DCT

4:25-cv-00914

Near Field Electronics LLC v. Trader Joes Co

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00914, E.D. Tex., 08/20/2025
  • Venue Allegations: Plaintiff alleges venue is proper because Defendants operate as a single enterprise, have committed acts of infringement in the district, and maintain a regular and established place of business within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that credit card reader devices used by Defendant, which incorporate specific Near-Field Communication (NFC) components, infringe five patents related to semiconductor interface technology, power management, and signal detection.
  • Technical Context: The patents-in-suit relate to foundational technologies for integrated circuits that manage communication protocols, interface with external devices, and control power consumption, which are critical for modern point-of-sale systems.
  • Key Procedural History: The complaint notes that four of the five asserted patents have expired. For these patents, Plaintiff asserts liability only for a damages period beginning August 20, 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
2005-05-05 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 Period Begins
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" (issued Feb. 10, 2004)

The Invention Explained

  • Problem Addressed: The patent describes that, at the time of the invention, peripheral devices like computer mice that needed to support multiple communication protocols (e.g., USB and PS/2) required additional external components, complex firmware, and dedicated input/output (I/O) pins on the micro-controller, which increased cost and circuit board space while compromising performance (Compl. ¶12; ’201 Patent, col. 1:40-50).
  • The Patented Solution: The invention is a single integrated circuit that can operate in multiple signaling protocols and automatically select the correct protocol based on the connected bus ('201 Patent, Abstract). This is achieved by using a single set of shared I/O pins for both protocols and an interrupt detection circuit that determines the active protocol, thereby eliminating the need for extra external components and simplifying the device design (Compl. ¶13; ’201 Patent, col. 1:50-2:8, col. 3:5-21).
  • Technical Importance: This single-chip solution offered a more integrated and cost-effective way for peripheral manufacturers to ensure compatibility with different generations of computer hardware without sacrificing performance or board space (Compl. ¶13).

Key Claims at a Glance

  • The complaint asserts independent claim 14 (Compl. ¶32).
  • Essential elements of claim 14, a method claim, include:
    • 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 protocols in response to the detected protocol, where each of the selected protocols operates over the connected bus through a single set of pins.
  • The complaint reserves the right to amend its infringement contentions (Compl. ¶33).

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: Conventional methods for implementing bus interfaces were often protocol-specific and rigid, limiting a product's marketability and relevance as standards evolved. User-programmable interfaces lacked the flexibility and sophistication needed for complex signaling (Compl. ¶17; ’071 Patent, col. 1:16-33).
  • The Patented Solution: The invention provides a flexible, real-time I/O processor architecture that can implement various bus interface protocols ('071 Patent, Abstract). This is accomplished with a processor having a limited, specialized instruction set (e.g., "branch on signal," "wait N clocks") capable of generating interface-specific waveforms and responding to external events on a clock-cycle basis, replacing rigid hardware with a programmable solution (Compl. ¶16; ’071 Patent, col. 2:51-67, col. 4:66-5:11).
  • Technical Importance: This programmable general-purpose interface (GPIF) allowed a single processor architecture to efficiently implement multiple industry-standard protocols, enabling higher-speed operation and greater adaptability compared to traditional designs (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts independent claim 15 (Compl. ¶37).
  • Essential elements of claim 15, a method claim, include:
    • generating a plurality of first control signals in response to a current state of a processor;
    • progressing to a next state based on the current state, an internal control signal, 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.
  • The complaint reserves the right to amend its infringement contentions (Compl. ¶38).

U.S. Patent No. 6,959,350 - "Configurable USB Interface With Virtual Register Architecture" (issued Oct. 25, 2005)

  • Technology Synopsis: The patent addresses the problem of hard-coded endpoint configurations in interface controllers, which required writing and maintaining different Hardware Description Language (HDL) code for each version of the controller (Compl. ¶21). The invention provides a configurable bus interface controller that uses an HDL-based configuration package to define parameters (e.g., endpoint number, type) and generate the necessary configuration circuitry, allowing for flexible configuration without separate HDL code for each endpoint (Compl. ¶20, ¶22).
  • Asserted Claims: The complaint asserts independent claim 10 (Compl. ¶42).
  • Accused Features: Defendants' use of credit card readers equipped with the NXP PN512 NFC Front-End is alleged to infringe (Compl. ¶42).

U.S. Patent No. 6,996,727 - "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor" (issued Feb. 7, 2006)

  • Technology Synopsis: The patent addresses the lack of low-power modes in conventional 3.3V power supplies for bus interfaces (Compl. ¶26). The invention discloses a power supply architecture that operates in a standard mode with a regulated voltage and a power-down (standby) mode with significantly reduced current consumption, using a programmable pullup resistor to maintain the necessary function during standby (Compl. ¶25).
  • Asserted Claims: The complaint asserts independent claim 18 (Compl. ¶47).
  • Accused Features: Defendants' use of credit card readers equipped with the NXP PN512 NFC Front-End is alleged to infringe (Compl. ¶47).

U.S. Patent No. 7,373,531 - "Signal Detection Method, Frequency Detection Method, Power Consumption Control Method..." (issued May 13, 2008)

  • Technology Synopsis: The patent is directed to methods and devices for detecting signals and power consumption status in an electronic circuit by monitoring through-current (Compl. ¶29). The invention applies a signal to the gates of connected transistors and detects the signal's presence, absence, or state based on whether a through-current flows, enabling power reduction by stopping or reducing the power supply when a certain operation state is detected (Compl. ¶29-30).
  • Asserted Claims: The complaint asserts independent claim 2 (Compl. ¶52).
  • Accused Features: Defendants' use of credit card readers equipped with the NXP PN512 NFC Front-End is alleged to infringe (Compl. ¶52).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are credit card reader devices equipped with an NXP PN512 NFC Front-End or other NFC front-end components with similar functionality (Compl. ¶32, ¶37).

Functionality and Market Context

  • The complaint alleges that Defendants use these NFC-capable credit card readers in the regular course of their business operations for processing NFC payment transactions (Compl. ¶34, ¶39). The complaint does not provide further technical detail on the operation of the accused devices beyond identifying the core accused component. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary claim charts attached as exhibits but does not include the exhibits themselves. The infringement theory is therefore summarized from the narrative allegations.

’201 Patent Infringement Allegations

The complaint alleges that when Defendants put the Accused Instrumentalities into use for processing NFC payments, the devices perform each step of the method claimed in claim 14 of the ’201 Patent (Compl. ¶34). This suggests the infringement theory centers on the device's ability to operate according to different communication protocols and automatically select the appropriate one when interacting with an NFC-enabled card or device, allegedly using a "single set of pins" as required by the claim (Compl. ¶32, ¶34; ’201 Patent, col. 6:19-21). The complaint asserts that this use constitutes direct infringement (Compl. ¶34).

’071 Patent Infringement Allegations

Similarly, the complaint alleges that the use of the Accused Instrumentalities in Defendants' business operations constitutes direct infringement of claim 15 of the ’071 Patent (Compl. ¶39). The narrative suggests that the internal processor of the NXP PN512 component operates according to a method that mirrors the claimed steps: generating control signals, progressing between states based on inputs, and updating its state to manage the bus interface during a transaction (Compl. ¶37, ¶39; ’071 Patent, col. 14:48-61).

Identified Points of Contention:

  • Scope Questions: A central question for the ’201 Patent may be whether the hardware architecture of the NXP PN512 chip, which handles NFC protocols, constitutes "a single set of pins" for a "plurality of signaling protocols" as understood in the context of the patent's USB and PS/2 examples.
  • Technical Questions: For the ’071 Patent, a key factual dispute may involve whether the accused processor's operation is properly characterized as executing a program of instructions that cause it to "progress to a next state" and "update" its current state in the specific manner required by the claim, or if it operates on a different architectural principle.

V. Key Claim Terms for Construction

The Term: "automatically selecting" (from ’201 Patent, claim 14)

  • Context and Importance: This term is central to the invention, which distinguishes itself from prior art requiring complex firmware or dedicated pins for protocol selection. The infringement analysis will depend on whether the accused device's protocol detection and configuration process meets the claimed level of automation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification describes the selection as occurring "without user input" (e.g., ’201 Patent, col. 2:52-53), which may support a broad definition covering any hardware- or firmware-driven selection process that does not require manual intervention.
    • Evidence for a Narrower Interpretation: The detailed description focuses on a specific mechanism involving detecting a "long low state" on data lines to trigger an interrupt and select a mode (e.g., ’201 Patent, col. 2:56-62). This could support a narrower construction limited to this or a structurally similar detection method.

The Term: "progressing to a next state based on said current state" (from ’071 Patent, claim 15)

  • Context and Importance: The ’071 Patent claims a method of operation for a programmable processor. Whether the accused device infringes will depend on if its internal logic can be characterized as a state-based machine that "progresses" and "updates" its state as claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The summary of the invention describes the method broadly as "progressing to a next state based on a current state and one or more input signals in a single cycle of the clock signal" ('071 Patent, col. 2:50-52). This language may support an interpretation covering any clocked logic circuit that changes state based on current conditions and inputs.
    • Evidence for a Narrower Interpretation: The detailed description ties the state progression to the execution of specific instructions like "branch on signal" stored in a memory, which defines the transitions ('071 Patent, col. 7:19-27, Fig. 11a). This may support a narrower interpretation requiring an architecture that executes a program from a control store to manage state transitions.

VI. Other Allegations

  • Indirect Infringement: For the ’531 patent, the complaint alleges induced infringement, stating that since receiving notice via the complaint, Defendants have induced partners, clients, customers, and end users to infringe by advertising, distributing, and providing instruction materials for the Accused Instrumentalities (Compl. ¶56-57).
  • Willful Infringement: The complaint alleges that infringement of the ’531 patent has been willful since the filing of the complaint, which allegedly provided Defendants with actual knowledge of the patent and their infringement (Compl. ¶58). No willfulness is alleged for the other four patents.

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

  1. A core issue will be one of technical mapping: Given that the patents-in-suit were developed in the context of computer peripheral interfaces like USB/PS/2, can the specific methods and architectures they claim be shown to read on the distinct technical operations of a modern NFC front-end component used for payment processing?
  2. A second key question will be one of damages scope: As four of the five asserted patents expired before the complaint was filed, the dispute will likely focus heavily on establishing the value of the accused technology during the defined pre-expiration damages period (2019-2023), which may require complex economic analysis of an established market.
  3. For the sole unexpired patent (’531 Patent), a central issue will be knowledge and intent: Can the Plaintiff develop sufficient evidence to support its claims of post-suit indirect and willful infringement, which require showing that Defendants acted with specific intent or willful blindness after being notified of the patent by the complaint itself?