On Wednesday in the Western District of Texas, the California Institute of Technology (Caltech) filed a complaint against Dell Technologies Inc. and Dell Inc. for patent infringement alleging that Dell infringed the patents-in-suit via its accused products’ purported use of its coding system and methods.
The patents-in-suit are United States Patent Nos. 7,116,710 (the ’710 patent); 7,421,032 (the ’032 patent); and 7,916,781 (the ’781 patent); all of which are entitled “Serial Concatenation of Interleaved Convolutional Codes Forming Turbo-Like Codes.” Caltech noted that earlier this year a jury found that Apple and Broadcom infringed these patents-in-suit in their respective suits, awarding Caltech $1.1 billion in damages.
Specifically, the patents-in-suit “disclose a seminal improvement to coding systems and methods. The Asserted Patents introduce a new type of error correction codes, called ‘irregular repeat and accumulate codes’ (or ‘IRA codes’). The claimed methods and apparatuses are directed to encoders and decoders. The claimed encoders generate an IRA codeword from message or information bits reordering irregularly repeated instances of those bits in a randomized but known way and performing other logical operations such as summing and accumulating bits. The claimed decoders facilitate recovery of the message or information bits from the codewords even when the codewords have been corrupted by noise such as the noise that is experienced when transmitting a codeword over a wireless communications channel.”
According to Caltech, Dell “manufactures, uses, imports, offers for sale, and/or sells Wi-Fi products that incorporate IRA/LDPC encoders and/or decoders” as described in the asserted patents. These allegedly accused products include laptops, such as Latitude, Vostro, Inspiron, XPS, G-Series, Chromebook, etc.; desktops and all-in-ones, such as OptiPlex, Precision, Vostro, and Inspiron, etc.; tablets and 2-in-1s, such as Latitude, Inspiron, and Rugged, etc.; workstations like Precision; and thin clients. Caltech proffered that the accused products “are compliant with the 802.11n, 802.11ac, and/or 802.11ax standards and the LDPC codes defined in those standards.”
For example, Caltech contended that Dell infringed at least claim 20 of the ’710 patent because its accused products allegedly comply with and infringe the standards and “12 LDPC error correction codes defined in those standards.” Accordingly, Caltech claimed that Dell’s accused products “encode information or message bits using an LDPC encoder that supports the 12 LDPC codes defined in the standards.” Specifically, Caltech alleged that the “LDPC encoders in the Accused Products encode information or message bits in accordance with the 12 parity-check matrices defined in the 802.11n standard.” However, Caltech proffered that Dell’s LDPC encoders “are implemented in a manner that meets each and every limitation of claim 20 of the ’710 patent. Specifically, the complaint stated that the LDPC’s “first coders have an input configured to receive a stream of bits (e.g., information or message bits). The first coders repeat the stream of bits irregularly and scramble the repeated bits. The irregular repetition and scrambling that occurs in the LDPC encoders in the Accused Products corresponds to the irregular repetition and scrambling depicted in the left-hand sides of the parity-check matrices.” Moreover, Dell’s LDPC encoders also allegedly have second coders corresponding to the right-hand sides of the parity-check matrices. As a result of this purported practice, Caltech averred that Dell has infringed the ’710 patent as Dell was not licensed or authorized to use the patented technology and methodology described in the claims of the patents-in-suit. The allegations against Dell for the remaining patents-in-suit were similar to the allegations against it for the ’710 patent.
Caltech has sought a declaratory judgment, compensation including a royalty to compensate for Dell’s purported infringement, pre- and post-judgment interest, an award for costs and fees, and other relief.
Caltech is represented by Mann Tindel Thompson as well as Quinn Emanuel Urquhart & Sullivan, LLP.
