DCT

4:25-cv-01428

Near Field Electronics LLC v. Leslies Poolmart Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:25-cv-01428, E.D. Tex., 12/19/2025
  • Venue Allegations: Venue is based on Defendant having a regular and established place of business in Frisco, Texas, within the Eastern District of Texas, and regularly conducting business in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s Near Field Communication (NFC)-capable credit card readers infringe five patents related to integrated circuit architecture, bus interface protocols, and power management.
  • Technical Context: The patents address foundational semiconductor technologies for enabling integrated circuits to flexibly handle multiple communication protocols, manage data flow, and conserve power.
  • Key Procedural History: The complaint alleges infringement of four patents that expired between November 2021 and August 2023. For these patents, Plaintiff seeks damages only for a specific period beginning December 19, 2019, and ending on each patent’s respective expiration date. One asserted patent remains active.

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 Issue Date
2004-05-25 ’071 Patent Issue Date
2005-01-11 ’531 Patent Priority Date
2005-10-25 ’350 Patent Issue Date
2006-02-07 ’727 Patent Issue Date
2008-05-13 ’531 Patent Issue Date
2019-12-19 Alleged Infringement Period Begins
2021-11-21 ’071 Patent Expiration Date
2022-01-31 ’201 Patent Expiration Date
2022-04-14 ’727 Patent Expiration Date
2023-08-12 ’350 Patent Expiration Date
2025-12-19 Complaint Filing Date

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 section describes that peripheral devices supporting multiple signaling protocols, such as Universal Serial Bus (USB) and Personal System/2 (PS/2), conventionally required additional external components, dedicated I/O pins, and complex firmware, which increased cost, board space, and complexity (Compl. ¶11; ’201 Patent, col. 1:40-50).
  • The Patented Solution: The invention is a single integrated circuit capable of automatically detecting the signaling protocol of a connected bus (e.g., USB or PS/2) and configuring itself to operate using that protocol over a single, shared set of I/O pins (Compl. ¶¶ 10, 12; ’201 Patent, col. 2:51-56). This "single chip solution" is intended to eliminate the need for extra components and simplify the device's firmware (’201 Patent, col. 1:50-2:8).
  • Technical Importance: This approach aimed to reduce the cost and physical footprint of multi-protocol peripheral devices like computer mice, making them more versatile and economical to manufacture (Compl. ¶12).

Key Claims at a Glance

  • The complaint asserts independent method claim 14 (Compl. ¶31).
  • Claim 14 requires the essential steps of:
    • (A) detecting a signaling protocol of a bus connected to an integrated circuit that operates in a plurality of signaling protocols; and
    • (B) configuring the integrated circuit to communicate using the detected protocol, where the different protocols operate over a single set of pins.
  • The complaint reserves the right to assert additional claims (Compl. ¶31).

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

The Invention Explained

  • Problem Addressed: Conventional approaches for implementing bus interfaces were often protocol-specific, which limited the flexibility and marketability of products as bus standards evolved. User-programmable interfaces were also limited and could be difficult to program (Compl. ¶16; ’071 Patent, col. 1:16-48).
  • The Patented Solution: The patent describes a flexible, real-time input/output (I/O) processor, referred to as a general-purpose interface (GPIF), that can implement various bus protocols. This is achieved using a processor with a limited instruction set that can generate interface-specific waveforms and change control outputs on a clock-cycle basis, allowing it to function as a master device controlling an external bus (Compl. ¶¶ 15-16; ’071 Patent, col. 6:4-16).
  • Technical Importance: The invention provided a programmable, high-speed solution to replace rigid, protocol-specific hardware, enabling a single chip design to interface with multiple or evolving bus standards (Compl. ¶16).

Key Claims at a Glance

  • The complaint asserts independent method claim 15 (Compl. ¶36).
  • Claim 15 requires the essential steps of:
    • (A) generating control signals based on a processor's current state;
    • (B) progressing to a next state based on the current state, an internal control signal, and an input signal from an external bus;
    • (C) driving an output control signal onto the external bus; and
    • (D) updating the processor's current state to the next state.
  • The complaint reserves the right to assert additional claims (Compl. ¶36).

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

  • Technology Synopsis: The patent addresses the rigidity of hard-coded USB endpoint configurations in interface controllers, which required writing and maintaining distinct Hardware Description Language (HDL) code for each variation (Compl. ¶20). The invention provides a configurable bus interface controller that uses an HDL-based configuration package to flexibly generate configuration circuitry for various USB endpoints, eliminating the need for separate HDL code for each endpoint (Compl. ¶¶ 19, 21).
  • Asserted Claims: At least independent claim 10 (Compl. ¶41).
  • Accused Features: The accused NFC-capable credit card readers are alleged to infringe by embodying the configurable bus interface controller (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 conventional power supplies that provided a constant voltage with no low-power mode, leading to unnecessary power consumption during idle states (Compl. ¶25). The patented solution is a power supply architecture with two modes: a standard mode and a power-down (standby) mode. In standby mode, the main supply is turned off, and a low-power programmable pullup resistor maintains the necessary bus signaling function, thereby reducing current consumption (Compl. ¶¶ 24-25).
  • Asserted Claims: At least independent claim 18 (Compl. ¶46).
  • Accused Features: The accused NFC-capable credit card readers are alleged to utilize the claimed power supply architecture (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 discloses methods and devices for detecting the operational state of an electronic apparatus by monitoring "through current" in a circuit. A signal is applied to the gates of connected transistors, and the presence, absence, or frequency of that signal is determined based on whether a through current flows (Compl. ¶28). This detection enables the apparatus to reduce power consumption by stopping or reducing the power supply when a target is not operating (Compl. ¶29).
  • Asserted Claims: At least independent claim 2 (Compl. ¶51).
  • Accused Features: The accused NFC-capable credit card readers are alleged to employ the claimed signal detection and power control methods (Compl. ¶51).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "a credit card reader device equipped with an NXP PN512 NFC Front-End" and any other NFC-capable credit card readers with similar functionality sold or used by Defendant (Compl. ¶¶ 31, 36, 41, 46, 51).

Functionality and Market Context

  • The complaint alleges these devices are used in the regular course of business for processing NFC payment transactions (Compl. ¶¶ 33, 38). The core accused functionality is centered on the NXP PN512 component, which enables NFC communication for payments. These devices are allegedly marketed and used by Defendant's partners, clients, and end users throughout the United States (Compl. ¶53).

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 that by making, using, and selling the accused credit card readers, and by putting them into use for NFC payment transactions, Defendant directly infringes the asserted claims (Compl. ¶¶ 33, 38).

For the ’201 Patent, the infringement theory appears to be that the NXP PN512 chip in the accused reader detects the communication protocol of a proximate NFC-enabled card or device and configures itself to communicate via that protocol, thereby performing the method of claim 14 (Compl. ¶¶ 31, 33).

For the ’071 Patent, the theory suggests the NXP PN512 chip functions as a real-time I/O processor that executes the state-based method of claim 15 to manage the NFC communication handshake (Compl. ¶¶ 36, 38).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Scope Questions: A central question for the ’201 Patent is whether the term "bus," as used in a patent focused on wired peripheral connections like USB and PS/2, can be construed to read on a wireless NFC interface. Similarly for the ’071 Patent, a question is whether the operation of an NFC front-end falls within the scope of a "method for providing an interface to an external bus" as described in the patent.
    • Technical Questions: What evidence does the complaint provide that the accused NXP PN512 chip performs the specific step of "detecting a signaling protocol" from a "plurality of signaling protocols" as required by claim 14 of the ’201 Patent? Further, what evidence supports the allegation that the chip's operation maps to the specific state-machine-like progression recited in claim 15 of the ’071 Patent?

V. Key Claim Terms for Construction

  • ’201 Patent, Claim 14

    • The Term: "detecting a signaling protocol of a bus"
    • Context and Importance: This term is critical because the infringement theory requires applying a claim from the context of wired computer peripherals (USB/PS/2) to wireless NFC technology. The construction of "bus" and the act of "detecting a signaling protocol" will determine if this technological leap is supportable.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to USB or PS/2, referring more generally to "a plurality of signaling protocols." Plaintiff may argue this term should be given its plain and ordinary meaning, covering any process of identifying a communication standard from a connected device, wired or wireless.
      • Evidence for a Narrower Interpretation: The specification exclusively discusses USB and PS/2 protocols, and the method of detection described involves monitoring specific electrical states on data lines, such as a "long low state" (’201 Patent, col. 2:57-62). Defendant may argue that the specification defines the invention in the narrow context of distinguishing between these specific wired protocols.

  • ’071 Patent, Claim 15

    • The Term: "progressing to a next state based on said current state, at least one internal control signal ... and an input signal received from said external bus"
    • Context and Importance: This limitation defines the core logic of the claimed state-machine method. The infringement analysis will turn on whether the accused NFC communication process can be characterized as this specific, multi-input state transition.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: Plaintiff may argue that any logical sequence in a communication protocol, where a device transitions from one operational step to another based on inputs, meets this definition.
      • Evidence for a Narrower Interpretation: The specification describes a specific processor architecture with a two-instruction set ("branch on signal" and "wait N clocks") that processes state vectors and control signals (’071 Patent, col. 8:16-55). Defendant may argue this detailed implementation narrows the claim's scope to a specific type of programmable I/O processor, not a generic communication handshake.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement of the ’531 Patent, asserting Defendant had knowledge from the filing of the complaint and induced infringement by providing customers with infringing devices along with "instruction materials, training, and services" regarding their use (Compl. ¶¶ 55-56).
  • Willful Infringement: Willfulness is alleged for the ’531 Patent based on Defendant's continued infringement after receiving notice of the patent via the complaint (Compl. ¶57).

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 wired computer peripheral interfaces (USB/PS/2) and general-purpose bus controllers be construed to cover the distinct technology of wireless Near Field Communication (NFC)? The outcome may depend on whether the claim language is interpreted broadly or is limited by the specific problems and solutions described in the patents' specifications.
  • A key evidentiary question will be one of operational mapping: beyond identifying the presence of an NXP PN512 chip, what specific, non-conclusory factual evidence will Plaintiff present to demonstrate that the accused devices perform the precise, multi-step methods recited in the asserted claims, particularly the protocol detection and state-based processing steps?
  • A central issue for four of the five patents will be damages for expired patents: since liability is asserted only for a closed period ending years before the suit was filed, the case will require a detailed historical analysis of sales and use of the accused products within those specific timeframes.