DCT

2:25-cv-00853

Hypercore Systems LLC v. Denso Ten Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00853, E.D. Tex., 08/24/2025
  • Venue Allegations: Venue for the foreign parent, Denso Ten Ltd, is alleged under statutes governing foreign corporations. Venue for the U.S. subsidiary, Denso Ten America Ltd, is based on an alleged regular and established place of business within the Eastern District of Texas and alleged acts of infringement committed there.
  • Core Dispute: Plaintiff alleges that Defendant’s automotive infotainment systems infringe patents related to methods for coordinating actions across multiple grouped electronic devices and systems for efficiently managing power for multiple processors.
  • Technical Context: The technologies at issue address challenges in modern multi-processor systems, where coordinating device management and power regulation is critical for performance, reliability, and efficient use of circuit board space.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history involving the patents-in-suit.

Case Timeline

Date Event
2003-03-28 U.S. Patent No. 7,392,329 Priority Date
2005-06-22 U.S. Patent No. 7,464,280 Priority Date
2008-06-24 U.S. Patent No. 7392329 Issued
2008-12-09 U.S. Patent No. 7464280 Issued
2025-08-24 Complaint Filed

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

U.S. Patent No. 7,392,329 - “System and method for applying an action initiated for a portion of a plurality of devices to all of the plurality of devices”

  • Patent Identification: U.S. Patent No. US7392329B2, “System and method for applying an action initiated for a portion of a plurality of devices to all of the plurality of devices,” issued June 24, 2008 (’329 Patent).

The Invention Explained

  • Problem Addressed: In computer systems with multi-device modules (e.g., multi-core processors), the operating system (OS) typically recognizes each device individually but is unaware of their physical grouping within a common module (’329 Patent, col. 2:56-65). This creates a problem when an action, such as deconfiguring a processor due to a fault, should ideally be applied to all devices in the module for serviceability, but the OS has no native mechanism to do so automatically (’329 Patent, col. 1:42-50).
  • The Patented Solution: The invention proposes a "status block," which is a shared memory structure corresponding to a multi-device module. When an initiator (like the OS or firmware) takes an action on a single device, it writes information about that action into the common status block. System firmware can then access this status block and automatically apply the same action to all other devices within that module, without the initiator needing to know about the device grouping (’329 Patent, col. 3:34-39; Abstract).
  • Technical Importance: This method decouples high-level system management software from the specific low-level hardware architecture, enabling hardware to be updated without requiring corresponding changes to the OS (’329 Patent, col. 3:1-7).

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 14 (’329 Patent, Compl. ¶22).
  • The essential elements of claim 14 are:
    • A plurality of devices
    • Means for storing status information for the plurality of devices
    • Means for initiating an action to alter the status of a portion of the devices, which involves writing to the storing means
    • Means for applying the action to other devices based on the information in the storing means, where this applying means comprises firmware
  • The complaint reserves the right to modify its infringement contentions during discovery (Compl. ¶22).

U.S. Patent No. 7,464,280 - “Power module for a plurality of processors”

  • Patent Identification: U.S. Patent No. US7464280B2, “Power module for a plurality of processors,” issued December 9, 2008 (’280 Patent).

The Invention Explained

  • Problem Addressed: Providing regulated power to multiple processors in an electronic device is costly and complex, particularly due to the limited space available on printed circuit boards (PCBs) (’280 Patent, col. 1:9-14). Implementing separate power regulation hardware for each processor consumes significant space and increases component count.
  • The Patented Solution: The patent describes a single, integrated "multi-processor power module" designed to serve multiple processors. This module is configured to handle the combined and dynamic power needs of all its associated processors, detecting individual power "demand" from each one and providing a shared, regulated power output (’280 Patent, Abstract; col. 2:50-54). This consolidation is intended to reduce redundant components and save space on the PCB (’280 Patent, col. 4:35-42).
  • Technical Importance: This approach allows for more compact and cost-effective designs for multi-processor systems by eliminating redundant power supply components, mounting hardware, and PCB keep-out areas (’280 Patent, col. 5:1-6).

Key Claims at a Glance

  • The complaint asserts infringement of independent claim 10 (’280 Patent, Compl. ¶28).
  • The essential elements of claim 10 are:
    • A plurality of processors
    • A multi-processor power module coupled to the processors that:
      • detects a demand from each processor,
      • provides a regulated power based on the demand, and
      • the regulated power is shared by the plurality of processors
    • A separate component power module that regulates power for non-processor components
  • The complaint reserves the right to modify its infringement contentions during discovery (Compl. ¶28).

III. The Accused Instrumentality

Product Identification

  • The Denso Ten 86140-47A70 Infotainment System and other "substantially similar products" (Compl. ¶¶21, 27).

Functionality and Market Context

  • The complaint identifies the accused products as automotive "infotainment systems" but provides no specific technical details regarding their internal architecture, multi-processor configuration, or power management systems (Compl. ¶11).
  • The infringement allegations are based on "publicly available information," though the specifics of that information are not detailed in the complaint body (Compl. ¶¶22, 28).

IV. Analysis of Infringement Allegations

The complaint alleges infringement of the ’329 and ’280 patents, referencing exemplary claim charts in Exhibits C and D, respectively (Compl. ¶¶22, 28). As these exhibits were not provided, the following analysis is based on the complaint's narrative allegations.

No probative visual evidence provided in complaint.

  • U.S. Patent No. 7,392,329 Narrative Theory: The complaint asserts that the "329 Accused Products," including the DENSO TEN 86140-47A70 Infotainment System, infringe at least claim 14 of the ’329 Patent (Compl. ¶¶21-22). The complaint does not, however, explain how the accused system is alleged to meet the limitations of the claim, such as by identifying the system's "plurality of devices" or its "means for storing status information."

  • U.S. Patent No. 7,464,280 Narrative Theory: The complaint asserts that the "280 Accused Products," also including the DENSO TEN AMERICA 86140-47A70 Infotainment System, infringe at least claim 10 of the ’280 Patent (Compl. ¶¶27-28). The complaint does not specify which components of the accused system allegedly constitute the claimed "multi-processor power module" or the separate "component power module."

  • Identified Points of Contention:

    • Evidentiary Questions: A central point of contention will be the actual hardware and software architecture of the accused infotainment systems. The complaint does not provide evidence demonstrating that the accused products contain the specific structures and perform the functions recited in the asserted claims.
    • Scope Questions (’329 Patent): The infringement analysis will depend on whether the accused system's architecture includes a structure equivalent to the claimed "means for applying said action... comprising firmware" (’329 Patent, col. 18:8-14). This raises the question of how the accused system coordinates actions across related components and whether that mechanism is structurally equivalent to the patent's disclosed use of a firmware-accessible status block.
    • Technical Questions (’280 Patent): A key dispute may arise over whether the accused system's power circuitry constitutes a single "multi-processor power module" that provides "shared" power, as distinct from a collection of independent power regulators (’280 Patent, col. 10:4-9). The analysis will also require identifying a separate "component power module" for non-processor electronics as required by the claim.

V. Key Claim Terms for Construction

  • For the ’329 Patent:

    • The Term: "means for applying said action ... comprising firmware" (from claim 14).
    • Context and Importance: This term is drafted in means-plus-function format under 35 U.S.C. § 112(f). Its scope is not limitless but is confined to the corresponding structures disclosed in the patent's specification and their equivalents. The viability of the infringement claim will depend on whether the accused product’s software and hardware architecture is structurally equivalent to the specific implementation described in the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the function being performed by "system firmware" accessing a "status structure," which could be argued to cover a range of low-level code implementations that read from a shared memory location to coordinate device states (’329 Patent, col. 4:15-18).
      • Evidence for a Narrower Interpretation: The detailed description links this function to a specific structure: firmware that is programmed to read a signature from a "status block" to ensure validity and then act based on specific bit-fields that identify which device initiated an action and what that action was (e.g., deconfiguration) (’329 Patent, col. 9:55 - col. 10:10; Fig. 2). A party could argue the term is limited to this disclosed algorithm and data structure.

  • For the ’280 Patent:

    • The Term: "multi-processor power module" (from claim 10).
    • Context and Importance: This term defines the central component of the invention. The infringement question will turn on whether the accused product's power delivery system can be characterized as a single, integrated module meeting the claim's functional requirements. Practitioners may focus on this term because its definition will determine whether a distributed power architecture falls outside the claim scope.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification functionally describes the module as being "configured to handle the dynamic power needs of both processors" and being mounted in close proximity to them (’280 Patent, col. 2:50-54). This could support a construction covering any single-package power solution that serves multiple processors.
      • Evidence for a Narrower Interpretation: The embodiments show a discrete physical unit containing specific, shared components like an "input stage" and "control logic," while replicating other components like "switching stages" for each processor (’280 Patent, Fig. 5). A party may argue the term should be construed to require a single, physically consolidated unit containing such shared and replicated internal structures.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for both patents, asserting that Defendant encourages infringement by providing customers and partners with the accused products along with "instructions, manuals, advertisements, [and] marketing materials" (Compl. ¶¶23, 29).
  • Willful Infringement: The complaint's prayer for relief seeks a finding of willful infringement and a corresponding trebling of damages (Compl. p. 7, ¶¶C, E). The body of the complaint, however, does not plead specific facts to support this claim, such as allegations of pre-suit knowledge of the patents-in-suit.

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

This case appears poised to center on fundamental questions of evidence and claim scope, prompted by a complaint that is light on technical detail. The key open questions for the court will likely be:

  • An Evidentiary Question of Architecture: Given the absence of technical detail in the complaint, a primary issue will be establishing the actual hardware and software architecture of the accused HYPERCORE SYSTEMS infotainment system. Discovery will be necessary to determine if the system's power distribution and device management functionalities map onto the structures recited in the asserted claims.

  • A Definitional Question of Scope (’280 Patent): Can the power-regulating circuitry within the accused system be properly characterized as a single "multi-processor power module" providing "shared" regulated power, as required by claim 10? The resolution will depend on the construction of this key term and whether the accused architecture aligns with it or represents a non-infringing distributed power design.

  • A Functional Question of Equivalence (’329 Patent): Does the accused system employ a software or firmware mechanism that is structurally equivalent to the "status block" architecture disclosed in the ’329 Patent for propagating an action (e.g., a deconfiguration command) across multiple related components? This will require a deep technical comparison between the accused system's operation and the specific "means for applying" structure described in the patent.