DCT

2:25-cv-00876

InnoMemory LLC v. Team Group Inc

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-00876, E.D. Tex., 08/26/2025
  • Venue Allegations: Plaintiff alleges venue is proper because the defendant is a foreign corporation, has committed acts of patent infringement in the district, and caused harm there.
  • Core Dispute: Plaintiff alleges that Defendant’s memory products infringe a patent related to methods for reducing power consumption in memory devices during refresh operations.
  • Technical Context: The patent addresses power management in dynamic random-access memory (DRAM), a critical issue for battery-powered electronics where standby power consumption directly impacts device longevity.
  • Key Procedural History: The complaint does not reference any prior litigation, licensing history, or administrative proceedings related to the patent-in-suit.

Case Timeline

Date Event
2002-03-04 ’960 Patent Priority Date
2006-06-06 ’960 Patent Issue Date
2025-08-26 Complaint Filing Date

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

U.S. Patent No. 7,057,960 - Method and architecture for reducing the power consumption for memory devices in refresh operations

The Invention Explained

  • Problem Addressed: The patent’s background section describes how conventional dynamic random access memories (DRAMs) consume significant power in standby mode by refreshing all memory cells, even if only a portion of the memory contains data that needs to be retained (’960 Patent, col. 1:35-44). This approach is particularly inefficient for battery-powered devices. A specific disadvantage noted is that conventional methods activate the support circuits (“periphery array circuits”) for all sections of the memory array during a refresh cycle, even when only a subset of the array requires refreshing (’960 Patent, col. 2:26-29).
  • The Patented Solution: The invention proposes a method and architecture to reduce power consumption by selectively controlling background operations, such as refresh cycles, in different sections of a memory array (’960 Patent, Abstract). The system uses specific control signals (e.g., REF0-REFn) to enable the periphery array circuits only for the memory sections currently being refreshed, while leaving the circuits for other sections inactive (’960 Patent, col. 2:50-55; Fig. 3). This selective activation prevents unnecessary power draw from the support circuitry of idle memory sections.
  • Technical Importance: This technique allows for lower standby power consumption in memory devices, a critical factor for extending the battery life of portable electronics like mobile phones (’960 Patent, col. 1:30-35).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims of the '960 Patent" but does not specify which claims are asserted, instead referring to "Exemplary '960 Patent Claims" detailed in an external Exhibit 2 (Compl. ¶¶11, 13). This exhibit was not provided with the filed complaint. Therefore, an analysis of specific asserted claims is not possible based on the provided documents.

III. The Accused Instrumentality

Product Identification

  • The complaint does not identify any specific accused products by name or model number (Compl. ¶¶11-13).

Functionality and Market Context

  • The complaint refers generally to "Defendant products" and "Exemplary Defendant Products" that allegedly "practice the technology claimed by the '960 Patent" (Compl. ¶¶11, 13). It does not provide sufficient detail for analysis of the accused products' specific functionality, features, or market positioning.

IV. Analysis of Infringement Allegations

The complaint references claim charts in an external Exhibit 2, which was not provided (Compl. ¶13). The narrative allegations state that the "Exemplary Defendant Products" satisfy all elements of the asserted claims, either literally or under the doctrine of equivalents (Compl. ¶¶11, 13). Without the specific asserted claims, accused products, or the referenced claim charts, a detailed infringement analysis is not possible.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

The complaint does not identify specific asserted claims, precluding an analysis of key claim terms that may be subject to construction.

VI. Other Allegations

  • Indirect Infringement: The complaint does not contain factual allegations to support claims for induced or contributory infringement.
  • Willful Infringement: The complaint does not allege facts to support willful infringement, such as pre-suit knowledge of the patent or its infringement. The prayer for relief includes a request for a finding that the case is exceptional under 35 U.S.C. § 285, but the complaint body does not plead the factual predicate for such a finding (Compl. p. 4, ¶E.i).

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

Based on the complaint and the patent-in-suit, the case at this initial stage presents foundational pleading and evidentiary questions rather than developed technical disputes.

  • A primary procedural issue will be one of specificity: The complaint’s reliance on an external, un-filed exhibit for identifying both the asserted claims and the accused products (Compl. ¶¶11, 13) will likely require supplementation or amendment before the case can proceed to substantive stages like claim construction or discovery.
  • Once the claims and products are identified, a central technical question will likely concern operational correspondence: The dispute may turn on whether the accused memory devices manage power during refresh cycles by selectively enabling and disabling periphery support circuits for distinct sections of the memory array, as described in the ’960 Patent, or if they achieve power savings through an alternative, non-infringing technical mechanism.