InnoMemory LLC v. Sunflower Bank NA

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: InnoMemory, LLC (Texas)
  • Defendant: Sunflower Bank, N.A. (Colorado)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00050, W.D. Tex., 02/03/2025
• Venue Allegations: Plaintiff alleges venue is proper because Defendant maintains an established place of business in the district and has committed alleged acts of infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes 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), which is critical for extending battery life in portable electronic devices.
• 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 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 addresses the problem of high power consumption in conventional dynamic semiconductor memory devices, particularly when in a standby or reduced power mode (Compl. Ex. 1, '960 Patent, col. 2:48-56). In battery-powered devices, refreshing all memory cells, even those not containing essential data, wastes power and shortens standby time (Compl. Ex. 1, '960 Patent, col. 2:36-47).
• The Patented Solution: The invention proposes a method and architecture to refresh only specific, selected sections of a memory array instead of the entire array (Compl. Ex. 1, '960 Patent, col. 2:57-64). This is achieved by using control signals to selectively enable or disable the "periphery array circuits"—the support circuitry for memory sections—so that power is only consumed refreshing the sections designated to retain data (Compl. Ex. 1, '960 Patent, col. 3:26-32; FIG. 3). The selection of which sections to refresh is controlled by a programmable address signal (Compl. Ex. 1, '960 Patent, col. 11:43-48).
• Technical Importance: This approach allows for a more granular control of power usage in memory systems, a key consideration for the growing market of mobile and battery-operated electronics (Compl. Ex. 1, '960 Patent, col. 2:32-35).

Key Claims at a Glance

The complaint does not specify which claims it asserts, referring only to the "Exemplary '960 Patent Claims" (Compl. ¶11). Independent claim 1 is representative of the method claims.

• Independent Claim 1:
  • A method for reducing power consumption during background operations in a memory array with a plurality of sections, comprising the steps of:
  • 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 name any specific accused products or services. It refers generally to "Defendant products identified in the charts incorporated into this Count below (among the 'Exemplary Defendant Products')" (Compl. ¶11). However, the referenced charts in Exhibit 2 were not provided with the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the accused instrumentality's functionality or market context.

IV. Analysis of Infringement Allegations

The complaint alleges that "the Exemplary Defendant Products practice the technology claimed by the '960 Patent" and that they "satisfy all elements of the Exemplary '960 Patent Claims" (Compl. ¶13). It incorporates by reference claim charts from an "Exhibit 2" to substantiate these allegations (Compl. ¶14). As this exhibit was not included with the public filing, a detailed infringement analysis based on the complaint's allegations is not possible. The complaint contains no narrative description of how any accused product meets any specific claim limitation.

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

Based on the technology and representative Claim 1, the following terms may be central to the dispute.

• The Term: "background operations"

  • Context and Importance: The scope of this term defines the types of activities covered by the patent. Infringement will depend on whether the accused activities (e.g., power-saving modes) in the Defendant's products fall within this definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent suggests the term is not limited to a single function, stating the invention can be used to "control other background memory access operations and/or housekeeping operations," including "a parity checking operation" (Compl. Ex. 1, '960 Patent, col. 8:21-24).
    • Evidence for a Narrower Interpretation: The patent title and the vast majority of the specification focus specifically on "refresh operations" as the primary example of a background operation (Compl. Ex. 1, '960 Patent, Title; col. 2:12-14).

• The Term: "periphery array circuits"

  • Context and Importance: This term defines the specific circuitry that must be controlled to practice the invention. A central question will be whether the accused products contain analogous circuits and control them in the claimed manner.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term is used generally to refer to support circuitry for memory sections (Compl. Ex. 1, '960 Patent, col. 3:24-28).
    • Evidence for a Narrower Interpretation: Claim 5 and the detailed description explicitly define the group of circuits this term comprises, including "sense amplifiers, column multiplexer circuits, equalization circuits, and wordline driver circuits" (Compl. Ex. 1, '960 Patent, col. 11:63-68; FIG. 5).

• The Term: "programmable address signal"

  • Context and Importance: The nature of this signal is key to the claimed invention, as it dictates which memory sections are selected for the "background operations". Practitioners may focus on this term because infringement will require showing that the accused products use a signal that is both "programmable" and serves as an "address" for controlling memory sections in the claimed way.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general, not specifying the format or origin of the signal.
    • Evidence for a Narrower Interpretation: The specification describes this signal as "a block address" stored in a "refresh address register," suggesting a specific implementation where a register is programmed with data that points to memory blocks (Compl. Ex. 1, '960 Patent, col. 8:1-4; col. 4:55-58).

VI. Other Allegations

• Indirect Infringement: The complaint does not contain allegations of indirect infringement.
• Willful Infringement: The complaint does not contain factual allegations to support a claim for willful infringement. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285, but the complaint body provides no predicate facts for such a finding (Compl., Prayer ¶E.i).

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

The initial phase of this case will likely focus on resolving fundamental pleading deficiencies before reaching technical arguments. The central questions are:

1. Identification of the Accused Instrumentality: The primary and immediate question is one of specificity: what specific products or services of the Defendant are accused of infringement? The complaint's reliance on "Exemplary Defendant Products" detailed in an unprovided exhibit leaves the core of the accusation undefined.
2. Factual Basis for Infringement: A key evidentiary question will be one of technical mapping: what specific features of the yet-to-be-identified accused products allegedly perform the functions recited in the patent claims? Without this, it is impossible to assess the merits of the infringement claim.
3. Definitional Scope: Assuming the case proceeds, a core issue will be whether the power management or memory control systems in the accused products can be characterized as performing "background operations" by controlling "periphery array circuits" for distinct memory "sections" in response to a "programmable address signal", as those terms are construed from the patent.