DCT
2:22-cv-01130
Wiesblatt Licensing LLC v. Smart Embedded Computing Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Wiesblatt Licensing LLC (Wisconsin)
- Defendant: SMART Embedded Computing, Inc. (Wisconsin)
- Plaintiff’s Counsel: Garteiser Honea, PLLC
- Case Identification: 2:22-cv-01130, E.D. Wis., 09/27/2022
- Venue Allegations: Venue is alleged to be proper as Defendant is a Wisconsin corporation with a regular and established business presence in the district, where it also allegedly commits acts of infringement.
- Core Dispute: Plaintiff alleges that Defendant’s Xperia 5 smartphone infringes a patent related to power-efficient circuitry for transferring data using a variable power supply.
- Technical Context: The technology concerns methods for ensuring reliable data conversion in electronic devices that dynamically adjust their power supply voltage to conserve energy, a critical function in modern mobile devices.
- Key Procedural History: The complaint notes the patent was originally assigned to Seiko Epson Corporation and that patents citing the asserted patent have been issued to industry leaders such as Honeywell International Inc. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Priority Date for U.S. Patent No. 8,396,112 |
| 2013-03-12 | U.S. Patent No. 8,396,112 Issued |
| 2022-09-27 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,396,112 - "Circuitry and Method For Transferring Data, and Circuitry and Method Utilizing Clock Pulses," Issued March 12, 2013
The Invention Explained
- Problem Addressed: The patent identifies a problem in computer systems that use variable power supply voltages to reduce power consumption. In such systems, it is difficult to reliably convert multi-value analog signals back into digital signals because the fluctuating power supply affects the reference voltages used for analog-to-digital (A/D) conversion (’112 Patent, col. 1:29-37).
- The Patented Solution: The invention proposes a data transfer circuit where both the transmitting and receiving components operate from the same variable power supply. Critically, a threshold voltage generator creates the reference voltages needed for A/D conversion based on, and proportional to, the variable power supply voltage itself. This ensures that the A/D conversion process remains accurate even as the system's overall voltage changes to save power (’112 Patent, Abstract; col. 2:1-9).
- Technical Importance: This design allows electronic devices to employ aggressive power-saving techniques (dynamic voltage scaling) without compromising the integrity of data communication between internal components like a processor and memory (’112 Patent, col. 1:26-30).
Key Claims at a Glance
- The complaint asserts independent Claim 1 as exemplary (Compl. ¶24).
- The essential elements of Claim 1 are:
- A variable power supply voltage generator.
- A transmitting circuit, operative at the variable voltage, that generates and transmits a multi-value analog signal.
- A receiving circuit, operative at the variable voltage, that receives the signal and performs A/D conversion to regenerate a multi-value digital signal.
- A threshold voltage generator that creates threshold voltages for the A/D conversion, with these voltages being generated from the variable power supply voltage or a signal proportional to it.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The accused instrumentalities include the Xperia 5 smartphone, with the Xperia 5 III model specifically identified in a supporting visual (Compl. ¶19).
Functionality and Market Context
- The complaint alleges the accused smartphones contain circuitry for data transfer between a host and memory, such as LPDDR5 RAM (Compl. ¶24(i)). This circuitry allegedly includes a Power Management Integrated Circuit (PMIC) that functions as a variable power supply voltage generator, providing variable voltages (e.g., VDDQ, VDD2) to transmitter and receiver circuits (Compl. ¶24(ii-iv)).
- The complaint alleges the receiver uses these variable voltages and performs A/D conversion with reference threshold voltages (e.g., VrefDQ) that are derived from the variable power supply voltage (e.g., VDDQ) (Compl. ¶24(v)). The complaint provides a screenshot from the defendant's website showing the accused Xperia 5 III smartphone and listing some of its key features (Compl. Fig. 1, p. 5).
- Plaintiff alleges Defendant generates substantial revenue from the accused products (Compl. ¶23).
IV. Analysis of Infringement Allegations
Infringement Allegations for U.S. Patent No. 8,396,112
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| a variable power supply voltage generator for generating a variable power supply voltage; | Defendant provides a variable power supply voltage generator (e.g., PMIC) for generating a variable power supply voltage (e.g., VDDQ and/or VDD2 from min to max voltage). | ¶24(ii) | col. 2:55-57 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal... | Defendant provides a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal (e.g., multiple analog waveforms). | ¶24(iii) | col. 2:57-61 |
| a receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion... | Defendant provides a receiving circuit operative at the variable power supply voltage for receiving the multi-value analog signal and performing A/D conversion to re-generate a multi-value digital signal. | ¶24(iv) | col. 2:61-65 |
| a threshold voltage generator for generating threshold voltages...the threshold voltages being generated from the variable power supply voltage or from a signal...proportional to the variable power supply voltage. | Defendant provides a threshold voltage generator for generating threshold voltages (e.g., VrefDQ) from the variable power supply voltage (e.g., VDDQ), with VrefDQ being used for the A/D conversion. | ¶24(v) | col. 2:65-col.3:2 |
- Identified Points of Contention:
- Scope Questions: The complaint maps claim limitations onto standard components like a PMIC and LPDDR5 RAM interface. A central dispute may be whether the term "multi-value analog signal", as used in the patent, reads on the signals transmitted over a standard, high-speed memory bus, which are fundamentally digital but exhibit analog characteristics.
- Technical Questions: The complaint alleges the threshold voltage "VrefDQ" is "derived from VDDQ" and is "usually ½ of VDDQ" (Compl. ¶24(v)). A key evidentiary question will be whether Plaintiff can prove that the accused threshold voltage generator performs the specific function of creating reference voltages that are dynamically proportional to the variable supply voltage, as required by the claim, or if the relationship is less direct.
V. Key Claim Terms for Construction
"multi-value analog signal"
- Context and Importance: This term is critical because infringement hinges on whether the signals within the accused device's memory interface qualify. Practitioners may focus on this term to determine if the patent applies to standard digital signaling schemes or is limited to specialized, non-binary data encoding methods.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The patent describes such signals as having "a multi-value signal level of three or higher" (’112 Patent, col. 4:51-52), which could be argued to encompass any non-binary waveform.
- Evidence for a Narrower Interpretation: The specification describes a specific system for converting multi-bit digital data ("Dmulti") into a corresponding analog signal ("Smulti") with discrete voltage levels and then converting it back (’112 Patent, Fig. 9; col. 8:41-67). This may support an argument that the term requires an intentional, multi-level encoding scheme, not merely the analog artifacts of a binary signal.
"threshold voltages being generated from the variable power supply voltage"
- Context and Importance: This limitation captures the core adaptive mechanism of the invention. The dispute will likely center on the nature of the "generated from" relationship between the power supply and the reference voltages.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: An argument could be made that any threshold voltage circuit that is powered by the variable supply is necessarily "generated from" it, as its output will be affected by its input.
- Evidence for a Narrower Interpretation: The specification discloses specific embodiments where the threshold voltages are created by dividing a peak voltage that is itself proportional to the variable supply, implying a direct, ratiometric relationship (’112 Patent, Fig. 5A, 5B; col. 7:41-56). This suggests the term requires a circuit that actively uses the variable supply voltage as a reference to ensure the threshold levels scale proportionally.
VI. Other Allegations
Indirect Infringement
- The complaint alleges inducement of infringement, asserting that Defendant's "advertising an infringing use" supports an inference of intent (Compl. ¶32). The complaint does not cite specific advertisements, user manuals, or other instructional materials.
Willful Infringement
- The willfulness claim is based on Defendant’s alleged knowledge of the ’112 Patent acquired upon service of the complaint (Compl. ¶28). The complaint also makes a general allegation that Defendant has a "practice of not performing a review of the patent rights of others" (Compl. ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: does the term "multi-value analog signal", as contemplated by the patent, cover the operation of a standard LPDDR5 memory interface, or is the patent limited to a more specialized data encoding technology? The outcome may depend on whether the court views the accused signals as fundamentally digital or as qualifying multi-level analog signals.
- A key evidentiary question will be one of functional proof: can the plaintiff demonstrate that the accused device’s threshold voltage generator performs the specific, adaptive function required by Claim 1? The case may turn on technical evidence showing that the reference voltages are not just powered by, but are "generated from" and scale proportionally with, the variable power supply voltage, as the patent describes.