DCT
6:22-cv-01217
Wiesblatt Licensing LLC v. Acer America Corp
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wiesblatt Licensing LLC (Texas)
- Defendant: Acer America Corporation (California)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 6:22-cv-01217, W.D. Tex., 11/23/2022
- Venue Allegations: Venue is asserted based on Defendant maintaining a regular and established place of business within the Western District of Texas.
- Core Dispute: Plaintiff alleges that Defendant’s Acer Predator Triton 500 SE laptop, which utilizes LPDDR5 memory technology, infringes a patent directed to circuitry for reliable data transmission in systems that use variable power supply voltages.
- Technical Context: The technology addresses the challenge of maintaining signal integrity for high-speed, multi-level data signals in electronic devices that dynamically scale voltage to conserve power, a common practice in modern mobile computing.
- Key Procedural History: The complaint notes that the patent-in-suit was originally assigned to Seiko Epson Corporation. No other significant procedural events, such as prior litigation or post-grant proceedings, are mentioned in the complaint.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Earliest Priority Date for U.S. Patent 8,396,112 |
| 2013-03-12 | U.S. Patent 8,396,112 Issued |
| 2019-02-19 | JEDEC Publishes LPDDR5 Standard |
| 2022-11-23 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,396,112 - "Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses" (Issued: Mar. 12, 2013)
The Invention Explained
- Problem Addressed: The patent identifies a technical challenge arising from the combination of two modern circuit design trends: using multi-value analog signals for high-speed data transfer and using variable power supply voltages to reduce power consumption. When the power supply voltage changes, it becomes "difficult to consistently convert the multi-value analog signals into multi-value digital signals" because the reference points for conversion become unstable (’112 Patent, col. 1:30-34).
- The Patented Solution: The invention proposes a system that includes a dedicated "threshold voltage generator." This component generates the reference voltages required for analog-to-digital (A/D) conversion directly from the variable power supply voltage itself, or from a signal proportional to it. By doing so, the reference thresholds dynamically track any fluctuations in the main supply voltage, allowing the receiving circuit to properly interpret the incoming data signals despite the changing power levels (’112 Patent, col. 2:1-9; Fig. 4).
- Technical Importance: This design principle enables the simultaneous benefits of power efficiency from dynamic voltage scaling and high data throughput from multi-level signaling, addressing a key signal integrity problem in power-managed, high-performance electronics (’112 Patent, col. 1:26-34).
Key Claims at a Glance
- The complaint asserts independent Claim 1.
- The essential elements of 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 signal and performing A/D conversion to re-generate a multi-value digital signal; and
- 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 does not specify any dependent claims but reserves the right to assert them later.
III. The Accused Instrumentality
Product Identification
- The complaint names the "Acer Predator Triton 500 SE" as an exemplary accused product, within a broader category of "a plurality of electronics with circuitry for transferring data" (Compl. ¶19).
Functionality and Market Context
- The infringement allegations focus on the product's use of LPDDR5 RAM technology, which involves circuitry for transmitting data between a host processor (SoC) and memory (DRAM) (Compl. ¶20, ¶25). The complaint alleges this system uses a variable power supply voltage (e.g., VDDQ) and generates reference voltages (e.g., VrefDQ) for data conversion that are proportional to that supply voltage (Compl. ¶25(v)).
- The complaint provides a block diagram illustrating the accused LPDDR5 electrical system, showing a System-on-Chip (SoC) package and a DRAM package connected via a motherboard (MB) (Compl. p. 7).
- The complaint positions the LPDDR5 standard, and by extension the accused products, as having an "enormous impact on the performance and capabilities of the next generation of portable electronic devices" (Compl. p. 6).
IV. Analysis of Infringement Allegations
’112 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a variable power supply voltage generator for generating a variable power supply voltage; | The accused products provide a variable power supply voltage generator (e.g., a PMIC) to generate a variable voltage (e.g., VDDQ and/or VDD2). | ¶25(ii) | col. 1:57-60 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal to other circuits; | The accused products provide a transmitting circuit (e.g., in the host) that operates at the variable voltage to generate and transmit multi-value analog signals to the receiver. | ¶25(iii) | col. 1:59-63 |
| 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; and | The accused products provide a receiving circuit (e.g., in the memory) that operates at the variable voltage to receive the signals and perform A/D conversion using a Decision Feedback Equalizer (DFE) system. | ¶25(iv) | col. 2:62-65 |
| a threshold voltage generator for generating threshold voltages used for the A/D conversion...the threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage. | The accused products provide a threshold voltage generator that generates reference voltages (e.g., VrefDQ) for the A/D conversion, where VrefDQ is generated from the variable supply voltage VDDQ and varies with it. | ¶25(v) | col. 2:1-4 |
Identified Points of Contention
- Technical Question: The complaint alleges that the accused LPDDR5 system's reference voltage (VrefDQ) is "usually ½ of" the variable supply voltage (VDDQ) and that a circuit onboard the DRAM generates it (Compl. ¶25(v), p. 9). A central evidentiary question will be whether the accused product's implementation of the LPDDR5 standard functions in a manner that is technically equivalent to the specific circuitry disclosed in the ’112 patent’s specification for generating threshold voltages.
- Scope Question: The ’112 patent's embodiments describe specific circuit blocks, such as a "sine wave clock generator" (Fig. 1, 120) and a "voltage distribution circuit" (Fig. 5A, 159). A potential dispute may arise over whether the scope of Claim 1 should be interpreted to cover any architecture that performs the claimed functions, such as the industry-standard LPDDR5 system, or if its scope is implicitly narrowed by the specific embodiments disclosed.
V. Key Claim Terms for Construction
The Term: "threshold voltage generator"
Context and Importance: This term recites the core inventive concept. The outcome of the infringement analysis will depend heavily on whether the LPDDR5 circuitry that generates the reference voltage (VrefDQ) is found to be a "threshold voltage generator" as defined by the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself defines the term functionally as a generator that creates "threshold voltages...generated from the variable power supply voltage" (’112 Patent, col. 14:58-65). The Summary of the Invention likewise describes the solution in broad, functional terms, which may support an interpretation that covers any circuit achieving this result, regardless of its specific implementation (’112 Patent, col. 2:1-9).
- Evidence for a Narrower Interpretation: The detailed description discloses a specific embodiment of the "threshold voltage generator 156" that includes a "peak voltage filter 158" and a "voltage distribution circuit 159" comprised of resistors (’112 Patent, col. 7:44-54; Figs. 5A-5B). A party could argue that the term should be construed as limited to structures similar to those explicitly disclosed as performing the function.
The Term: "multi-value analog signal"
Context and Importance: The nature of the signal being transmitted is a prerequisite for infringement. Practitioners may focus on this term because the signaling used in modern high-speed memory interfaces like LPDDR5, while multi-level, may be characterized differently than the "analog" signals depicted in the patent.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification suggests that these are "signals having a multi-value signal level of three or higher," a functional description that could encompass the multi-level signaling schemes used in LPDDR5 technology (’112 Patent, col. 4:50-52).
- Evidence for a Narrower Interpretation: Figures in the patent depict the "multi-value analog signal" ("Smulti") as a smoothly varying, continuous waveform that is then sampled to determine its value (’112 Patent, Fig. 9). A party could argue this implies a specific type of analog signal distinct from the discrete-level, pulse-amplitude modulated signals characteristic of many modern digital buses.
VI. Other Allegations
- Indirect Infringement: The complaint alleges inducement based on Defendant's knowledge of the ’112 Patent from the filing of the lawsuit, combined with its continued acts of "making, using, importing, offering for sale, and/or selling" the accused products (Compl. ¶30-31). It also cites "advertising an infringing use" as an active step to induce (Compl. ¶33).
- Willful Infringement: Willfulness is alleged based on knowledge acquired upon service of the complaint (Compl. ¶29). The complaint further alleges willful blindness, asserting that Defendant has a "practice of not performing a review of the patent rights of others first for clearance" before launching products (Compl. ¶34).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction: can the term "threshold voltage generator", as used in the patent, be broadly construed to cover the standardized reference voltage generation circuitry within the accused LPDDR5 memory systems, or is its meaning limited by the specific circuit embodiments disclosed in the patent's specification?
- A second central question will be one of technical equivalence: assuming a construction favorable to the plaintiff, does the accused LPDDR5 circuitry that generates a reference voltage (VrefDQ) from a supply voltage (VDDQ) operate in a way that is functionally and structurally the same as the invention claimed in the ’112 patent, or are there material differences in their technical operation?