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: [Wiesblatt Licensing LLC](https://ai-lab.exparte.com/party/wiesblatt-licensing-llc) v. Smart Embedded Computing Inc, 2:22-cv-01130, E.D. Wis., 10/26/2022
- Venue Allegations: Plaintiff alleges venue is proper because Defendant is a Wisconsin corporation that conducts extensive business, maintains physical locations, employs personnel, and generates substantial revenue within the Eastern District of Wisconsin.
- Core Dispute: Plaintiff alleges that Defendant’s development kit, which utilizes LPDDR5 memory technology, infringes a patent related to circuitry for transferring data using multi-value analog signals in systems with variable power supply voltages.
- Technical Context: The technology addresses power consumption and signal integrity in modern electronics by enabling reliable data conversion even when system power levels are dynamically adjusted to save energy.
- Key Procedural History: The complaint notes the patent’s inventor is Kesatoshi Takeuchi and the original assignee was Seiko Epson Corporation. It also mentions the patent has been cited in patents issued to industry leaders like Honeywell International Inc. No prior litigation or post-grant proceedings are mentioned.
Case Timeline
| Date | Event |
|---|---|
| 2006-11-28 | Earliest Priority Date for U.S. Patent No. 8,396,112 |
| 2013-03-12 | U.S. Patent No. 8,396,112 Issued |
| 2019-02-19 | JEDEC announces LPDDR5 standard publication |
| 2022-10-26 | 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 describes a problem in electronic systems that use variable power supply voltages to reduce power consumption. In such systems, it is difficult to consistently convert multi-value analog data signals back into digital signals, because the changing supply voltage can disrupt the reference points used for analog-to-digital (A/D) conversion (’112 Patent, col. 1:30-36). The patent also notes that transmitting high-frequency clock pulses can create high-harmonic noise and signal degradation (’112 Patent, col. 1:39-42).
- The Patented Solution: The invention proposes a data transfer circuitry where the threshold voltages used for A/D conversion are themselves generated from the variable power supply voltage, or from a signal proportional to it. This allows the A/D converter's reference levels to dynamically track the fluctuating system voltage, ensuring that the multi-value analog signals are properly reconverted into digital signals regardless of the current power state (’112 Patent, col. 2:1-9; Fig. 1).
- Technical Importance: This design allows electronic devices to benefit from the power savings of variable voltage supplies without sacrificing the reliability of high-speed, multi-level analog data transmission (’112 Patent, col. 2:21-29).
Key Claims at a Glance
- The complaint asserts independent claim 1 as exemplary (Compl. ¶24).
- Claim 1 requires:
- A variable power supply voltage generator for generating a variable power supply voltage.
- A transmitting circuit operative at the variable power supply voltage for generating and transmitting a multi-value analog signal.
- 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.
- A threshold voltage generator for generating threshold voltages used for the A/D conversion and supplying them to the receiving circuit, where the threshold voltages are generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage.
III. The Accused Instrumentality
Product Identification
- The "Smart Wireless Computing Inforce 68A1 Development Kit" and any augmentations thereof (the "Accused Instrumentalities") (Compl. ¶19). A visual of the accused development kit is provided in the complaint (Compl. p. 5).
Functionality and Market Context
- The complaint alleges the Accused Instrumentalities are a "circuitry for transmitting data between a host and a memory (e.g., LPDDR5 RAM)" (Compl. ¶19). A features list from the product's manual highlights the inclusion of LPDDR5 Memory (Compl. p. 6). Plaintiff alleges the performance benefits of LPDDR5, such as significantly boosted memory speed and efficiency, are relevant to its use in mobile computing and mission-critical applications (Compl. p. 7). The complaint includes a generic block diagram to represent the LPDDR5 electrical system, showing a System-on-Chip (SoC) and DRAM package connected on a motherboard (Compl. p. 7, Fig. 1).
IV. Analysis of Infringement Allegations
8,396,112 Infringement Allegations
| 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 | The product provides a variable power supply voltage generator, such as a Power Management Integrated Circuit (PMIC), for generating a variable power supply voltage (e.g., VDDQ and/or VDD2). | ¶24(ii) | col. 2:56-59 |
| a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal and transmitting the multi-value analog signal to other circuits | The product provides a transmitting circuit operative at the variable power supply voltage for generating a multi-value analog signal (e.g., multiple analog waveforms) and transmitting it. | ¶24(iii) | col. 2:59-63 |
| 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 | The product provides a receiving circuit that operates at the variable power supply voltage, receives the multi-value analog signal, and performs A/D conversion to re-generate a digital signal, utilizing Decision Feedback Equalization (DFE). | ¶24(iv) | col. 2:63-3:1 |
| a threshold voltage generator for generating threshold voltages ... the threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage | The product provides a threshold voltage generator that generates threshold voltages (e.g., VrefDQ) for A/D conversion. The complaint alleges VrefDQ is generated from the variable supply voltage VDDQ and that VrefDQ is used by the DFE system. | ¶24(v) | col. 3:1-5 |
Identified Points of Contention
- Scope Questions: A central question may be whether the accused product's alleged generation of a reference voltage (VrefDQ) from a supply voltage (VDDQ) constitutes the "threshold voltage generator" required by the claim. The functionality is alleged to be performed by a "circuit onboard each DRAM" (Compl. ¶24(v)), which raises the question of whether this distributed functionality, if proven, meets the definition of the claimed "generator."
- Technical Questions: What evidence does the complaint provide that the reference voltage VrefDQ in the accused product is in fact "generated from" or "proportional to" the variable supply voltage VDDQ? The complaint makes this allegation on "information and belief" and states that "VrefDQ is usually ½ of VDDQ" (Compl. ¶24(v)), but does not cite product-specific documentation to substantiate this technical claim. The factual basis for this core allegation may be a primary point of dispute.
V. Key Claim Terms for Construction
- The Term: "threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to the variable power supply voltage"
- Context and Importance: This limitation is the inventive core of Claim 1. The infringement case hinges on whether the accused product's method for creating its A/D conversion reference voltage falls within the scope of this phrase. Practitioners may focus on this term because the plaintiff's theory of infringement—that VrefDQ is derived from VDDQ—is a direct attempt to map onto this language.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The plain language of the claim, "generated from... or from a signal... proportional to," is functionally broad and not tied to a specific structure. The specification supports this by stating that the threshold voltages can be generated using the variable power supply voltage "itself or a voltage that changes in proportion to the variable power supply voltage" (’112 Patent, col. 9:39-42). This could support an argument that any circuit implementation where the reference voltage tracks the supply voltage is covered.
- Evidence for a Narrower Interpretation: The patent's detailed description discloses a specific embodiment where the threshold voltages are generated by a "threshold voltage generator" (156) that operates on the peak voltage (Ep) of a sine wave clock signal (Swave), which is itself proportional to the main variable supply voltage Vvar (’112 Patent, col. 5:48-58; Fig. 5A). A defendant could argue that the term should be construed more narrowly in light of this disclosed embodiment, potentially limiting it to systems where the threshold is derived indirectly via a clock signal rather than directly from a DC supply line.
VI. Other Allegations
- Indirect Infringement: Plaintiff alleges inducement to infringe under 35 U.S.C. § 271(b), asserting that Defendant will have knowledge of the patent from the filing of the complaint and takes "active steps to induce infringement, such as advertising an infringing use" (Compl. ¶30, ¶32).
- Willful Infringement: The complaint alleges willful infringement based on post-suit notice ("will now be willful through the filing and service of this Complaint") and on an alleged "practice of not performing a review of the patent rights of others" (Compl. ¶28, ¶33).
VII. Analyst’s Conclusion: Key Questions for the Case
- A key evidentiary question will be one of technical implementation: what is the actual circuit design and operational relationship between the variable power supply (VDDQ) and the A/D conversion reference voltage (VrefDQ) within the accused Inforce 68A1 Development Kit? The case outcome may depend heavily on facts established during discovery, as the complaint's core technical allegations currently rest on "information and belief."
- A core issue will be one of claim scope: how broadly will the court construe the limitation "threshold voltages being generated from the variable power supply voltage or from a signal having a voltage value proportional to [it]"? The resolution of this question will determine whether the product's method of generating its reference voltage, once revealed, falls within the patent's legal boundaries.