InnoMemory LLC v. American Airlines Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: American Airlines, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 2:25-cv-00108, E.D. Tex., 02/01/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Eastern District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s unspecified products infringe a patent related to methods for reducing power consumption in memory devices during refresh operations.
• Technical Context: The technology concerns power-saving techniques for dynamic random-access memory (DRAM) by selectively refreshing only necessary portions of a memory array, a feature of particular importance for battery-powered electronic devices.
• Key Procedural History: The complaint states that Plaintiff is the assignee of the patent-in-suit. The patent itself is a continuation of an earlier application.

Case Timeline

Date	Event
2002-03-04	’960 Patent Priority Date
2003-07-29	’960 Patent Application Filing Date
2006-06-06	U.S. Patent No. 7,057,960 Issues
2025-02-01	Complaint Filed

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

U.S. Patent No. 7,057,960 - "Method and architecture for reducing the power consumption for memory devices in refresh operations"

The Invention Explained

• Problem Addressed: The patent’s background section describes the problem of high power consumption in conventional dynamic random access memories (DRAMs) when in standby mode ('960 Patent, col. 1:27-35). Specifically, even when applications only require a portion of the memory’s data to be retained, conventional systems activate the support circuitry for the entire memory array to perform periodic refresh operations, which wastes power and is detrimental for battery-powered devices like portable telephones ('960 Patent, col. 1:36-56).
• The Patented Solution: The invention proposes a method and architecture to reduce this power consumption by dividing the memory array into multiple sections (e.g., quadrants) and selectively controlling "background operations," such as refresh cycles, on a per-section basis ('960 Patent, Abstract). This allows the power-consuming periphery array circuits for sections not being refreshed to remain inactive, thereby saving standby power ('960 Patent, col. 2:36-48). The architecture uses dedicated control signals (e.g., REF0-REF3 in Fig. 3) to enable or disable the circuitry for each memory section independently.
• Technical Importance: This selective refresh capability was designed to extend the continuous standby time for mobile and battery-powered devices, a critical market demand at the time of the invention ('960 Patent, col. 1:50-56).

Key Claims at a Glance

• The complaint does not identify specific claims asserted, instead incorporating them by reference to an unattached Exhibit 2 (Compl. ¶13-14). For analytical purposes, this report will examine Independent Claim 1, as it is representative of the invention's core method.
• Independent Claim 1 of the ’960 Patent recites the essential elements of:
  • Controlling background operations in each of a plurality of sections of a memory array using one or more control signals.
  • The control signals are generated in response to a programmable address signal.
  • The background operations can be enabled simultaneously in two or more sections, independently of any other section.
  • Presenting the control signals and decoded address signals to the periphery array circuits of the sections.
• The complaint generally alleges infringement of "one or more claims" of the patent (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused product, method, or service (Compl. ¶11).

Functionality and Market Context

The complaint alleges infringement by "Defendant products identified in the charts incorporated into this Count" but does not provide the charts or name the products (Compl. ¶11, ¶13). It further alleges infringement occurs through Defendant's employees internally testing and using these "Exemplary Products" (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits comparing the asserted claims to the "Exemplary Defendant Products" but does not attach these exhibits (Compl. ¶13-14). Therefore, a claim chart summary cannot be constructed. The complaint’s narrative theory of infringement is that the unspecified "Exemplary Defendant Products" practice the technology claimed and satisfy all elements of the asserted claims (Compl. ¶13). No probative visual evidence provided in complaint.

Identified Points of Contention

Given the absence of an identified accused product, the primary points of contention are presently procedural and speculative.

• Procedural Question: The most immediate issue is the identification of the accused instrumentalities. The complaint's failure to name any product or provide its referenced exhibits raises a fundamental question of notice and pleading sufficiency.
• Scope Questions: Once a product is identified (e.g., a server, an avionics system, a consumer device), a potential dispute may arise over whether its memory architecture falls within the scope of the claims. For example, a question may be whether the accused system's power management features constitute "controlling said background operations" as recited in the claims.
• Technical Questions: A central technical question will likely be whether any accused memory system implements a power-saving mode by selectively activating and deactivating "periphery array circuits" for discrete "sections" of a memory array, or if it achieves power reduction through alternative means such as global voltage scaling or clock frequency reduction.

V. Key Claim Terms for Construction

• The Term: "background operations"

• Context and Importance: This term defines the scope of activities covered by the patent. The infringement analysis will depend on whether the power-saving functions in an accused device qualify as the claimed "background operations."

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The patent provides a non-exhaustive list of examples, stating that such operations include "memory cell refresh operations," "parity checking," and "housekeeping operations" ('960 Patent, col. 2:49-56; Claim 4). A party may argue this list is merely illustrative of a broader category of routine, non-user-initiated memory maintenance tasks.
  • Evidence for a Narrower Interpretation: The specification's detailed description focuses almost exclusively on "refresh operations" as the primary embodiment ('960 Patent, col. 3:18-24). A party may argue that the term should be construed as limited to the specific types of memory refresh and parity check cycles described in the patent.

• The Term: "programmable address signal"

• Context and Importance: This term is critical as it defines the mechanism for selecting which memory sections are active. Whether an accused device's control method meets this definition will be a key issue.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: Claim 1 requires control signals to be generated "in response to a programmable address signal." This could be argued to cover any configurable signal, whether set by software or hardware, that dictates which memory portions are to be refreshed or maintained.
  • Evidence for a Narrower Interpretation: The preferred embodiment describes this signal as a "refresh block address" (AR1) that is latched into a dedicated "refresh address register" (138) ('960 Patent, col. 4:56-64, Fig. 3). A party could argue the term is limited to this specific hardware register-based implementation for storing addresses of memory blocks.

VI. Other Allegations

• Indirect Infringement: The complaint does not plead facts to support, or include a count for, indirect infringement.
• Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. The prayer for relief requests that the case be declared "exceptional" under 35 U.S.C. § 285, which pertains to attorney's fees, but does not allege the predicate facts for willfulness, such as pre-suit knowledge of the patent or infringement (Compl. p. 4).

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

1. A threshold procedural and evidentiary question will be the identification of the accused instrumentalities. The complaint’s failure to name any specific product or to include its referenced exhibits creates a significant information deficit that will likely be the first issue addressed in the litigation.
2. Once a product is identified, a central issue will be one of architectural correspondence: does the accused memory subsystem achieve power savings by selectively disabling periphery circuits for discrete, independently controllable memory sections in response to a programmable signal, as claimed, or does it employ a different technical approach to power management?
3. A core question of claim scope will be whether the term "background operations" can be construed to cover modern, dynamic power management techniques that may not have been explicitly contemplated in the patent's 2002-era disclosure, which focuses primarily on scheduled refresh cycles.