On Friday, plaintiff M-Red Inc. filed a complaint against defendant Nintendo in the Eastern District of Texas, alleging that the defendant infringed the patents-in-suit for utilizing infringing chips in its products.
The patents-in-suit are United States Patent Nos. 6,853,259 (the ’259 patent); 7,068,557 (the ’557 patent); 7,209,401 (the ’401 patent); 6,177,843 (the ’843 patent); 6,628,171 (the ’171 patent); of which the first three are entitled “Ring oscillator dynamic adjustments for auto calibration,” the fourth is entitled “Oscillator circuit controlled by programmable logic,” and the last is entitled “Method, architecture and circuit for controlling and/or operating an oscillator.”
The plaintiff stated that the ’259, ’557, and ’401 patents “generally describe integrated circuits comprising voltage and temperat(ur)e sensors which output a voltage and temperat(ur)e and store the output in memory.” According to M-Red, the patented “temperature monitoring and power saving techniques are incorporated into integrated circuits (‘ICs’) and software utilized in Nintendo Accused Products.” For instance, the plaintiff noted that this functionality is “included and utilized” in System-on-a-Chips (‘SoCs’) that are used in the Nintendo Accused Products, including the Nvidia and Broadcom SoCs, which “adjust a clock frequency based on variations in voltage and temperature.”
Meanwhile, the ’843 and ’171 patents generally describe “methods and apparatuses to present an output signal having a frequency from an oscillator, including and/or utilizing (i) a reference signal, (ii) a control signal and (iii) the output signal.” Additionally, the plaintiff stated that “(i)n some embodiments of the invention, a logic circuit may be configured to present the control signal in response to (i) the output signal and (ii) the reference signal.” M-Red claimed that “(t)hese techniques are incorporated into IC and software utilized in Nintendo Accused Products” because, for example, “this functionality is included and utilized in” Nvidia and Broadcom SoCs.
The plaintiff added that it has suffered irreparable harm and damages as a result of this purported infringement and is seeking declaratory judgment in its favor; an award for damages, costs, and fees; and other relief. M-Red is represented by Fabricant LLP and Truelove Law Firm, PLLC.
