Helix Microinnovations LLC v. NXP USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Helix Microinnovations LLC (Delaware)
  • Defendant: NXP USA, Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00241, W.D. Tex., 05/22/2025
• Venue Allegations: Venue is alleged to be proper based on Defendant maintaining an established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s methods for fabricating certain semiconductor products infringe a patent related to the manufacturing of Chip-on-Board modules using selectively settable materials.
• Technical Context: The technology concerns cost-effective manufacturing processes for semiconductor memory modules, specifically methods that enable the use of unpackaged and potentially partially-defective silicon die to build functional components.
• Key Procedural History: The complaint does not mention any prior litigation, inter partes review (IPR) proceedings, or licensing history related to the patent-in-suit.

Case Timeline

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

• Patent Identification: U.S. Patent No. 7,238,550, "Methods and apparatus for fabricating Chip-on-Board modules," issued July 3, 2007. (Compl. ¶8, ¶9).
• The Invention Explained:
  • Problem Addressed: The patent describes an "ongoing need in the art for means and methods of producing low cost semiconductor devices," particularly by salvaging "partially-defective" chips that would otherwise be wasted. (’550 Patent, col. 2:13-18). A further problem is that standard high-temperature "burn-in" testing can cause chip failures due to differing thermal expansion rates between the silicon die and the printed circuit board (PCB) on which it is mounted. (’550 Patent, col. 2:7-12).
  • The Patented Solution: The invention proposes a method for mounting an unpackaged die to a PCB using "selectively settable liquids," such as UV-curable adhesives. (’550 Patent, col. 3:1-4). A ring of this material is first hardened around the die to hold it in place, while a layer of the same material between the die and the PCB can remain liquid to serve as a physical and thermal buffer. (’550 Patent, col. 4:26-33, col. 11:57-64). A second layer of material is then applied over the first to "capture" the bonding wires that electrically connect the die to the PCB, securing them and preventing shorts. (’550 Patent, col. 4:41-55).
  • Technical Importance: This method was designed to reduce manufacturing costs by enabling the use of less-than-perfect die and to improve module reliability by mitigating thermal stress during testing. (’550 Patent, col. 2:49-54).
• Key Claims at a Glance:
  • The complaint alleges infringement of "one or more claims" and refers to "'Exemplary '550 Patent Claims'" identified in a non-proffered exhibit. (Compl. ¶11). Independent method claim 1 is a representative asserted claim.
  • Independent Claim 1:
    • mounting unpackaged die using a first layer of selectively-settable material;
    • hardening a ring of said first layer of selectively-settable material around a periphery said unpackaged die;
    • covering said first layer of selectively-settable material with a second layer of selectively-settable material; and
    • capturing bonding wires connecting said unpackaged die to a printed circuit board in said second layer of selectively-settable material.
  • The complaint does not explicitly reserve the right to assert dependent claims but alleges infringement of "one or more claims." (Compl. ¶11).

III. The Accused Instrumentality

• Product Identification: The complaint does not identify specific products by name. It accuses "Exemplary Defendant Products" that are identified in charts incorporated as Exhibit 2, which was not provided with the complaint. (Compl. ¶11, ¶13). The infringement allegations are directed at the methods used to manufacture these products.
• Functionality and Market Context: The complaint alleges that the accused products "practice the technology claimed by the '550 Patent." (Compl. ¶13). It further alleges direct infringement occurs through Defendant's acts of "making, using, offering to sell, selling and/or importing" products made by the infringing method, as well as through internal testing and use by employees. (Compl. ¶11, ¶12). The complaint does not provide further detail on the functionality or market context of the accused products.

IV. Analysis of Infringement Allegations

The complaint references, but does not include, "charts comparing the Exemplary ’550 Patent Claims to the Exemplary Defendant Products" as Exhibit 2. (Compl. ¶13). It alleges these charts demonstrate that the accused products "satisfy all elements of the Exemplary '550 Patent Claims." (Compl. ¶13).

In the absence of the specific claim charts, the infringement theory must be drawn from the general allegations. The complaint asserts that Defendant directly infringes the ’550 Patent by making, using, and selling products that are fabricated using the patented methods. (Compl. ¶11). This suggests the core of the infringement allegation is that Defendant’s manufacturing process for certain Chip-on-Board modules includes mounting an unpackaged die with a selectively settable material, hardening a portion of that material to fix the die's position, and using additional material to secure the bonding wires, thereby practicing the patented method. (Compl. ¶11, ¶13).

No probative visual evidence provided in complaint.

Identified Points of Contention:

• Technical Questions: A central question will be what specific materials and process steps comprise Defendant's manufacturing process. Without the claim charts, the complaint provides no evidence regarding how Defendant's process allegedly meets limitations such as "hardening a ring" while other material remains less cured, or how it performs the "capturing bonding wires" step.
• Scope Questions: A dispute may arise over whether Defendant's process, once revealed, constitutes "making" or "using" the claimed method in the United States. Further, it raises the question of whether the components used by Defendant qualify as "unpackaged die" as contemplated by the patent.

V. Key Claim Terms for Construction

• The Term: "selectively-settable material"

• Context and Importance: This term is the technological core of the asserted claims. Its definition will determine what types of manufacturing processes can infringe. Practitioners may focus on this term because its scope could be limited to the specific UV-curable liquids discussed in the specification or construed more broadly to cover other materials that can be hardened in a targeted manner.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claims use the general term "selectively-settable material" without limitation to a specific chemistry. (’550 Patent, col. 10:50-54). The specification states that "many types of adhesives may be used." (’550 Patent, col. 4:1-2).
  • Evidence for a Narrower Interpretation: The specification heavily emphasizes the use of "UV material" that can be hardened to different degrees using different wavelengths of light, and refers to a specific commercial product. (’550 Patent, col. 4:2-11). The detailed description of the process relies on the properties of these UV-curable liquids to achieve the distinct liquid buffer and hardened ring. (’550 Patent, col. 4:26-33).

• The Term: "capturing bonding wires"

• Context and Importance: This term defines the action of securing the fragile wires that connect the die to the circuit board. The infringement analysis will depend on whether "capturing" requires the specific two-layer trapping process described in the patent or if it can read on more generic encapsulation methods.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself does not specify the mechanism of capture, only that the wires are captured "in said second layer." (’550 Patent, col. 10:62-65).
  • Evidence for a Narrower Interpretation: The specification describes a specific process where wires are placed "within the second ring while the selectively settable material is still manageable and then hardening the ring." (’550 Patent, col. 4:48-51). Figure 4b and its accompanying description show the wires (415) physically trapped between layers of material (413, 416). (’550 Patent, col. 7:35-44).

VI. Other Allegations

• Indirect Infringement: The complaint does not include a count for indirect infringement and pleads no specific facts to support the elements of inducement or contributory infringement.
• Willful Infringement: The complaint does not allege willful infringement in the main body or plead any facts related to pre-suit or post-suit knowledge of the patent. The prayer for relief includes a request that the case be declared "exceptional" under 35 U.S.C. § 285, which allows for the award of attorney fees. (Compl., Prayer for Relief, ¶E.i).

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

1. An Evidentiary Question of Process: The complaint's infringement allegations are conclusory and rely entirely on an unprovided exhibit. A threshold issue will be whether Plaintiff can produce sufficient factual evidence to demonstrate how Defendant's specific, and currently undescribed, manufacturing process aligns with each step of the asserted method claims.
2. A Definitional Question of Material: The case will likely turn on the construction of "selectively-settable material". The central question for the court will be whether this term is limited to the UV-curable liquids that enable the distinct liquid-buffer and solid-ring functionality described in the patent's embodiments, or if it can be construed more broadly to encompass any material that can be hardened in a targeted fashion.
3. A Functional Question of "Capture": A key point of contention may be the meaning of "capturing bonding wires". The dispute will likely focus on whether the accused process performs the specific physical trapping action detailed in the patent’s specification, or whether a more general encapsulation of the wires is sufficient to meet this limitation.