DCT

7:25-cv-00047

InnoMemory LLC v. Simply Nuc Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:

  • Case Identification: 7:25-cv-00047, W.D. Tex., 02/03/2025

  • Venue Allegations: Venue is alleged to be proper based on the Defendant maintaining an established place of business within the Western District of Texas.

  • Core Dispute: Plaintiff alleges that Defendant’s products, which are not specifically identified, infringe a patent related to methods for reducing power consumption in memory devices during refresh operations.

  • Technical Context: The technology concerns power-saving techniques in Dynamic Random Access Memory (DRAM), a critical component in electronic devices, by selectively refreshing only necessary portions of the memory array.

  • Key Procedural History: The patent-in-suit is a continuation of a prior application filed in 2002. The complaint does not mention any other prior litigation, licensing history, or administrative proceedings related to the patent.

Case Timeline

Date Event
2002-03-04 '960 Patent Priority Date
2003-07-29 '960 Patent Application Filing Date
2006-06-06 U.S. Patent No. 7,057,960 Issues
2025-02-03 Complaint Filed

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"

The Invention Explained

  • Problem Addressed: The patent describes a problem with conventional DRAMs in battery-powered devices, where significant power is consumed in standby mode because the entire memory array is periodically refreshed to prevent data loss, even when only a small portion of the data needs to be retained (Compl. ¶9; ’960 Patent, col. 1:36-56). Conventional methods that refresh only a portion of the memory still activate the support circuitry for the entire array, leading to unnecessary power consumption (’960 Patent, col. 2:25-30).
  • The Patented Solution: The invention proposes a method and architecture to reduce this power consumption by enabling the selective refresh of independent sections (e.g., quadrants) of the memory array (’960 Patent, Abstract). This is achieved by using control signals, generated in response to a programmable address, to activate the "periphery array circuits" (such as wordline drivers and sense amplifiers) only for the specific sections being refreshed, while leaving the circuitry for other sections inactive (’960 Patent, col. 2:36-44, Fig. 5).
  • Technical Importance: This approach aimed to reduce standby power consumption, a critical factor for extending the battery life of the growing market of mobile devices like portable telephones in the early 2000s (’960 Patent, col. 1:33-47).

Key Claims at a Glance

  • The complaint asserts infringement of "at least the exemplary method claims" (Compl. ¶11). Independent method claim 1 is representative.
  • Independent Claim 1: A method for reducing power consumption in a memory array, comprising the steps of:
    • Controlling background operations in each of a plurality of sections of the memory array in response to one or more control signals.
    • The control signals are generated in response to a programmable address signal.
    • The background operations can be enabled simultaneously in two or more sections independently of any other section.
    • Presenting the control signals and one or more decoded address signals to one or more periphery array circuits of the sections.
  • The complaint does not explicitly reserve the right to assert dependent claims but refers to infringing "one or more claims" (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not identify any specific accused products by name. It refers generally to "Exemplary Defendant Products" that are purportedly identified in claim charts attached as Exhibit 2 (Compl. ¶11, ¶13).

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused products' functionality or market context. All technical details regarding the alleged infringement are incorporated by reference from an exhibit that was not included with the filed complaint (Compl. ¶14).

IV. Analysis of Infringement Allegations

The complaint alleges that infringement is detailed in claim charts provided in Exhibit 2; however, this exhibit was not provided (Compl. ¶13-14). The narrative allegations state that "the Exemplary Defendant Products practice the technology claimed by the '960 Patent" and "satisfy all elements of the Exemplary '960 Patent Claims" (Compl. ¶13). No probative visual evidence provided in complaint.

Identified Points of Contention

  • Evidentiary Questions: A primary question will be what evidence Plaintiff can produce to show that Defendant’s products practice the claimed method. The complaint's lack of specific factual allegations regarding the operation of the accused products places the entire burden of demonstrating infringement on evidence that may be produced later in the case.
  • Technical Questions: A key technical question will be whether the accused products, which likely utilize modern memory technologies, use a "programmable address signal" to selectively enable "periphery array circuits" for distinct sections of a memory array during "background operations" in the manner required by Claim 1.
  • Scope Questions: The dispute may raise the question of whether the term "periphery array circuits", as defined in a 2002-priority patent, can be construed to read on the architecture of the integrated memory controllers and power management units found in modern computer systems.

V. Key Claim Terms for Construction

"background operations" (Claim 1)

  • Context and Importance: The scope of this term defines the types of activities to which the claimed power-saving method applies. A narrow definition could limit the claim’s applicability. Practitioners may focus on this term to determine if it is limited to the specific "refresh operations" mentioned throughout the patent or covers a wider range of low-power memory maintenance tasks.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests the term is not limited to refresh, stating the invention may be used "to control other background memory access operations and/or housekeeping operations," including "a parity checking operation" (’960 Patent, col. 8:21-25).
    • Evidence for a Narrower Interpretation: The patent's title, abstract, and background section consistently and repeatedly frame the invention in the context of "refresh operations," which may support an argument that this is the intended and sole meaning of the term (’960 Patent, Title; Abstract; col. 1:12-15).

"programmable address signal" (Claim 1)

  • Context and Importance: This term is critical as it is the input that allegedly dictates which sections of the memory are refreshed. The nature of this "programmability" will be a central point of contention in determining infringement.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general, not specifying the mechanism of programmability. This could support a reading on any system where a user or operating system can designate memory regions for different power states.
    • Evidence for a Narrower Interpretation: The specification describes this signal in a specific context: "The portion of the array to be refreshed may be controlled by information (e.g., a block address) stored in a refresh address register" (’960 Patent, col. 8:2-5). This could be used to argue that the term requires a dedicated, hardware-based "refresh address register" as depicted in the patent's figures (e.g., Fig. 3, element 138).

VI. Other Allegations

Indirect Infringement

The complaint does not plead any specific facts to support claims of induced or contributory infringement. The allegations are limited to direct infringement (Compl. ¶11-12).

Willful Infringement

The complaint does not allege pre- or post-suit knowledge of the patent or other facts that would typically support a claim for willful infringement. However, the prayer for relief requests a judgment that the case be "declared exceptional within the meaning of 35 U.S.C. § 285" (Compl. p. 4, ¶E(i)).

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

  • A central issue is one of evidentiary support: Given that the complaint lacks specific factual allegations and omits the referenced claim charts, a threshold question is whether Plaintiff can produce, through discovery or other means, concrete evidence that Defendant’s modern products implement the specific, multi-step power-saving method claimed in the '960 patent.

  • The case will also turn on claim construction: A key legal question will be whether the scope of terms like "periphery array circuits" and "programmable address signal", which are rooted in the DRAM architecture of the early 2000s, can be construed to cover the potentially different power management systems and integrated memory controllers used in contemporary computer products.