4:25-cv-00665
Near Field Electronics LLC v. Enterprise Holdings Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Near Field Electronics LLC (Texas)
- Defendant: New Balance Athletics, Inc. (Massachusetts)
- Plaintiff’s Counsel: Shea | Beaty PLLC
- Case Identification: 4:25-cv-00711, E.D. Tex., 01/30/2026
- Venue Allegations: Venue is based on Defendant maintaining a "regular and established place of business" in Allen, Texas, located within the Eastern District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s use of NFC-capable credit card readers infringes five patents related to semiconductor interface architecture, power management, and signal detection.
- Technical Context: The patents-in-suit generally concern integrated circuit designs for managing communication between computer peripherals and hosts, with a focus on protocol flexibility and power efficiency.
- Key Procedural History: The complaint asserts infringement for a period beginning July 3, 2019. Four of the five asserted patents ('201, '071, '350, '727) are expired, limiting any potential damages to past infringement only. For the single unexpired patent ('531), the complaint alleges inducement and willful infringement based on knowledge acquired as of the filing of the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2000-06-21 | '201 Patent Priority Date |
| 2000-07-25 | '071 Patent Priority Date |
| 2000-08-28 | '727 Patent Priority Date |
| 2002-06-28 | '350 Patent Priority Date |
| 2004-02-10 | '201 Patent Issued |
| 2004-05-25 | '071 Patent Issued |
| 2005-01-11 | '531 Patent Priority Date |
| 2005-10-25 | '350 Patent Issued |
| 2006-02-07 | '727 Patent Issued |
| 2008-05-13 | '531 Patent Issued |
| 2019-07-03 | Alleged Infringement Period Begins for Expired Patents |
| 2021-11-21 | '071 Patent Expired |
| 2022-01-31 | '201 Patent Expired |
| 2022-04-14 | '727 Patent Expired |
| 2023-08-12 | '350 Patent Expired |
| 2026-01-30 | First Amended Complaint Filed |
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.
The Invention Explained
- Problem Addressed: The patent’s background section describes that conventional peripheral devices, such as computer mice, required separate sets of external components, dedicated microcontroller I/O pins, and complex firmware to support both the Universal Serial Bus (USB) and Personal System 2 (PS/2) signaling protocols, increasing cost, board space, and design complexity (Compl. ¶11; ’201 Patent, col. 1:39-52).
- The Patented Solution: The invention is an integrated circuit that automatically detects which protocol (USB or PS/2) is being used by a connected bus and configures itself to operate accordingly using a single shared set of I/O pins, thereby eliminating the need for redundant external components (Compl. ¶10, ¶12; ’201 Patent, Abstract; col. 2:51-56).
- Technical Importance: The single-chip solution offered a way for peripheral device manufacturers to reduce hardware costs and simplify design while maintaining compatibility with both a modern standard (USB) and a legacy standard (PS/2) (Compl. ¶12).
Key Claims at a Glance
- The complaint asserts infringement of independent method claim 14 (Compl. ¶31).
- Claim 14 requires the essential elements of:
- detecting a signaling protocol of a bus connected to an integrated circuit that operates in a plurality of signaling protocols; and
- configuring the integrated circuit to communicate in one of the signaling protocols in response to the detection, where the protocols operate over the bus through a single set of pins.
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.
The Invention Explained
- Problem Addressed: The patent addresses the limitations of protocol-specific hardware interfaces, which are inflexible and unable to adapt to evolving bus standards or custom interface requirements without a complete redesign (Compl. ¶16; ’071 Patent, col. 1:16-32).
- The Patented Solution: The invention provides a flexible, programmable real-time input/output (I/O) processor, referred to as a general-purpose interface (GPIF). This processor uses a limited instruction set to generate interface-specific waveforms and respond to external events, allowing a single hardware architecture to implement multiple different bus protocols by changing its programming (Compl. ¶15; ’071 Patent, Abstract; col. 6:4-16).
- Technical Importance: This programmable architecture allowed for higher-speed and more adaptable I/O solutions compared to traditional microprocessor-based systems, enabling a single device to support multiple or changing communication standards (Compl. ¶16).
Key Claims at a Glance
- The complaint asserts infringement of independent method claim 15 (Compl. ¶36).
- Claim 15 requires the essential elements of:
- generating control signals based on a processor's current state;
- progressing to a next state based on the current state, internal control signals, and an input signal from an external bus;
- driving an output control signal onto the external bus; and
- updating the current state to the next state.
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.
- Technology Synopsis: The patent addresses the inefficiency of using hard-coded endpoint configurations in USB interface controllers, which required designers to write and maintain different Hardware Description Language (HDL) code for each variation (Compl. ¶20). The invention provides a configurable interface controller that uses a single HDL-based configuration package to flexibly generate the necessary configuration circuitry, eliminating the need for separate HDL code for each endpoint configuration (Compl. ¶19, ¶21).
- Asserted Claims: Independent method claim 10 is asserted (Compl. ¶41).
- Accused Features: The complaint alleges that the NFC front-end components within the accused credit card readers practice the claimed method (Compl. ¶41).
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.
- Technology Synopsis: The patent addresses the problem of power consumption in conventional USB interfaces that provided only a constant voltage supply with no low-power mode (Compl. ¶25). The invention discloses a power supply architecture for a bus interface that operates in both a standard mode and a power-down (standby) mode, which reduces current consumption by using a low-power programmable resistor to maintain the required pullup function during idle states (Compl. ¶24).
- Asserted Claims: Independent method claim 18 is asserted (Compl. ¶46).
- Accused Features: The complaint alleges that the NFC front-end components of the accused credit card readers perform the claimed power-saving method (Compl. ¶46).
U.S. Patent No. 7,373,531 - "Signal Detection Method...and Electronic Apparatus"
- Patent Identification: U.S. Patent No. 7,373,531, "Signal Detection Method...and Electronic Apparatus," Issued May 13, 2008.
- Technology Synopsis: The patent discloses methods and devices for detecting the status of a signal by monitoring the "through current" flowing in a circuit (Compl. ¶28). A signal is applied to the gates of connected transistors, and its presence, absence, or state is determined based on whether a through current flows, which enables an apparatus to reduce its power consumption by stopping or reducing power supply when a target device is not in an active operational state (Compl. ¶28-29).
- Asserted Claims: Independent method claim 2 is asserted (Compl. ¶51).
- Accused Features: The complaint alleges that the NFC front-end components within the accused credit card readers practice the claimed signal detection method (Compl. ¶51).
III. The Accused Instrumentality
Product Identification
The accused products are identified as "credit card reader device[s] equipped with an NXP PN512 NFC Front-End" and any other "NFC-capable credit card reader with similar functionality" (Compl. ¶31, ¶36, ¶41, ¶46, ¶51). The complaint collectively refers to these as the "Relevant Instrumentalities."
Functionality and Market Context
The complaint alleges that Defendant uses these devices in the "regular course of its business operations for processing NFC payment transactions" (Compl. ¶33). The specific accused functionality is attributed to the "NFC front-end components" of the readers, but the complaint provides no further technical detail regarding their operation beyond this general description (Compl. ¶31). No probative visual evidence provided in complaint.
IV. Analysis of Infringement Allegations
The complaint references exemplary claim chart exhibits (Exhibits A-1, B-1, etc.) for each asserted patent but does not include them in the filing (Compl. ¶32, ¶37, ¶42, ¶47, ¶52). The narrative infringement allegations are summarized below.
'201 Patent Infringement Allegations
The complaint alleges that by using the Relevant Instrumentalities to process NFC payments, Defendant directly infringes claim 14 (Compl. ¶31, ¶33). The pleading asserts in a conclusory manner that when put into use, the devices perform "each and every step" of the claimed method (Compl. ¶33). It does not, however, provide specific factual allegations explaining how an NFC reader performs the claimed steps of detecting one of multiple signaling protocols (e.g., USB or PS/2) on a connected bus and reconfiguring an integrated circuit in response.
- Identified Points of Contention:
- Scope Questions: A primary question is whether the operation of an NFC reader falls within the scope of a claim directed at automatically selecting between wired peripheral connection protocols like USB and PS/2. The analysis may focus on whether the interactions in an NFC transaction can be characterized as "detecting a signaling protocol of a bus" as understood in the context of the patent.
- Technical Questions: What evidence does the complaint provide that an NFC reader performs the specific function of detecting a protocol and then "configuring said integrated circuit to communicate" using a "single set of pins" for multiple different protocols? The complaint does not detail this alleged technical operation.
'071 Patent Infringement Allegations
The complaint asserts direct infringement of claim 15, alleging that the Relevant Instrumentalities perform all steps of the claimed method when used by Defendant for processing NFC payments (Compl. ¶36, ¶38). The complaint does not specify which features of the NFC reader correspond to the claimed method steps of generating control signals, progressing through states based on signals from an "external bus," and driving signals onto that bus.
- Identified Points of Contention:
- Scope Questions: The infringement analysis will raise the question of whether the wireless, radio-frequency communication channel of an NFC system constitutes an "external bus" as that term is used in the patent, which describes interfaces with signals like READ and WRITE.
- Technical Questions: What specific operations within the accused NFC reader constitute "progressing to a next state" based on an "input signal received from said external bus"? The factual connection between the accused NFC functionality and the claim's specific state-machine-like process is not articulated in the complaint.
V. Key Claim Terms for Construction
For the '201 Patent:
- The Term: "signaling protocol"
- Context and Importance: The applicability of claim 14 to the accused NFC readers depends entirely on the scope of this term. Practitioners may focus on this term because the patent’s specification is centered on USB and PS/2 protocols, whereas the accused technology is NFC, a distinct wireless communication standard.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself refers to a "plurality of signaling protocols" without express limitation, and the abstract describes an "apparatus comprising an integrated circuit configured to operate in a plurality of signaling protocols" ('201 Patent, Abstract). This could support a construction covering any distinct set of communication rules.
- Evidence for a Narrower Interpretation: The patent’s title ("Dual Mode USB-PS/2 Device"), background, and embodiments are exclusively focused on the technical problem of supporting both USB and PS/2 protocols for computer peripherals ('201 Patent, Title; col. 1:15-27). This context may support an argument that the term is implicitly limited to wired peripheral interface protocols.
For the '071 Patent:
- The Term: "external bus"
- Context and Importance: Claim 15 requires progressing to a new state based on a signal from an "external bus." The infringement analysis hinges on whether the wireless communication field in an NFC transaction qualifies as an "external bus."
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the invention is for implementing "multiple industry-standard protocols" and "customer-specific interfaces," which could imply a broad and flexible definition of the communication channel ('071 Patent, col. 1:56-59).
- Evidence for a Narrower Interpretation: The patent's figures and detailed descriptions depict conventional, physical multi-line buses with control and data lines, such as a "DATA_BUS" and signals like "RD" and "WR" ('071 Patent, FIG. 2; col. 1:47-54). This may support a narrower construction limited to such physical bus structures, rather than a wireless RF interface.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b) for the ’531 patent only. The allegation is based on Defendant’s knowledge of the patent "since at least the time Defendant received notice," combined with actions such as "advertising and distributing the Relevant Instrumentalities" and providing "instruction materials, training, and services" that allegedly instruct partners, customers, and end users to perform the infringing method (Compl. ¶55-56).
- Willful Infringement: Willfulness is alleged for the ’531 patent, based on knowledge obtained from the filing of the complaint: "Since the filing of this Complaint, Defendant’s infringement has been willful" (Compl. ¶57).
VII. Analyst’s Conclusion: Key Questions for the Case
- A central issue will be one of technological applicability: can claims directed to solving problems in early 2000s wired computer peripheral interfaces (e.g., USB/PS/2 switching, programmable I/O for parallel buses) be construed to cover the fundamentally different technology of modern wireless NFC payment processing?
- The case will likely turn on claim construction: the dispute may be resolved by the court’s interpretation of foundational terms such as "signaling protocol" (’201 Patent) and "external bus" (’071 Patent). The outcome of construction will determine if the patents' scope can bridge the technological gap between the disclosed embodiments and the accused products.
- An initial procedural question will be one of pleading sufficiency: given the absence of claim charts or detailed technical mappings, the court may need to assess whether the complaint’s allegations that the accused devices perform "each and every step" of the asserted methods are sufficient to state a plausible claim for relief.