DCT

5:22-cv-00074

MIMO Research LLC v. Murata Mfg Co Ltd

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:22-cv-00074, E.D. Tex., 06/15/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant Murata is incorporated in Texas, maintains a regular and established place of business in the district (Carrollton, TX), transacts business in the district, and has committed the alleged acts of infringement within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s wireless communication modules, which support technologies such as Wi-Fi, Bluetooth, and Ultra-Wideband (UWB), infringe four U.S. patents related to Multiple-Input Multiple-Output (MIMO) systems, UWB sensor networks, and multichannel communication techniques.
  • Technical Context: The dispute centers on foundational technologies for modern wireless communications, including MIMO for enhancing signal reliability and UWB for high-precision location and data transfer, which are critical in a wide array of consumer and industrial electronics.
  • Key Procedural History: The complaint does not mention any prior litigation or post-grant proceedings involving the patents-in-suit, but notes that the plaintiff's patent portfolio has been widely cited by numerous major technology companies, which may be presented to suggest the portfolio's significance.

Case Timeline

Date Event
2003-07-07 Priority Date for ’057 Patent and ’382 Patent
2004-04-09 Priority Date for ’854 Patent
2004-05-03 Priority Date for ’470 Patent
2006-02-21 Issue Date for U.S. Patent No. 7,002,470
2006-04-17 Murata acquires Plano, TX-based SyChip Inc.
2006-08-15 Issue Date for U.S. Patent No. 7,091,854
2007-12-04 Issue Date for U.S. Patent No. 7,305,057
2008-10-07 Issue Date for U.S. Patent No. 7,433,382
2012-04-16 Murata acquires Dallas, TX-based RF Monolithics, Inc.
2016-02-12 Murata announces expansion of its Carrollton, TX facility
2022-03-01 Murata announces purchase of Resonant, Inc., a Texas-based designer
2022-06-15 Complaint Filed

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

U.S. Patent No. 7,091,854 - "Multiple-Input Multiple-Output Wireless Sensor Networks Communications," Issued Aug. 15, 2006

The Invention Explained

  • Problem Addressed: The patent describes the challenge of reliable communication in wireless sensor networks, where signals are subject to multipath propagation (reflection, diffraction, etc.) that causes fading and various forms of interference, such as co-channel and intersymbol interference (’854 Patent, col. 2:40-53; Compl. ¶20).
  • The Patented Solution: The invention proposes a system architecture for wireless sensor nodes that utilizes Multiple-Input Multiple-Output (MIMO) technology. By equipping both sensor nodes and a central basestation with multiple antennas, the system can exploit spatial diversity to improve signal power, mitigate fading, and reduce interference, thereby enhancing the capacity, coverage, and quality of the sensor network communication (’854 Patent, Abstract; Fig. 1; Compl. ¶17).
  • Technical Importance: Applying MIMO techniques to power-constrained sensor networks provided a path toward more robust and reliable data collection in complex physical environments where line-of-sight communication is not guaranteed (Compl. ¶17).

Key Claims at a Glance

  • The complaint asserts at least independent claim 15 (Compl. ¶60).
  • The essential elements of independent claim 15 include:
    • A sensor array unit coupled to an analog-to-digital converter unit;
    • The analog-to-digital converter unit coupled to a signal processing and data computing unit;
    • The signal processing and data computing unit coupled to a multiple-input multiple-output space-time transceiver connected to N antennas (N > 1);
    • A memory bank coupled to the ADC unit, processing unit, and transceiver;
    • A power generator coupled to a power unit; and
    • The power unit coupled to the sensor array unit, ADC unit, processing unit, and transceiver.

U.S. Patent No. 7,002,470 - "Wireless UWB-Based Space-Time Sensor Networks Communications," Issued Feb. 21, 2006

The Invention Explained

  • Problem Addressed: The patent addresses the need for efficient network management when a large number of sensors are deployed, particularly when some sensors are not in a direct line-of-sight with a receiver and the network topology may change frequently ('470 Patent, col. 1:39-44; Compl. ¶25-26).
  • The Patented Solution: The invention discloses a method for organizing a wireless Ultra-Wideband (UWB) sensor network by grouping nodes into clusters. Designated "sensor node forward stations" act as cluster heads, advertising their presence to other nodes. Sensor nodes then join a cluster based on signal strength and transmit their data to the cluster head, which can aggregate data before forwarding it to a central basestation. This hierarchical structure is designed to make communication more efficient and robust ('470 Patent, Fig. 9; col. 4:35-67; Compl. ¶27).
  • Technical Importance: This clustering architecture improves the scalability, energy efficiency, and organization of large-scale, densely deployed sensor networks, which is critical for their practical implementation (Compl. ¶25).

Key Claims at a Glance

  • The complaint asserts at least independent claim 19 (Compl. ¶83).
  • The essential elements of independent claim 19, an article of manufacture claim, require a medium storing instructions that cause a processor to:
    • Start a clustering approach for wireless UWB-based space-time sensor nodes;
    • Select each of sensor node forward stations as a cluster central-head; and
    • Classify the wireless UWB-based space-time sensor nodes into each of the cluster groups.

Multi-Patent Capsule: U.S. Patent No. 7,305,057

  • Patent Identification: U.S. Patent No. 7305057, "Multichannel Filter-Based Handheld Ultra Wideband Communications," Issued Dec. 4, 2007 (Compl. ¶29).
  • Technology Synopsis: The patent addresses interference between UWB devices and other wireless services, such as WLAN 802.11a, that operate in overlapping frequency bands (Compl. ¶31, ¶37). It proposes a multichannel UWB transceiver that uses a digital filter system to shape the transmitted signal, enabling the device to avoid specific frequencies and coexist with other technologies, thereby permitting more efficient use of the radio spectrum ('057 Patent, Abstract; Compl. ¶31, ¶33).
  • Asserted Claims: At least independent claim 1 (Compl. ¶114).
  • Accused Features: Murata's UWB modules (e.g., Type 2DK, 2BP, 2AB) and evaluation kits are accused of implementing a multichannel filter-based UWB transmitter that utilizes multiple channels for precise UWB localization (Compl. ¶92, ¶99).

Multi-Patent Capsule: U.S. Patent No. 7,433,382

  • Patent Identification: U.S. Patent No. 7433382, "Spread Spectrum Based Multichannel Modulation for Ultra Wideband Communications," Issued Oct. 7, 2008 (Compl. ¶35).
  • Technology Synopsis: Like the ’057 patent, this patent is directed to solving interference problems between UWB and WLAN 802.11a devices (Compl. ¶37). The solution involves a spread spectrum multichannel modulation transceiver that uses techniques such as pseudorandom noise mapping and digital filtering to improve interference rejection capabilities, allowing for robust operation in crowded radio environments ('382 Patent, Abstract; Compl. ¶39-41).
  • Asserted Claims: At least independent claim 1 (Compl. ¶140).
  • Accused Features: The same UWB modules and evaluation kits are accused of comprising a spread spectrum based multichannel UWB transceiver that utilizes techniques like BPM-BPSK modulation and spreading sequences (Compl. ¶123, ¶128-131).

III. The Accused Instrumentality

Product Identification

  • For the ’854 patent, the accused instrumentalities are Murata Wi-Fi Modules, including models LBEE5XV1XA, LBEE5XV1YM, LBEE5U91CQ, LBEE5XV1VA, LBEH5UL1CX, and LBEE5ZZ1XL (the "Murata '854 Products") (Compl. ¶45).
  • For the ’470 patent, the accused instrumentalities are Murata Type 2AB UWB Modules and the Murata LBUA5QJ2AB-EVB Evaluation Kit (the "Murata '470 Products") (Compl. ¶69).

Functionality and Market Context

  • The Murata '854 Products are described as Wi-Fi and Bluetooth combo modules that are "Compliant with IEEE802.11a/b/g/n/ac, MU-MIMO" (Compl. ¶47, p. 13 visual). The complaint alleges these modules function as MIMO wireless sensor and transceiver systems, asserting that their ability to perform Dynamic Frequency Selection ("DFS") to detect radar pulses constitutes a sensing function (Compl. ¶49).
  • The Murata '470 Products are UWB modules containing a Qorvo DW3110/3120 chipset, which enables "Precision real time location systems (RTLS)" (Compl. ¶72, ¶76, p. 25 visual). The complaint alleges that this RTLS functionality, which supports high densities of "tags" tracked by "anchors," constitutes the claimed clustering of UWB sensor nodes (Compl. ¶76-77).

IV. Analysis of Infringement Allegations

'854 Patent Infringement Allegations

Claim Element (from Independent Claim 15) Alleged Infringing Functionality Complaint Citation Patent Citation
a sensor array unit coupled to an analog-to-digital converter unit; The products include a MIMO sensor node with MIMO antennas forming a "sensor array unit" that receives Wi-Fi and Bluetooth signals and is coupled to an analog-to-digital converter. A block diagram shows antennas connected to a transceiver module (Compl. p. 14 visual). ¶48, ¶51 col. 5:2-4
the analog-to-digital converter unit coupled to a signal processing and data computing unit; The products contain integrated circuits, such as the CYW88359 chipset, with analog-to-digital converters (ADCs) coupled to central processing units that perform signal and data computing (Compl. p. 16 visual). ¶51-52 col. 5:10-14
the signal processing and data computing unit coupled to a multiple-input multiple-output space-time transceiver that is connected to N antennas... The products' central processing unit is coupled to a MIMO transceiver connected to two antennas, as confirmed by datasheets identifying the products as "2x2 MU-MIMO" compliant (Compl. p. 17 visual). ¶50, ¶53 col. 6:33-36
a memory bank coupled to the analog-to-digital converter unit, the signal processing and data computing unit, and the multiple-input...transceiver; The products include memory that is coupled to the ADC, processing unit, and transceiver components. ¶54 col. 5:32-36
a power generator coupled to a power unit; and The products include a power regulator (power management integrated circuit or PMIC) connected to a power unit (supply voltages like VBAT) (Compl. p. 18 visual). ¶55 col. 5:24-26
the power unit coupled to the sensor array unit, the analog-to-digital converter unit, the signal processing...and the multiple-input...transceiver. The products' power unit is connected to and supplies power for the operation of the antennas (sensor array), ADC, processing unit, and transceiver. ¶56 col. 5:20-24
  • Identified Points of Contention:
    • Scope Questions: A central dispute may arise over the definition of "sensor array unit". The defense may argue that this term, in the patent's context of environmental sensing, does not read on a radio transceiver that "senses" communication signals or radar pulses for DFS, as alleged by the plaintiff (Compl. ¶48-49). The plaintiff's case relies on a broader interpretation of "sensor."
    • Technical Questions: The complaint alleges the standard power architecture of the accused modules (a PMIC and voltage supply) meets the claimed "power generator coupled to a power unit" structure. The court may need to determine if this common architecture maps onto the specific two-part structure recited in the claim or if there is a technical distinction.

'470 Patent Infringement Allegations

Claim Element (from Independent Claim 19) Alleged Infringing Functionality Complaint Citation Patent Citation
start a clustering approach for wireless UWB-based space-time sensor nodes; The products contain a DW3110/DW3120 UWB chipset and are marketed for use in "Precision real time location systems (RTLS)," which the complaint alleges is a form of clustering for UWB nodes (Compl. p. 25 visual). ¶76 col. 4:35-36
select each of sensor node forward stations as a cluster central-head; and The products allegedly enable certain nodes to function as a "gateway/anchor node" that controls other nodes, which the complaint equates to the claimed "cluster central-head" (Compl. p. 26 visual). ¶77-78 col. 4:50-51
classify said wireless UWB-based space-time sensor nodes into each of cluster groups. The products allegedly include instructions for classifying nodes into groups, as shown in a network architecture diagram where "cluster nodes" are grouped together and communicate with "sink nodes" (Compl. p. 27 visual). ¶78, ¶82 col. 4:56-59
  • Identified Points of Contention:
    • Scope Questions: The infringement theory hinges on equating a commercial Real-Time Location System (RTLS) with the patent's specific "clustering approach". The defense may argue that RTLS, with its "anchors" and "tags," is a distinct and well-known technology that does not practice the claimed method of selecting "sensor node forward stations" as "cluster central-heads".
    • Technical Questions: Claim 19 is directed to a "medium for storing programmable instructions." The plaintiff's case will depend on demonstrating that Murata provides software or firmware (e.g., the "DecaRange RTLS ARM Source Code" referenced in Compl. ¶77) with its hardware that, when executed, performs all steps of the claimed method. The precise functionality of this code will be a key factual question.

V. Key Claim Terms for Construction

’854 Patent: "sensor array unit" (Claim 15)

  • Context and Importance: This term's construction is critical because the infringement case depends on whether a MIMO radio antenna system, which receives communication signals and detects radar for DFS, qualifies as a "sensor array unit." A narrow construction limited to environmental sensors could be fatal to the plaintiff's claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself does not specify the type of sensor. The specification states the "multimode sensor" can be one of "electronic, optical, chemical, nuclear fusion, gas/liquid, or any combination" (’854 Patent, col. 5:44-50). Plaintiff may argue that an antenna system that detects "electronic" fields falls within this definition.
    • Evidence for a Narrower Interpretation: The patent's background and summary repeatedly frame the invention in the context of collecting data about physical phenomena, such as detecting "biological, chemical and/or radiological weapons" or monitoring "domestic infrastructure systems" (’854 Patent, col. 1:59-64). This context may support an interpretation limited to sensors that detect environmental conditions rather than communication signals.

’470 Patent: "clustering approach" (Claim 19)

  • Context and Importance: Practitioners may focus on this term because the infringement allegation equates the accused RTLS functionality with the claimed "clustering approach." The outcome of the case could depend on whether these are deemed synonymous or if the patent's method is more specific.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim uses the general term "clustering approach," and the patent's abstract describes the high-level goal of organizing "spatially distributed UWB-based sensor nodes into efficient, robust, reliable, and secure wireless sensor communications," a purpose that could be argued to encompass RTLS.
    • Evidence for a Narrower Interpretation: The specification provides a detailed flowchart (Fig. 9) illustrating a specific multi-step process for clustering, including nodes "inform[ing] sensor forward stations" (step 960) and sending data to them (step 970). A court could construe "clustering approach" as being limited to methods that incorporate the specific steps and architecture detailed in the specification.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Murata induces infringement of all four patents by providing products along with documentation, data sheets, user manuals, and training materials that allegedly instruct and encourage customers and end-users to operate the products in an infringing manner (Compl. ¶63, ¶86, ¶117, ¶143).
  • Willful Infringement: Willfulness is alleged for all four patents. The complaint bases its allegation of knowledge primarily on Murata's awareness of the patents after the lawsuit was filed, stating Murata "has had knowledge of the [asserted] patent since at least service of this Complaint" (Compl. ¶62, ¶85, ¶116, ¶142).

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

  • A core issue will be one of definitional scope: can the term "sensor array unit" from the '854 patent, which is described in the context of networks sensing environmental data, be construed to cover a standard MIMO Wi-Fi module that "senses" radio frequency signals for purposes of communication and regulatory compliance (DFS)?
  • A key question of technical and legal equivalence will arise for the '470 patent: does a commercial Real-Time Location System (RTLS) with "anchors" and "tags" practice the specific "clustering approach" with "sensor node forward stations" as detailed in the patent, or are these fundamentally different technological and structural concepts?
  • An evidentiary challenge for the plaintiff will be to prove that the accused UWB modules for the '057 and '382 patents, which are shown to operate on specific channels, do so by implementing the specific patented methods of multichannel filtering and spread spectrum modulation, as opposed to other, non-infringing techniques for channelized communication.