DCT
6:21-cv-00933
MyPAQ Holdings Ltd v. Dell Tech Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: MyPAQ Holdings Ltd. (Republic of Seychelles)
- Defendant: Dell Technologies Inc. and Dell Inc. (Delaware)
- Plaintiff’s Counsel: Parker, Bunt & Ainsworth, P.C.; Shore Chan LLP; Susman Godfrey LLP
- Case Identification: 6:21-cv-00933, W.D. Tex., 12/06/2021
- Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendants maintain regular and established places of business in the district, including Dell's principal place of business in Round Rock and other offices in Austin. The complaint also alleges Defendants derive substantial revenue from sales in the district, including through authorized third-party retailers.
- Core Dispute: Plaintiff alleges that certain of Defendant's USB-C power adapters infringe two patents related to adaptive power conversion technology that improves energy efficiency.
- Technical Context: The technology concerns dynamically adjusting a power converter's internal operating parameters in response to the operational state of the device it is powering, thereby optimizing efficiency across different load conditions.
- Key Procedural History: The complaint is a First Amended Complaint. It alleges that Defendants have been on notice of the asserted patents since at least the date of service of the original complaint on September 13, 2021, which is relevant to allegations of ongoing infringement. The complaint also details the assignment history of the patents to the Plaintiff.
Case Timeline
| Date | Event |
|---|---|
| 2006-12-01 | Priority Date for ’759 and ’514 Patents |
| 2010-03-09 | U.S. Patent No. 7,675,759 Issues |
| 2013-07-02 | U.S. Patent No. 8,477,514 Issues |
| 2021-09-13 | Alleged date of service of Original Complaint on Defendant |
| 2021-12-06 | First Amended Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 7,675,759 - "Power System with Power Converters Having an Adaptive Controller," issued March 9, 2010 (’759 Patent)
- The Invention Explained:
- Problem Addressed: The patent's background describes that the operating efficiency of conventional switch-mode power converters is typically optimized for a single operating point (e.g., high load) and degrades significantly under other conditions, such as light loads, which are common in modern electronics ('759 Patent, col. 1:56-65). Prior attempts to address this were limited and did not account for the broader operational context of the system being powered ('759 Patent, col. 2:21-28).
- The Patented Solution: The invention proposes a two-tiered control architecture. A high-level "power system controller" (e.g., part of the powered device) receives a signal indicating the "system operational state" of the load (e.g., a server's processing state). This system controller then sends a command to the power converter's own internal controller, instructing it to enter a specific "power converter operational state." In response, the converter's controller regulates an "internal operating characteristic" (such as its switching frequency or an internal bus voltage) to maximize efficiency for that specific system-level state, while continuing to provide a regulated output voltage ('759 Patent, Abstract; col. 5:46-65).
- Technical Importance: This approach enabled a more holistic form of power management by linking the power supply’s behavior directly to the functional state of the larger system it supports, moving beyond simple adjustments based only on the immediate power draw ('759 Patent, col. 4:43-54).
- Key Claims at a Glance:
- The complaint asserts independent claims 1 (a power converter), 6 (a power system), and 16 (a method of operation) (Compl. ¶52).
- Independent Claim 1 recites:
- A power converter coupled to a power system controller configured to receive a signal indicating a system operational state of a load.
- The converter comprises a power switch and a controller.
- The controller is configured to receive a command from the power system controller to enter a specific power converter operational state.
- The controller then adjusts the power switch's duty cycle to regulate an internal operating characteristic, thereby improving efficiency as a function of the system operational state.
- The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶52).
U.S. Patent No. 8,477,514 - "Power System with Power Converters Having an Adaptive Controller," issued July 2, 2013 (’514 Patent)
- The Invention Explained:
- Problem Addressed: Like the parent ’759 Patent, this patent addresses the problem of suboptimal power converter efficiency when operating away from a design-specific peak load condition ('514 Patent, col. 3:9-20).
- The Patented Solution: The invention describes a power converter that directly responds to the needs of the load. The power converter's controller is configured to receive a signal directly from the load that indicates the load's "system operational state." Based on this signal, the converter's controller adjusts an "internal operating characteristic" to improve efficiency. For example, one embodiment describes sensing a "power level of said state of power drain" and controlling an internal characteristic as a function of that sensed power level ('514 Patent, Abstract; col. 8:19-34).
- Technical Importance: This patent refines the adaptive control concept by describing a more direct communication link between the load and the power converter for efficiency optimization, and introduces the concept of sensing the load's specific "state of power drain" to inform the control adjustments ('514 Patent, col. 13:28-48).
- Key Claims at a Glance:
- The complaint asserts independent claims 1 (a power converter), 6 (a power system), 11 (a power system), and 16 (a method of operation) (Compl. ¶81).
- Independent Claim 1 recites:
- A power converter coupled to a load.
- The converter comprises a power switch and a power converter controller.
- The controller is configured to receive a signal from the load indicating a system operational state.
- The controller controls an internal operating characteristic of the power converter as a function of that signal.
- The complaint reserves the right to assert additional claims, including dependent claims (Compl. ¶81).
III. The Accused Instrumentality
- Product Identification: The complaint identifies the Accused Instrumentality as "power adapters and converters compatible with USB Type-C plugs, such as Dell part no. LA90PM170" (Compl. ¶48). The complaint includes a photograph of the LA90PM170 adapter (Compl. ¶48).
- Functionality and Market Context:
- The Accused Instrumentality is a 90-watt power adapter that converts AC power to DC power for devices like laptops (Compl. ¶53). The complaint alleges it uses the USB Type-C standard to communicate with the connected device (the "load") via Configuration Channel (CC) pins (Compl. ¶54). This communication allegedly determines the required voltage and current for the load.
- The complaint alleges the adapter contains a controller, identified as ON Semiconductor part number NCP1937, and a power switch, identified as "Q050" (Compl. ¶¶55-56). Based on the power requirements signaled over the CC pins, the controller allegedly adjusts internal operating characteristics, such as the gate drive voltage ("QDRV") and DC bus voltage, to provide the requested power with improved efficiency (Compl. ¶¶57-59, ¶85). The complaint provides a chart of the NCP1937 controller's pin functions, identifying a "Feedback input" (QFB) and a "switch driver" (QDRV) (Compl. ¶56).
- The complaint alleges these adapters are marketed and sold for use with Dell products, including the Latitude 5320 and 5520 laptops (Compl. ¶64).
IV. Analysis of Infringement Allegations
’759 Patent Infringement Allegations
The complaint provides an efficiency graph purporting to show that the operating efficiency of the Accused Instrumentality is improved as a function of its operational state (Compl. ¶59).
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A power converter coupled to a power system controller configured to receive a signal indicating a system operational state of a load coupled thereto... | The LA90PM170 adapter is a power converter. The connected device (e.g., a laptop) acts as the "power system controller" and communicates its operational state (power requirements) via signals on the USB-C Configuration Channel (CC) pins. | ¶53, ¶54 | col. 5:46-51 |
| a power switch configured to conduct for a duty cycle to provide a regulated output characteristic at an output thereof; and | The adapter includes a power switch ("Q050") that conducts to provide regulated output at various voltage and current levels (e.g., 5V, 9V, 15V, 20V). | ¶55 | col. 5:52-54 |
| a controller configured to receive a command from said power system controller to enter a power converter operational state as a function of said signal indicating said system operational state... | The adapter's NCP1937 controller receives signals via the CC pins indicating the system's operational state. The controller's "QFB" pin receives a command to enter a new operational state, such as increasing the DC bus voltage. | ¶56, ¶57 | col. 5:55-60 |
| said controller further configured to provide a signal to control said duty cycle of said power switch... thereby regulating an internal operating characteristic of said power converter to improve an operating efficiency thereof as a function of said system operational state. | The NCP1937 controller provides a "QDRV" signal to control the Q050 power switch. This regulates an internal characteristic (gate drive voltage) and, as a result, improves the adapter's operating efficiency as a function of the operational state, as illustrated in the complaint's efficiency graph. | ¶58, ¶59 | col. 5:60-65 |
- Identified Points of Contention:
- Scope Questions: A central issue may be whether the connected laptop can be considered the "power system controller" as claimed, which the patent specification at times depicts as a separate entity from the load. A further question is whether the negotiation of power levels under the USB-C standard constitutes a signal indicating a "system operational state" as contemplated by the patent, which provides processor P-states and C-states as primary examples.
- Technical Questions: The analysis may turn on whether the accused controller's regulation of "QDRV" is a programmed response intended to improve efficiency as a function of the system state, or if the efficiency change is an incidental physical effect of operating at a different power level.
’514 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| A power converter coupled to a load, comprising: | The Accused Instrumentality LA90PM170 is a power converter coupled to a load, such as a laptop, via its USB Type-C plug. | ¶82 | col. 7:1-2 |
| a power switch configured to conduct for a duty cycle to provide an output characteristic at an output thereof; and | The adapter contains a power switch ("Q050") that provides various regulated DC outputs (e.g., 5V at 2 amps, 20V at 2 amps). | ¶83 | col. 7:3-5 |
| a power converter controller configured to receive a signal from said load indicating a system operational state of said load and control an internal operating characteristic of said power converter as a function of said signal. | The adapter's NCP1937 controller receives signals from the load over the USB-C CC pins indicating the required operational state. In response, the controller controls internal characteristics, such as the gate drive voltage ("QDRV") and the DC bus voltage ("VBUS"), as a function of those signals. | ¶84, ¶85 | col. 7:6-9 |
- Identified Points of Contention:
- Scope Questions: Similar to the ’759 Patent, a key question will be whether the USB-C power delivery negotiation qualifies as the claimed "signal... indicating a system operational state."
- Technical Questions: It raises the question of what evidence demonstrates that the NCP1937 controller's adjustment of "QDRV" and "VBUS" is a direct control function based on the CC pin signals, as required to "control an internal operating characteristic... as a function of said signal."
V. Key Claim Terms for Construction
The Term: "system operational state" (asserted in claims of both patents)
- Context and Importance: This term is the central input that triggers the claimed adaptive behavior. Its construction is critical to determining if the standardized communication protocol of the accused USB-C power adapter falls within the scope of the claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests the term can encompass a wide range of conditions, including "a request for a particular load voltage, or a particular level of system readiness" ('759 Patent, col. 4:46-48), which may support reading the term on the power negotiation of the USB-C standard.
- Evidence for a Narrower Interpretation: The specification frequently uses a processor's P-states and C-states as the primary examples of a "system operational state" ('759 Patent, col. 4:3-31). A party could argue the term should be limited to such specific, defined processor performance or sleep states, not a generic power request.
The Term: "power system controller" ('759 Patent, Claim 6)
- Context and Importance: This term defines a key component of the claimed two-tiered system architecture in the ’759 Patent. Whether the connected laptop itself can be considered the "power system controller" is a primary question for infringement of the system claims.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes this controller functionally as something "configured to receive a signal... and to select a power converter operational state" ('759 Patent, col. 6:8-11). Any device performing this function, including the processor in the connected laptop, could arguably meet this definition.
- Evidence for a Narrower Interpretation: Figure 11 of the patent depicts the "Power System Controller (PSC)" as a distinct block separate from the "Servers (SVR)," which are the loads ('759 Patent, Fig. 11). This could support an argument that the term requires a logically or physically separate entity from the load itself.
VI. Other Allegations
- Indirect Infringement: The complaint alleges induced infringement against Dell for both patents. The allegations are based on Dell's advertising, marketing, and sale of the Accused Instrumentality and compatible products (e.g., Latitude laptops). The complaint specifically points to Dell's online user guides, which allegedly instruct customers on how to use the accused adapters with these products, thereby causing direct infringement by end-users (Compl. ¶¶62-68, ¶¶88-94). A screenshot from a user guide is provided as evidence of these instructions (Compl. ¶65).
- Willful Infringement: While the complaint does not include a separate count for "Willful Infringement," it alleges that Defendants have known of their infringement of both patents "since at least the date of service of MyPAQ's Original Complaint on September 13, 2021" (Compl. ¶69, ¶95). This allegation establishes a basis for post-suit willfulness, and the prayer for relief seeks enhanced damages pursuant to 35 U.S.C. § 284 (Compl. ¶106(B)).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "system operational state," which the patents describe using examples of processor P-states and C-states, be construed to cover the standardized power delivery negotiations conducted over a modern USB Type-C interface?
- A second key issue will be one of architectural mapping, particularly for the ’759 Patent: does the accused system, where a laptop communicates with a power adapter, embody the claimed two-tiered control architecture? Specifically, can the laptop be considered the claimed "power system controller," or does the patent require a more distinct control entity?
- A central evidentiary question will be one of functional causality: does the accused adapter's controller actively adjust internal parameters for the purpose of improving efficiency as a function of the received state signal, or are the observed efficiency improvements an incidental, inherent physical property of the converter operating at different power levels?