Sovereign Peak Ventures LLC v. NXP Semiconductors NV

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Sovereign Peak Ventures, LLC (Texas)
  • Defendant: NXP USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Connor Lee & Shumaker PLLC
• Case Identification: Sovereign Peak Ventures, LLC v. NXP USA, Inc., 1:25-cv-01574, W.D. Tex., 12/12/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant NXP USA, Inc. maintains its U.S. Corporate Headquarters, a regular and established place of business, within the Western District of Texas and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s semiconductor products, specifically its Wi-Fi Systems-on-Chip (SoCs) and wireless charging components, infringe six U.S. patents related to Wi-Fi network architecture and inductive power transfer technologies.
• Technical Context: The patents-in-suit address technologies for managing Wi-Fi network roaming and for designing components used in inductive wireless charging systems compliant with standards such as Qi.
• Key Procedural History: The complaint states that the asserted patents originate from inventions by employees of Panasonic Corporation. Plaintiff alleges that it provided Defendant with notice of infringement on at least two occasions prior to filing the complaint.

Case Timeline

Date	Event
2004-03-02	Earliest Priority Date for '531 and '384 Patents
2005-03-14	Earliest Priority Date for '512 Patent
2010-09-14	'512 Patent Issued
2011-01-26	Earliest Priority Date for '684 and '490 Patents
2011-10-25	'531 Patent Issued
2011-12-14	Earliest Priority Date for '282 Patent
2012-09-18	'384 Patent Issued
2013-10-08	'684 Patent Issued
2015-02-24	'490 Patent Issued
2017-04-11	'282 Patent Issued
2024-07-19	First Alleged Notice Date of Infringement
2025-01-28	Second Alleged Notice Date of Infringement
2025-12-12	Complaint Filing Date

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

U.S. Patent No. 7,796,512 - *"Switching Source Device, Switching Destination Device, High Speed Device Switching System and Signaling Method"*

• Patent Identification: U.S. Patent No. 7,796,512, "Switching Source Device, Switching Destination Device, High Speed Device Switching System and Signaling Method," Issued September 14, 2010. (Compl. ¶14).

The Invention Explained

• Problem Addressed: The patent's background section describes the problem of latency in "device switching," where a user wants to move a media session (e.g., a streaming movie) from one device to another (e.g., from a mobile phone to a television) without interruption. ('512 Patent, col. 2:27-34). Conventional methods require several seconds for service discovery and session establishment, causing a noticeable delay that can degrade the user experience. ('512 Patent, col. 3:26-34).
• The Patented Solution: The invention proposes a "high speed device switching" system where a "switching source device" proactively prepares for a potential session handoff. Before a user initiates a switch, the source device discovers nearby "switching destination candidate devices," establishes preliminary sessions with them, and may even begin transmitting media data to them for buffering. ('512 Patent, Abstract; col. 4:5-15). When the user selects a destination device, the switch can occur almost instantly because much of the setup work is already complete, as illustrated in the sequence diagram of Figure 2. ('512 Patent, Fig. 2).
• Technical Importance: This method aims to make session mobility between devices "seamless" by minimizing the user-perceptible delay, which is critical for maintaining quality of service in real-time media applications. ('512 Patent, col. 3:35-40).

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶¶15, 115).
• Claim 1 recites the essential elements of a "switching source device," including:
  • A "service discovery section" for finding neighboring devices.
  • A "high speed device switching section" that, at an "arbitrary timing," instructs the discovery section, determines candidate devices, generates a list of them, and instructs for session establishment.
  • A "signaling section" to establish the session with a candidate device.
  • An "input section" for a user to request the candidate list and a "device switching request."
  • An "output section" to present the candidate list to the user.
  • A final step wherein upon receiving a user's switching request, the signaling section is notified and sends a "switching instruction to the selected device."
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,045,531 - *"System and Method for Negotiation of WLAN Entity"*

• Patent Identification: U.S. Patent No. 8,045,531, "System and Method for Negotiation of WLAN Entity," Issued October 25, 2011. (Compl. ¶33).

The Invention Explained

• Problem Addressed: The patent addresses incompatibilities that arise in "split architecture" wireless local area networks (WLANs). In these systems, network intelligence is divided between centralized "control nodes" (CNs) and distributed "wireless access points" (WAPs). The problem is that WAPs from different manufacturers often have dissimilar capabilities, which hinders interoperability and limits the development of large-scale, multi-vendor WLANs. ('531 Patent, col. 1:24-33).
• The Patented Solution: The patent describes a system where WAPs and CNs can "dynamically negotiate" a "function split arrangement." ('531 Patent, col. 2:20-29). The system includes a "negotiation unit" that allows a WAP to communicate its capabilities to a CN. The CN then negotiates with the WAP to determine which network functions the WAP will handle locally and which the CN will provide as "complementary functionality." ('531 Patent, Abstract). This allows heterogeneous WAPs to work together in a single, centrally managed network, as depicted in the negotiation flowchart of Figure 2. ('531 Patent, Fig. 2).
• Technical Importance: This technology provides a method for achieving interoperability in enterprise-grade WLANs, enabling flexible network architectures that can incorporate hardware from multiple vendors with varying levels of functionality. ('531 Patent, col. 3:7-13).

Key Claims at a Glance

• The complaint asserts independent Claim 1. (Compl. ¶¶34, 140).
• Claim 1 recites a system for providing service in a WLAN, comprising:
  • One or more "wireless access points (WAP)" for processing a "subset" of the complete functionality.
  • One or more "control nodes (CN)" for providing a "subset or complete" functionality.
  • A "negotiation unit" for the WAPs to "dynamically negotiate with the control node for a secure connection and function split arrangement."
  • The system operates whereby the control node negotiates using the negotiation unit and "provides complementary functionality" to the WAPs to form a "complete functionality" for the network.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 8,270,384 - *"Wireless Point that Provides Functions For a Wireless Local Area Network To Be Separated Between the Wireless Point and One or More Control Nodes..."*

• Patent Identification: U.S. Patent No. 8,270,384, "Wireless Point that Provides Functions For a Wireless Local Area Network To Be Separated Between the Wireless Point and One or More Control Nodes...," Issued September 18, 2012. (Compl. ¶45).
• Technology Synopsis: Related to the '531 Patent, this patent claims a "wireless point" (e.g., an AP) with distinct units for discovering control nodes, selecting a control node based on the functions offered in discovery responses, establishing a secure session with the selected node, and negotiating the separation of network functions between itself and the control node. (Compl. ¶46).
• Asserted Claims: Independent Claim 1. (Compl. ¶¶46, 164).
• Accused Features: The complaint accuses NXP Access Point Systems that use the CAPWAP protocol, alleging that the protocol's discovery, selection, and configuration phases implement the claimed invention. (Compl. ¶¶47, 51-56).

U.S. Patent No. 8,552,684 - *"Non-Contact Charging Module and Reception-Side and Transmission-Side Non-Contact Charging Apparatuses Using the Same"*

• Patent Identification: U.S. Patent No. 8,552,684, "Non-Contact Charging Module and Reception-Side and Transmission-Side Non-Contact Charging Apparatuses Using the Same," Issued October 8, 2013. (Compl. ¶58).
• Technology Synopsis: This patent describes a transmission-side wireless charging module designed to be compatible with receiving devices that may or may not use a magnet for alignment. The invention specifies a planar coil with a central hole of a predetermined size that is both larger than any magnet in the receiver and greater than 15.5 mm, combined with a ferrite sheet that attracts a magnet if one is present. (Compl. ¶59).
• Asserted Claims: Independent Claim 12. (Compl. ¶59).
• Accused Features: NXP's Qi wireless charging transmitters, such as the WCT-15W1CFFPD, are accused. The complaint alleges that the physical dimensions of the coils, central holes, and ferrite sheets in these products meet the specific limitations of the claim. (Compl. ¶¶60, 68-72).

U.S. Patent No. 8,963,490 - *"Non-Contact Charging Module and Reception-Side and Transmission-Side Non-Contact Charging Apparatuses Using the Same"*

• Patent Identification: U.S. Patent No. 8,963,490, "Non-Contact Charging Module and Reception-Side and Transmission-Side Non-Contact Charging Apparatuses Using the Same," Issued February 24, 2015. (Compl. ¶74).
• Technology Synopsis: Belonging to the same family as the '684 Patent, this patent claims a generic non-contact charging module (either transmitter or receiver). The claimed module includes a planar coil with a hollow portion greater than 15.5 mm and a magnetic sheet, allowing it to align with another module regardless of whether that other module uses a magnet for alignment. (Compl. ¶75).
• Asserted Claims: Independent Claim 1. (Compl. ¶¶75, 212).
• Accused Features: The same NXP Qi-compliant wireless charging transmitters are accused. The infringement allegations focus on the module's planar coil structure, the specified size of its hollow portion, and the use of a magnetic sheet. (Compl. ¶¶76, 80-82).

U.S. Patent No. 9,620,282 - *"Noncontact Connector Apparatus and System Using Inductive Coupling Between Coils"*

• Patent Identification: U.S. Patent No. 9,620,282, "Noncontact Connector Apparatus and System Using Inductive Coupling Between Coils," Issued April 11, 2017. (Compl. ¶87).
• Technology Synopsis: This patent describes a power transfer apparatus, such as a wireless charging receiver, that includes a receiver coil and a "second magnetic body" (e.g., shielding). The claimed invention involves intentionally decreasing the coupling coefficient between the transmitter and receiver coils by increasing their self-inductance. This design is alleged to shift the transmission efficiency characteristic from a less stable "double-peaked narrow-band" to a more robust "single-peaked wide-band." (Compl. ¶88).
• Asserted Claims: Independent Claim 10. (Compl. ¶¶88, 236).
• Accused Features: NXP's Qi-compliant wireless charging receivers (e.g., WPR1500-HV). The complaint alleges that these receivers, by incorporating a magnetic body as required by the Qi standard, inherently increase the coil's self-inductance, decrease the coupling coefficient, and thereby achieve the frequency characteristic transformation claimed by the patent. (Compl. ¶¶89, 99-104).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities fall into two main categories:

1. Wi-Fi SoCs and Systems: NXP Wi-Fi SoCs that support 802.11k/r standards (e.g., 88MW32X, AW611, IW610 families) and NXP Access Point Systems that use the CAPWAP protocol (e.g., RDT1023WLAN). (Compl. ¶¶16, 35).
2. Wireless Charging Components: NXP wireless charging transmitters and receivers compliant with the Qi standard (e.g., WCT-15W1CFFPD, WPR1500-HV). (Compl. ¶¶60, 76, 89).

Functionality and Market Context

• The complaint alleges that the accused Wi-Fi SoCs are used in access points to enable standards-based fast roaming (802.11r) and network optimization (802.11k), which are core features for enterprise and high-performance consumer Wi-Fi networks. (Compl. ¶¶17-18). It further alleges that the accused Access Point Systems use the CAPWAP protocol to enable centralized management of multiple APs, a common architecture for enterprise WLANs. (Compl. ¶37).
• The complaint alleges that the accused wireless charging components are designed for use in Qi-compliant products, a widely adopted standard for inductive charging in consumer electronics like smartphones. The complaint provides an image of an NXP reference design board, the "MP-A11 (WCT-15W1CFFPD) demo board," to illustrate the structure of an accused transmitter. (Compl. p. 48).

IV. Analysis of Infringement Allegations

'512 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a switching source device for moving a session established with a communication counterpart to a switching destination device...	Accused Access Points (APs) containing NXP SoCs act as a switching source device to assist connected clients in roaming to a destination AP.	¶17	col. 1:11-17
a service discovery section for obtaining information as to whether a service can be provided from a neighboring communication device;	The accused products use the 802.11k standard to compile a "neighbor report," which contains information about neighboring APs that are candidates for a service set transition.	¶¶19-20	col. 4:50-54
a high speed device switching section for... generating a switching destination candidate device list describing the switching destination candidate devices...	NXP's SoCs supporting 802.11k/r generate a "neighbor list" that describes the switching candidate APs for a client to roam to.	¶24	col. 5:22-26
and making an instruction for establishing a session with the switching destination candidate device;	The respective BSSID from the neighbor report is used to subsequently establish a Fast Transition session with the target AP.	¶25	col. 5:26-29
a signaling section for establishing a session with the switching destination candidate device when the instruction... is received...	The Remote Request Broker (RRB) of an AP containing an NXP SoC establishes a session over the Distribution System (DS) with the destination AP.	¶26	col. 5:1-5
an input section for receiving a switching destination candidate device list request from a user;	The APs receive neighbor report requests from connected users' devices.	¶27	col. 5:6-9
an output section for presenting the switching destination candidate device list...	The APs present the neighbor report to a connected client in response to a neighbor report request.	¶28	col. 5:10-14
wherein when the high speed device switching section receives a device switching request from a user... it notifies the signaling section... and the signaling section sends a switching instruction to the selected device.	When the accused SoC receives a switching request (FT Action Request) from a user's device, it sends a RemoteRequest message to the target AP, which contains a switching instruction.	¶¶31-32	col. 6:1-8

'531 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a single or plurality of wireless access points (WAP) for processing a subset of complete functionality defined for the wireless local area network;	NXP Access Controllers (ACs) manage one or more NXP APs (also called WTPs), which process a subset of the total WLAN functionality.	¶38	col. 4:5-8
a single or plurality of control nodes (CN) for providing a subset or complete functionalities defined for the wireless local area network;	An NXP Access Controller (AC) acts as the control node, managing the APs in the network.	¶37	col. 4:8-10
a negotiation unit for the single or plurality of WAPs to dynamically negotiate with the control node for a secure connection and function split arrangement;	Through the CAPWAP protocol's discovery process, NXP APs convey their capabilities to an AC, which uses this information to configure the network and establish a secure DTLS session.	¶¶40-41	col. 2:20-29
whereby the control node negotiates... and provides complementary functionality for the single or plurality of each of the WAPs to form a complete functionality...	The AC provides complementary functionality, such as performing the 802.11 integration function in a split MAC mode, with the final configuration decision made on the AC based on the negotiation.	¶¶43-44	col. 2:29-35

• Identified Points of Contention:
  • Scope Questions: For the '512 Patent, a potential issue is whether the patent's claims, which describe a "switching source device" moving a session between different types of devices (e.g., phone to TV), can be construed to read on the standardized 802.11k/r process of a single client device roaming between similar access points. For the '531 Patent, a question is whether the standardized discovery and configuration procedures of the CAPWAP protocol constitute "dynamic negotiation" as required by the claims, or if they represent a more static, one-way information exchange.
  • Technical Questions: A key technical question for the '512 patent infringement theory is whether the accused AP is the "device for moving a session" or merely a facilitator for a client device that is itself moving its own session. The complaint provides a diagram from an IEEE standard showing "over-the-DS FT Protocol messages," which illustrates the inter-AP communication that Plaintiff alleges constitutes the claimed signaling. (Compl. p. 19).

V. Key Claim Terms for Construction

For the '512 Patent:

• The Term: "a switching source device for moving a session"
• Context and Importance: The construction of this phrase is central to determining whether an AP that facilitates a client's roam is the infringing "device." The identity of the "device" and the nature of the "moving" action will be critical. Practitioners may focus on whether the AP actively transfers the session state or simply provides information that allows the client to re-establish its session elsewhere.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself is broad, referring simply to "a switching source device" without limiting it to an end-user device. The Abstract describes moving a session "held between a switching source device and a communication counterpart," which could describe an AP's relationship with a server.
  • Evidence for a Narrower Interpretation: The Background Art section repeatedly frames the problem in the context of a user with a "mobile terminal" such as a "portable telephone" wanting to switch the display to a "large size television display." ('512 Patent, col. 2:56-64). This user-centric context may support a narrower definition limited to end-user devices.

For the '531 Patent:

• The Term: "negotiation unit" / "dynamically negotiate"
• Context and Importance: This term is the inventive core of Claim 1. The outcome may depend on whether a standardized, state-based protocol like CAPWAP, where capabilities are declared and a configuration is assigned, qualifies as "negotiation." Practitioners may focus on whether the protocol allows for the back-and-forth exchange implied by "negotiation."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent's Abstract states the method "introduces means for flexibly accommodating the varying degrees of differences in capabilities," suggesting a broad interpretation that could encompass any protocol achieving this flexible accommodation.
  • Evidence for a Narrower Interpretation: The detailed description and Figure 2 describe a process that includes the possibility of a WAP sending a "negative acknowledgement to CN controller with additional information." ('531 Patent, Fig. 2, step 215). This suggests a potential for a multi-step, iterative process more akin to traditional negotiation than a simple capability advertisement.

VI. Other Allegations

• Indirect Infringement: For all asserted patents, the complaint alleges both induced and contributory infringement. The inducement allegations are based on NXP allegedly marketing the accused features (e.g., 802.11k/r, CAPWAP, Qi-compliance) and providing instructional materials, datasheets, and technical support that encourage and instruct customers on how to use them in an infringing manner. (Compl. ¶¶123, 148). The contributory infringement allegations are based on the assertion that the accused features are specially made and adapted to infringe and have no substantial non-infringing use. (Compl. ¶¶131, 155).
• Willful Infringement: The complaint alleges willful infringement based on NXP’s alleged continued infringement after receiving notice of the asserted patents on July 19, 2024, and January 28, 2025. (Compl. ¶109, 133).

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

This case presents several key questions for the court, rooted in the interpretation of claim language as applied to industry-standard technologies.

• A core issue will be one of applicability: can claims drafted in the context of specific use cases—such as moving a media stream between a phone and a TV ('512 patent)—be applied to the general, standardized functionality of a Wi-Fi client roaming between access points?
• A second central question will be one of definitional scope: does the term "dynamically negotiate" ('531 patent) encompass a standardized protocol like CAPWAP where devices declare capabilities and receive a configuration, or does it require a more interactive, back-and-forth bargaining process?
• Finally, an evidentiary question will be one of functional operation: for the wireless charging patents ('282 patent), does the use of a magnetic body in NXP's Qi-compliant receivers, as a matter of technical fact, necessarily result in the claimed frequency characteristic shift from a "double-peaked" to a "single-peaked" response, or can that functionality be separated?