Delta Electronics Inc v. Vicor Corp

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Delta Electronics, Inc. (Taiwan)
  • Defendant: Vicor Corporation (Delaware)
  • Plaintiff’s Counsel: Perkins Coie LLP
• Case Identification: 6:23-cv-00726, W.D. Tex., 10/23/2023
• Venue Allegations: Plaintiff alleges venue is proper because Defendant Vicor has a regular and established place of business in the district, specifically a facility in Cedar Park, Texas, and has committed acts of infringement in the district.
• Core Dispute: Plaintiff alleges that Defendant’s power converter products infringe a patent related to the structural design and manufacturing method of power converters.
• Technical Context: The technology concerns the physical packaging and interconnection of components within DC-to-DC power converters, which are critical for providing power to high-end electronics like data center servers.
• Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the patent-in-suit due to its own investigation of Plaintiff's patent portfolio before filing separate, prior complaints against Plaintiff in the ITC and the Eastern District of Texas.

Case Timeline

Date	Event
2015-10-09	'263 Patent Priority Date
2016-10-05	'263 Patent Application Filing Date
2017-11-14	'263 Patent Issue Date
2023-07-12	Date before which Defendant allegedly gained knowledge of '263 Patent
2023-10-23	Complaint Filing Date

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

U.S. Patent No. 9,819,263 - "Power Converter and Method for Manufacturing the Same," Issued November 14, 2017

The Invention Explained

• Problem Addressed: The patent addresses the challenge of designing connection pins for point-of-load (POL) power converters. The background section notes that as these converters become smaller and more powerful, their pins must handle high currents efficiently without taking up excessive space, which creates a design trade-off between application range, size, cost, and power consumption (’263 Patent, col. 1:35-52).
• The Patented Solution: The invention proposes a power converter architecture where electronic components are mounted on both the top and bottom surfaces of a central carrier, such as a printed circuit board (PCB). Crucially, the external connection parts (pins) are fabricated in a way that they receive mechanical support directly from one of the electronic components, rather than solely from the PCB or a separate bulky structure. This allows the connection parts to be smaller and designed primarily for electrical performance, as their structural integrity is derived from the component itself (’263 Patent, Abstract; col. 4:46-49). Figure 1 illustrates this general stacked arrangement with a carrier (PCB), a first component (C1) below, a second component (C2) above, and connection parts (P1, P2).
• Technical Importance: This design approach seeks to improve the power density and space utilization of the converter by minimizing the footprint and material cost associated with the connection pins, a key challenge in high-density electronics packaging (’263 Patent, col. 5:28-41).

Key Claims at a Glance

• The complaint asserts infringement of at least one claim without specifying which (Compl. ¶52). Independent claim 1 is representative of the apparatus claims.
• The essential elements of independent claim 1 include:
  • A carrier with an upper and lower surface.
  • A first electronic component disposed at the lower surface of the carrier.
  • A second electronic component disposed at the upper surface of the carrier.
  • A first connection part, which comprises:
    • a first terminal electrically coupled to the carrier.
    • a second terminal (a bonding pad) attached to a surface of the first electronic component apart from the carrier.
  • Wherein the carrier is disposed at 1/3 to 2/3 of the height of the power converter.
  • Wherein the first connection part is fabricated by mechanical support of the first electronic component.
• The complaint does not explicitly reserve the right to assert dependent claims, but makes a general allegation of infringement of "one or more claims" (Compl. ¶28).

III. The Accused Instrumentality

• Product Identification: The complaint identifies the "Vicor Accused Products" as a line of power converters designed and manufactured by Defendant (Compl. ¶29). It specifically names the "Vicor NBM2317S60D1580T0R power converter" as an exemplary infringing product (Compl. ¶46).
• Functionality and Market Context: The accused products are power converters used in various devices, including power supplies for servers (Compl. ¶29). The complaint alleges that Defendant manufactures these products in the United States and sells them directly and through distributors (Compl. ¶¶31, 32). It further alleges that Defendant provides datasheets and technical support to assist customers in integrating these converters into their own end-products (Compl. ¶¶35, 41).

IV. Analysis of Infringement Allegations

The complaint does not contain an element-by-element breakdown of its infringement allegations in its main body. Instead, it incorporates by reference an "Exhibit 2" which purportedly demonstrates how the accused products meet the claim limitations (Compl. ¶30). As this exhibit was not provided, a detailed claim chart analysis is not possible based on the complaint text alone.

The core of the infringement allegation is that Vicor's power converters, exemplified by the NBM2317S60D1580T0R, possess a physical structure that meets all the limitations of at least one claim of the ’263 Patent (Compl. ¶¶46, 52). No probative visual evidence provided in complaint.

• Identified Points of Contention:
  • Scope Questions: A central question may be whether the accused products, which are commercial power converter modules, fall within the scope of the patent's claims. For example, does the architecture of the Vicor converters include a "first connection part" that is "fabricated by mechanical support of the first electronic component"?
  • Technical Questions: The complaint's infringement theory rests on the assertion that the physical construction of Vicor's products is "substantially similar to the exemplary Vicor NBM2317S60D1580T0R power converter shown in Exhibit 2" (Compl. ¶48). A key factual question will be whether the internal structure of the accused products actually incorporates the claimed method of using an electronic component to provide mechanical support to its electrical terminals, as opposed to more conventional mounting techniques.

V. Key Claim Terms for Construction

• The Term: "fabricated by mechanical support of the first electronic component" (from Claim 1)
• Context and Importance: This phrase appears to describe the core inventive concept of the patent. The infringement analysis will likely turn on the definition of this limitation. Practitioners may focus on this term because it distinguishes the invention from prior art where connection pins are supported primarily by the PCB or other housing structures. The construction will determine whether infringement requires a specific manufacturing process or merely a resulting structure where one component provides physical stability to another.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The plain language of the claim suggests a structural outcome: a connection part that is, in its final form, mechanically supported by the component. This could potentially read on any design where the component bears a significant portion of the mechanical load for the connection part, regardless of the specific manufacturing steps.
  • Evidence for a Narrower Interpretation: The specification, particularly the description of the manufacturing method, provides a more specific context. It describes a process of bonding a component to a lead frame, cutting away part of the frame, and then "curving the connection part by mechanical support of the first electronic component to fix the connection part at the first electronic component" (’263 Patent, col. 9:44-51, step 2330). This could support a narrower construction requiring the fabrication process itself to use the electronic component as a tool or jig to form the connection part, or for the connection part to be an integral piece of a lead frame attached to the component.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement under 35 U.S.C. § 271(b), stating that Vicor provides "datasheets and other technical and marketing materials that actively encourage Vicor's customers to incorporate and implement the Vicor Accused Products in an infringement manner" (Compl. ¶41, ¶55). It also alleges contributory infringement under § 271(c), asserting that the accused products are a "material part of the infringing functionality" and are not a "staple article or commodity of commerce suitable for substantial noninfringing use" (Compl. ¶56).
• Willful Infringement: Willfulness is alleged based on Defendant’s purported knowledge of the ’263 Patent. The complaint alleges this knowledge arises from two sources: (1) Vicor’s status as an active competitor that "would have periodically investigated Delta's patent portfolio" (Compl. ¶42), and (2) Vicor’s "pre-suit investigation of Delta before filing complaints against Delta" in other venues, which allegedly occurred "before July 12, 2023" (Compl. ¶43).

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

The resolution of this case may depend on the answers to two central questions:

1. A core issue will be one of claim construction: how narrowly will the court define the phrase "fabricated by mechanical support of the first electronic component"? Does it describe a general structural relationship, or does it require a specific manufacturing method, such as one involving a lead frame being physically formed using the component?

2. A key evidentiary question will be one of technical implementation: assuming a construction of the key claim term, what does a physical teardown and analysis of the accused Vicor power converters reveal? Do their connection terminals derive structural support from an electronic component in the manner required by the claims, or are they supported by the converter's substrate or housing in a conventional way?