Wiesblatt Licensing LLC v. Razer USA Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Wiesblatt Licensing LLC (Texas)
  • Defendant: Razer USA LTD. (Delaware)
  • Plaintiff’s Counsel: Garteiser Honea, PLLC
• Case Identification: 6:22-cv-00990, W.D. Tex., 12/02/2022
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining a regular and established business presence within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s high-performance gaming laptops and handheld devices, which incorporate modern memory standards, infringe a patent related to power-adaptive circuitry for reliable data transfer.
• Technical Context: The technology addresses the challenge of maintaining data signal integrity in electronic devices that use dynamic voltage scaling—a common technique to reduce power consumption by varying operating voltages—which is critical in battery-powered and high-performance electronics.
• Key Procedural History: The operative pleading is a First Amended Complaint. The complaint alleges that Defendant has been on notice of the patent since at least the date of service of the original complaint in the litigation.

Case Timeline

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

U.S. Patent 8,396,112 - “Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses”

• Patent Identification: U.S. Patent 8,396,112, “Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses,” issued March 12, 2013.

The Invention Explained

• Problem Addressed: The patent’s background section identifies a problem in electronic systems that use a variable power supply voltage to conserve energy. In such systems, it is "difficult to consistently convert the multi-value analog signals into multi-value digital signals because the power supply voltage changes" ('112 Patent, col. 1:30-36).
• The Patented Solution: The invention proposes a system where the reference threshold voltages used for analog-to-digital (A/D) conversion are themselves generated from the variable power supply voltage. This ensures that as the system's main supply voltage fluctuates, the A/D conversion thresholds track those fluctuations proportionally, allowing for the proper and consistent conversion of data signals ('112 Patent, col. 2:1-9). Figure 4 of the patent illustrates a threshold voltage generator (156) that receives a voltage proportional to the system's peak voltage (Ep/2) to generate multiple, stable reference thresholds (Vth1, Vth2, Vth3) for the A/D conversion process ('112 Patent, Fig. 4).
• Technical Importance: This design principle enables robust data communication within power-efficient devices that must dynamically alter their voltage and frequency to balance performance with battery life ('112 Patent, col. 2:21-26).

Key Claims at a Glance

• The complaint asserts independent Claim 1 as exemplary (Compl. ¶24).
• The essential elements of independent Claim 1 are:
  • A variable power supply voltage generator for generating a variable power supply voltage.
  • A transmitting circuit operative at the variable power supply voltage for generating and transmitting a multi-value analog signal.
  • A receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal.
  • A threshold voltage generator that generates threshold voltages for the A/D conversion from the variable power supply voltage or a signal proportional to it, and supplies them to the receiving circuit.
• The complaint reserves the right to assert additional claims (Compl. ¶24).

III. The Accused Instrumentality

Product Identification

• The Accused Instrumentalities include the Razer Blade 15, Razer Edge Wi-Fi, Razer Edge Founders Edition, and Razer Edge 5G (Compl. ¶19).

Functionality and Market Context

• The accused products are high-performance gaming laptops and handheld devices. The complaint’s allegations center on the circuitry for transferring data between a host processor and the device's memory, specifically identifying the use of LPDDR5 RAM (Compl. ¶24).
• The complaint alleges the accused products utilize Dynamic Voltage Scaling (DVS), a feature of the LPDDR5 memory standard, where "the memory controller can reduce both the DRAM frequency and voltage during channel idle times" to save power (Compl. p. 10). A specifications table for the Razer Edge products is included in the complaint, confirming they use 8GB of LPDDR5 RAM (Compl. p. 8).

IV. Analysis of Infringement Allegations

'112 Patent Infringement Allegations

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the electrical signals transmitted on a modern LPDDR5 memory bus qualify as a "multi-value analog signal" under the patent's claims. A court may need to determine if this term, as used in the patent, can be construed to read on the high-speed, discrete-level signals used in modern digital systems.
  • Technical Questions: The complaint alleges that the threshold voltage (VrefDQ) in the accused devices is generated from the variable power supply voltage (VDDQ). The infringement case may turn on what factual evidence Plaintiff can produce to show this specific generative relationship exists within the accused products, beyond pointing to industry standards.

V. Key Claim Terms for Construction

The Term: "multi-value analog signal"

• Context and Importance: The interpretation of this term is fundamental to the infringement analysis. Defendant may argue that signals in a modern memory interface are inherently digital, not analog. Practitioners may focus on this term because its construction could determine whether the patent applies to modern digital electronics or is confined to an older, more purely analog technology.
• Intrinsic Evidence for a Broader Interpretation: The specification states that the multi-value analog signals "express[] digital values" and can have a "multi-value signal level of three or higher," suggesting the term is not limited to purely analog information but can encompass digital data encoded into multiple voltage levels ('112 Patent, col. 4:45-52).
• Intrinsic Evidence for a Narrower Interpretation: The patent’s figures, such as Figure 9, depict the "Smulti" signal as a smoothly curved, continuous waveform. A party could argue that this disclosure limits the term to such waveforms, as distinguished from the sharp, rectangular transitions characteristic of high-speed digital bus signals.

The Term: "threshold voltages being generated from the variable power supply voltage"

• Context and Importance: This phrase captures the core of the patented solution—linking the reference voltages to the fluctuating supply. The infringement case depends on proving this specific causal link.
• Intrinsic Evidence for a Broader Interpretation: The claim uses the general phrasing "generated from," which could be interpreted to cover any circuit architecture where the threshold voltage is designed to track changes in the supply voltage, regardless of the specific components used.
• Intrinsic Evidence for a Narrower Interpretation: The specification describes a specific embodiment where threshold voltages are created by a voltage distribution circuit that divides a peak voltage (Ep), which is itself proportional to the variable supply voltage ('112 Patent, col. 8:36-44, Fig. 5A). An opposing party might argue this limits the claim to methods involving peak voltage detection and division, rather than any direct derivation from the supply rail.

VI. Other Allegations

• Indirect Infringement: The complaint pleads induced infringement, alleging Defendant took active steps such as "advertising an infringing use" and had knowledge of the patent from at least the service of the original complaint (Compl. ¶32-33).
• Willful Infringement: Willfulness is alleged based on Defendant’s continued conduct after the complaint was filed and on an alleged "practice of not performing a review of the patent rights of others" before launching products (Compl. ¶28, ¶34).

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

• A core issue will be one of definitional scope: can the term "multi-value analog signal," as defined and described in the context of the '112 patent, be construed to cover the high-speed, multi-level electrical signals utilized in the LPDDR5 memory interfaces of the accused products?
• A key evidentiary question will be one of technical causality: what proof will be offered to demonstrate that the accused devices contain a "threshold voltage generator" that creates its reference voltages from the variable power supply voltage, as required by the claim, versus a system where the reference voltage is generated independently but may coincidentally track supply fluctuations?