UniQom LLC v. LG Electronics USA Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: UniQom LLC (New Mexico)
  • Defendant: LG Electronics U.S.A., Inc. (Delaware)
  • Plaintiff’s Counsel: Rabicoff Law LLC
• Case Identification: 7:25-cv-00358, W.D. Tex., 08/21/2025
• Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant has an established place of business in the District and has committed acts of patent infringement there.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to a digital identity device that uses a unique microprocessor identifier for secure electronic communications.
• Technical Context: The technology addresses the need for secure authentication in digital communications by linking a user's or entity's digital identity to a unique, permanent hardware identifier within a microprocessor.
• Key Procedural History: The patent-in-suit recently survived two ex parte reexamination proceedings initiated in 2023. The U.S. Patent and Trademark Office issued a reexamination certificate on April 19, 2024, confirming the patentability of claims 1-4, 12, and 13. This suggests that the asserted technology has withstood a recent validity challenge based on prior art.

Case Timeline

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

U.S. Patent No. 7,493,497 - "DIGITAL IDENTITY DEVICE"

The Invention Explained

• Problem Addressed: The patent's background section identifies a need in electronic communication for reliable authentication, wherein each party can be "clearly identifiable and distinguishable" to ensure security (’497 Patent, col. 1:13-18).
• The Patented Solution: The invention proposes a "digital identity device" that links a person's or corporation's digital identity data (e.g., name) to a unique hardware identifier inherent to a microprocessor. This "microprocessor identity information" is described as being permanently "etched" into the microprocessor's memory at the time of manufacture, creating a secure, hardware-based root of trust (’497 Patent, Abstract; col. 1:28-33; col. 4:1-15). An operating system then "binds" the digital identity data to this hardware identifier through an encryption process that uses the microprocessor identity information as a parameter, securing electronic transactions and communications (’497 Patent, col. 4:36-43).
• Technical Importance: This approach sought to improve digital security by tying identity verification to a unique physical component, making it more difficult to spoof or compromise than purely software-based credentials.

Key Claims at a Glance

• The complaint asserts "one or more claims" and "exemplary method claims" without specifying which ones (Compl. ¶11). Independent claim 1 is representative of the device claims.
• Independent Claim 1:
  • A digital identity device, comprising:
  • a microprocessor comprising a microprocessor identity that uniquely identifies the microprocessor, wherein the microprocessor comprises an on-die Programmable Read-Only Memory (PROM) and the microprocessor identity is etched into the PROM;
  • digital identity data, wherein the digital identity data identifies an owner of the digital identity device, wherein the digital identity data comprises a name of the owner;
  • a memory configured to store at least the digital identity data;
  • wherein the microprocessor identity is an alpha-numeric value; and
  • wherein the digital identity data is bound to the microprocessor identity by encrypting the digital identity data using an algorithm that uses the microprocessor identity.
• The complaint does not explicitly reserve the right to assert dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint refers to "Exemplary Defendant Products" that are identified in claim charts incorporated as Exhibit 2 (Compl. ¶¶11, 13). Because Exhibit 2 was not filed with the complaint, the specific accused products are not identified in the public record.

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 the products "practice the technology claimed by the '497 Patent" (Compl. ¶13).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant's "Exemplary Defendant Products" directly infringe "at least the exemplary method claims" of the ’497 Patent (Compl. ¶11). The specific mapping of claim elements to accused functionality is contained in Exhibit 2, which was not publicly filed (Compl. ¶13). The complaint’s narrative theory is that the Defendant's products "satisfy all elements of the Exemplary '497 Patent Claims" through their ordinary operation, as well as through internal testing by Defendant's employees (Compl. ¶¶12-13).

No probative visual evidence provided in complaint.

The complaint does not provide sufficient detail for a tabular analysis of infringement allegations.

Identified Points of Contention

• Scope Questions: A central question may be whether the term "etched into the PROM," which suggests a permanent physical marking during manufacturing, can be construed to cover modern methods of storing unique hardware keys, such as in secure enclaves or through physically unclonable functions (PUFs).
• Technical Questions: The complaint does not explain how the accused products perform the claimed function of "binding" digital identity data to a hardware identifier "by encrypting the digital identity data using an algorithm that uses the microprocessor identity." A point of contention will likely be the specific mechanism of this binding and encryption process in the accused products and whether it aligns with the claim language.

V. Key Claim Terms for Construction

• The Term: "microprocessor identity is etched into the PROM" (Claim 1)

  • Context and Importance: This term appears to define a specific physical implementation for storing the unique hardware identifier. Practitioners may focus on this term because its construction could determine whether the claim reads on contemporary security hardware, which may store unique identifiers in different ways than were common when the application was filed in 2000.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification's overall goal is to use a unique hardware identifier for security, suggesting the precise method of storing it may be less important than its uniqueness and permanence. The patent refers to this identity information as a "shortcut reference to the digital identity data," emphasizing its functional role ('497 Patent, col. 4:61-63).
    • Evidence for a Narrower Interpretation: The term "etched" implies a permanent, physical alteration. The specification reinforces this by stating the identity information "is etched at the time the microprocessor component... is etched" and "at the time of manufacturing," suggesting an unalterable, factory-set condition ('497 Patent, col. 6:1-3; col. 5:32-35).

• The Term: "digital identity data is bound to the microprocessor identity by encrypting the digital identity data using an algorithm that uses the microprocessor identity" (Claim 1)

  • Context and Importance: This limitation defines the core security link between the hardware and the digital data. The dispute will likely focus on what it means for an algorithm to "use" the microprocessor identity.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: This could be interpreted to cover any process where the microprocessor identity is an input, a key, or a seed for the encryption algorithm that protects the digital identity data.
    • Evidence for a Narrower Interpretation: The specification describes the operating system encoding data "by an algorithm that uses the microprocessor identity information 230" and using this information "as a parameter of encryption," which could support a narrower construction requiring the identity to be a direct, explicit input to the encryption function ('497 Patent, col. 4:41-43; col. 6:50-52).

VI. Other Allegations

The complaint does not provide sufficient detail for analysis of indirect or willful infringement.

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

• A core issue will be one of technological scope: Can the claim limitation "microprocessor identity... etched into the PROM," drafted in the context of early 2000s hardware, be construed to cover the sophisticated secure key storage mechanisms (e.g., secure enclaves) used in modern microprocessors? The outcome may depend on whether "etched" is interpreted as a specific manufacturing process or functionally as any method of creating a permanent, on-die identifier.
• A key evidentiary question will be one of technical proof: Given the proprietary and often opaque nature of modern hardware security architectures, a central challenge for the plaintiff will be to present evidence demonstrating precisely how the accused products perform the claimed "binding" and "encrypting" steps, and specifically how the hardware "microprocessor identity" is "used" by the encryption algorithm as required by the claims.