DCT

4:25-cv-00915

Near Field Electronics LLC v. Vans Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-00915, E.D. Tex., 08/20/2025
  • Venue Allegations: Venue is alleged based on Defendant having a regular and established place of business in Frisco, Texas, located within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s Near Field Communication (NFC)-capable credit card readers infringe five patents related to integrated circuit architecture for managing I/O protocols, bus interfaces, and power consumption.
  • Technical Context: The patents address foundational technologies for integrated circuits that enable peripheral devices to flexibly communicate with host systems and manage power, a critical domain for devices like modern point-of-sale terminals.
  • Key Procedural History: The complaint asserts infringement of four patents that expired between 2021 and 2023, limiting the damages period for those patents from August 20, 2019, to their respective expiration dates. One patent remains active, for which Plaintiff alleges ongoing direct infringement, induced infringement, and willful infringement based on knowledge from the filing of the suit.

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
2005-05-05 ’531 Patent Priority Date
2005-10-25 ’350 Patent Issued
2006-02-07 ’727 Patent Issued
2008-05-13 ’531 Patent Issued
2019-08-20 Alleged Infringement Start Date 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
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 peripheral devices supporting multiple communication protocols, such as both USB and PS/2, conventionally required separate sets of external components, leading to higher costs, larger circuit boards, and more complex firmware (Compl. ¶11; ’201 Patent, col. 1:40-51).
  • The Patented Solution: The invention provides a single integrated circuit that automatically detects the signaling protocol (e.g., USB or PS/2) of a connected bus and configures itself to operate accordingly using a single, shared set of input/output pins. This "single chip solution" is intended to eliminate the need for redundant external components and simplify the design of dual-mode peripheral devices (Compl. ¶12; ’201 Patent, col. 1:52-65). The specification details a circuit that can distinguish between the protocols and control a driver circuit appropriately (’201 Patent, col. 3:54-4:3).
  • Technical Importance: This approach enabled manufacturers to produce more compact, cost-effective peripherals that could seamlessly connect to both modern (USB) and legacy (PS/2) systems, maximizing connectivity and marketability (’201 Patent, col. 1:24-26).

Key Claims at a Glance

  • The complaint asserts independent method claim 14 (Compl. ¶31).
  • Essential elements of claim 14 include:
    • Detecting a signaling protocol of a bus connected to an integrated circuit.
    • Configuring the integrated circuit to communicate in the detected protocol.
    • Operating over the connected bus through a single set of pins for each of the selected protocols.
  • The complaint reserves the right to amend its infringement contentions (Compl. ¶32).

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 states that conventional bus interface designs were often protocol-specific and rigid. Alternatives, such as user-programmable interfaces with fixed wait-states, lacked the flexibility and sophistication needed to implement complex or evolving communication standards (Compl. ¶16; ’071 Patent, col. 1:15-48).
  • The Patented Solution: The invention discloses a programmable, real-time I/O processor, referred to as a General-Purpose Interface (GPIF), capable of generating interface-specific waveforms and responding to external events on a clock-cycle-by-clock-cycle basis. This processor uses a limited instruction set to allow a single hardware architecture to implement numerous different bus protocols, replacing inflexible hardware-based designs (Compl. ¶15; ’071 Patent, col. 2:53-67). Figure 6 shows the processor's architecture, including a finite state machine and logic function block that control its operation (’071 Patent, Fig. 6).
  • Technical Importance: This programmable architecture provided a flexible and high-speed solution for interfacing with multiple bus protocols, allowing a single chip design to adapt to changing standards and customer-specific requirements, thereby reducing development risk and time-to-market (Compl. ¶16; ’071 Patent, col. 6:4-9).

Key Claims at a Glance

  • The complaint asserts independent method claim 15 (Compl. ¶36).
  • Essential elements of claim 15 include:
    • Generating a plurality of first 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 an external bus.
    • Updating the current state to the next state.
  • The complaint reserves the right to amend its infringement contentions (Compl. ¶37).

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 conventional USB interface controllers having "hard-coded" endpoint configurations, which required writing and maintaining different Hardware Description Language (HDL) code for each controller version (Compl. ¶20; ’350 Patent, col. 1:19-28). The patented solution is a configurable bus interface controller that uses a single HDL-based "configuration package" to flexibly generate the necessary configuration circuitry, such as registers or logic, for different USB endpoint setups without requiring separate HDL code for each endpoint (Compl. ¶19, ¶21; ’350 Patent, col. 2:38-53).
  • Asserted Claims: Independent claim 10 (Compl. ¶41).
  • Accused Features: The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End infringe this patent (Compl. ¶41).

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 notes that conventional power supplies for USB interfaces provided a constant voltage (e.g., 3.3V) with no low-power mode, leading to unnecessary power consumption during idle states (Compl. ¶25; ’727 Patent, col. 1:16-20). The invention provides a dual-mode power supply architecture that operates in a standard mode and a power-down (standby) mode. In standby mode, the main supply is turned off, and a low-power programmable resistor is used to maintain the required bus pullup function, significantly reducing current consumption (Compl. ¶24; ’727 Patent, col. 2:30-41).
  • Asserted Claims: Independent claim 18 (Compl. ¶46).
  • Accused Features: The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End infringe this patent (Compl. ¶46).

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 presence, absence, or frequency of signals within an electronic device by monitoring the "through current" flowing in a circuit (Compl. ¶28; ’531 Patent, Abstract). The technique involves applying a signal to the gates of connected transistors and detecting whether a through current flows. Based on this detection, the apparatus can determine an operational state and execute a power-saving action, such as stopping or reducing the power supply (Compl. ¶29; ’531 Patent, col. 2:48-65).
  • Asserted Claims: Independent claim 2 (Compl. ¶51).
  • Accused Features: The complaint alleges that credit card readers equipped with an NXP PN512 NFC Front-End infringe this 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 components with similar NFC functionality (Compl. ¶31, ¶36, ¶41, ¶46, ¶51).

Functionality and Market Context

  • These devices are used by Defendant Vans in its "regular course of its business operations for processing NFC payment transactions" (Compl. ¶33, ¶38). The complaint alleges that when these readers are put into use to process payments, the internal NXP PN512 integrated circuit performs the methods claimed in the patents-in-suit (Compl. ¶33). The allegations position the accused technology as integral to Vans's retail payment infrastructure.
  • No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim chart exhibits detailing its infringement theories (Compl. ¶32, ¶37). The narrative allegations suggest the following infringement theories:

  • ’201 Patent Infringement Allegations: The complaint alleges that when Vans uses the accused credit card readers, the devices perform the method of claim 14. The theory appears to be that the NXP PN512 chip inside the reader detects the type of NFC communication protocol being used for a transaction and configures its internal circuitry to communicate using that protocol, all through a common set of physical connection points (Compl. ¶33).
  • ’071 Patent Infringement Allegations: The complaint alleges that the accused readers perform the method of claim 15 during NFC payment processing. This suggests the NXP PN512 chip operates as the claimed "processor," generating control signals, transitioning between internal states based on incoming NFC data, driving signals to an external bus, and updating its state to manage the communication sequence (Compl. ¶38).
  • Identified Points of Contention:
    • Scope Questions: A primary issue may be whether the term "signaling protocol of a connected bus," as used in the ’201 Patent, can be construed to cover wireless NFC protocols. The patent's specification is written entirely in the context of wired peripheral standards (USB and PS/2), which may support a narrower construction.
    • Technical Questions: For the ’071 Patent, a key question will be whether the accused NXP PN512 chip, an NFC front-end, functions as the claimed "processor" that executes a program by progressing through states. The analysis may turn on whether the accused chip's operation is more akin to a fixed-function state machine than the programmable, instruction-based processor described in the patent.

V. Key Claim Terms for Construction

  • The Term: "signaling protocol of a connected bus" (from ’201 Patent, claim 14)

    • Context and Importance: This term's construction is central because the accused technology is NFC, a wireless protocol, whereas the patent's disclosure is grounded in wired protocols (USB/PS/2). The case may depend on whether "bus" can encompass a wireless communication link and whether "signaling protocol" can extend beyond the patent's examples.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Claim 14 itself refers to a "plurality of signaling protocols" without expressly limiting them to USB or PS/2, which may support an argument that the claim language is not confined to the disclosed embodiments (’201 Patent, col. 6:15-16).
      • Evidence for a Narrower Interpretation: The patent is titled "Dual Mode USB-PS/2 Device," and the background, summary, and detailed description sections exclusively discuss the problems and solutions related to supporting USB and PS/2 protocols, which may suggest the claims should be interpreted in light of that specific context (’201 Patent, col. 1:15-51).

  • The Term: "processor" (from ’071 Patent, claim 15)

    • Context and Importance: Infringement of claim 15 requires that the accused device contain a "processor" that generates signals and transitions between states. Practitioners may focus on this term because the accused NXP PN512 is a specialized NFC transceiver, and the dispute will likely concern whether its operation meets the patent's definition of a "processor."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent describes the invention in general terms as a "logic processor" and an "I/O processor," which could be argued to cover any logic circuit that performs the claimed state-based functions (’071 Patent, col. 6:41, 10:55-56).
      • Evidence for a Narrower Interpretation: The specification describes the processor as implementing a "user programmable instruction set" and being controlled by instructions in a "control store" or "look up table." This may support an argument that the term "processor" requires an architecture capable of executing stored instructions, not merely a hard-wired logic circuit (’071 Patent, col. 7:42-46).

VI. Other Allegations

  • Indirect Infringement: For the ’531 Patent, the complaint alleges induced infringement. The factual basis is that Defendant allegedly aids and abets infringement by its partners, customers, and end users through "advertising and distributing the Accused Instrumentalities and providing instruction materials, training, and services regarding the Accused Instrumentalities" (Compl. ¶56).
  • Willful Infringement: The complaint alleges willful infringement of the ’531 Patent. The allegation is based on post-suit knowledge, stating that Defendant was made aware of the patent and its infringement "at least as early as the filing of this Complaint" and that infringement "since the filing of this Complaint" has been willful (Compl. ¶54, ¶57).

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

  • A core issue will be one of definitional scope: can claims and terms rooted in the technical context of wired computer peripheral interfaces (e.g., "bus," "processor," "USB/PS/2") be construed broadly enough to read on the distinct technology of wireless Near-Field Communication (NFC) as implemented in the accused payment systems?
  • A key evidentiary question will be one of technical correspondence: does the actual operation of the accused NXP PN512 integrated circuit—a specialized NFC transceiver—perform the specific, multi-step methods of protocol detection, state-based processing, and power management as recited in the asserted claims, or is there a fundamental mismatch in the underlying technology?
  • A central damages question will concern the relevance of expired patents: with four of the five patents-in-suit having expired years before the complaint was filed, the case will likely focus on the availability and calculation of pre-suit damages for a closed and aging infringement period, raising potential questions of laches and the staleness of evidence.