal depending on whether the circuit is operating normally or abnormally (Compl. ¶¶11, 33).

’145 Patent Infringement Allegations

The complaint alleges inducement of infringement of at least Claim 10 by providing the accused credit cards (Compl. ¶42). The infringement theory, based on Claim 8, is structural. It alleges that the cards contain a transponder and a "metal component," and that an antenna for the transponder is formed by a "recess" within that metal component. The theory further posits that this structure includes a "cover" creating a "cavity" that is filled with a "dielectric material," thereby mapping to the elements of the asserted claim (Compl. ¶¶43; '145 Patent, cl. 8).

Identified Points of Contention

• Scope Questions: For the '926 patent, a central question may be whether the term "operation detection circuit" requires active monitoring of a CPU's execution state, as shown in the patent's preferred embodiment, or if it can be read more broadly to cover simpler voltage-level detection circuits common in electronic devices. For the '145 patent, a key question will be whether the physical construction of a standard credit card's chip and antenna assembly meets the specific structural definitions of "recess," "cover," and "cavity" as used in the claims.
• Technical Questions: What evidence does the complaint provide that the accused cards' reset function distinguishes between "normal" and "abnormal" operation, as required by Claim 1 of the ’926 patent, rather than just performing a standard power-on reset? For the '145 patent, does the accused card's antenna function by means of the alleged "recess," or is the antenna a conventional design where any such physical feature is incidental and not functional in the claimed manner?

V. Key Claim Terms for Construction

Term 1 (’926 Patent): "operation detection circuit"

• Context and Importance: This term is the central feature distinguishing the invention from conventional reset circuits. Its construction will determine whether infringement requires a sophisticated circuit that monitors CPU behavior or if a simpler, more common voltage-monitoring circuit falls within the claim's scope. Practitioners may focus on this term because the infringement analysis for the '926 patent depends heavily on whether the accused cards contain more than a generic power-on reset mechanism.
• Intrinsic Evidence for a Broader Interpretation: The specification states the circuit’s function is "for detecting an operation state of the synchronous circuit" ('926 Patent, col. 2:2-4). This could support a reading that encompasses any means of determining if the circuit is operating correctly.
• Intrinsic Evidence for a Narrower Interpretation: A described embodiment details an up-counter that is periodically cleared by the CPU during normal operation; failure to clear the counter indicates an abnormal state ('926 Patent, col. 4:17-46). This specific example may support a narrower construction requiring a mechanism that actively monitors CPU execution rather than merely power levels.

Term 2 (’145 Patent): "recess"

• Context and Importance: The claims of the '145 patent are entirely structural, making the definition of "recess" critical. The infringement case rests on whether the physical layout of the accused card's chip and antenna can be mapped to this term.
• Intrinsic Evidence for a Broader Interpretation: The term is not explicitly defined, and a party may argue for its plain and ordinary meaning, which could include any slot, groove, or breakthrough in a metal component ('145 Patent, Fig. 3).
• Intrinsic Evidence for a Narrower Interpretation: The specification describes the aerial formed by the recess as a "negative image of a dipole aerial," suggesting the "recess" is not an arbitrary opening but a feature engineered with specific dimensions and electromagnetic properties ('145 Patent, col. 4:45-48).

VI. Other Allegations

Indirect Infringement

• The complaint exclusively asserts induced infringement under 35 U.S.C. § 271(b) for all five patents. The alleged inducing acts include Defendant's "provision and support of branded contactless consumer credit cards" and providing "instruction materials, training, and services regarding the Accused Instrumentalities" (Compl. ¶¶32, 37, 42, 52, 62, 72). Knowledge and intent are alleged to arise "at least as early as the filing of this Complaint" (Compl. ¶35).

Willful Infringement

• Willfulness is alleged for all asserted patents. The allegation is based on post-suit conduct, stating that "Since the filing of this Complaint, Defendant's induced infringement has been willful" (Compl. ¶¶38, 48, 58, 68, 78).

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

• A primary issue will be one of evidentiary sufficiency. The complaint asserts five distinct and complex semiconductor patents against "branded contactless consumer credit cards" generally. A key question will be what specific technical evidence Plaintiff can produce to show that the particular, unidentified integrated circuits in cards associated with Defendant practice the specific limitations of each asserted patent.
• A second core issue will be one of specific intent for inducement. As the case rests entirely on induced infringement against a retailer that does not manufacture the accused cards' internal components, the case may turn on whether Plaintiff can prove that Defendant acted with the specific intent to encourage its customers and partners to infringe the patents, rather than merely providing a standard payment tool.
• A third question will be one of claim scope versus commodity technology. Across all five patents, which cover fundamental circuit functions, a central dispute will likely be whether the claims, when properly construed, are limited to the specific novel embodiments described in the specifications or are broad enough to read on the conventional, off-the-shelf components ubiquitously used in modern electronics.