UniQom LLC v. Micro Star Intl Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: UniQom LLC (New Mexico)
  • Defendant: Micro-Star International Co. Ltd. (Taiwan)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00833, E.D. Tex., 08/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant is a foreign corporation.
• Core Dispute: Plaintiff alleges that Defendant’s unnamed products infringe a patent related to a hardware-based digital identity system for securing electronic communications.
• Technical Context: The patent addresses the need for secure, verifiable digital authentication by cryptographically binding a user's personal data to a unique, permanent identifier physically etched into a microprocessor.
• Key Procedural History: The complaint does not mention any prior litigation or licensing history. However, public records associated with the patent-in-suit indicate that an Ex Parte Reexamination Certificate was issued in April 2024. The reexamination confirmed the patentability of claims 1-4, 12, and 13, which may strengthen the presumption of validity for those specific claims during litigation.

Case Timeline

Date	Event
2000-02-03	’497 Patent Priority Date (Provisional App. 60/179,989)
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

U.S. Patent No. 7,493,497 - “DIGITAL IDENTITY DEVICE”

The Invention Explained

• Problem Addressed: The patent addresses the general need for reliable authentication and security in electronic communications, where parties must be "clearly identifiable and distinguishable" to ensure privacy and integrity ('497 Patent, col. 1:12-16). It identifies a specific need for a method of using unique microprocessor identifiers to create digital identities for individuals or corporations ('497 Patent, col. 1:21-24).
• The Patented Solution: The invention is a "digital identity device" that creates a secure, hardware-rooted digital identity. It accomplishes this by linking two key components: a unique "microprocessor identity information" that is permanently "etched" into a microprocessor's on-die Programmable Read-Only Memory (PROM), and separate "digital identity data" (e.g., a person's name, address, etc.) stored in memory ('497 Patent, Abstract; col. 4:1-16). An operating system cryptographically "binds" the user's digital data to the permanent hardware identifier by using an algorithm that incorporates the unique microprocessor identity, thus creating a secure and verifiable link between the physical device and the user's identity ('497 Patent, col. 4:36-42, 59-62). Figure 2 illustrates this architecture, showing the microprocessor identity device (205) with its embedded identity information (230) connected to memory (210) containing the digital identity data (220) and the binding operating system (225).
• Technical Importance: The approach aimed to provide a higher level of security than software-only solutions by anchoring a user's digital identity to a unique, unalterable physical characteristic of the hardware itself.

Key Claims at a Glance

• The complaint asserts "one or more claims" and "exemplary method claims" without specifying numbers (Compl. ¶11). The asserted independent claims are likely among claims 1, 5, and 9.
• Independent Claim 1 (Device):
  • A microprocessor with a unique "microprocessor identity" that is "etched into" an "on-die Programmable Read-Only Memory (PROM)".
  • "Digital identity data" that identifies an owner by 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 digital identity data using an algorithm that uses the microprocessor identity".
• Independent Claim 5 (Method):
  • Obtaining digital identity data from a digital identity device connected to a computer.
  • Encrypting an electronic document using the digital identity data.
  • The method requires the use of a digital identity device that comprises all the structural elements of Claim 1, including the microprocessor with the etched PROM identity.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in an exhibit not attached to the filed complaint (Compl. ¶¶11, 13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that the "Exemplary Defendant Products practice the technology claimed by the '497 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint does not contain a claim chart or any specific factual allegations detailing how the accused products infringe the ’497 Patent. Instead, it states that "Exhibit 2 includes charts comparing the Exemplary ’497 Patent Claims to the Exemplary Defendant Products" (Compl. ¶13). As this exhibit was not provided, a summary of the infringement theory is not possible.

No probative visual evidence provided in complaint.

• Identified Points of Contention: Based on the language of the patent claims, any infringement analysis would raise several key technical and legal questions:
  • Structural Questions: Does any accused product contain a microprocessor with a unique identifier that is physically "etched into" an "on-die Programmable Read-Only Memory (PROM)" as required by Claim 1? This limitation describes a specific method of manufacture and hardware configuration that may be a focal point of dispute.
  • Functional Questions: What is the mechanism by which the accused products link hardware identifiers to user data? Specifically, does the accused software perform the claimed function of "encrypting the digital identity data using an algorithm that uses the microprocessor identity"? The analysis will require determining if the hardware identifier is an active input into the encryption algorithm itself, as the claim language suggests.
  • Scope Questions: How broadly will the court construe the term "etched"? The question may arise whether other methods of creating a permanent, unique hardware identifier (e.g., using electronic fuses or other non-volatile memory technologies) fall within the literal scope of this term or the doctrine of equivalents.

V. Key Claim Terms for Construction

• The Term: "a microprocessor identity... etched into the PROM" (Claim 1)

• Context and Importance: This term is central to the invention's core concept of a permanent, physically-instantiated hardware identifier. The infringement analysis will depend heavily on whether the accused products possess this specific hardware feature. Practitioners may focus on this term because its specificity could create a high bar for proving literal infringement if the accused products use alternative technologies for unique device identification.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Narrower Interpretation: The patent repeatedly uses the specific term "etched" when describing how the identity information is placed onto the hardware ('497 Patent, col. 4:24-25, col. 5:2-3, col. 5:17-18, col. 5:33-35, col. 6:1-3, Claim 13). This consistent and specific language may support a construction limited to the physical process of etching, as distinct from other methods of programming or storing an identifier.
  • Evidence for a Broader Interpretation: The complaint does not provide a basis for a broader interpretation. A party might argue that "etched" should be understood in the context of creating a permanent, unalterable identifier, but the specification does not appear to provide explicit support for extending the term beyond its common meaning in semiconductor manufacturing.

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

• Context and Importance: This functional limitation defines the required cryptographic link between the hardware and the user data. The dispute will likely center on whether the accused products' software performs this exact operation. If an accused system links the two pieces of data without using the hardware ID as a direct input to the encryption algorithm, it may not infringe.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Narrower Interpretation: The specification provides a description consistent with the claim language, stating the operating system "binds the digital identity data... by encoding" and the data "is encoded by an algorithm that uses the microprocessor identity information" ('497 Patent, col. 4:36-42). This supports a construction requiring the hardware ID to be a functional part of the cryptographic process.
  • Evidence for a Broader Interpretation: The patent’s summary describes the invention more generally as having "means for binding the microprocessor identity device to the digital identity" ('497 Patent, col. 1:36-38). A party could argue this suggests a broader concept of "binding," though this is less specific than the language used in the claim itself and the detailed description.

VI. Other Allegations

• Indirect Infringement: The complaint makes no specific allegations of induced or contributory infringement.
• Willful Infringement: The complaint contains no factual allegations to support a claim of willful infringement, such as pre-suit knowledge of the patent. The prayer for relief requests a finding that the case is "exceptional" but provides no basis for such a finding in the body of the complaint (Compl., Prayer for Relief E.i).

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

This case appears poised to turn on the resolution of highly specific technical questions related to hardware architecture and cryptographic methods.

• A core issue will be one of structural correspondence: Can the plaintiff demonstrate that the accused products, which remain unidentified in the complaint, incorporate the precise hardware structure claimed—namely, a unique identifier physically "etched" into an on-die PROM?
• A second key question will be one of functional operation: Assuming the hardware limitation is met, does the software in the accused products perform the specific cryptographic function of "binding" data by "using an algorithm that uses the microprocessor identity," or does it achieve a similar security objective through a technically distinct, non-infringing method?
• Finally, a threshold evidentiary question will be whether the plaintiff, having filed a complaint devoid of specific factual allegations, can produce discovery evidence sufficient to map these detailed claim limitations onto the defendant's products.