Heritage IP LLC v. Motorola Solutions Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Heritage IP LLC (Texas)
  • Defendant: Motorola Solutions, Inc. (Delaware)
  • Plaintiff’s Counsel: Banie & Ishimoto LLP
• Case Identification: 2:22-cv-01374, W.D. Wash., 09/27/2022
• Venue Allegations: Venue is alleged to be proper in the Western District of Washington because Defendant maintains a regular and established place of business within the district.
• Core Dispute: Plaintiff alleges that Defendant’s specified product infringes a patent related to programmable reset circuits for electronic devices that use multiple power supply voltages.
• Technical Context: The technology concerns power management within complex integrated circuits, specifically ensuring system stability by triggering a reset when one of several different power supplies fails.
• 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

U.S. Patent No. 7,221,200 - "Programmable Low Voltage Reset Apparatus for Multi-VDD Chips"

The Invention Explained

• Problem Addressed: The patent describes a problem with conventional low-voltage reset circuits, which are typically designed for a single, fixed power supply. Such circuits are inadequate for modern devices that use multiple power supplies at different voltages (e.g., 3.3V and 5V) on the same chip, as they cannot manage a reset if one of these multiple supplies fails (’200 Patent, col. 1:46-53).
• The Patented Solution: The invention proposes a programmable and adaptable reset apparatus. It includes a "reset selector" that allows a user to choose which power supply to monitor and a "programmable reference voltage generator" that adjusts the voltage threshold at which a reset is triggered. This allows a single, flexible circuit to be configured via firmware to handle various power supply scenarios within a multi-voltage environment (’200 Patent, Abstract; col. 2:1-4). For example, a multiplexer can act as the reset selector to enable or disable monitoring of a specific power supply signal (’200 Patent, col. 2:60-68).
• Technical Importance: This approach enables a single microcontroller or chip to reliably interface with different devices on a circuit board that may operate at different power levels, enhancing design flexibility and preventing data corruption from partial power loss (’200 Patent, col. 1:54-59).

Key Claims at a Glance

• The complaint does not specify which claims are asserted, alleging infringement of "at least one or more claims" (Compl. ¶5).
• Independent Claim 1, an apparatus claim, includes the following essential elements:
  • A programmable reference voltage generator for generating a programmable reference voltage according to a power supply voltage.
  • A low voltage signal generator, coupled to the reference voltage generator, for generating a low voltage signal when the power supply voltage falls below the reference voltage.
  • A reset selector, coupled to the low voltage signal generator, for selectively passing the low voltage signal as a reset signal based on a control signal.
• The complaint does not preclude the assertion of other independent or dependent claims.

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused instrumentality as "at least Motorola Solutions PMLN5792" ("Accused Product") (Compl. ¶2).

Functionality and Market Context

The complaint does not provide any specific details regarding the technical operation, internal architecture, or specific features of the Accused Product. It alleges that Defendant develops, manufactures, and sells the Accused Product in the United States and within the state of Washington (Compl. ¶9). The commercial importance of the product is not detailed.

IV. Analysis of Infringement Allegations

The complaint does not provide a claim chart or specific factual allegations mapping features of the Accused Product to the limitations of any asserted claim. It alleges infringement in a conclusory manner, stating that Defendant infringes by making, using, or selling the Accused Product (Compl. ¶19). Due to the lack of detail, a claim chart summary cannot be constructed.

• Identified Points of Contention: Given the complaint’s lack of technical detail, the central infringement questions are currently foundational and speculative.
  • Evidentiary Question: A primary issue for the court will be whether discovery reveals that the Accused Product contains circuitry that performs the functions recited in the asserted claims. For instance, what evidence will show that the PMLN5792 product incorporates a "programmable reference voltage generator" and a "reset selector" as claimed?
  • Technical Question: A key technical question will be whether the Accused Product's internal architecture, once understood, aligns with the specific functional requirements of the claims. For example, does the accused circuitry generate a reset signal "in response to a reset selector control signal," or does it operate in a fundamentally different manner?

No probative visual evidence provided in complaint.

V. Key Claim Terms for Construction

• The Term: "programmable reference voltage generator" (from Claim 1)

• Context and Importance: The "programmable" nature of the reference voltage is a core inventive concept, allowing the circuit to adapt to different power supply levels. The outcome of the infringement analysis may depend on whether the accused device’s method for setting a voltage threshold falls within the construed scope of this term.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim language itself is functional and does not specify a particular structure, potentially covering any generator whose reference voltage can be configured or changed.
  • Evidence for a Narrower Interpretation: The specification discloses a specific embodiment where programmability is achieved by a user writing to a configuration register (70) to select different tapping points (65) on a resistor ladder (60) (’200 Patent, col. 4:35-51; Fig. 3). A party may argue that "programmable" should be construed to require a similar mechanism of user-configurable firmware or register writes.

• The Term: "reset selector" (from Claim 1)

• Context and Importance: This term is critical for establishing the claimed ability to choose which power supply to monitor. Infringement will require identifying a corresponding structure or function in the Accused Product. Practitioners may focus on this term to dispute whether a component in the accused device performs the required selective function.

• Intrinsic Evidence for Interpretation:

  • Evidence for a Broader Interpretation: The claim describes the element functionally, as being "for selectively passing the low voltage signal." This could support an interpretation that covers any component, whether hardware or software-controlled, that performs this selective gating function.
  • Evidence for a Narrower Interpretation: The patent's detailed description illustrates the "reset selector" as a hardware multiplexer (20) controlled by a D-type flip-flop (30) (’200 Patent, col. 2:60-62, col. 3:7-12; Fig. 2). A party could argue that the term should be limited to this or structurally similar implementations.

VI. Other Allegations

• Indirect Infringement: The complaint alleges induced infringement by asserting that Defendant provides the Accused Product with instructions that encourage infringing use (Compl. ¶21, ¶23). It also alleges contributory infringement, stating the Accused Product contains material components specially made for infringement that are not staple articles of commerce and have no substantial non-infringing uses (Compl. ¶24).
• Willful Infringement: The complaint alleges that Defendant has had "actual knowledge of the ’200 Patent" at least as early as the filing of the complaint, forming the basis for a claim of post-suit willful infringement (Compl. ¶20, ¶25).

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

1. An Evidentiary Question of Functionality: The foremost issue is factual and depends entirely on discovery. Does the Motorola PMLN5792 product—whose technical operation is not described in the complaint—contain circuitry that actually performs the power monitoring functions recited in the '200 Patent's claims? The case cannot proceed without evidence establishing this foundational link.

2. A Definitional Question of Scope: Assuming the accused device is found to have some form of voltage monitoring, a central issue will be one of claim construction. Will key terms like "programmable reference voltage generator" and "reset selector", which are detailed with specific hardware embodiments in the patent, be interpreted broadly enough to encompass the (currently unknown) specific architecture implemented in the Accused Product?