DCT

1:22-cv-01161

TurboCode LLC v. HTC Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-01161, W.D. Tex., 11/09/2022
  • Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation, and under 28 U.S.C. § 1391(c), venue in a patent action against such a defendant is proper in any judicial district.
  • Core Dispute: Plaintiff alleges that Defendant’s mobile communication devices equipped with 3G and/or 4G/LTE capabilities infringe a patent related to high-speed, power-efficient decoder architectures for error correction.
  • Technical Context: The technology concerns turbo codes, a type of forward error correction used in 3G and 4G wireless communication standards to ensure the integrity of data transmitted over noisy channels.
  • Key Procedural History: The complaint alleges that Plaintiff provided Defendant with formal notice of infringement on October 18, 2021, more than a year prior to filing suit. The asserted patent underwent an ex parte reexamination, resulting in the cancellation of two claims and the amendment of the remaining claims, including the one asserted in this case. The complaint also states that enforcement of the patent against other third parties is ongoing.

Case Timeline

Date Event
1999-05-26 '742 Patent Priority Date
2004-11-02 '742 Patent Issue Date
2009-02-10 '742 Patent Reexamination Certificate Issue Date
2016-01-01 Start of alleged infringement period for certain products
2021-10-18 Plaintiff provided formal notice of infringement to HTC
2022-07-10 Release date noted for HTC Desire 22 Pro
2022-11-09 Complaint Filing Date

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

U.S. Patent No. 6,813,742 - High speed turbo codes decoder for 3G using pipelined SISO log-map decoders architecture, issued November 2, 2004

The Invention Explained

  • Problem Addressed: The patent's background section explains that as 3G wireless technology emerged, there was a need for decoders that could handle high data rates with low power consumption and low cost ('742 Patent, col. 2:23-28). Prior art decoders based on the Maximum a Posteriori (MAP) algorithm were effective but computationally complex, requiring numerous multiplications that were slow and expensive to implement in the semiconductor (ASIC) devices used in mobile phones ('742 Patent, col. 1:50-61).
  • The Patented Solution: The invention proposes a decoder architecture that uses two pipelined Soft-In/Soft-Out (SISO) Log-MAP decoders operating in a feedback loop ('742 Patent, FIG. 4). This "Log-MAP" approach simplifies the hardware by performing calculations in the logarithmic domain, primarily using simpler binary adder circuits instead of complex multipliers ('742 Patent, col. 2:56-59). The pipelined structure allows the two decoders to work simultaneously, with one processing data while the other receives feedback, enabling a continuous output and therefore higher data throughput ('742 Patent, col. 2:44-50).
  • Technical Importance: The described architecture aimed to make powerful turbo code error correction practical for mass-market 3G mobile devices by improving decoding speed while reducing the power consumption and implementation cost associated with prior methods ('742 Patent, col. 2:32-37).

Key Claims at a Glance

  • The complaint asserts independent claim 6, as amended by an ex parte reexamination certificate ('742 Patent, Reexam. Cert., col. 2:14-49; Compl. ¶24).
  • The essential elements of method claim 6 include:
    • Providing an input buffer with at least three shift registers to receive and generate shifted input signals.
    • Providing first and second "soft decision decoders" serially coupled in a "circular circuit," where each processes soft decision data from the preceding decoder, and where the decoders also receive the shifted input signals from the input buffer.
    • Providing a memory module coupled to each decoder's output, where the output from the second decoder's memory is fed back to the first decoder's input.
    • Processing "systematic information data and extrinsic information data" using a MAP probability algorithm or a logarithmic approximation thereof.
    • Generating a soft decision based on the MAP algorithm.
    • Weighing and storing the soft decision information into the memory module.
    • Performing iterative decoding for a predetermined number of times, propagating the output in the circular circuit.
  • The complaint reserves the right to assert dependent claims (Compl. ¶24).

III. The Accused Instrumentality

  • Product Identification: The complaint identifies the "Exemplary Accused Products" as the HTC U12+, HTC Desire 21, and HTC 5G Hub, as well as the HTC Desire 22 Pro (Compl. ¶¶16, 19).
  • Functionality and Market Context: The Accused Products are telecommunications devices (smartphones and a mobile hub) that feature 3G and/or 4G/LTE connectivity (Compl. ¶16). The complaint alleges that these products, in order to comply with the governing 3GPP cellular standards, must "process data utilizing a sliding window having a predetermined block size" to manage memory and power consumption efficiently (Compl. ¶20). The complaint includes a screenshot of the HTC 5G Hub's technical specifications, which lists its "Qualcomm® Snapdragon™ 855" processor and "4G LTE (US)" capabilities (Compl. ¶17). A second screenshot provides network specifications for the HTC Desire 22 Pro, confirming its support for HSPA and LTE-A technologies (Compl. ¶19). The infringement theory links the functionality required by these standards to the method claimed in the ’742 Patent.

IV. Analysis of Infringement Allegations

The complaint references a claim-chart exhibit (Exhibit 3) detailing the infringement of claim 6, but the exhibit was not included with the complaint document provided for analysis. The infringement theory is therefore summarized based on the narrative allegations in the complaint.

The complaint's infringement theory posits that the Accused Products directly infringe the method of claim 6 by virtue of their compliance with 3G and/or 4G/LTE standards (Compl. ¶24). It alleges that these standards require a decoding process that uses a "sliding window," which Plaintiff contends is the commercial embodiment of the patented method (Compl. ¶20). The complaint further supports this by alleging that processors used in the Accused Products, such as those from MediaTek, are known to implement "sliding window turbo decoding algorithms" that practice the claimed invention (Compl. ¶21). The complaint asserts that through this standards-compliant operation, all steps of claim 6 are performed by the Accused Products (Compl. ¶29).

  • Identified Points of Contention:
    • Technical Question: A primary technical question is whether the functionality mandated by the 3G/4G/LTE standards, or the operation of processors like those from MediaTek or Qualcomm, performs every step of the method as recited in amended claim 6. The complaint does not map specific sections of the 3GPP standards to individual claim limitations.
    • Scope Question: A central issue for claim construction may be whether the term "soft decision decoders serially coupled in a circular circuit" can be read to cover the architecture of a modern, highly integrated System-on-a-Chip (SoC). The court may need to decide if this claim language is limited to the distinct two-decoder hardware layout depicted in the patent or if it can encompass a more complex, software-driven process within a single processor.
    • Evidentiary Question: What specific evidence does the complaint provide that the Accused Products, which include devices with Qualcomm processors as shown in a provided visual, practice the claimed method, especially when the complaint’s narrative specifically calls out decoding algorithms used by MediaTek? (Compl. ¶¶17, 21).

V. Key Claim Terms for Construction

  • The Term: "soft decision decoders serially coupled in a circular circuit"

  • Context and Importance: This phrase defines the core architecture of the claimed method. The viability of the infringement case hinges on whether the decoding process within the Accused Products' modern SoCs can be characterized as this specific arrangement. Practitioners may focus on this term because it appears to describe a structural configuration, which may or may not map cleanly onto the functional blocks of a complex, multi-purpose processor.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party arguing for a broader scope may point to language describing the system functionally as a "feedback loop" and performing "re-iterative decoding of data back-and-forth between the two Log-MAP decoders" ('742 Patent, col. 4:11, col. 2:59-62). This could suggest the term covers any process with two iterative decoding stages that exchange information.
    • Evidence for a Narrower Interpretation: A party arguing for a narrower scope could cite Figure 4, which shows two distinct decoder blocks (42, 44) connected via separate memory modules (43, 45) in a specific feedback path. This evidence may support a construction limiting the term to a physical or logical architecture that mirrors this explicit two-component structure.

  • The Term: "processing systematic information data and extrinsic information data"

  • Context and Importance: This limitation describes the type of data being manipulated in the decoding process, a fundamental aspect of how turbo codes operate. Infringement requires showing that the Accused Products process data that can be categorized in this specific way.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: A party could argue the terms "systematic" and "extrinsic" have well-understood meanings in the art of error-correction coding and that any standard-compliant turbo decoder would necessarily process these data types, making the term broadly applicable.
    • Evidence for a Narrower Interpretation: The patent details how these data types are generated and used within its specific Log-MAP algorithm, including the combination of "soft-values" from an input buffer and outputs from the other decoder ('742 Patent, col. 4:34-50). A party could argue the term is implicitly limited by the specific algorithmic context provided in the patent's embodiments.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement, asserting that HTC encourages infringement by providing instructions and specifications that direct customers to use the Accused Products in their intended, infringing manner (Compl. ¶25). Contributory infringement is also alleged on the basis that the products are especially made or adapted for use in an infringing manner and are not staple articles of commerce (Compl. ¶26).
  • Willful Infringement: Willfulness is alleged based on HTC's knowledge of the ’742 Patent "at least since the provision of notice of infringement" on October 18, 2021 (Compl. ¶¶22, 25). Plaintiff seeks enhanced damages for this alleged willful conduct (Compl. ¶(c), p. 9).

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

  • A core issue will be one of technical mapping: does compliance with the broad 3G/4G/LTE wireless standards, as the complaint alleges, inherently require the performance of every specific step of the method recited in amended claim 6? The case will likely turn on whether the patent claims a general, standard-essential function or a more specific, optional implementation of a decoder.
  • A key question of architectural scope will be central to both claim construction and infringement: can the phrase "soft decision decoders serially coupled in a circular circuit," which originates from a patent with a 1999 priority date, be construed to read on the functionality of a modern, highly integrated processor, or is there a fundamental mismatch between the claimed architecture and the accused technology?
  • An important evidentiary question will be whether Plaintiff can demonstrate that the accused functionality is present across all named devices, particularly given the complaint's reliance on the known algorithms of one chip supplier (MediaTek) while providing visual evidence of an accused product using a different supplier's chip (Qualcomm).