DCT
3:22-cv-02148
Wiesblatt Licensing LLC v. OnePlus USA Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wiesblatt Licensing LLC (Texas)
- Defendant: OnePlus USA Corp. (Delaware)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: [Wiesblatt Licensing LLC](https://ai-lab.exparte.com/party/wiesblatt-licensing-llc) v. OnePlus USA Corp, 3:22-cv-02148, N.D. Tex., 09/27/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains a regular and established business presence in the Northern District of Texas, including physical locations and employees.
- Core Dispute: Plaintiff alleges that Defendant’s OnePlus 9 smartphone infringes a patent related to circuitry that enables reliable data transfer in electronic devices using a variable power supply voltage.
- Technical Context: The technology addresses power management in modern electronics, where operating voltages are varied to reduce power consumption, creating challenges for maintaining the integrity of data signals.
- Key Procedural History: The complaint notes that the asserted patent was originally assigned to Seiko Epson Corporation. The complaint itself serves as Defendant's initial notice of the patent for the purpose of willfulness allegations.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Earliest Priority Date for '112 Patent |
| 2013-03-12 | U.S. Patent No. 8,396,112 Issues |
| 2022-09-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,396,112 - Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses, issued March 12, 2013
The Invention Explained
- Problem Addressed: The patent describes a problem in electronic systems that vary their power supply voltage to conserve energy. This variation makes it "difficult to consistently convert the multi-value analog signals into multi-value digital signals because the power supply voltage changes" (’112 Patent, col. 1:31-35).
- The Patented Solution: The invention proposes a data transfer circuit where the threshold voltages used for analog-to-digital (A/D) conversion are themselves generated from the variable power supply voltage or a signal proportional to it (’112 Patent, col. 2:1-4). By making the reference voltage for A/D conversion track the main supply voltage, the system can properly interpret the data signals even as the overall voltage levels fluctuate.
- Technical Importance: This approach allows for the combined benefits of two modern design trends: using multi-level analog signaling to increase data transfer rates and using dynamic voltage scaling to reduce power consumption in battery-powered devices (’112 Patent, col. 1:21-28).
Key Claims at a Glance
- The complaint identifies Claim 1 as exemplary (Compl. ¶24).
- Independent Claim 1 requires:
- A variable power supply voltage generator
- A transmitting circuit operative at the variable voltage to generate and transmit a multi-value analog signal
- A receiving circuit operative at the variable voltage to receive the signal and perform A/D conversion
- A threshold voltage generator that generates the A/D conversion threshold voltages from, or proportional to, the variable power supply voltage
III. The Accused Instrumentality
Product Identification
- The complaint names the "OnePlus 9 smartphone" and its associated electronics as the "Accused Instrumentalities" (Compl. ¶19).
Functionality and Market Context
- The complaint alleges that the OnePlus 9 smartphone contains circuitry for transferring data between a host processor and memory, such as LPDDR5 RAM (Compl. ¶24(i)). It further alleges the phone includes a Power Management Integrated Circuit (PMIC) that functions as a variable power supply voltage generator (Compl. ¶24(ii)). Figure 1 presents a screenshot from Defendant's website advertising the "OnePlus 9" smartphone for sale, establishing its presence in commerce (Compl. Fig. 1, p. 5).
IV. Analysis of Infringement Allegations
’112 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a variable power supply voltage generator for generating a variable power supply voltage; | The accused product provides a variable power supply voltage generator (e.g., PMIC) that generates a variable power supply voltage (e.g., VDDQ and/or VDD2) from a minimum to a maximum voltage. | ¶24(ii) | col. 2:56-58 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal... | The accused product provides a transmitting circuit that operates at the variable power supply voltage to generate a multi-value analog signal (e.g., multiple analog waveforms). | ¶24(iii) | col. 2:58-62 |
| a receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal; and | The accused product provides a receiving circuit that operates at the variable power supply voltage, receives the multi-value analog signal, and performs A/D conversion using a Decision Feedback Equalizer (DFE) to regenerate a digital signal. | ¶24(iv) | col. 2:62-65 |
| a threshold voltage generator for generating threshold voltages...the threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage. | The accused product provides a threshold voltage generator that generates threshold voltages (e.g., VrefDQ) for A/D conversion. The complaint alleges these voltages are derived from the variable power supply voltage (VDDQ), for instance, where VrefDQ is approximately 1/2 of VDDQ, causing VrefDQ to vary with VDDQ. | ¶24(v) | col. 2:65 - col. 3:4 |
- Identified Points of Contention:
- Scope Questions: The infringement theory appears to map functions of standard, off-the-shelf components (PMIC, LPDDR5 RAM) to the claim limitations. A point of contention may be whether the claimed "circuitry for transferring data" can be read to cover the interaction of these discrete, general-purpose components, or if it requires a more integrated, purpose-built architecture.
- Technical Questions: The complaint alleges that the threshold voltage (VrefDQ) used by the receiver is "derived from VDDQ" and "is usually 1/2 of VDDQ" (Compl. ¶24(v)). A central evidentiary question will be whether discovery confirms that the accused OnePlus 9 smartphone operates in this specific manner and that this relationship satisfies the claim limitation of being "generated from" or "proportional to" the variable supply voltage.
V. Key Claim Terms for Construction
- The Term: "threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage"
- Context and Importance: This limitation appears to contain the central inventive concept. The outcome of the infringement analysis will likely depend on how this causal and proportional relationship is defined. Practitioners may focus on this term because infringement hinges on proving that the accused device's A/D reference voltage is not fixed or independent, but is functionally tied to the main supply voltage as claimed.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim language "proportional to" could be argued to encompass any functional relationship where the threshold voltage tracks the supply voltage, even if indirectly. The specification notes that an objective is for the reference voltage to "vary with" the supply voltage, suggesting the precise mechanism may be less important than the outcome (’112 Patent, Abstract; Compl. ¶24(v)).
- Evidence for a Narrower Interpretation: A defendant may argue that "generated from" or "proportional to" requires a direct, designed-in electrical connection, such as a dedicated voltage divider circuit as depicted in one of the patent's embodiments (’112 Patent, Fig. 5B). Language in the summary describing the threshold generator as generating voltages "based on the peak voltage of the sine wave clock signal" (’112 Patent, col. 2:28-32), which is itself proportional to the supply voltage, might be used to argue for a specific, intended method of derivation rather than an incidental one.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement to infringe, stating that Defendant has taken active steps such as "advertising an infringing use" (Compl. ¶32). The complaint does not, however, identify specific instructions, user manuals, or marketing materials that allegedly encourage the infringing activity.
- Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after receiving notice of the ’112 Patent via the filing of the complaint (Compl. ¶28). The complaint also makes a broader assertion of willful blindness, alleging Defendant has a "practice of not performing a review of the patent rights of others" (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of technical proof: Can the plaintiff produce evidence from the accused OnePlus 9 smartphone that demonstrates its standard components (e.g., PMIC and LPDDR5 memory interface) actually operate together in the specific manner recited in Claim 1? In particular, the case may turn on evidence showing that the threshold voltage used for A/D conversion in the memory controller is, in fact, "proportional to" the variable power supply voltage from the PMIC.
- A second central issue will be one of claim scope: How will the court construe the phrase "threshold voltage generator"? The dispute will likely focus on whether this term requires a distinct, purpose-built circuit element as described in the patent's embodiments, or if its functional language can be met by the combined, inherent operation of general-purpose components present in a modern smartphone.