DCT

1:22-cv-01331

Network System Tech LLC v. Qualcomm Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:22-cv-01331, W.D. Tex., 08/07/2023
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants have committed acts of infringement in the district and maintain regular and established places of business in Austin, Texas, where business related to the accused System-on-a-Chip (SoC) products is conducted.
  • Core Dispute: Plaintiff alleges that Defendants’ System-on-a-Chip (SoC) products, which incorporate interconnect technology, infringe six patents related to managing data communication and resources in Network-on-Chip (NoC) architectures.
  • Technical Context: The patents relate to Network-on-Chip technology, a fundamental architecture for managing communication between multiple processing cores, memory, and other functional units on a single integrated circuit, which is critical for the performance and efficiency of modern electronics.
  • Key Procedural History: The complaint alleges a detailed history suggesting pre-suit knowledge of the asserted patents by both Arteris and Qualcomm. This history includes pre-2010 technical meetings between the original patent owner (Philips) and Arteris, presentations at industry conferences where both parties discussed the patented technology, and multiple instances where the asserted patents were cited during the prosecution of patent applications later assigned to Arteris and/or Qualcomm. A central event cited is Qualcomm's 2013 acquisition of a substantial part of Arteris's NoC business, engineering team, and technology, during which Qualcomm allegedly conducted due diligence that would have revealed Arteris's knowledge of and potential infringement of the asserted patents.

Case Timeline

Date Event
2002-10-08 Priority Date for ’818, ’449, and ’9893 Patents
2004-03-17 Priority Date for ’052 Patent
2004-05-18 Priority Date for ’800 Patent
2005-04-21 Priority Date for ’2893 Patent
2005-07-12 MPSoC 2005 conference presentation by Arteris founder
2006-08-17 MPSoC 2006 conference presentation by Arteris founder
2008-04-29 U.S. Patent No. 7,366,818 Issues
2008-05-13 U.S. Patent No. 7,373,449 Issues
2009-09-22 U.S. Patent No. 7,594,052 Issues
2010-08-03 U.S. Patent No. 7,769,893 Issues
2011-12-06 U.S. Patent No. 8,072,893 Issues
2011-12-27 U.S. Patent No. 8,086,800 Issues
2013-10-01 Qualcomm's acquisition of certain Arteris technology assets
2023-08-07 First Amended Complaint Filed

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

U.S. Patent No. 7,366,818 - "INTEGRATED CIRCUIT COMPRISING A PLURALITY OF PROCESSING MODULES AND A NETWORK AND METHOD FOR EXCHANGING DATA USING SAME"

  • Issued: April 29, 2008

The Invention Explained

  • Problem Addressed: The patent's background describes that as the number of modules on a chip increases, traditional bus-based communication creates a bottleneck, as it typically allows only one device to send data at a time ('818 Patent, col. 1:28-35).
  • The Patented Solution: The invention proposes a Network-on-Chip (NoC) architecture where modules communicate via a network. A key feature is an "interface means" that includes a "dropping means" for selectively dropping data exchanged between modules. This allows for more flexible and efficient management of data transactions by controlling which data packets can be dropped, rather than guaranteeing delivery for all data, which can be resource-intensive ('818 Patent, Abstract; col. 6:33-43).
  • Technical Importance: This approach provided an alternative to conventional, rigid transaction protocols, enabling more efficient resource utilization in complex SoCs by not requiring full, immediate transaction completion for all cases ('818 Patent, Abstract).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶236).
  • Claim 1 recites an integrated circuit with:
    • A plurality of processing modules on the same chip.
    • A network-on-chip for connecting the modules.
    • The connection supporting transactions with outgoing and return messages.
    • At least one "dropping means" for dropping data exchanged between modules.
    • At least one "interface means" for managing the module-to-network interface, wherein this interface means comprises a dropping means and can control data dropping and transaction completion.
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’818 patent.

U.S. Patent No. 7,373,449 - "APPARATUS AND METHOD FOR COMMUNICATING IN AN INTEGRATED CIRCUIT"

  • Issued: May 13, 2008

The Invention Explained

  • Problem Addressed: The patent addresses the inefficient use of network resources in SoCs that occurs when the connections between modules are not tailored to the specific communication requirements of the tasks being performed ('449 Patent, col. 7:16-23).
  • The Patented Solution: The invention describes a method where a first module requests a connection to a second module by specifying "desired connection properties" to a communication manager. This manager forwards the request to a "resource manager," which then determines if a connection with the desired properties is available. This allows for the independent configuration of communication channels, enabling more efficient allocation of network resources like bandwidth or latency guarantees ('449 Patent, Abstract; col. 7:40-54).
  • Technical Importance: This method introduced a more dynamic and granular approach to resource management in NoCs, allowing connections to be established based on specific performance needs rather than using a one-size-fits-all approach ('449 Patent, col. 7:24-30).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶261).
  • Claim 10 recites a method for exchanging messages in an integrated circuit, comprising the steps of:
    • A first module issuing a request for a connection to a communication manager, with the request comprising desired connection properties.
    • The communication manager forwarding the request to a resource manager.
    • The resource manager determining whether a target connection with the desired properties is available.
    • The resource manager responding with the availability of the target connection.
    • Establishing the target connection based on the available properties.
  • The complaint does not explicitly reserve the right to assert dependent claims for the ’449 Patent.

U.S. Patent No. 7,594,052 - "INTEGRATED CIRCUIT AND METHOD OF COMMUNICATION SERVICE MAPPING"

  • Issued: September 22, 2009
  • Technology Synopsis: The patent describes a method for mapping a requested communication service (identified by properties like a communication thread or address range) to a specific network connection that has a corresponding set of properties. This allows different types of data traffic to be handled by network connections optimized for those traffic types (Compl. ¶104; ’052 Patent, Abstract).
  • Asserted Claims: Independent claim 6 (Compl. ¶286).
  • Accused Features: The complaint alleges infringement by SoCs that offer differentiated intermodular communication services by mapping requested services to connections with corresponding properties (Compl. ¶104).

U.S. Patent No. 7,769,893 - "INTEGRATED CIRCUIT AND METHOD FOR ESTABLISHING TRANSACTIONS"

  • Issued: August 3, 2010
  • Technology Synopsis: The patent discloses a method using an address translation unit within a network interface to map addresses. The unit determines both the location of a target module within the network and a specific location (e.g., a memory address) within that module from a single address provided in a message request (Compl. ¶133; ’893 Patent, Abstract).
  • Asserted Claims: Independent claim 4 (Compl. ¶311).
  • Accused Features: The complaint alleges infringement by SoCs that use an address translation unit for address mapping as part of a network interface (Compl. ¶133).

U.S. Patent No. 8,072,893 - "INTEGRATED CIRCUIT WITH DATA COMMUNICATION NETWORK AND IC DESIGN METHOD"

  • Issued: December 6, 2011
  • Technology Synopsis: This patent covers a method for designing SoCs to improve data communication speed and synchronization. It involves identifying communication channels with excessive data transfer delays and inserting a specific number of data storage elements to introduce a delay that is correlated to the size of the data packet, thereby synchronizing communication (Compl. ¶168; ’2893 Patent, Abstract).
  • Asserted Claims: Independent claim 10 (Compl. ¶336).
  • Accused Features: The complaint alleges infringement by SoCs designed with processes that improve data communication speed and frequency synchronization through the use of packetized data and the introduction of correlated delays (Compl. ¶168).

U.S. Patent No. 8,086,800 - "INTEGRATED CIRCUIT AND METHOD FOR BUFFERING TO OPTIMIZE BURST LENGTH IN NETWORKS ON CHIPS"

  • Issued: December 27, 2011
  • Technology Synopsis: The patent describes a method for optimizing data transfers in a NoC by using "wrappers" at both the master (requesting) and slave (responding) modules. These wrappers buffer data until an optimal amount is collected for transfer over the interconnect, improving efficiency by creating optimized data bursts (Compl. ¶187; ’800 Patent, Abstract).
  • Asserted Claims: Independent claim 10 (Compl. ¶361).
  • Accused Features: The complaint alleges infringement by SoCs that employ data buffering at master and slave modules via network interfaces with wrappers to buffer data into optimal amounts for transfer (Compl. ¶187).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are broadly defined as "Qualcomm Accused Products" and "Arteris Accused Products" (Compl. ¶¶209, 222). The Qualcomm products include Snapdragon processors and other integrated circuits containing Arteris interconnect technology, as well as downstream products incorporating them, such as phones, tablets, and automotive platforms (Compl. ¶209). The Arteris products include its interconnect intellectual property (IP) and IP deployment technology, such as Arteris FlexNoC and Ncore products (Compl. ¶222).

Functionality and Market Context

  • The complaint alleges that Arteris is a provider of interconnect technology for SoCs and that Qualcomm's Snapdragon SoCs incorporate this technology (Compl. ¶¶207, 209). This interconnect technology is described as the "communications backbone" of an SoC, managing how the various processors, memories, and functional units communicate with each other (Compl. ¶206, 73 n.61). The complaint alleges this technology is the "backbone" of Qualcomm's Snapdragon processors, LTE modems, and other key products, highlighting its commercial importance (Compl. ¶26).

IV. Analysis of Infringement Allegations

The complaint references claim-chart exhibits (Exhibits 8-19) that are not provided in the filed document. The infringement theories are summarized below in prose. No probative visual evidence provided in complaint.

U.S. Patent No. 7,366,818 Infringement Allegations

The complaint alleges that the accused SoCs infringe claim 1 because they contain an interface with a "dropping means" for dropping data exchanged between modules to control transaction completion (Compl. ¶44). The specific components of the Qualcomm and Arteris products that allegedly perform this function are detailed in the non-provided Exhibit 8 and Exhibit 14 (Compl. ¶¶236, 248).

U.S. Patent No. 7,373,449 Infringement Allegations

The complaint alleges that the accused SoCs infringe the method of claim 10 by employing a "resource manager" that manages network resources. This manager allegedly determines whether communication channels and connection properties are available in response to a request from a module, thereby establishing a connection based on desired properties (Compl. ¶73). The specific operations of the Qualcomm and Arteris products that allegedly practice these steps are detailed in the non-provided Exhibit 9 and Exhibit 15 (Compl. ¶¶261, 273).

V. Key Claim Terms for Construction

The Term: "dropping means" ('818 Patent, claim 1)

  • Context and Importance: This term appears in a means-plus-function format ("means for dropping data"). Its construction will be central to determining infringement, as the analysis will depend on identifying the corresponding structure in the specification and its equivalents in the accused products. Practitioners may focus on whether the function of "dropping data... [so that] transaction completion can be controlled" is performed by a specific hardware component or a more general software-driven logic within the accused interconnect fabric.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language is functional, suggesting any structure that performs the dropping and control function could satisfy the limitation. The specification describes the dropping means as a general component for managing data in case of buffer overflow or for implementing connections without flow control ('818 Patent, col. 7:39-43, col. 5:35-40).
    • Evidence for a Narrower Interpretation: The specification explicitly identifies a "dropping manager DM" within the network interfaces (ANIP, PNIP) as the structure performing this function ('818 Patent, Fig. 2; col. 6:38-43). A defendant may argue that the scope of the term is limited to this specific disclosed structure and its equivalents.

The Term: "resource manager" ('449 Patent, claim 10)

  • Context and Importance: The infringement allegation hinges on the accused products performing the claimed method steps, including the step of a "resource manager determining whether a target connection...is available." The definition of "resource manager" and what it means to "determine availability" will be critical. Practitioners may focus on whether the accused system's general arbitration or quality-of-service (QoS) logic performs the specific, multi-step request-and-response process recited in the claim.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes the resource manager (RM) and communication manager (CM) as logical entities that manage network resources and connections, without being limited to a single hardware implementation ('449 Patent, col. 7:35-39). The function is described broadly as "managing the resources of the network N" (Id.).
    • Evidence for a Narrower Interpretation: The detailed description outlines a specific sequence: a module requests a connection from a communication manager, which forwards the request to the resource manager, which then checks for availability and responds ('449 Patent, col. 7:40-54). A defendant may argue that infringement requires practicing this specific protocol, not just performing general resource allocation.

VI. Other Allegations

Indirect Infringement

  • For Qualcomm, the complaint alleges inducement by providing products, data sheets, and technical documentation that encourage and instruct customers and end-users on how to use the accused SoCs in an infringing manner (Compl. ¶¶239, 264). For Arteris, the complaint alleges inducement by providing its interconnect IP and technology to Qualcomm and other customers, knowing it will be incorporated into infringing SoCs (Compl. ¶¶226, 251). Contributory infringement is alleged on the basis that the accused products are especially made for practicing the inventions and are not staple articles of commerce (Compl. ¶¶241, 253).

Willful Infringement

  • The complaint alleges willful infringement against both Qualcomm and Arteris based on extensive pre-suit knowledge. The allegations assert Arteris knew of the patents from direct interactions with Philips (the original assignee) and from their citation during its own patent prosecution (Compl. ¶¶58-59, 88-89). It is alleged that Qualcomm obtained this knowledge no later than its 2013 due diligence and acquisition of Arteris's NoC business, and also through citations of the asserted patents in the prosecution of its own patents (Compl. ¶¶69-70, 100-101).

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

  • A central factual question will be one of pre-suit knowledge and intent: Can the Plaintiff prove, through discovery, the detailed narrative of knowledge transfer from Philips to Arteris, and subsequently from Arteris to Qualcomm during the 2013 acquisition, to support its claims for willful infringement?
  • A key technical question will be one of functional mapping: As the complaint does not provide claim charts, a core issue will be whether the alleged functions, such as the "dropping means" of the ’818 patent and the "resource manager" of the ’449 patent, can be mapped onto the actual operation of the Arteris interconnect fabric within Qualcomm’s SoCs, or if there are fundamental mismatches in their technical operation and control logic.
  • A core issue of claim scope will arise during claim construction: Will terms like "dropping means" and "resource manager" be construed broadly based on their function, or will they be limited to the specific embodiments and protocols described in the patent specifications, potentially narrowing the scope of infringement?