DCT

2:25-cv-00832

UniQom LLC v. Beckhoff Automation GmbH

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00832, E.D. Tex., 08/21/2025
  • Venue Allegations: Venue is asserted on the basis that the defendant is a foreign corporation and has allegedly committed acts of patent infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a hardware-based digital identity device for securing electronic communications.
  • Technical Context: The technology concerns anchoring a digital identity to a unique, unalterable identifier within a microprocessor to enhance authentication and security for digital transactions and communications.
  • Key Procedural History: The patent-in-suit, U.S. Patent No. 7,493,497, was the subject of an ex parte reexamination proceeding which concluded in April 2024. The U.S. Patent and Trademark Office issued a certificate confirming the patentability of claims 1-4, 12, and 13, which may strengthen the patent's presumption of validity in this litigation.

Case Timeline

Date Event
2000-02-03 ’497 Patent Priority Date (Provisional Application)
2000-09-08 ’497 Patent Application Filing Date
2009-02-17 ’497 Patent Issue Date
2024-04-19 ’497 Patent Ex Parte Reexamination Certificate Issued
2025-08-21 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 7,493,497, "DIGITAL IDENTITY DEVICE," issued February 17, 2009.

The Invention Explained

  • Problem Addressed: The patent's background section identifies a need for reliable authentication of parties in electronic communications, requiring that each party be "clearly identifiable and distinguishable" to ensure security (’497 Patent, col. 1:13-16). It specifically frames the problem as needing "a method of identifying microprocessors and using this method... for entities to use in electronic communications" (’497 Patent, col. 1:21-25).
  • The Patented Solution: The invention proposes a "digital identity device" that links a user's digital information (e.g., name, personal data) to a unique, hardware-level identifier permanently associated with a microprocessor (’497 Patent, col. 1:28-36). This "microprocessor identity information" is described as being "etched" onto a component like an on-die Programmable Read-Only Memory (PROM) during manufacturing (’497 Patent, cl. 1). The system then cryptographically "binds" the user's digital identity data to this hardware identifier, creating a secure token that can be used for authentication, secure transactions, and software licensing (’497 Patent, col. 4:36-42).
  • Technical Importance: The approach of tying a digital identity to an immutable physical hardware feature was a method for creating a higher level of trust and non-repudiation in digital systems than purely software-based solutions could provide at the time (’497 Patent, col. 8:59-62).

Key Claims at a Glance

  • The complaint does not specify which claims are asserted, referring only to "exemplary method claims" (Compl. ¶11). Independent claim 1, a device claim, is representative of the core technology.
  • Independent Claim 1 Elements:
    • A microprocessor comprising a unique "microprocessor identity," where the microprocessor has an on-die Programmable Read-Only Memory (PROM) and the identity is "etched into the PROM."
    • "Digital identity data" that identifies an owner and includes the owner's name.
    • A memory to store the digital identity data.
    • The microprocessor identity is an "alpha-numeric value."
    • The digital identity data is "bound" to the microprocessor identity by encrypting the data "using an algorithm that uses the microprocessor identity."

III. The Accused Instrumentality

  • Product Identification: The complaint does not identify any specific accused products by name (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are detailed in claim charts allegedly attached as Exhibit 2, but this exhibit was not included with the public filing of the complaint (Compl. ¶13).
  • Functionality and Market Context: The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint incorporates by reference claim charts from an external document (Exhibit 2) which was not provided with the complaint itself (Compl. ¶¶13-14). Therefore, a detailed claim chart summary cannot be constructed. The complaint's narrative allegations are limited to general assertions of direct infringement by Defendant and its employees (Compl. ¶¶11-12).

No probative visual evidence provided in complaint.

  • Identified Points of Contention: Based on the technology described in the ’497 Patent, litigation will likely focus on several key technical and legal questions:
    • Scope Questions: A central question may be whether the hardware identifiers in the accused products constitute a "microprocessor identity... etched into the PROM" as required by claim 1. This raises the issue of whether identifiers implemented through other means (e.g., fused bits, software-readable serial numbers not stored in an "etched" PROM) fall within the claim's scope.
    • Technical Questions: A key factual dispute may concern the mechanism of "binding." The complaint provides no detail on how the accused products allegedly perform the claimed step of "encrypting the digital identity data using an algorithm that uses the microprocessor identity." The analysis will question whether the accused products use a hardware ID as a direct input or key for an encryption algorithm, or if they use a less direct form of association.

V. Key Claim Terms for Construction

  • The Term: "microprocessor identity ... etched into the PROM" (from claim 1)

  • Context and Importance: This term appears central to defining the physical characteristics of the claimed invention. The dispute will likely focus on whether the term "etched" requires a specific manufacturing process or can be interpreted more broadly to cover other methods of permanently embedding an identifier in silicon.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification discusses various embodiments, including one where identity information is etched onto a memory using a "commercially available PROM programming device," which could suggest the means of fixation is less important than its permanence (’497 Patent, col. 5:16-19).
    • Evidence for a Narrower Interpretation: The patent repeatedly emphasizes the physical creation of the identity, stating the information "is etched at the time the microprocessor component 405 is etched" and "is etched at the time of manufacturing of the microprocessor component" (’497 Patent, col. 6:2-4, col. 5:33-35). This language suggests a narrow construction tied to the original semiconductor fabrication process.

  • The Term: "bound ... by encrypting the digital identity data using an algorithm that uses the microprocessor identity" (from claim 1)

  • Context and Importance: This functional language defines the specific cryptographic relationship between the hardware identifier and the user's data. Its construction will determine whether infringement requires a specific type of cryptographic operation.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party might argue that any system where the hardware ID is used to secure or authenticate the user data effectively "binds" them, even if the ID is not a direct input to the encryption algorithm itself.
    • Evidence for a Narrower Interpretation: The specification provides a more direct link: "The operating system 225 binds the digital identity data 220 to the microprocessor identity device 205 by encoding the digital identity data ... by an algorithm that uses the microprocessor identity information 230" (’497 Patent, col. 4:36-42). This suggests the microprocessor identity is an active element in the encryption process itself, supporting a narrower reading.

VI. Other Allegations

  • Indirect Infringement: The complaint does not plead specific facts to support claims of induced or contributory infringement.
  • Willful Infringement: The complaint does not allege facts supporting pre-suit knowledge of the patent or egregious conduct required for a finding of willfulness. It does, however, include a request in the prayer for relief that the case be declared "exceptional," which is the standard for awarding attorney's fees (Compl. p. 4, ¶E.i).

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

The resolution of this dispute, based on the complaint and patent, appears to hinge on two primary questions for the court:

  1. A core issue will be one of physicality and scope: Does the term "microprocessor identity... etched into the PROM" require a specific semiconductor manufacturing process, or can it be construed to cover other forms of permanent hardware identification allegedly used in the accused products?
  2. A key evidentiary question will be one of cryptographic mechanism: What evidence will show that the accused products perform the specific function of "binding" by using the hardware identifier as an input to the algorithm that encrypts the user's "digital identity data," as the claim language requires?