InnoMemory LLC v. Rio Bank

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: Rio Bank (Texas)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00046, W.D. Tex., 02/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant has an established place of business in the Western District of Texas and has committed acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods for reducing power consumption in computer memory by selectively refreshing portions of a memory array.
• Technical Context: The technology addresses power efficiency in dynamic random-access memory (DRAM), a critical consideration for battery-powered and mobile devices where minimizing standby power usage is paramount.
• Key Procedural History: The patent-in-suit is a continuation of a prior application. The complaint does not mention any other prior litigation, licensing history, or post-grant proceedings.

Case Timeline

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

U.S. Patent No. 7,057,960 - "Method and architecture for reducing the power consumption for memory devices in refresh operations"

• Issued: June 6, 2006

The Invention Explained

• Problem Addressed: The patent describes a problem with conventional dynamic semiconductor memory devices (DRAMs), which must periodically refresh all memory cells to prevent data loss due to electrical leakage. This constant refresh process consumes significant power, especially in standby mode, which is detrimental for battery-powered devices like portable telephones (’960 Patent, col. 2:30-56). Conventional methods refresh the entire memory array even if only a portion of it contains data that needs to be retained, leading to unnecessary power consumption (’960 Patent, col. 2:25-29).
• The Patented Solution: The invention proposes a method and architecture to reduce power consumption by selectively refreshing only specific sections (e.g., "quadrants") of the memory array that contain essential data, while leaving the support circuits for other sections inactive (’960 Patent, Abstract; col. 2:46-56). This is achieved by using control signals, generated in response to a programmable address, to enable or disable the "periphery array circuitry" for each individual section of memory, thereby minimizing the power used during a refresh cycle (’960 Patent, col. 4:47-54; Fig. 3).
• Technical Importance: This approach allows for a more granular control over power usage in DRAM, enabling lower standby power modes critical for extending the battery life of the growing mobile device market at the time of the invention (’960 Patent, col. 2:30-34).

Key Claims at a Glance

• The complaint does not identify specific claims, asserting infringement of "one or more claims" (’960 Patent, Compl. ¶11). Independent claim 1 is representative of the patented method.
• Independent Claim 1 (Method):
  • controlling said background operations in each of said plurality of sections of said memory array in response to one or more control signals,
  • wherein said one or more control signals are generated in response to a programmable address signal,
  • and said background operations can be enabled simultaneously in two or more of said plurality of sections independently of any other section; and
  • presenting said one or more control signals and one or more decoded address signals to one or more periphery array circuits of said plurality of sections.

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products, services, or methods by name (Compl. ¶¶11-14). It refers generally to "Exemplary Defendant Products" and incorporates by reference "charts of Exhibit 2," which are not attached to the filed complaint (Compl. ¶13, 14).

Functionality and Market Context

The complaint alleges that Defendant, a bank, has directly infringed by "making, using, offering to sell, selling and/or importing" the unspecified products (Compl. ¶11). It further alleges that Defendant's employees "internally test and use these Exemplary Products" (Compl. ¶12). The complaint does not provide sufficient detail for analysis of the functionality or market context of any accused instrumentality. No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not contain specific infringement allegations or claim charts mapping patent claims to accused products. It states that "Exhibit 2 includes charts comparing the Exemplary ’960 Patent Claims to the Exemplary Defendant Products," but this exhibit was not provided (Compl. ¶13). The infringement theory is therefore limited to the conclusory allegation that the unspecified "Exemplary Defendant Products practice the technology claimed by the ’960 Patent" (Compl. ¶13). Without identification of an accused product or the specific claims asserted, a detailed infringement analysis is not possible based on the complaint.

V. Key Claim Terms for Construction

• The Term: "background operations"

  • Context and Importance: This term defines the scope of the activity being controlled. The infringement analysis will depend on whether this term is limited to the primary example of "refresh operations" or if it encompasses other activities. Practitioners may focus on this term to determine if the accused devices perform the specific type of "background operation" claimed.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests other operations may be included, stating the invention may be implemented to control "other background memory access operations and/or housekeeping operations," including "a parity checking operation" (’960 Patent, col. 8:21-25). Claim 4 also explicitly recites "parity checking."
    • Evidence for a Narrower Interpretation: The patent title, abstract, and background are heavily focused on "refresh operations" as the primary context (’960 Patent, Title; Abstract; col. 2:12-13). Claim 2 explicitly limits "background operations" to "a refresh operation."

• The Term: "programmable address signal"

  • Context and Importance: This term is central to how the selective refresh is initiated and controlled. The definition of "programmable" will be critical to determining infringement, as it distinguishes the invention from systems with fixed or non-programmable refresh schemes.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: Claim 1 itself uses the general term "programmable address signal" without further limitation, suggesting it could cover any signal that can be programmed to select different sections.
    • Evidence for a Narrower Interpretation: The preferred embodiment describes a specific implementation where this signal is a "refresh block address" (signal AR1) that is loaded into a "refresh address register" (register 138) (’960 Patent, col. 4:30-34; Fig. 3). An argument could be made that the term should be limited to this disclosed register-based implementation.

VI. Other Allegations

Willful Infringement

The complaint does not explicitly allege willful infringement. However, the prayer for relief requests a judgment that awards "all appropriate damages under 35 U.S.C. § 284" (which allows for up to treble damages) and a declaration that the "case be declared exceptional" for the purpose of awarding attorneys' fees under § 285 (Compl. ¶¶D, E.i). These requests are typically predicated on allegations of willful or egregious conduct. The complaint does not, however, plead any specific facts to support pre-suit or post-suit knowledge of the patent.

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

• Pleading Sufficiency: A threshold procedural question will be one of pleading sufficiency: Does the complaint, by failing to identify any accused product and instead relying on a missing exhibit, provide the defendant with fair notice and state a plausible claim for relief as required by federal pleading standards?
• Instrumentality Identification: A fundamental evidentiary question will be one of instrumentality identification: What specific computer systems, servers, or other hardware used by Rio Bank, a financial institution, are alleged to contain memory components that practice the patented power-saving architecture, and what evidence will Plaintiff offer to substantiate these allegations?
• Operational Mapping: A key technical question for infringement will be one of operational mapping: Assuming an accused memory device is identified, does its method of managing power states and refresh cycles meet the specific claim limitation of enabling sections "independently of any other section" in response to a "programmable address signal," or does it operate via a different, non-infringing mechanism?