DCT

4:25-cv-00912

Near Field Electronics LLC v. Pep Boys Manny Moe & Jack LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00912, E.D. Tex., 08/20/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant has a regular and established place of business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s use of credit card readers equipped with specific Near Field Communication (NFC) components infringes five patents related to integrated circuit architecture, bus protocol management, and power consumption control.
  • Technical Context: The patents-in-suit relate to foundational technologies for creating flexible, efficient, and low-power integrated circuits capable of managing communications with external devices.
  • Key Procedural History: The complaint alleges infringement of five patents, four of which expired between 2021 and 2023. Consequently, for those four patents, the infringement claims are limited to a historical damages period ending on their respective expiration dates.

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
2019-08-20 Alleged Infringement Start Date for all Patents
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
2025-08-20 Complaint Filed

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

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

The Invention Explained

  • Problem Addressed: The patent’s background describes the challenge of designing peripheral devices (e.g., a computer mouse) to support multiple communication protocols, such as Universal Serial Bus (USB) and Personal System 2 (PS/2). Conventional approaches required distinct sets of external components for each protocol, which increased cost, circuit board space, and firmware complexity (’201 Patent, col. 1:29-50; Compl. ¶11).
  • The Patented Solution: The invention is an integrated circuit that can automatically detect which protocol a connected bus is using (e.g., USB or PS/2) and configure itself to communicate using that protocol over a single, shared set of input/output pins. This single-chip solution eliminates the need for redundant external components ('201 Patent, Abstract; col. 2:51-62; Compl. ¶12).
  • Technical Importance: The invention simplified the design of peripheral devices, reducing their cost and physical size while maximizing connectivity options for end-users.

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶31).
  • Claim 14 is a method for automatically selecting a signaling protocol, comprising the essential elements of:
    • Detecting a signaling protocol of a bus connected to an integrated circuit.
    • Configuring the integrated circuit to communicate in the detected protocol.
    • Operating in the selected protocol over the connected bus through a single set of pins.
  • The complaint does not explicitly reserve the right to assert dependent claims.

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

The Invention Explained

  • Problem Addressed: The patent addresses the inflexibility of conventional bus interfaces. Protocol-specific interfaces were rigid and quickly became obsolete as standards evolved, while user-programmable interfaces were often too simplistic to handle complex signaling requirements (’071 Patent, col. 1:16-43; Compl. ¶16).
  • The Patented Solution: The invention provides a flexible, real-time input/output (I/O) processor architecture. This "general-purpose interface" (GPIF) uses a specialized processor with a limited instruction set to generate interface-specific waveforms and respond to external events in real-time, allowing it to act as a master device managing communication with various external logic circuits ('071 Patent, Abstract; col. 3:42-51; Compl. ¶15).
  • Technical Importance: This programmable solution allowed a single processor architecture to implement multiple, evolving, or custom bus protocols at high speed without requiring new hardware designs for each standard.

Key Claims at a Glance

  • The complaint asserts independent claim 15 (Compl. ¶36).
  • Claim 15 is a method for providing an interface to an external bus, comprising the essential elements of:
    • Generating control signals in response to a processor's current state.
    • Progressing to a next state based on the current state, an internal control signal, and an external input signal.
    • Driving an output control signal onto the external bus.
    • Updating the processor's current state to the next state.
  • The complaint does not explicitly reserve the right to assert dependent claims.

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

Technology Synopsis

The patent addresses the inefficiency of hard-coded USB endpoint configurations in interface controllers, which required designers to write and maintain different Hardware Description Language (HDL) code for each version (Compl. ¶20). The invention provides a configurable bus interface controller that uses an HDL-based "configuration package" to flexibly generate the necessary configuration circuitry, allowing the controller to be configured for different endpoints without rewriting the base HDL code (Compl. ¶19, 21).

Asserted Claims

Independent claim 10 is asserted (Compl. ¶41).

Accused Features

The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End or similar components infringe the patent (Compl. ¶41).

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

Technology Synopsis

The patent addresses the power consumption of conventional USB interfaces, which typically operated with a constant voltage supply and lacked a low-power mode (Compl. ¶25). The invention discloses a dual-mode power supply architecture for a bus interface that includes a standard operating mode and a power-down (standby) mode, where a low-power programmable resistor maintains the necessary bus pullup function, thereby reducing current consumption during idle states (Compl. ¶24).

Asserted Claims

Independent claim 18 is asserted (Compl. ¶46).

Accused Features

The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End or similar components infringe the patent (Compl. ¶46).

U.S. Patent No. 7,373,531 - “Signal Detection Method, Frequency Detection Method, Power Consumption Control Method, Signal Detecting Device, Frequency Detecting Device, Power Control Consumption Device and Electronic Apparatus”

Technology Synopsis

The patent is directed to methods and devices for detecting signals and power status in an electronic device by monitoring the "through current" flowing in a circuit (Compl. ¶28). By applying a signal to the gates of connected transistors, the device can detect the presence, frequency, or state of the signal based on whether a current flows, which in turn enables the device to reduce power consumption by stopping or reducing the power supply (Compl. ¶28-29).

Asserted Claims

Independent claim 2 is asserted (Compl. ¶51).

Accused Features

The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End or similar components infringe the patent (Compl. ¶51).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "credit card reader device[s] equipped with an NXP PN512 NFC Front-End" or other NFC components with similar functionality (Compl. ¶31, 36, 41, 46, 51).

Functionality and Market Context

The complaint alleges that Defendant Pep Boys uses these devices in the regular course of its business for processing NFC payment transactions (Compl. ¶33). The core technical function identified is the ability to read data from NFC-enabled payment devices to conduct commercial transactions. The complaint does not provide further technical detail on the operation of the accused readers or their market positioning beyond their use in Defendant's business. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that are not provided. The infringement theories are summarized below in prose.

’201 Patent Infringement Allegations

The complaint alleges that when the Accused Instrumentalities are used to process NFC payments, they perform the method of claim 14 (Compl. ¶33). The narrative infringement theory is that the integrated circuit within the device (the NXP PN512 chip) detects the signaling protocol of the NFC payment device (the "bus") and automatically configures itself to communicate using that protocol through a single set of pins.

Identified Points of Contention

  • Scope Questions: A central question may be whether the patent’s claims, which are described in the context of wired PC peripheral protocols like USB and PS/2, can be construed to cover the distinct technological environment of wireless, short-range NFC payment protocols.
  • Technical Questions: The analysis may focus on whether the accused device's protocol detection and configuration is "automatic" in the manner contemplated by the patent, or if it relies on a different mechanism, such as host-level software commands that fall outside the claim scope.

’071 Patent Infringement Allegations

The complaint alleges that the Accused Instrumentalities, when used for NFC payments, perform each step of the method claimed in claim 15 (Compl. ¶38). The infringement theory posits that the NXP PN512 chip functions as the claimed real-time I/O "processor." In this role, it allegedly generates control signals based on its internal state, progresses to new states based on inputs from the NFC device, drives output signals to manage the communication, and updates its internal state accordingly.

Identified Points of Contention

  • Scope Questions: A dispute may arise over whether the NXP PN512 chip, an NFC front-end, qualifies as the claimed "processor" that executes a program to generate waveforms, or if it is a fundamentally different type of circuit, such as a hard-coded application-specific integrated circuit (ASIC).
  • Technical Questions: The case may require evidence demonstrating that the accused chip actually performs the specific sequence of steps in claim 15—generating signals, progressing state, driving outputs, and updating state—in the manner required by the claim language.

V. Key Claim Terms for Construction

For the ’201 Patent

The Term

"automatically selects" (from claim 14)

Context and Importance

This term is central to the invention's contribution over prior art that required manual or complex configuration. The infringement analysis will depend on whether the accused NFC device's method of establishing communication meets the definition of "automatically selects."

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification suggests the automatic selection occurs "without user input" ('201 Patent, col. 2:52-53), which may support a broad construction covering any machine-initiated protocol selection.
  • Evidence for a Narrower Interpretation: The patent describes a specific embodiment where selection is triggered by detecting a "long low state" on both data lines ('201 Patent, col. 2:56-62). A defendant may argue the term should be limited to this or a similar hardware-level detection mechanism, as opposed to a software-driven process.

For the ’071 Patent

The Term

"processor" (from claim 15)

Context and Importance

Claim 15 recites a method with steps tied to the "current state of a processor." The applicability of the claim to the accused device hinges on whether the NXP PN512 chip is considered a "processor" within the meaning of the patent.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification describes the invention as a "specialized input-output processor with two instructions" ('071 Patent, col. 5:6-8) and a "processor-based solution" ('071 Patent, col. 2:58-59), suggesting a functional definition that could encompass various logic circuits that execute instructions or sequences.
  • Evidence for a Narrower Interpretation: A defendant could argue that "processor" is implicitly limited to the specific architectures disclosed, such as the finite state machine and lookup table shown in Figure 6 ('071 Patent, Fig. 6). This could support an argument that a device with a different internal architecture is not a "processor" as claimed.

VI. Other Allegations

Indirect Infringement

The complaint alleges induced infringement of the '531 patent under 35 U.S.C. § 271(b) (Compl. ¶55). The allegations state that Defendant actively aids and abets infringement by providing the accused devices along with "instruction materials, training, and services" to its partners, clients, and customers, with specific intent or willful blindness that their use will constitute direct infringement (Compl. ¶56).

Willful Infringement

The complaint alleges willful infringement of the '531 patent (Compl. ¶57). The basis for this allegation is knowledge of the patent and the alleged infringement "at least as early as the filing of this Complaint" (Compl. ¶54, 57).

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

  • A core issue will be one of technological scope: can claims originating from and described in the context of wired computer peripheral interfaces (USB/PS/2) be construed to cover the operations of a modern, wireless Near Field Communication (NFC) payment system, or does the difference in technological field place the accused products outside the patent's reach?
  • A second key question will be one of operational mapping: what evidence will be presented to show that the accused NXP PN512 chip, a complex integrated circuit, actually performs the specific, ordered method steps recited in the asserted claims, particularly those related to a "processor" updating its "state" ('071 patent) and "automatically selecting" a protocol ('201 patent)?
  • Finally, with four of the five asserted patents having expired prior to the suit's filing, a central issue will be the quantification of past damages. The analysis will likely focus on establishing a reasonable royalty for a limited, pre-expiration time window for technologies that are now part of the public domain.