DCT

6:22-cv-00787

Sonrai Memory Ltd v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 6:22-cv-00787, W.D. Tex., 07/15/2022
  • Venue Allegations: Plaintiff alleges venue is proper because Apple is registered to do business in Texas, has transacted business in the district, and maintains regular and established places of business in the Western District of Texas.
  • Core Dispute: Plaintiff alleges that a wide range of Apple’s products, including iPhones, iPads, and Mac computers, infringes patents related to chip multiprocessor architecture and variable charge pump circuits used in memory components.
  • Technical Context: The patents address foundational semiconductor technologies concerning the efficient operation of multiple processors on a single chip and the stable management of power within integrated circuits.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the asserted patents.

Case Timeline

Date Event
2001-05-29 U.S. Patent No. 6,874,014 Priority Date
2002-10-25 U.S. Patent No. 6,724,241 Priority Date
2004-04-20 U.S. Patent No. 6,724,241 Issued
2005-03-29 U.S. Patent No. 6,874,014 Issued
2022-07-15 Complaint Filed

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

U.S. Patent No. 6,874,014 - "Chip multiprocessor with multiple operating systems," issued March 29, 2005

The Invention Explained

  • Problem Addressed: The patent's background describes the well-known "scalability problems" that arise when a single operating system is used to manage a large number of processors (Compl. ¶8; ’014 Patent, col. 1:45-54). As the number of processors increases, the efficiency of a single managing OS "goes down dramatically," creating a performance bottleneck (’014 Patent, col. 1:50-54).
  • The Patented Solution: The invention proposes a multiprocessor architecture on a single chip where different processors, or groups of processors, can each execute a distinct operating system stored in a connected memory (’014 Patent, Abstract; Fig. 3). By partitioning the system this way, the architecture seeks to avoid the scaling limitations of a single, monolithic OS and allows a large number of processors on one die to operate efficiently (’014 Patent, col. 3:65-col. 4:2).
  • Technical Importance: This architectural approach was aimed at improving the scalability of high-density computing environments, such as internet data centers, where maximizing the number of processing nodes in a given volume is critical (’014 Patent, col. 1:11-20).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶10).
  • Essential elements of claim 1 include:
    • multiple processors mounted on a single die;
    • multiple operating systems residing in a memory connected to said multiple processors;
    • wherein each of said multiple processors executes an operating system of said multiple operating systems;
    • and two or more of said multiple processors are capable of simultaneously executing two or more operating systems of said multiple operating systems.
  • The complaint alleges infringement of "one or more claims" and thus may assert additional claims later in the litigation (Compl. ¶10).

U.S. Patent No. 6,724,241 - "Variable charge pump circuit with dynamic load," issued April 20, 2004

The Invention Explained

  • Problem Addressed: The patent addresses the issue of voltage instability in charge pump circuits, which are used to generate specific high voltages needed for operations in memory devices (Compl. ¶14; ’241 Patent, col. 1:11-15). A charge pump designed to supply a high voltage can be "over efficient" when required to supply a much lower voltage, resulting in an unstable output with significant voltage "ripple" or "overshoot" (’241 Patent, col. 2:16-28).
  • The Patented Solution: The invention is a charge pump circuit that includes a "plurality of loads" which can be selectively connected to the circuit's output by a "load selector means" (’241 Patent, Abstract). By dynamically coupling the appropriate load for a given target voltage, the circuit can match its output characteristics to the demand, thereby minimizing ripple and providing a stable voltage (’241 Patent, col. 3:17-19, Fig. 3).
  • Technical Importance: The described technology provides a method for achieving precise and stable voltage regulation across a range of operating levels within a single integrated circuit, a critical requirement for the reliability of memory chips that use different voltages for reading, erasing, and programming operations (’241 Patent, col. 1:11-15).

Key Claims at a Glance

  • The complaint asserts independent claim 1 (Compl. ¶16).
  • Essential elements of claim 1 include:
    • a pumping circuit comprising one or more stages operable to receive a supply voltage and generate a selected one of a plurality of pump voltages;
    • a plurality of loads selectively coupleable to an output of the pumping circuit, each load associated with a specific pump voltage; and
    • a load selector means for selectively coupling a load associated with a specific pump voltage to the output of said pumping circuit.
  • The complaint alleges infringement of "one or more claims" and thus may assert additional claims later in the litigation (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

  • For the ’014 Patent, the accused instrumentalities are Apple products containing A-series, M-series, or T-series chipsets, a list that includes numerous generations of the iPhone, iPad, and MacBook (Compl. ¶9-10).
  • For the ’241 Patent, the accused instrumentalities are specific Apple products that contain an "SK Hynix NAND Flash die," including certain models of the MacBook Pro, iPhone, and iPad Pro (Compl. ¶15).

Functionality and Market Context

  • The complaint alleges that Apple's A-series, M-series, and T-series systems-on-a-chip (SoCs) are the infringing "chip multiprocessor[s]" relevant to the ’014 Patent (Compl. ¶10). These chips are known to contain multiple processing cores.
  • For the ’241 Patent, infringement is alleged to occur via the functionality of a specific component, the "SK Hynix NAND Flash die," within certain Apple products (Compl. ¶16). This points to an infringement theory based on the internal operation of the power management or voltage generation circuitry within the third-party memory chip.
  • The complaint does not provide specific details on the market positioning of these products but identifies them as widely sold, high-volume consumer electronics. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided with the filed document (Compl. ¶10, ¶16). Accordingly, the infringement allegations are summarized below based on the narrative text of the complaint.

  • ’014 Patent Infringement Allegations
    The complaint asserts that Apple's multi-core A-series, M-series, and T-series processors, which are mounted on a single die, infringe claim 1 of the ’014 Patent (Compl. ¶10). The core of the infringement theory is that these chipsets execute multiple operating systems simultaneously, thereby satisfying all limitations of the asserted claim (Compl. ¶10). The complaint does not, however, specify what software components in Apple's products constitute the "multiple operating systems" or provide technical details on how they are allegedly executed simultaneously by different processors.
  • ’241 Patent Infringement Allegations
    The complaint asserts that the infringement of the ’241 Patent occurs within a specific third-party component, the "SK Hynix NAND Flash die," which is incorporated into certain Apple products (Compl. ¶15, ¶16). The theory is that the voltage-regulating circuitry inside this flash memory chip constitutes a "variable charge pump circuit" that meets the elements of claim 1. This includes having a pumping circuit, a plurality of selectable loads, and a "load selector means" that couples a specific load to stabilize the output voltage (Compl. ¶16; ’241 Patent, cl. 1). The complaint does not provide any specific technical evidence regarding the internal design of the accused SK Hynix component.

Identified Points of Contention

  • Scope Questions (’014 Patent): The case may turn on the definition of "operating system." A key question is whether the term, which the patent exemplifies with "WINDOWS NT, UNIX and the like" (’014 Patent, col. 3:42-43), can be construed to cover specialized software like the operating system for Apple’s Secure Enclave or other firmware running on co-processors, as opposed to only general-purpose, user-facing operating systems like iOS and macOS.
  • Technical Questions (’014 Patent): A central factual dispute will likely be whether Apple's processors are "capable of simultaneously executing two or more operating systems" in the manner required by the claim. The complaint lacks specific evidence demonstrating this simultaneous execution of distinct operating systems on different processors.
  • Technical Questions (’241 Patent): As the infringement allegation targets a third-party component, a primary question for the court will be an evidentiary one: does the internal circuitry of the accused SK Hynix NAND Flash die in fact contain the claimed "pumping circuit," "plurality of loads," and "load selector means"? Answering this will likely require detailed discovery into the proprietary design of that component.

V. Key Claim Terms for Construction

  • ’014 Patent, Claim 1: "operating system"

    • Context and Importance: The viability of the infringement claim for the ’014 Patent hinges on the construction of this term. Practitioners may focus on this term because the allegation requires Apple's products to run "multiple" such systems simultaneously. Whether low-level firmware or a secure microkernel qualifies as a distinct "operating system" alongside iOS or macOS will be a dispositive issue.
    • Intrinsic Evidence for a Broader Interpretation: The patent does not provide a formal definition, which may support an argument for applying a broad, plain-and-ordinary meaning. A party could argue any software layer that manages hardware resources for a processor should qualify.
    • Intrinsic Evidence for a Narrower Interpretation: The specification gives "conventional operating systems, such as WINDOWS NT, UNIX and the like" as examples (’014 Patent, col. 3:42-43). A party could argue this limits the term's scope to full-featured, general-purpose operating systems and excludes specialized firmware or monitors.

  • ’241 Patent, Claim 1: "load selector means"

    • Context and Importance: This term is drafted in means-plus-function format under 35 U.S.C. § 112(f). Its scope is not its plain meaning but is instead limited to the specific structure disclosed in the patent's specification for performing the recited function and its equivalents. The function is "selectively coupling a load... to the output of said pumping circuit." Practitioners may focus on this term because infringement will require a structural comparison, not just a functional one.
    • Intrinsic Evidence for Interpretation (Corresponding Structure): The specification discloses the corresponding structure as a set of switches (e.g., "switches 320, 324, and 328") that are activated by "respective control signals" (e.g., "EN_A, EN_B, and EN_C") generated by a controller in response to an instruction for a target voltage (’241 Patent, col. 4:36-56; Fig. 3). Another embodiment includes comparators and a logic circuit that automatically control the switches (’241 Patent, Fig. 7). The infringement analysis will be limited to these disclosed structures and their equivalents.

VI. Other Allegations

  • Indirect Infringement: The complaint includes a general recitation of "indirect infringement" but does not plead specific facts to support the requisite elements of knowledge and intent for either induced or contributory infringement (Compl. ¶6).
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It includes a prayer for a finding that the case is "exceptional" to recover attorney's fees under 35 U.S.C. § 285, but this is a separate legal standard from willful infringement (Compl., Prayer for Relief ¶e).

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

  • A core issue will be one of definitional scope: can the term "operating system," as used in the ’014 Patent and illustrated with conventional examples like UNIX, be construed to cover the specialized, non-user-facing firmware or secure microkernels that run on various co-processors within Apple's integrated chipsets? The answer to this question may determine the outcome of the claim against Apple's SoCs.
  • A key evidentiary question will be one of component-level architecture: does the internal design of the accused SK Hynix memory component, supplied by a third party, actually contain a "load selector means" with a structure equivalent to the switch-and-controller configurations disclosed in the ’241 Patent? The infringement allegation for this patent appears to depend entirely on the yet-unseen proprietary details of that chip.