DCT

2:25-cv-01824

Merle Innovations Inc v. Intel Corp

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:25-cv-01824, W.D. Wash., 09/19/2025
  • Venue Allegations: Venue is alleged to be proper based on Defendants maintaining regular and established places of business in the district and committing acts of infringement within the district. The complaint also notes a local interest, as the patented inventions were developed at the University of Washington, located within the district.
  • Core Dispute: Plaintiff alleges that semiconductor chips designed and sold by Intel, and later by Apple, for use in products such as iPhones and other wireless devices, infringe a patent related to a switched-capacitor architecture for radio frequency power amplifiers.
  • Technical Context: The technology concerns all-digital power amplifiers designed for integration into modern CMOS semiconductor processes, a key component for improving power efficiency and enabling cost-effective, single-chip radios in battery-powered devices.
  • Key Procedural History: The complaint alleges an extensive history of pre-suit knowledge by Intel, beginning in 2010 with direct disclosures from a named inventor who was an intern at Intel. It further alleges that Intel praised the technology, discussed licensing, but ultimately incorporated the invention without a license. Plaintiff asserts that Intel subsequently filed for and obtained its own patent (U.S. Patent No. 9,490,834) that copied diagrams from the patent-in-suit. This business unit and the associated patent were later acquired by Apple in 2019.

Case Timeline

Date Event
2010-05-12 ’177 Patent Priority Date
2010-07-13 Inventor allegedly discloses SCPA invention to Intel engineers
2013-10-01 U.S. Patent No. 8,547,177 Issues
2016-09-01 Apple allegedly launches iPhone 7 with infringing Intel chip
2017-09-01 Plaintiff Merle Innovations, Inc. is founded
2018-12-06 Apple allegedly cites inventors' publication in an IDS
2019-07-25 Apple announces acquisition of Intel's smartphone modem business
2019-09-01 Apple allegedly launches iPhone 11 with infringing Intel chip
2019-12-02 Apple completes acquisition of Intel's modem business
2025-02-19 Apple reportedly launches its first in-house modem (C1)
2025-09-19 Complaint Filed

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

U.S. Patent No. 8,547,177 - "All-Digital Switched-Capacitor Radio Frequency Power Amplification"

The Invention Explained

  • Problem Addressed: The patent describes the difficulty of fully implementing radio frequency (RF) power amplifiers in high-volume complementary metal-oxide-semiconductor (CMOS) systems. Conventional designs face inherent tradeoffs between output power, energy efficiency, and linearity, which has limited the ability to create cost-effective, fully integrated single-chip radio systems (’177 Patent, col. 1:29-43).
  • The Patented Solution: The invention discloses a new digital power amplifier architecture, termed a Switched-Capacitor Radio Frequency Power Amplifier (SCPA). This architecture uses a plurality of parallel stages, where each stage contains a selection circuit, a switch, and a storage element (e.g., a capacitor). The system controls the amplifier's output amplitude by selectively activating a number of these stages based on the amplitude of the signal to be amplified (’177 Patent, col. 2:15-31). The outputs from all stages are then combined to form an amplified approximate square wave, which can be filtered to produce the final amplified RF signal (’177 Patent, Abstract; Fig. 1).
  • Technical Importance: This digitally-controlled, capacitor-based architecture is particularly well-suited for fabrication in modern CMOS processes and "benefits from continued CMOS technology scaling," allowing for more power-efficient and highly integrated RF amplifiers in consumer electronics (’177 Patent, col. 3:33-38).

Key Claims at a Glance

  • The complaint asserts infringement of at least independent Claim 1 and dependent Claims 2-10, and reserves the right to assert all 20 claims (’177 Patent, col. 12:27-14:31; Compl. ¶¶73, 81, 84, 87, 90, 93, 96, 99, 105, 108).
  • Independent Claim 1 requires:
    • A power amplifier circuit comprising a plurality of stages.
    • Each stage must include:
      • a selection circuit configured to output a selection signal;
      • a switch configured to receive the selection signal, select an input signal based on it, and output the selected input signal; and
      • a storage element with a first terminal coupled to the switch's output and a second terminal providing an output signal.
    • A combination circuit configured to combine the output signals from each stage's storage element to provide a combined output signal.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies three categories of accused products: "Intel Accused Products," "Apple Accused Products," and "Jointly Accused Products" (Compl. ¶66). These include:
    • Intel-designed radio frequency transceivers and chips (e.g., PMB5750, SMARTi5-8 series, Wi-Fi 6/6E/7 products, Bluetooth products) (Compl. ¶63).
    • Apple devices that incorporate the accused Intel chips, such as the iPhone 7 through iPhone 11 product lines (Compl. ¶64).
    • Apple's in-house designed wireless chips (e.g., C1, C1X, and N1 modems), which are alleged to be based on the technology Apple acquired from Intel (Compl. ¶¶54-57, 64).

Functionality and Market Context

  • The accused instrumentalities are components that provide wireless connectivity (e.g., cellular, Wi-Fi, Bluetooth) for a vast range of consumer electronics, most notably Apple's iPhones (Compl. ¶¶49, 63). The complaint alleges that the power amplifier portion of these chips employs the patented switched-capacitor architecture (Compl. ¶¶63(a), 64(a)).
  • The complaint alleges these products represent a major commercial success, citing Apple's $1 billion acquisition of Intel's smartphone modem business in 2019 as evidence of the value of the allegedly infringing technology (Compl. ¶¶50-51).

IV. Analysis of Infringement Allegations

The complaint's infringement theory is primarily based on the allegation that the Accused Products implement the architecture described in Intel's U.S. Patent No. 9,490,834 (the "'834 Patent"), which Plaintiff in turn alleges was copied from the ’177 Patent (Compl. ¶¶71, 74). The complaint presents side-by-side diagrams from the ’177 Patent and the ’834 Patent to support its copying claim. A side-by-side comparison of circuit diagrams from the '177 Patent (Figure 5) and Intel's later-filed '834 Patent (Figure 4) with annotations alleges at least 17 replicated circuit elements (Compl. ¶43, p. 16). The following chart summarizes the infringement allegations for Claim 1 by mapping them to descriptions from the ’834 Patent as cited in the complaint.

U.S. Patent No. 8,547,177 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality (based on the '834 Patent proxy) Complaint Citation Patent Citation
a plurality of stages... A power amplifier circuit comprising a "plurality of capacitive elements 130-1, 130-2, . . ., 130-n," with each capacitive element forming part of a stage. ¶75 col. 2:33-34
each stage comprising: a selection circuit configured to output a selection signal; Each stage comprises a selection circuit (identified as selection logic 160 and switch driver 170) that is configured to output a selection signal to a switch. ¶76 col. 2:35-37
a switch configured to (a) receive the selection signal from the selection circuit, (b) select an input signal based on the received selection signal... Each stage includes a switch (180) that receives the selection signal and, based on it, selects an input signal such as a voltage (e.g., 2VDD) or Ground. ¶77 col. 2:40-42
and (c) output the selected input signal; The switch (180) outputs the selected input signal to the storage element (130-1). ¶77 col. 2:42-44
a storage element, wherein the storage element has (a) a first terminal coupled to an output of the switch and (b) a second terminal configured to provide an output signal Each stage includes a storage element (130-1) with a first terminal connected to the switch output and a second terminal that provides an output voltage. ¶78 col. 2:44-49
a combination circuit configured to provide a combined output signal by combining the output signal provided at the second terminal of each storage element... A combination circuit (described as a "wire OR" circuit) combines the output signals from the second terminal of each storage element (130-1 to 130-n). ¶79 col. 2:49-54
  • Identified Points of Contention:
    • Evidentiary Questions: The complaint's infringement case relies heavily on establishing that the accused products practice the teachings of the '834 Patent. A primary point of contention may be whether the Plaintiff can provide sufficient evidence to link the actual circuitry of the diverse accused products (spanning nearly a decade of releases) to the specific diagrams in the '834 Patent.
    • Scope Questions: The interpretation of "selection circuit" may become a focal point. The complaint maps this single claim element to two distinct components in the '834 patent's diagram (selection logic 160 and switch driver 170) (Compl. ¶76). This raises the question of whether this combination of components in the accused products performs the function of the single claimed "selection circuit" in the manner disclosed by the ’177 Patent.

V. Key Claim Terms for Construction

  • The Term: "selection circuit"

  • Context and Importance: This term defines the control element within each amplifier stage that translates amplitude information into a switching decision. The scope of this term will be critical because if the accused logic and driver blocks do not collectively meet the definition of a "selection circuit," the infringement argument may fail. Practitioners may focus on whether the term implies a single, integrated component or can cover a distributed set of logic elements as alleged in the complaint.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The patent describes the circuit functionally, stating it is "configured to output a selection signal" and "interpret the amplitude information" to cause the switch to select the correct corresponding voltage (’177 Patent, col. 5:7-15). This functional description may support an interpretation that is not limited to a specific physical structure.
    • Evidence for a Narrower Interpretation: The detailed description of the embodiment in Figure 6 shows a specific arrangement of logic gates (OR gates 610B, 610C and inverter 610A) that receive non-overlapping clock signals and an input data bit (’177 Patent, col. 8:55-9:2). A party could argue that this embodiment defines the structure and necessary inputs for what the patent contemplates as a "selection circuit."

  • The Term: "storage element"

  • Context and Importance: The patent is titled "Switched-Capacitor... Amplifier," and the complaint accuses "switched-capacitor power amplifiers" (Compl. ¶63). Establishing that the "storage element" is a capacitor is central to the plaintiff's case aligning with its broader narrative.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: Claim 1 uses the generic term "storage element." The specification introduces the element with parenthetical language: "each stage including a storage element (e.g., a capacitor)" (’177 Patent, col. 2:18-19). This suggests a capacitor is an example, not an exclusive definition.
    • Evidence for a Narrower Interpretation: The patent repeatedly and consistently refers to the technology as "Switched-Capacitor" and identifies the storage element as a capacitor in its primary embodiment (e.g., "storage element...may be a CMOS capacitor," '177 Patent, col. 2:58-59; "storage element, which is shown as capacitor 606," '177 Patent, col. 8:49-50). The consistent focus on capacitors could be used to argue that the scope of "storage element" should be limited to capacitors or their structural equivalents in this context.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges inducement by Defendants providing products along with "instructions, documentation, technical support, marketing materials, [and] advertisements" that encourage and teach end-users to operate the products in an infringing manner (Compl. ¶110). It also alleges contributory infringement, asserting the accused components are not staple articles of commerce and are especially made for infringing use (Compl. ¶111).
  • Willful Infringement: Willfulness is a central theme of the complaint. It alleges Intel had pre-suit knowledge of the invention and pending patent application as early as July 2010 through direct communications with one of the inventors (Compl. ¶26). The complaint includes excerpts of emails where Intel engineers allegedly praised the invention as a "breakthrough" and discussed licensing it from the University of Washington (Compl. ¶¶29, 32). The most pointed allegation for willfulness is that Intel copied circuit diagrams from the ’177 Patent "nearly verbatim" into its own ’834 Patent without attribution (Compl. ¶¶42-43). The complaint alleges this liability for willfulness was transferred to Apple upon its 2019 acquisition of Intel's modem business (Compl. ¶52).

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

  • A core issue will be one of evidentiary linkage: the complaint's infringement theory is built on the premise that the accused products embody the circuitry of Intel's '834 patent, which is itself alleged to be a copy of the '177 patent's invention. A key question for the court will be whether Plaintiff can prove this chain of copying and implementation across a wide array of products manufactured over many years by two different companies.
  • A second central question will be one of corporate succession and culpability: given the extensive factual allegations of pre-suit knowledge, licensing discussions, and direct copying against Intel, a critical issue will be whether these actions are sufficient to support a finding of willful infringement, and whether the liability for such conduct was legally transferred to Apple upon its acquisition of the accused business unit.