DCT

6:21-cv-00398

MyPAQ Holdings Ltd v. Samsung Electronics Co Ltd

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:21-cv-00398, W.D. Tex., 02/04/2022
  • Venue Allegations: Venue is alleged to be proper against Samsung Electronics Co., Ltd. as a foreign defendant and against the other defendants based on their having regular and established places of business within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s power supply adapters and power management integrated circuits infringe four patents related to the architecture of switch-mode power supplies and methods for adaptively controlling power converter efficiency.
  • Technical Context: The technology concerns the design and control of power converters, which are essential components in chargers for consumer electronics that convert AC wall power to DC power for devices like smartphones and tablets.
  • Key Procedural History: The operative complaint is the Second Amended Complaint. It alleges knowledge of the patents since at least May 18, 2021, the date of service waiver for the original complaint. Subsequent to the filing of this complaint, Inter Partes Review (IPR) proceedings have impacted two of the asserted patents. An IPR certificate for the ’399 Patent indicates that all asserted claims have been either cancelled or disclaimed by the patent owner. A separate IPR certificate for the ’489 Patent indicates that a majority of its asserted claims have been cancelled. The status of the asserted claims in light of these proceedings presents a threshold issue for the case.

Case Timeline

Date Event
2005-03-31 ’399 Patent Priority Date
2006-12-01 ’759 and ’514 Patents Priority Date
2007-08-03 ’489 Patent Priority Date
2008-07-22 ’399 Patent Issue Date
2010-03-09 ’759 Patent Issue Date
2011-07-12 ’489 Patent Issue Date
2013-07-02 ’514 Patent Issue Date
2021-05-18 Defendant's Alleged Knowledge of Patents via Original Complaint Service Waiver
2022-02-04 Second Amended Complaint Filing Date

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

U.S. Patent No. 7,403,399 - "Active Primary-Sided Circuit Arrangement for a Switch-Mode Power Supply"

  • Patent Identification: U.S. Patent No. 7,403,399, "Active Primary-Sided Circuit Arrangement for a Switch-Mode Power Supply," issued July 22, 2008 (Compl. ¶20).

The Invention Explained

  • Problem Addressed: The patent describes conventional switch-mode power supplies as being overly complex, often consisting of more than 20 separate components on the primary side, which consumes significant space, increases manufacturing complexity, and complicates logistics for component procurement (’399 Patent, col. 1:19-30).
  • The Patented Solution: The invention proposes a modular circuit arrangement where the control circuit is on a first semiconductor chip, while the primary-sided switch and other active components are integrated into at least one separate, additional semiconductor chip. Both the control chip and the additional chip(s) are mounted on a single, shared "circuit carrier," such as a leadframe, to create a compact, integrated module. (’399 Patent, Abstract; col. 2:45-54; Fig. 2). This integration reduces the overall component count and footprint.
  • Technical Importance: This approach enabled significant miniaturization of power supply circuits, a critical step for developing smaller and more economical chargers for portable consumer electronics. (’399 Patent, col. 2:59-64).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 13 (Compl. ¶113).
  • Claim 1 recites a "Circuit arrangement for a switch-mode power supply" with the following essential elements:
    • A primary-sided switch, a control circuit, and additional active, primary-sided components.
    • The control circuit is formed by a first integrated semiconductor chip.
    • The primary-sided switch and additional components are integrated in at least one additional semiconductor chip.
    • The additional chip is separate from the control circuit chip.
    • Both chips are arranged on a circuit carrier shared with the control circuit.
  • Claim 13 recites a "Switch-mode power supply" comprising the circuit arrangement of Claim 1.
  • The complaint also asserts dependent claims 2, 4, 5, 6, and 10 (Compl. ¶113).

U.S. Patent No. 7,675,759 - "Power System with Power Converters Having an Adaptive Controller"

  • Patent Identification: U.S. Patent No. 7,675,759, "Power System with Power Converters Having an Adaptive Controller," issued March 9, 2010 (Compl. ¶33).

The Invention Explained

  • Problem Addressed: The patent notes that power converter efficiency varies significantly with operating conditions (like load current) and component variations from manufacturing. Prior art efficiency optimization techniques were static and could not adapt to real-time changes in the load's operational needs, such as a processor entering a sleep state. (’759 Patent, col. 2:20-32, col. 3:41-54).
  • The Patented Solution: The invention describes a power system where a "power system controller" receives a "signal indicating a system operational state of a load" (e.g., a processor's performance state). In response, the system controller sends a command to the power converter's own controller, inducing it to enter a specific "power converter operational state." This involves regulating an "internal operating characteristic" (e.g., internal bus voltage or switching frequency) to improve efficiency for that specific load state. (’759 Patent, Abstract; col. 5:8-17).
  • Technical Importance: This adaptive control enables a power supply to dynamically optimize its efficiency in real time based on the power demands of the connected device, a key feature for battery life and energy conservation in modern electronics. (’759 Patent, col. 3:41-54).

Key Claims at a Glance

  • The complaint asserts independent claims 1, 6, and 16 (Compl. ¶113).
  • Claim 1 recites a "power converter" comprising a power switch and a controller that receives a command from a separate "power system controller" to enter a specific "power converter operational state" and regulates an internal operating characteristic to improve efficiency as a function of the "system operational state."
  • Claim 6 recites a "power system" comprising a "power system controller" that selects a "power converter operational state" based on the load's "system operational state," and a "power converter" that implements that state to improve efficiency.
  • Claim 16 recites a "method of operating a power system" comprising the steps of receiving a signal indicating the system operational state, generating a power converter operational state, inducing the converter to enter that state, and controlling an internal characteristic to improve efficiency.
  • The complaint also asserts dependent claims 2, 3, 11, 12, 13, and 19 (Compl. ¶113).

U.S. Patent No. 7,978,489 - "Integrated Power Converters"

  • Patent Identification: U.S. Patent No. 7,978,489, "Integrated Power Converters," issued July 12, 2011 (Compl. ¶48).
  • Technology Synopsis: The patent addresses the inefficient use of space and poor thermal dissipation in conventional power adapters by proposing a more integrated physical construction. The solution centers on using a "flexible contact" to electrically connect the AC power blades directly to the printed circuit boards within the adapter housing, enabling a more compact and thermally efficient design. (’489 Patent, col. 1:18-32, col. 2:35-47).
  • Asserted Claims: The complaint asserts independent claims 1, 22, and 43, among numerous dependent claims (Compl. ¶113).
  • Accused Features: The complaint alleges that Samsung's TA800, TA845, and TA865 power supply adapters infringe by including a rectifier, regulator, transformer, and a "flexible contact" that couples the AC power blades to the internal printed circuit boards (Compl. ¶109).

U.S. Patent No. 8,477,514 - "Power System with Power Converters Having an Adaptive Controller"

  • Patent Identification: U.S. Patent No. 8,477,514, "Power System with Power Converters Having an Adaptive Controller," issued July 2, 2013 (Compl. ¶85).
  • Technology Synopsis: This patent, related to the ’759 Patent, also addresses improving power converter efficiency by adapting to the load's operational state. It claims a power converter with a controller that receives a signal from the load indicating its "system operational state" and, in response, controls an "internal operating characteristic" of the converter (such as switching frequency or gate drive voltage) as a function of that signal to optimize performance. (’514 Patent, Abstract; col. 2:39-50).
  • Asserted Claims: The complaint asserts independent claims 1, 6, 11, and 16, among other dependent claims (Compl. ¶113).
  • Accused Features: The accused instrumentalities are alleged to infringe by implementing power systems that adapt their internal operations based on signals received from the load, such as a processor system, to manage power consumption and efficiency (Compl. ¶¶87, 91, 95).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused instrumentalities as Samsung power supply adapters (models EP-TA800XBEGUS, EP-TA845XBEGUS, EP-TA865) and a power management integrated circuit (model S2MM101) (Compl. ¶107).

Functionality and Market Context

  • The accused adapters are described as "USB-C Fast Charging Wall Charger" products that provide power to consumer electronics (Compl. ¶¶109, 115; p. 22). A screenshot provided in the complaint identifies the EP-TA800XBEGUS as a "25W USB-C Fast Charging Wall Charger" (Compl. p. 22). The accused S2MM101 IC is described on Samsung's website as a "Power Delivery IC" intended for "Phone Charger" applications (Compl. ¶110). A screenshot from Samsung's semiconductor website shows the S2MM101 chip marketed as a "Samsung Power IC" (Compl. p. 23). These products are positioned in the market as accessories for charging mobile devices, such as Samsung's Galaxy phones (Compl. ¶119).

IV. Analysis of Infringement Allegations

The complaint states that detailed claim charts are attached as Exhibits E-KK, but these exhibits were not included with the filed complaint (Compl. ¶113). The complaint's narrative infringement theory is therefore highly generalized.

For the ’399 Patent, the complaint conclusorily alleges that the Accused Instrumentalities practice the asserted claims without providing a specific narrative of how any feature meets a claim limitation (Compl. ¶¶107, 113).

For the ’759 Patent, the complaint similarly provides a conclusory allegation of infringement, stating that the Accused Instrumentalities practice the claims and referring to the unattached exhibits (Compl. ¶¶107, 113).

  • Identified Points of Contention:
    • ’399 Patent: A threshold, and potentially dispositive, issue for the ’399 Patent will be the status of the asserted claims. An Inter Partes Review certificate (IPR2022-00307) issued after the complaint was filed indicates that all asserted claims (1, 2, 4, 5, 10, and 13) have been disclaimed by the patent owner and that claims 6 and 10 have been cancelled. The continued viability of the infringement count for this patent raises a significant legal question.
    • ’759 Patent: A primary point of contention will likely be factual and technical. The complaint does not specify what constitutes the "signal indicating a system operational state of a load" or the "internal operating characteristic" that is allegedly regulated in the accused products. The key question will be whether the communication protocol used by Samsung's chargers (e.g., USB Power Delivery) conveys the type of "system operational state" required by the claims, and whether the chargers' response constitutes the claimed adaptive efficiency optimization. The complaint includes a screenshot of a Samsung support page discussing "Fast charge your Galaxy phone" which may form part of the plaintiff's infringement theory (Compl. p. 24).

V. Key Claim Terms for Construction

  • ’399 Patent, Claim 1: "circuit carrier"

    • Context and Importance: The definition of this term is central to the claimed physical architecture. Its scope determines what types of substrates or mounting structures satisfy the requirement that the separate control and power component chips be "arranged on a circuit carrier shared with the control circuit."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the term is not limited to a single structure, stating that "ceramic circuit carriers, flexible circuit carriers, ball grid arrays or the like can be used" in addition to the primary embodiment (’399 Patent, col. 6:10-13).
      • Evidence for a Narrower Interpretation: The detailed description of the first embodiment focuses heavily on a "leadframe 112" as the circuit carrier, implemented as a "Micro Leadframe Package" component (’399 Patent, col. 6:42-44). A party might argue the term should be construed in light of this specific, detailed embodiment.

  • ’759 Patent, Claim 1: "system operational state of a load"

    • Context and Importance: This term defines the critical input signal that triggers the patented adaptive control. Its construction will determine whether standard power negotiation signals (e.g., voltage/current requests) meet the limitation, or if a more specific type of processor or system status information is required. Practitioners may focus on this term because it distinguishes the invention from conventional power supplies that merely respond to load current changes.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the state in general terms, including "a request for a particular load voltage, or a particular level of system readiness, or the response time for changes in a system operational level" (’759 Patent, col. 4:46-50).
      • Evidence for a Narrower Interpretation: The patent’s background section provides substantial context by discussing processor "P-states" and "C-states" as specific examples of system-level states that affect power consumption (’759 Patent, col. 4:1-40). A party could argue the term should be limited to these types of detailed processor status indicators rather than generic power requests.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, asserting that Defendants take active steps to encourage customers to use the accused products in an infringing manner (Compl. ¶117). The alleged steps include marketing, advertising, and publishing online instructions and best practices, such as support pages that instruct users on how to "Fast charge your Galaxy phone" and encourage them to purchase the accused chargers (Compl. ¶¶118-120; p. 24).
  • Willful Infringement: The complaint does not contain an explicit count for willful infringement. However, it alleges that Defendants have had knowledge of the patents and their alleged infringement "since at least Samsung's waiver of service of MyPAQ's Original Complaint on May 18, 2021" (Compl. ¶123). This allegation of post-suit knowledge could form the basis for a request for enhanced damages under 35 U.S.C. § 284.

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

  • Claim Viability: The central threshold issue is the legal status of the patents-in-suit. Can Plaintiff maintain its action on the ’399 Patent, for which all asserted claims appear to be disclaimed or cancelled post-filing? Similarly, how does the cancellation of numerous asserted claims of the ’489 Patent affect the scope of the dispute?
  • Technical Evidence for Adaptive Control: For the ’759 and ’514 Patents, a key evidentiary question will be one of technical operation. What evidence will Plaintiff provide to demonstrate that Samsung's power delivery system performs the specific adaptive control loop recited in the claims, particularly the requirement of receiving a "system operational state" from the load and responsively modifying an "internal operating characteristic" to improve efficiency?
  • Definitional Scope: The case may also turn on a core issue of claim construction: can the term "system operational state of a load," which the patent specification links to detailed processor P-states and C-states, be construed to cover the standardized communications within protocols like USB Power Delivery?