DCT

2:25-cv-00790

Induction Devices LLC v. Recreational Equipment Inc

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Key Events
Amended Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00790, E.D. Tex., 01/14/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant maintains a place of business in Plano, Texas, and conducts business 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 various semiconductor circuit designs and functionalities.
  • Technical Context: The patents-in-suit address fundamental aspects of modern electronics, including circuit reliability, signal integrity, secure memory systems for near-field communication, and efficient digital signal processing.
  • Key Procedural History: The complaint notes that U.S. Patent No. 7,889,145 was the subject of prior litigation in the Western District of Texas, which was 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 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
2026-01-14 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 addresses the risk that a synchronous circuit, such as a CPU or RAM, may not initialize correctly if it is operating abnormally, as a standard synchronous reset signal may fail. (Compl. ¶10; ’926 Patent, col. 2:50-64). A purely asynchronous reset, however, could cause data loss in a memory that is otherwise functioning properly. (Compl. ¶11; ’926 Patent, col. 2:32-38).
  • 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 determines if a synchronous circuit (like a CPU) is operating normally or abnormally. Based on this determination, a "signal control circuit" generates either a data-preserving synchronous reset signal (if normal) or an immediate, asynchronous reset signal (if abnormal), enhancing overall system reliability. (Compl. ¶10-11; ’926 Patent, Abstract; col. 6:58-7:6).
  • Technical Importance: This selective reset capability improves circuit reliability by ensuring a proper reset occurs under various operating conditions, including system faults or unstable power supply voltages. (Compl. ¶11-12).

Key Claims at a Glance

  • The complaint asserts at least independent claim 1. (Compl. ¶33).
  • Essential elements of claim 1 include:
    • 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, connected to the operation detection circuit, for generating the first reset signal based on a system reset signal, the clock signal, and the operation detection signal;
    • wherein the signal control circuit generates the first reset signal that is synchronous to the clock signal in response to the system reset signal when the synchronous circuit is operating normally; and
    • wherein the signal control circuit generates the first reset signal that is asynchronous to the clock signal in response to the system reset signal when the synchronous circuit is operating abnormally. (’926 Patent, col. 13:4-24).

U.S. Patent No. 7,889,145 - *"Circuit, System, and Method for Multiplexing Signals with Reduced Jitter,"* issued March 1, 2011

The Invention Explained

  • Problem Addressed: The patent describes how prior art techniques for multiplexing signals in clock networks, such as those using phase-locked loops (PLLs), introduced undesirable timing delays, crosstalk, and power supply noise, which degraded the performance and reliability of synchronous systems. (Compl. ¶16; ’145 Patent, col. 1:49-52, 2:60-63).
  • The Patented Solution: The invention provides an improved multiplexer circuit that reduces jitter and noise. It achieves this by using a logic block to ensure only one signal path is active at a time and by arranging logic gates within separate power domains to isolate them from noise, thereby minimizing crosstalk and improving signal integrity. (Compl. ¶15, ¶17; ’145 Patent, col. 3:13-28).
  • Technical Importance: This approach enhances the reliability and performance of high-speed electronic systems by providing cleaner, more stable clock signals, which are critical for proper synchronous operation. (Compl. ¶16).

Key Claims at a Glance

  • The complaint asserts at least independent claim 10. (Compl. ¶43). The complaint does not provide the language of claim 10.

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 integrates non-volatile memory, a security processor, and a Near Field Communication (NFC) component. This creates a secure execution environment for storing and processing NFC transaction data, preventing unauthorized access and ensuring data integrity through features like memory partitioning with individualized access rights. (Compl. ¶19, ¶21-22).
  • Asserted Claims: At least claims 1 and 3 are asserted. (Compl. ¶53).
  • Accused Features: The complaint accuses "branded contactless consumer credit cards" of infringement. (Compl. ¶53).

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

  • Technology Synopsis: The patent is directed to systems and methods for synchronizing access to a device resource (e.g., memory) between components operating in different clock domains. The invention purports to achieve this synchronization without requiring the high-speed clocks or minimum pulse width controls common in prior art designs, thereby reducing complexity and power consumption. (Compl. ¶23, ¶25-27).
  • Asserted Claims: At least claim 16 is asserted. (Compl. ¶63).
  • Accused Features: The complaint accuses "branded contactless consumer credit cards" of infringement. (Compl. ¶63).

U.S. Patent No. 8,543,628 - *"Method and System of Digital Signal Processing,"* issued September 24, 2013

  • Technology Synopsis: The patent describes a dynamically reconfigurable digital filtering system on a chip. In this system, a microcontroller provides instruction sets to configure a controller and an address-calculation device, which then select filter coefficients for a data path device to use in performing digital signal processing on incoming data. This approach is described as improving resource efficiency and enabling dynamic reconfiguration. (Compl. ¶28, ¶30-31).
  • Asserted Claims: At least claim 1 is asserted. (Compl. ¶73).
  • Accused Features: The complaint accuses "branded contactless consumer credit cards" of infringement. (Compl. ¶73).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the accused instrumentalities as "branded contactless consumer credit cards" provided and supported by Defendant REI. (Compl. ¶33, ¶43).
  • Functionality and Market Context: The complaint alleges that these credit cards are marketed and provided to Defendant's partners, clients, customers, and end users throughout the United States. (Compl. ¶35). The complaint does not provide specific technical details regarding the internal circuitry or operational methods of these cards. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references exemplary infringement analysis for each asserted patent in Exhibits A-1, B-1, C-1, D-1, and E-1. (Compl. ¶34, ¶44, ¶54, ¶64, ¶74). As these exhibits were not provided with the complaint, a claim chart summary cannot be constructed.

The complaint's narrative infringement theory is that Defendant induces infringement by third parties (e.g., partners, customers) who directly infringe the asserted claims when they use the accused contactless credit cards. (Compl. ¶33, ¶35). The complaint does not, however, describe the specific actions performed by these users or map the technical functionalities of the accused cards to the specific elements of the asserted claims for any of the five patents-in-suit.

  • Identified Points of Contention:
    • Technical Questions: A central question for all five asserted patents will be what evidence the complaint provides that the circuitry within the accused "contactless consumer credit cards" performs the specific, low-level functions required by the claims. For example, regarding the ’926 patent, it raises the question of whether the cards contain an "operation detection circuit" that distinguishes between normal and abnormal CPU states to select a reset type as claimed.
    • Scope Questions: The dispute may raise questions about whether the technologies described in the patents, which are directed to fundamental semiconductor-level operations, are applicable to the end-user product of a contactless credit card. For example, for the ’628 patent, a question may be whether the operations within a credit card constitute "dynamically reconfigurable digital filtering" as contemplated by the patent.

V. Key Claim Terms for Construction

’926 Patent, Claim 1

  • The Term: "operation detection circuit"
  • Context and Importance: This term is the lynchpin of claim 1, as the circuit's ability to "detect" whether a synchronous circuit is "operating normally or abnormally" is what triggers the selective generation of either a synchronous or asynchronous reset. The definition of this functional block will be critical to determining infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the circuit's function broadly as generating a signal "showing the detection result" of "whether the CPU 11 is operating normally." (’926 Patent, col. 4:14-17). This could support an argument that any circuit performing this general function meets the limitation.
    • Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment where the circuit is an "up-counter for counting the internal clock signal" which compares its count to a "predetermined value" to determine if a periodic clear signal from the CPU was missed. (’926 Patent, col. 4:18-26). This may support a narrower construction limited to this or a structurally similar implementation.

’145 Patent, Claim 10

  • The complaint does not provide the language of asserted claim 10 or sufficient detail regarding the infringement theory to identify key terms for construction.

VI. Other Allegations

  • Indirect Infringement: The complaint exclusively pleads induced infringement under 35 U.S.C. § 271(b) for all five patents. It alleges Defendant induces infringement by "partners, clients, customers, and end users" through the "provision and support of branded contactless consumer credit cards." (Compl. ¶33). The complaint further alleges that Defendant's inducement includes "advertising and distributing the Accused Instrumentalities and providing instruction materials, training, and services regarding" them. (Compl. ¶38, ¶48, ¶58, ¶68, ¶78).
  • Willful Infringement: The complaint alleges that Defendant had knowledge of the patents and their infringement "at least as early as the filing of this Complaint." (Compl. ¶36, ¶46, ¶56, ¶66, ¶76). Willfulness is alleged based on this post-suit knowledge, with the complaint stating, "Since the filing of this Complaint, Defendant's induced infringement has been willful." (Compl. ¶39, ¶49, ¶59, ¶69, ¶79).

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

  • Evidentiary Basis: A primary issue will be one of evidence: what technical proof can Plaintiff present to bridge the gap between the high-level accused product—a "contactless credit card"—and the specific, granular circuit-level operations required by the claims of the five asserted patents? The complaint itself does not articulate this connection.
  • Doctrine of Inducement: The case will likely test the sufficiency of the inducement allegations. A key question will be whether Plaintiff can establish that Defendant, by merely providing credit cards and support materials, possessed the specific intent required by law to encourage its customers to perform the specific infringing acts claimed in the patents.
  • Technical Applicability: A fundamental question will be whether the diverse technologies claimed across the patent portfolio are, in fact, practiced by the accused credit cards. The case may turn on whether a set of general-purpose semiconductor inventions can be shown to read on the specific implementation and use case of a consumer financial product.