DCT

4:25-cv-00665

Near Field Electronics LLC v. Enterprise Holdings Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00665, E.D. Tex., 06/23/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants have committed acts of infringement in the Eastern District of Texas and maintain a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that credit card readers used by Defendants, which incorporate a specific Near Field Communication (NFC) front-end component, infringe five patents related to semiconductor interface architecture, protocol management, and power control.
  • Technical Context: The patents-in-suit address foundational technologies for integrated circuits designed to manage communication with external devices, including methods for handling multiple protocols, flexible interface configuration, and power efficiency.
  • Key Procedural History: The complaint notes that four of the five asserted patents are expired. For these patents, Plaintiff seeks damages only for a period of alleged infringement beginning June 23, 2019, and ending on each patent's respective expiration date.

Case Timeline

Date Event
2000-06-21 U.S. Patent No. 6,691,201 Priority Date
2000-07-25 U.S. Patent No. 6,742,071 Priority Date
2000-08-28 U.S. Patent No. 6,996,727 Priority Date
2002-06-28 U.S. Patent No. 6,959,350 Priority Date
2004-02-10 U.S. Patent No. 6,691,201 Issued
2004-05-25 U.S. Patent No. 6,742,071 Issued
2005-01-11 U.S. Patent No. 7,373,531 Priority Date
2005-10-25 U.S. Patent No. 6,959,350 Issued
2006-02-07 U.S. Patent No. 6,996,727 Issued
2008-05-13 U.S. Patent No. 7,373,531 Issued
2019-06-23 Start of Alleged Damages Period
2021-11-21 U.S. Patent No. 6,742,071 Expired
2022-01-31 U.S. Patent No. 6,691,201 Expired
2022-04-14 U.S. Patent No. 6,996,727 Expired
2023-08-12 U.S. Patent No. 6,959,350 Expired
2025-06-23 Complaint Filing Date

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

U.S. Patent No. 6,691,201 - "Dual Mode USB-PS/2 Device"

  • Patent Identification: U.S. Patent No. 6,691,201, "Dual Mode USB-PS/2 Device," issued February 10, 2004. (Compl. ¶9).

The Invention Explained

  • Problem Addressed: The patent describes that, at the time of the invention, peripheral devices supporting multiple communication protocols, such as both Universal Serial Bus (USB) and the legacy PS/2 protocol, required additional external components, increased circuit board space, and dedicated input/output (I/O) pins, which increased cost and complexity. (’201 Patent, col. 1:40-50; Compl. ¶12).
  • The Patented Solution: The invention is an integrated circuit that consolidates the functionality for multiple protocols onto a single chip. It is designed to automatically detect which protocol a connected bus is using (e.g., USB or PS/2) and configure itself to communicate using that protocol, all through a single shared set of I/O pins, thereby simplifying the peripheral's design. (’201 Patent, Abstract; col. 3:5-21; Compl. ¶11, ¶13).
  • Technical Importance: This single-chip solution aimed to reduce the cost, physical size, and firmware complexity of computer peripherals, such as mice, that needed to maintain compatibility with different generations of host computer interfaces. (’201 Patent, col. 1:50-54; Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 14. (Compl. ¶32).
  • The essential elements of independent claim 14 are:
    • A method for automatically selecting a signaling protocol for communicating with a host.
    • Detecting a signaling protocol of a bus connected to an integrated circuit that operates in a plurality of signaling protocols.
    • Configuring the integrated circuit to communicate in the detected protocol.
    • Wherein the selected protocols operate over the connected bus through a single set of pins.
  • The complaint reserves the right to assert other claims. (Compl. ¶33).

U.S. Patent No. 6,742,071 - "Real-time I/O Processor Used to Implement Bus Interface Protocols"

  • Patent Identification: U.S. Patent No. 6,742,071, "Real-time I/O Processor Used to Implement Bus Interface Protocols," issued May 25, 2004. (Compl. ¶14).

The Invention Explained

  • Problem Addressed: Conventional approaches for implementing bus interfaces were either protocol-specific, which limited a product's flexibility and marketability, or user-programmable with fixed wait-states, which could be difficult to program and lacked the sophistication for complex interface signaling. (’071 Patent, col. 1:16-48).
  • The Patented Solution: The patent discloses a specialized, real-time input/output processor, described as a general-purpose interface (GPIF). This processor uses a limited, dedicated instruction set to generate custom waveforms and respond to external events, allowing it to function as a master device that can flexibly implement various bus interface protocols without rigid, protocol-specific hardware. (’071 Patent, Abstract; col. 2:35-46; Compl. ¶16-17).
  • Technical Importance: This technology provided a programmable, high-speed alternative to fixed hardware, enabling a single processor architecture to efficiently implement multiple, changing, or customer-specific interface standards. (’071 Patent, col. 2:53-62; Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent claim 15. (Compl. ¶37).
  • The essential elements of independent claim 15 are:
    • A method for providing an interface to an external bus.
    • Generating a plurality of first control signals based on a processor's current state.
    • Progressing to a next state based on the current state, an internal control signal, and an input signal from the external bus.
    • Driving an output control signal onto the external bus.
    • Updating the current state to the next state.
  • The complaint reserves the right to assert other claims. (Compl. ¶38).

U.S. Patent No. 6,959,350 - "Configurable USB Interface With Virtual Register Architecture"

  • Patent Identification: U.S. Patent No. 6,959,350, "Configurable USB Interface With Virtual Register Architecture," issued October 25, 2005. (Compl. ¶18).
  • Technology Synopsis: The patent addresses the problem of hard-coded USB endpoint configurations in interface controllers, which required writing and maintaining separate HDL code for different versions. The invention provides a configurable bus interface controller that uses an HDL-based configuration package to flexibly generate the necessary configuration circuitry for various USB endpoints, simplifying design and avoiding clumsy, error-prone scripts. (Compl. ¶20-22).
  • Asserted Claims: At least independent claim 10. (Compl. ¶42).
  • Accused Features: Credit card reader devices equipped with an NXP PN512 NFC Front-End or similar components. (Compl. ¶42).

U.S. Patent No. 6,996,727 - "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor"

  • Patent Identification: U.S. Patent No. 6,996,727, "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor," issued February 7, 2006. (Compl. ¶23).
  • Technology Synopsis: Conventional USB interfaces at the time provided a constant voltage supply with no low-power mode. This invention discloses a power supply architecture for a bus interface that operates in two modes: a standard mode and a power-down standby mode. In standby, the main power is turned off to reduce current consumption, while a low-power programmable resistor maintains the necessary pullup function for the bus. (Compl. ¶25-26).
  • Asserted Claims: At least independent claim 18. (Compl. ¶47).
  • Accused Features: Credit card reader devices equipped with an NXP PN512 NFC Front-End or similar components. (Compl. ¶47).

U.S. Patent No. 7,373,531 - "Signal Detection Method, Frequency Detection Method, Power Consumption Control Method..."

  • Patent Identification: U.S. Patent No. 7,373,531, "Signal Detection Method, Frequency Detection Method, Power Consumption Control Method..." issued May 13, 2008. (Compl. ¶27).
  • Technology Synopsis: The patent describes methods and devices for detecting the presence, frequency, or state of a signal by monitoring the "through current" in a circuit with connected transistors. Based on this detection, the apparatus can determine the operational state of a target and execute a power supply stopping or reduction process to reduce power consumption. (Compl. ¶29-30).
  • Asserted Claims: At least independent claim 2. (Compl. ¶52).
  • Accused Features: Credit card reader devices equipped with an NXP PN512 NFC Front-End or similar components. (Compl. ¶52).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the "Accused Instrumentalities" as credit card reader devices equipped with an NXP PN512 NFC Front-End. The allegations are also directed at "any other NFC-capable credit card reader equipped with an NXP PN512 NFC Front-End or NFC front-end components with similar NFC functionality." (Compl. ¶32, ¶37).
  • Functionality and Market Context: The complaint alleges that Defendants use these devices in the regular course of their business for the purpose of processing NFC payment transactions. (Compl. ¶34). The complaint does not provide further technical detail on the specific operation of the readers beyond identifying the core NFC component.

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement claim charts in Exhibits A-1, B-1, C-1, D-1, and E-1, but these exhibits were not filed with the complaint. (Compl. ¶33, ¶38, ¶43, ¶48, ¶53). Therefore, the infringement allegations are summarized below based on the narrative text of the complaint.

  • '201 and '071 Patents Infringement Allegations
    The complaint alleges that Defendants directly infringe the method claims of the ’201 and ’071 patents by using the Accused Instrumentalities. The theory of infringement is that when Defendants "put the Accused Instrumentalities to use in the regular course of their business operations for processing NFC payment transactions," the devices necessarily perform each step of the claimed methods. (Compl. ¶34, ¶39).

  • Identified Points of Contention

    • Scope Questions: A primary question for the ’201 Patent is whether the term "plurality of signaling protocols," which the patent describes in the context of USB and PS/2 computer peripheral interfaces, can be construed to read on the communication protocols used in the accused NFC payment readers (e.g., ISO/IEC 14443). A similar question arises for the ’071 Patent regarding whether the general-purpose, state-machine-like method claimed for implementing bus protocols can be mapped onto the specific operations of a dedicated NFC reader.
    • Technical Questions: The complaint's infringement theory relies on the act of "processing NFC payment transactions" inherently performing the claimed steps. A key technical question will be what evidence demonstrates that this use case causes the accused device to perform the specific functions required by the claims, such as "automatically selecting" between protocols (’201 Patent) or "progressing to a next state" based on bus inputs in the manner of the claimed processor (’071 Patent).

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

  • For the '201 Patent:

    • The Term: "plurality of signaling protocols" (from claim 14).
    • Context and Importance: The patent's specification is heavily focused on the USB and PS/2 protocols. The viability of the infringement case may depend on whether this term is interpreted broadly to include any set of protocols, such as those used in NFC, or is limited by the specification's context to computer-to-peripheral protocols.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is general and does not name any specific protocols, referring only to a "plurality." (’201 Patent, col. 7:3).
      • Evidence for a Narrower Interpretation: The patent's title ("Dual Mode USB-PS/2 Device"), abstract, and background section exclusively discuss USB and PS/2, which may be used to argue that the scope of the claimed invention is implicitly constrained to that technological context. (’201 Patent, Title; Abstract; col. 1:15-25).

  • For the '071 Patent:

    • The Term: "progressing to a next state based on said current state...and an input signal" (from claim 15).
    • Context and Importance: This term is central to the claimed method, which describes a state-based processor. Practitioners may focus on this term because the infringement analysis will require mapping the real-world operation of the accused NFC device onto this abstract, state-machine-like process.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim uses general language such as "progressing," "state," and "signal," which could arguably be applied to a wide range of hardware or software operations where a device's logic changes in response to an input. (’071 Patent, col. 14:3-6).
      • Evidence for a Narrower Interpretation: The specification describes this process in the specific context of a specialized I/O processor executing instructions like "branch on signal" or "wait N clocks" from a control store. A party could argue that "progressing to a next state" requires this specific instruction-driven architecture, not just any logical operation. (’071 Patent, col. 7:14-46, Fig. 11a).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of the ’531 Patent. It alleges that Defendants had knowledge of the patent "at least as early as the filing of this Complaint" and induced infringement by "advertising and distributing the Accused Instrumentalities and providing instruction materials, training, and services" that cause end users to directly infringe. (Compl. ¶55-57).
  • Willful Infringement: The complaint alleges willful infringement of the ’531 Patent. The allegation is based entirely on post-suit conduct, stating that "Since the filing of this Complaint, each Defendant's infringement has been willful." (Compl. ¶58).

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

  • A core issue will be one of technological scope: Can claims drafted in the context of computer peripheral interfaces (USB/PS/2) and general-purpose programmable I/O processors be construed to cover the distinct and specialized technology of modern NFC payment systems?
  • A key evidentiary question will be one of functional mapping: Can Plaintiff produce evidence that the accused NFC readers, when processing a payment, perform the specific, multi-step methods recited in the claims—such as automatically selecting between protocols or executing instruction-driven state progressions—or will discovery reveal a fundamental mismatch in technical operation?
  • Given that four of the five asserted patents have expired, a significant question will concern the calculation of damages. The dispute will likely focus on establishing a reasonable royalty for a finite, historical period of infringement, which may affect the overall value of the case and the parties' litigation strategies.