DCT

7:25-cv-00080

Modulus Systems LLC v. Silicon Laboratories Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:25-cv-00080, W.D. Tex., 02/19/2025
  • Venue Allegations: Venue is asserted on the basis that Defendant maintains an established place of business within the Western District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s radio frequency products infringe a patent related to the physical layout and configurable operation of a wireless module.
  • Technical Context: The technology concerns compact, integrated radio frequency (RF) modules used in a wide array of wireless devices, where component density and interference mitigation are significant design considerations.
  • Key Procedural History: The complaint does not reference any prior litigation, inter partes review proceedings, or licensing history concerning the patent-in-suit. The Plaintiff is the assignee of the patent.

Case Timeline

Date Event
2008-09-11 ’573 Patent Priority Date
2009-09-11 ’573 Patent Application Filing Date
2013-12-17 ’573 Patent Issue Date
2025-02-19 Complaint Filing Date

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

U.S. Patent No. 8,610,573 - Radio frequency module and methods of transmitting/receiving data, issued December 17, 2013

The Invention Explained

  • Problem Addressed: The patent describes challenges in designing compact RF modules, noting that prior art solutions were often limited in size due to the linear alignment of antenna and filtering components. (Compl. ¶9; ’573 Patent, col. 1:30-34). It also identifies problems with interference from other devices in the crowded 2.4 GHz band, such as those using Wi-Fi, and the limited configurability of existing modules. (’573 Patent, col. 1:35-51).
  • The Patented Solution: The invention claims a specific physical arrangement for the components of an RF module to achieve a smaller footprint. This involves a transceiver assembly, a matching/filtering network, and a chip antenna arranged to form a "generally U-shape configuration" on a printed circuit board, with a radio frequency shield covering the transceiver. (’573 Patent, Abstract; col. 2:1-17). This layout is intended to create an efficient antenna structure in a compact space. (’573 Patent, col. 5:35-43).
  • Technical Importance: The described solution addresses a persistent market demand for smaller, more power-efficient, and versatile wireless modules that can operate reliably in congested radio frequency environments. (’573 Patent, col. 1:26-29).

Key Claims at a Glance

  • The complaint asserts infringement of unspecified "exemplary claims" of the ’573 Patent. (Compl. ¶11). Independent claim 1, a representative apparatus claim, includes the following essential elements:
    • A base member including a printed circuit board
    • A transceiver assembly on the board, which includes a transceiver and a matching/filtering network with components in a linear arrangement
    • A ground plane on the board’s surface
    • A radio frequency shield coupled to the ground plane and covering a substantial portion of the transceiver assembly
    • A chip antenna located on the board outside of the shield and parallel to the matching/filtering network
    • A radio feed point connecting the antenna and network, where the antenna, network, and feed point together form a "generally U-shape configuration"
  • The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint alleges infringement by "Exemplary Defendant Products" that are identified in an incorporated Exhibit 2. (Compl. ¶11). This exhibit was not filed with the complaint, and the specific names or models of the accused products are not mentioned in the body of the complaint.

Functionality and Market Context

The complaint does not provide sufficient detail for analysis of the functionality or market context of the accused products. It alleges only that they "practice the technology claimed by the '573 Patent." (Compl. ¶16).

IV. Analysis of Infringement Allegations

The complaint references, but does not include, claim charts in an "Exhibit 2" that purportedly compare the "Exemplary '573 Patent Claims to the Exemplary Defendant Products." (Compl. ¶16). The body of the complaint alleges that these charts demonstrate that the accused products "satisfy all elements of the Exemplary '573 Patent Claims." (Compl. ¶16). Without access to this exhibit or a more detailed narrative, a specific element-by-element analysis of the infringement allegations is not possible.

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Evidentiary Questions: As the complaint lacks specific factual allegations mapping product features to claim elements, a primary point of contention will be whether the Plaintiff can produce evidence demonstrating that the accused products possess the specific physical architecture required by the asserted claims. The case may turn on evidence of the internal layout of Defendant’s products.
    • Scope Questions: A likely dispute will concern the scope of the phrase "generally U-shape configuration." The infringement analysis may depend on whether this term, which is defined primarily by reference to figures in the patent, can be construed to read on the physical layout of Defendant's products.

V. Key Claim Terms for Construction

  • "a generally U-shape configuration" (from Claim 1)
    • Context and Importance: This term is central to the claimed physical structure of the module. The infringement analysis will depend heavily on whether the arrangement of the antenna, filtering network, and feed point in the accused products falls within the scope of this term.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not provide a textual definition for the term, and the use of the word "generally" suggests a degree of flexibility beyond a perfect geometric "U" shape. Parties arguing for a broader scope may contend it applies to any layout where the antenna and filtering network are roughly parallel and connected at one end.
      • Evidence for a Narrower Interpretation: The specification consistently refers to the figures (e.g., FIG. 1, FIG. 2) when describing the invention. (’573 Patent, col. 2:15-17). A party may argue that the term should be limited to the specific embodiment shown, where the antenna and filtering network are parallel, adjacent, and form a distinct U-shape with the feed point. (’573 Patent, Fig. 1).
  • "a radio frequency shield ... covering at least a substantial portion of the transceiver assembly" (from Claim 1)
    • Context and Importance: The extent of coverage required by the shield is a potential point of dispute. Practitioners may focus on this term because the degree to which the accused products' shielding "covers" the internal components will be a factual question for infringement.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The term "substantial portion" is not explicitly defined, which could support a plain and ordinary meaning that does not require complete or near-complete coverage.
      • Evidence for a Narrower Interpretation: The figures show the shield 22 enclosing all components of the transceiver assembly 14 except for the antenna. (’573 Patent, Fig. 2; col. 4:6-10). A party could argue this disclosure limits "substantial portion" to mean covering nearly all of the assembly to achieve the patent's stated objectives.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant distributes "product literature and website materials" that instruct end users on how to use the accused products in a manner that infringes the ’573 Patent. (Compl. ¶14).
  • Willful Infringement: The allegation of willfulness is based on post-suit conduct. The complaint asserts that Defendant has actual knowledge of its infringement from the date of service of the complaint and that its continued infringing activities are therefore willful. (Compl. ¶¶13-14). No facts supporting pre-suit knowledge are alleged.

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

  1. An Evidentiary Question of Structure: The central issue appears to be factual: can the Plaintiff produce evidence that Defendant’s unnamed products contain the specific physical architecture claimed by the ’573 Patent? The case will likely depend on discovery into the internal layout of the accused products to determine if they meet the structural limitations of the claims, such as the "generally U-shape configuration."
  2. A Definitional Question of Scope: A core legal issue will be the construction of the claim term "generally U-shape configuration." The court’s determination of whether this term is limited to the patent’s depicted embodiment or encompasses a broader range of non-linear layouts will be critical in defining the scope of the patent and resolving the question of infringement.