DCT

3:08-cv-00397

Lineage Power Corp v. SynQor Inc

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Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 3:08-cv-00397, W.D. Wis., 07/10/2008
  • Venue Allegations: Venue is alleged to be proper in the Western District of Wisconsin based on Defendants’ business activities in the state, including making, using, or selling the accused products. The complaint specifically notes that Victory Sales acts as a manufacturer's representative and Avnet as a distributor for SynQor products in Wisconsin, with both having physical locations in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s power converter modules, and the methods used to manufacture them, infringe five patents related to power converter manufacturing processes, structural design, and operational circuitry.
  • Technical Context: The dispute centers on the technology inside DC-DC power converters, which are fundamental components in modern electronics, particularly in telecommunications and network equipment, for converting direct current from one voltage level to another.
  • Key Procedural History: The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patents-in-suit.

Case Timeline

Date Event
1989-12-28 Earliest Priority Date ('452 Patent)
1991-07-30 U.S. Patent No. 5,036,452 Issues
1996-12-23 Earliest Priority Date ('773 Patent)
1997-08-08 Earliest Priority Date ('344 Patent)
1998-11-02 Earliest Priority Date ('093 Patent)
1999-04-08 Earliest Priority Date ('301 Patent)
1999-12-21 U.S. Patent No. 6,005,773 Issues
2000-10-31 U.S. Patent No. 6,138,344 Issues
2001-07-24 U.S. Patent No. 6,264,093 Issues
2001-10-30 U.S. Patent No. 6,310,301 Issues
2008-07-10 Complaint Filed

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

U.S. Patent No. 6,264,093 - “Lead-Free Solder Process for Printed Wiring Boards,” Issued July 24, 2001

The Invention Explained

  • Problem Addressed: When a component-laden subsystem (like a power module) is soldered onto a larger system board in a secondary reflow process, the original solder joints on the subsystem can re-melt. If conventional lead-tin solders are used in both steps, this can create weak tertiary alloys at the joints, causing premature failure. ('093 Patent, col. 1:49-2:13).
  • The Patented Solution: The invention proposes a two-stage soldering method. First, the subsystem is assembled using a "substantially lead-free" solder, which has a higher melting point (e.g., >221°C). Second, the completed subsystem is attached to the main system board using a conventional solder with a lower melting point (e.g., 183°C). During the second step, the higher-temperature, lead-free joints on the subsystem remain solid, preserving their integrity. ('093 Patent, Abstract; col. 2:18-45).
  • Technical Importance: This process enables the reliable, mass-production assembly of complex, multi-layered electronic systems, such as encapsulated modules, without compromising the structural integrity of the pre-assembled components. ('093 Patent, col. 1:16-25).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 11 is representative of the asserted method.
  • Key elements of independent claim 11 include:
    • providing a subsystem printed wiring board;
    • applying a substantially lead-free solder to the subsystem board;
    • placing an electronic component with lead-free terminals on the solder;
    • heating the subsystem board to reflow the lead-free solder; and
    • soldering the subsystem board to a system board using a solder with a lower eutectic point than the lead-free solder.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,138,344 - “Methods of Manufacturing a Magnetic Device and Tool for Manufacturing the Same,” Issued October 31, 2000

The Invention Explained

  • Problem Addressed: The patent describes prior art methods of assembling magnetic devices (e.g., transformers) as being manual, inefficient, and potentially damaging due to the use of mechanical clips or clamps that apply compressive force to hold core halves together during curing. ('344 Patent, col. 2:12-35).
  • The Patented Solution: The invention is a highly automated method for manufacturing a magnetic device. It employs an "automated pick and placement tool" to adhesively secure magnetic core-portions to a planar winding assembly (e.g., a printed circuit board). A key aspect is that the core-portions are secured "without substantial compressive forces," relying on adhesives (such as shrink adhesives) to form the bond. ('344 Patent, Abstract; col. 4:9-24).
  • Technical Importance: This method allows for the automated, high-yield, and cost-effective production of compact power magnetic devices essential for modern electronics. ('344 Patent, col. 2:36-41).

Key Claims at a Glance

  • The complaint does not identify specific asserted claims. Independent claim 10 is a representative method claim.
  • Key elements of independent claim 10 include:
    • providing a substrate with conductive traces and apertures;
    • disposing a shrink adhesive on the substrate;
    • adhesively securing a first core-portion to the substrate using an automated pick and placement tool;
    • disposing a shrink adhesive on a second core-portion; and
    • adhesively securing the second core-portion to the substrate with the automated tool, such that the core-portions mate through the apertures and the adhesive cures to form a bond.
  • The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 6,005,773 - “Board-Mountable Power Supply Module,” Issued December 21, 1999

  • Technology Synopsis: This patent addresses the need for a high-density, thermally efficient, and manufacturable power supply module. The disclosed solution is a compact package design that uses a single printed circuit board with integrated planar magnetics and a thermally conductive baseplate, enabling the placement of components in close proximity to optimize space and thermal performance. ('773 Patent, Abstract; col. 2:38-48).
  • Asserted Claims: The complaint does not identify specific asserted claims.
  • Accused Features: The complaint accuses "quarter-brick and eight-brick power supply modules having a baseplate, e.g., baseplated PowerQor Half-Brick and Quarter-Brick modules" of infringement. (Compl. ¶29).

U.S. Patent No. 5,036,452 - “Current Sharing Control with Limited Output Voltage Range for Paralleled Power Converters,” Issued July 30, 1991

  • Technology Synopsis: This patent addresses the problem of unequal current distribution when multiple power converters are connected in parallel to power a common load. The invention is a control circuit that monitors current from each converter and adjusts an error signal in their regulation circuits to force equal load sharing, while also including circuitry to limit output voltage excursions during transients or faults. ('452 Patent, Abstract; col. 1:49-col. 2:4).
  • Asserted Claims: The complaint does not identify specific asserted claims.
  • Accused Features: The complaint accuses "half-brick power supply modules with active current sharing circuitry, e.g., Full-Feature PowerQor Half-Brick modules" of infringement. (Compl. ¶35).

U.S. Patent No. 6,310,301 - “Inter-Substrate Conductive Mount for a Circuit Board, Circuit Board and Power Magnetic Device Employing the Same,” Issued October 30, 2001

  • Technology Synopsis: This patent addresses challenges in surface-mounting one circuit board onto another. The invention is an "inter-substrate conductive mount" (e.g., a small metal ball) with a melting point higher than the solder. During reflow soldering, the surface tension of the molten solder holds the mount in place, creating a reliable electrical and mechanical connection between the two boards. ('301 Patent, Abstract; col. 2:42-47).
  • Asserted Claims: The complaint does not identify specific asserted claims.
  • Accused Features: The complaint accuses "surface mount non-isolated power supply modules, e.g., NiQor SMT modules" of infringement. (Compl. ¶41).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are a range of SynQor's power converter modules, including the "AcuQor, AdvancedTCA, BusQor, NiQor, PowerQor, DualQor and InQor" product lines. (Compl. ¶17, 23, 29, 35, 41).

Functionality and Market Context

These products are DC-DC power converter modules, typically sold as components for integration into larger systems. (Compl. ¶6). The complaint alleges they are marketed to customers such as "telecommunications equipment and network equipment manufacturers." (Compl. ¶9). The infringement allegations connect specific product features to each patent: products made with "lead-free solder" ('093 Patent), containing a "magnetic core" ('344 Patent), having a "baseplate" ('773 Patent), including "active current sharing circuitry" ('452 Patent), and being "surface mount" capable ('301 Patent). (Compl. ¶16, 22, 28, 34, 40). The complaint does not provide further detail on the technical operation or market position of the accused products.

Visual Evidence in Complaint

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide claim charts or detailed factual allegations mapping accused product features to specific claim limitations. The following summarizes the narrative infringement theory for the lead patents.

The infringement theory for the '093 Patent is that the defendants' method of manufacturing their power converters, which are alleged to have "lead-free solder," practices the steps of the patent's claims. (Compl. ¶16). Similarly, the theory for the '344 Patent is that the defendants' method of manufacturing the "magnetic core" within their power converters infringes the patented method. (Compl. ¶22).

The complaint does not provide sufficient detail for analysis of infringement via a claim chart.

Identified Points of Contention

  • Evidentiary Questions (Method Claims): For the '093 and '344 patents, the core dispute will be factual and evidentiary. The complaint alleges infringement of method claims based on the existence of a final product. A primary question for the court will be whether the plaintiff can produce evidence, likely through discovery, that the defendants' internal manufacturing processes actually perform all the specific steps required by the asserted claims (e.g., the two-stage soldering process of the '093 Patent or the automated, low-force adhesive process of the '344 Patent).
  • Scope Questions: The infringement analysis raises the question of whether simply selling a product "having lead-free solder" (Compl. ¶16) constitutes infringement of a multi-step process claim. The defendants' process may achieve a lead-free result through a different sequence of steps than what is claimed in the '093 Patent.

V. Key Claim Terms for Construction

Term: "substantially lead-free solder" ('093 Patent)

Context and Importance

This term is central to the scope of the '093 Patent. Its construction will determine whether the solder used by the defendants in their manufacturing process falls within the claims. Practitioners may focus on this term because its ambiguity could be dispositive; a narrow definition might exclude the accused process, while a broad one might cover it.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The specification defines the term as being "substantially free of lead, containing only trace amounts of lead insufficient to form significant amounts of tertiary alloys." ('093 Patent, col. 2:48-51). This language suggests that the presence of some lead is permissible, as long as it does not cause the underlying technical problem.
  • Evidence for a Narrower Interpretation: The patent also states, "In a preferred embodiment, however, the solder or terminal leads are totally free of lead; that is, not even minute or trace amounts (e.g., <0.5 percent) of lead are present." ('093 Patent, col. 4:11-15). A party could argue this passage narrows the term's meaning to effectively zero lead content.

Term: "without substantial compressive forces" ('344 Patent)

Context and Importance

This phrase distinguishes the claimed automated method from prior art manual methods that used mechanical clamps. The definition of "substantial" will be critical to determining if the defendants' assembly process infringes.

Intrinsic Evidence for Interpretation

  • Evidence for a Broader Interpretation: The patent contrasts the invention with prior art that uses a "clip or clamp," suggesting that any force significantly less than that applied by such a dedicated mechanical device would not be "substantial." ('344 Patent, col. 2:25-27).
  • Evidence for a Narrower Interpretation: The specification provides a potential quantitative limit, stating the force is "less than about 110% of the weight of a core-portion." ('344 Patent, col. 5:26-27). A party could argue this sets a specific, narrow boundary for what constitutes a non-substantial force.

VI. Other Allegations

Indirect Infringement

The complaint includes allegations of active inducement and contributory infringement for all five patents-in-suit. (Compl. ¶16, 22, 28, 34, 40). These allegations are supported by the statement that the accused products are "known by the Defendants to be especially made or adapted for use in an infringement" and are "not staple articles or commodities of commerce suitable for substantial non-infringing uses." (Compl. ¶17, 23, 29, 35, 41). The complaint does not plead specific facts, such as the provision of instructional materials, to support the element of intent for inducement.

Willful Infringement

Willfulness is alleged for all five patents based on the assertion that Defendants infringed "with full knowledge of the existence of the... Patent[s]." (Compl. ¶16, 22, 28, 34, 40). The complaint does not allege specific facts supporting pre-suit knowledge, such as a prior notice letter or citation of the patents.

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

  • A central issue for the method patents ('093 and '344) will be one of evidentiary proof: can the plaintiff demonstrate, through discovery, that the defendants’ confidential manufacturing processes practice the specific, ordered steps of the asserted claims, or will the evidence show a different, non-infringing method of production?
  • A second key issue will be one of claim construction: the viability of the infringement claims may depend on whether the court adopts a broader or narrower definition for critical terms such as "substantially lead-free solder" ('093 Patent) and "without substantial compressive forces" ('344 Patent), as the intrinsic evidence provides arguments for both interpretations.
  • A third question is one of pleading sufficiency in a modern context: the complaint was filed under older, more lenient pleading standards. A core question is whether its generalized allegations—tying infringement of method patents to the mere existence of a product with certain characteristics—would provide sufficient factual matter to state a plausible claim for relief under the more rigorous standards established later by the Supreme Court.