Helix Microinnovations LLC v. Cree LED Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Helix Microinnovations LLC (Delaware)
  • Defendant: Cree LED, Inc. (Delaware)
  • Plaintiff’s Counsel: Silverman, McDonald & Friedman; Rabicoff Law LLC
• Case Identification: 1:25-cv-01581, D. Del., 02/25/2026
• Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Defendant, a Delaware corporation, has an established place of business in the district.
• Core Dispute: Plaintiff alleges that Defendant infringes a patent related to methods and apparatus for fabricating Chip-on-Board electronic modules.
• Technical Context: The technology at issue addresses cost-effective semiconductor manufacturing, specifically methods for mounting unpackaged silicon die onto printed circuit boards using specialized adhesives to improve yield and enable the use of partially-defective components.
• Key Procedural History: This filing is a First Amended Complaint; no other significant procedural events are mentioned in the complaint.

Case Timeline

Date	Event
2002-02-26	U.S. Patent No. 7,238,550 Priority Date (Provisional)
2003-02-20	U.S. Patent No. 7,238,550 Application Filing Date
2007-07-03	U.S. Patent No. 7,238,550 Issue Date
2026-02-25	Complaint Filing Date

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

U.S. Patent No. 7,238,550 - Methods and apparatus for fabricating Chip-on-Board modules

The asserted patent is U.S. Patent No. 7,238,550 (the “’550 Patent”), issued on July 3, 2007.

The Invention Explained

• Problem Addressed: The patent describes an ongoing need in the semiconductor industry for low-cost manufacturing methods, particularly for memory modules (Compl. ¶9; ’550 Patent, col. 1:13-20). A specific challenge identified is the high rate of failure during "burn-in" testing, where thermal stress caused by mismatched thermal expansion coefficients between a silicon chip and a circuit board can damage the component ('550 Patent, col. 2:6-11).
• The Patented Solution: The invention proposes a method for mounting an unpackaged semiconductor die directly onto a printed circuit board (a "Chip-on-Board" process) using "selectively settable" materials, such as UV-curable adhesives ('550 Patent, abstract; ’550 Patent, col. 3:61-65). A key aspect of the solution is using a multi-step adhesive process: a ring of adhesive is first hardened around the die to hold it in place, while a layer of adhesive between the die and the board can remain liquid to act as a physical and thermal buffer ('550 Patent, col. 4:21-34; ’550 Patent, col. 11:1-5). A second layer of adhesive can then be applied over the first to "capture" and secure the delicate bonding wires that electrically connect the die to the board ('550 Patent, col. 4:44-55). This process is illustrated in figures such as Figure 4b, which shows the liquid material (414) under the die (412) and the hardened rings of material (413, 416) securing it.
• Technical Importance: This fabrication method aimed to improve manufacturing yields and lower costs by enabling the use of less-expensive, unpackaged die and even salvaging partially-defective semiconductor parts that might otherwise be discarded ('550 Patent, col. 1:49-55).

Key Claims at a Glance

• The complaint asserts infringement of "exemplary method claims" of the ’550 Patent without specifying claim numbers (Compl. ¶11). Independent claim 1 is representative of the core method.
• The essential elements of independent claim 1 include:
  • A method of fabricating Chip-on-Board logic modules using selectively settable materials,
  • mounting unpackaged die using a first layer of selectively-settable material;
  • hardening a ring of said first layer of selectively-settable material around a periphery said unpackaged die;
  • covering said first layer of selectively-settable material with a second layer of selectively-settable material; and
  • capturing bonding wires connecting said unpackaged die to a printed circuit board in said second layer of selectively-settable material.
• The complaint alleges infringement of "one or more claims," suggesting the right to assert additional dependent or independent claims is reserved (Compl. ¶11).

III. The Accused Instrumentality

Product Identification

The complaint does not name any specific accused products (Compl. ¶11). It refers generally to "Exemplary Defendant Products" that are identified in claim charts attached as Exhibit 2 (Compl. ¶11; Compl. ¶13). Exhibit 2 was not provided with the complaint.

Functionality and Market Context

The complaint does not provide any description of the accused products' functionality, features, or market context (Compl. ¶¶11-14). Given the defendant's name, "Cree LED, Inc.," the accused products may relate to Light Emitting Diode (LED) modules or components, but the complaint itself makes no such allegation (Compl. ¶3).

IV. Analysis of Infringement Allegations

The complaint alleges that Defendant’s "Exemplary Defendant Products" infringe the "Exemplary '550 Patent Claims" either literally or under the doctrine of equivalents (Compl. ¶11). The pleading states that claim charts in an incorporated but un-provided Exhibit 2 demonstrate that the accused products "practice the technology claimed by the '550 Patent" and "satisfy all elements" of the asserted claims (Compl. ¶13). The complaint does not contain a narrative description of the infringement theory or identify which specific features of the accused products allegedly map to the claim limitations.

No probative visual evidence provided in complaint.

Identified Points of Contention

• Scope Questions: The patent specification is heavily focused on the fabrication of "memory modules" ('550 Patent, abstract; ’550 Patent, col. 2:42-52). The asserted independent claim, however, uses the broader term "logic modules" ('550 Patent, claim 1). A central dispute may arise over whether the claims, when read in light of the specification, can be construed to cover the accused products, which, based on the defendant's name, may be LED modules rather than memory modules.
• Technical Questions: The asserted claims recite a specific multi-step manufacturing process involving first hardening a ring of adhesive and then "capturing bonding wires" in a second layer of material ('550 Patent, claim 1). A key factual question for the court will be whether the defendant's manufacturing process actually performs these discrete steps. The complaint provides no evidence or specific allegations on this point (Compl. ¶¶11-14).

V. Key Claim Terms for Construction

"logic modules" (from claim 1)

• Context and Importance: The construction of this term may be dispositive. The patent’s specification almost exclusively discusses "memory modules" ('550 Patent, abstract; ’550 Patent, col. 2:25-52). Defendant Cree LED, Inc., operates in the LED market (Compl. ¶3). Practitioners may focus on this term because the viability of the infringement claim could depend on whether an LED module is considered a "logic module" within the meaning of the patent.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim itself uses the broader term "logic modules," not the narrower term "memory modules" ('550 Patent, claim 1). A patentee is generally not limited to the specific embodiments disclosed in the specification.
  • Evidence for a Narrower Interpretation: The specification repeatedly frames the invention as relating to memory, referencing "DRAM, Synchronous Dynamic Random Access Memory (SDRAM), Double Data Rate (DDR), etc." ('550 Patent, col. 2:40-44). A defendant may argue that the consistent and exclusive focus on memory should limit the scope of "logic modules" to that context.

"capturing bonding wires" (from claim 1)

• Context and Importance: This term describes a key step in the claimed manufacturing process. The infringement analysis will turn on the specific actions required to meet this limitation. Practitioners may focus on this term to determine if it requires physically embedding the wires within a settable material, as opposed to merely coating them for protection.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The term "capturing" is not explicitly defined and could arguably be met by any process that encases or covers the bonding wires with the second layer of material.
  • Evidence for a Narrower Interpretation: The patent describes how the second ring is used to "capture the wires" and that "trapping the wires" facilitates the connection process, suggesting a more active securing or positional-fixing function than a simple protective coating ('550 Patent, col. 4:45-50; ’550 Patent, col. 7:41-43). Dependent claim 3, which recites "placing only a part of each of the bonding wires" in the second layer, further suggests a specific, physical interaction ('550 Patent, claim 3).

VI. Other Allegations

Indirect Infringement

The complaint’s single count is for "Direct Infringement" (Compl. ¶11). It does not allege specific facts required to support claims for induced or contributory infringement, such as knowledge of the patent and intent to encourage infringement by others.

Willful Infringement

The complaint does not contain an explicit allegation of willful infringement. The prayer for relief requests a finding that the case is "exceptional" under 35 U.S.C. § 285, but does not plead the factual basis for such a finding, such as pre-suit knowledge of the patent or egregious infringement conduct (Compl., Prayer E.i).

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

The complaint as filed presents a high-level notice of infringement, leaving the central disputes to be developed during discovery and claim construction. Based on the provided documents, the case appears likely to turn on two primary questions:

• A core issue will be one of definitional scope: can the term "logic modules," which is used in a patent specification almost exclusively dedicated to "memory modules," be construed broadly enough to read on the accused products, which may be LED components?
• A key evidentiary question will be one of process correspondence: what specific steps does the defendant's manufacturing process entail, and do those steps include the distinct method of using a hardened ring of a first adhesive layer followed by "capturing" bonding wires in a second adhesive layer, as required by the patent's claims?