Crestone IP Management LLC v. HP Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Crestone IP Management, LLC (Delaware)
  • Defendant: HP Inc. (Delaware)
  • Plaintiff's Counsel: Devlin Law Firm LLC
• Case Identification: 2:26-cv-00586, E.D. Tex., 07/16/2026
• Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Defendant HP Inc. maintains a regular and established place of business in the district, including a location in Plano, Texas, and has previously admitted to or not contested venue in the district in other patent cases.
• Core Dispute: Plaintiff alleges that Defendant's desktop computers, laptop computers, and chromebooks infringe four patents related to hybrid oscillator design, secure Trusted Platform Module (TPM) operations, remote media device control, and adaptive voltage regulation in memory circuits.
• Technical Context: The patents-in-suit address foundational technologies in modern computing, including processor clocking, hardware-based security, device interoperability, and power management for memory, which are integral to the performance and security of consumer electronics.
• Key Procedural History: The complaint asserts that HP was put on actual notice of infringement for each of the four asserted patents via a series of communications between July 2025 and June 2026. The complaint also references prior litigation in the district where HP allegedly did not contest venue, which Plaintiff presents to support its venue allegations.

Case Timeline

Date	Event
2006-03-24	'072 Patent Priority Date
2006-10-11	'231 Patent Filing Date
2006-11-30	'072 Patent Filing Date
2009-10-07	'231 Patent Issue Date
2010-05-12	'534 Patent Priority Date
2011-05-12	'534 Patent Filing Date
2012-09-04	'072 Patent Issue Date
2016-03-15	'534 Patent Issue Date
2017-04-19	'012 Patent Priority Date
2019-09-30	'012 Patent Filing Date
2020-09-08	'012 Patent Issue Date
2025-07-29	Alleged Notice of '012 Patent Infringement
2025-12-17	Alleged Notice of '072 Patent Infringement
2026-03-26	Alleged Notice of '534 Patent Infringement
2026-06-26	Alleged Notice of '231 Patent Infringement
2026-07-16	Complaint Filing Date

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

U.S. Patent No. 10,771,012 - "Hybrid RC/crystal oscillator", Issued September 8, 2020

The Invention Explained

• Problem Addressed: The patent's background section explains that microprocessors require oscillators, which can be internal (e.g., resistor-capacitor or RC) or external (e.g., crystal) Compl. ¶25 The patent notes that conventional clock sources present a trade-off between the accuracy of a crystal reference and the flexibility and fast startup of a tunable internal oscillator Compl. ¶25
• The Patented Solution: The invention is a hybrid oscillator that combines an internal tunable oscillator with an external crystal, which acts as a reference element or sensor rather than the primary clock source '012 Patent, col. 4:56-61 The system uses a phase detector to compare the output of the tunable oscillator against the response from the external crystal and an oscillator controller to continuously adjust the tunable oscillator's frequency, thereby achieving high accuracy and reliability while retaining the fast-startup benefits of an internal oscillator Compl. ¶26 '012 Patent, abstract
• Technical Importance: This hybrid design provides a clock source with improved reliability, fast startup, and high frequency stability compared to systems relying solely on either an internal or external oscillator Compl. ¶28

Key Claims at a Glance

• The complaint asserts independent claim 19 Compl. ¶27
• The essential elements of independent claim 19 include:
  • A semiconductor device with a first external pin and an internal oscillator.
  • An external resonant element (e.g., a crystal) coupled to the device via the pin.
  • The internal oscillator comprising a tunable oscillator, a phase detector circuit, and an oscillator controller circuit.
  • The oscillator controller circuit is configured to adjust the frequency of the tunable oscillator based on phase detection between the output of the tunable oscillator and the output of the external resonant element.
  • The oscillator controller is configured to use the external resonant element's output to adjust the tunable oscillator's frequency "during the entire operation of the tunable oscillator."

U.S. Patent No. 8,261,072 - "Method and system for secure external TPM password generation and use", Issued September 4, 2012

The Invention Explained

• Problem Addressed: The patent identifies a security vulnerability that exists even when a Trusted Platform Module (TPM) is used. Communicating codes and secrets with devices external to the TPM creates opportunities for interception, forcing a trade-off between system security and user accessibility Compl. ¶36
• The Patented Solution: The '072 patent discloses a system where a secure code is generated in a "remote device" and securely transmitted to the TPM along with "usage authorization information" '072 Patent, col. 6:1-10 Because both the remote device and the TPM recognize a common secret, the TPM can securely authenticate subsequent uses of a key without exposing the underlying credentials to software attacks or malware during operation Compl. ¶37
• Technical Importance: The invention aims to markedly improve computer system security during normal use without decreasing the usability and accessibility for the user Compl. ¶39

Key Claims at a Glance

• The complaint asserts independent claim 1 Compl. ¶38
• The essential elements of independent claim 1 include:
  • A computer system comprising standard components (CPU, memory, I/O adapters).
  • A trusted platform module configured to perform a set of operations.
  • The operations comprise: "receiving a secure access code from a remote device outside of the trusted platform module."
  • The operations further comprise: "receiving usage authorization information generated by a secure generator, the usage authorization information being attached to the secure access code."
  • The operations further comprise: "recognizing the secure access code; and using the secure access code as a parameter for various trusted platform module commands."

U.S. Patent No. 9,288,534 - "Systems and methods for operating media devices", Issued March 15, 2016

• Patent Identification: U.S. Patent No. 9,288,534, "Systems and methods for operating media devices", Issued March 15, 2016 Compl. ¶¶40-41
• Technology Synopsis: The patent addresses the difficulty of controlling multiple, often incompatible, media sources and players Compl. ¶¶45-46 The patented solution uses a mobile computing device as a universal remote that communicates with both media sources and media players over separate wireless links, analyzing device capabilities to build a unified, protocol-agnostic user interface for controlling content delivery Compl. ¶47
• Asserted Claims: The complaint asserts independent claim 6 Compl. ¶48
• Accused Features: The complaint alleges that various HP Chromebook computers infringe by implementing the claimed remote controller functionality for managing media between different sources and players Compl. ¶82

U.S. Patent No. 7,599,231 - "Adaptive regulator for idle state in a charge pump circuit of a memory device", Issued October 7, 2009

• Patent Identification: U.S. Patent No. 7,599,231, "Adaptive regulator for idle state in a charge pump circuit of a memory device", Issued October 7, 2009 Compl. ¶¶50-51
• Technology Synopsis: The patent addresses electrical disturbances, such as voltage spikes, that occur in memory devices when switching between high-voltage operations (e.g., programming) and low-voltage operations (e.g., reading) Compl. ¶55 The invention introduces an intermediate "idle voltage state" that serves as a buffer during these transitions, reducing disturbances and allowing for faster, more reliable memory operations '231 Patent, abstract Compl. ¶56
• Asserted Claims: The complaint asserts independent claim 12 Compl. ¶57
• Accused Features: The complaint alleges that HP computers utilizing TLC 3D NAND flash memory infringe the '231 patent by incorporating the claimed adaptive voltage regulation scheme Compl. ¶92

III. The Accused Instrumentality

Product Identification

The complaint identifies several categories of HP products, including desktop computers, laptop computers, and Chromebooks Compl. ¶1 Specific exemplary products include the "HP OMEN Gaming Laptop 16t-am000, 16"" for the '012 and '231 patents, the "HP EliteBook Ultra G1i 14 inch Notebook" for the '072 patent, and the "HP Chromebook 14a-nf0050nr" for the '534 patent Compl. ¶62 Compl. ¶72 Compl. ¶82 Compl. ¶92

Functionality and Market Context

The complaint alleges that the accused products are computing devices that incorporate the patented technologies as standard components. These functionalities include the integrated circuit clocking systems, the use of a TPM for hardware-based security, the management of media via software, and the operation of flash memory (Compl. ¶¶26; Compl. ¶37; Compl. ¶47; Compl. ¶56). The complaint alleges HP develops, manufactures, markets, and sells these products throughout the United States, including in the Eastern District of Texas Compl. ¶10 The complaint includes a 2025 tax statement for HP Inc. in Collin County, Texas, as evidence of its business operations in the district Compl. p. 5 The complaint also presents screenshots from LinkedIn identifying individuals as high-level HP employees working in the Eastern District of Texas to support its allegations of Defendant's established business presence Compl. p. 11

IV. Analysis of Infringement Allegations

The complaint references claim chart exhibits that were not provided. The following tables are synthesized based on the asserted claims and infringement theories described in the complaint.

U.S. Patent No. 10,771,012 Infringement Allegations

Claim Element (from Independent Claim 19)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a semiconductor device, comprising a first external pin and an internal oscillator	The accused HP laptops are semiconductor devices containing an internal oscillator and external pins for connecting components like crystals.	¶¶27, 62	col. 4:25-28
an external resonant element coupled to the semiconductor device at least through the first external pin	The accused HP laptops utilize an external crystal as a resonant element, which is coupled to the device's internal circuitry.	¶26	col. 4:5-10
wherein the internal oscillator comprises: a tunable oscillator... a phase detector circuit... and an oscillator controller circuit...	The internal oscillator in the accused HP laptops allegedly contains a tunable oscillator, a phase detector, and a controller circuit to manage the clock signal.	¶26	col. 5:1-54
wherein the oscillator controller circuit is configured to use the output of the external resonant element to adjust frequency of the tunable oscillator during the entire operation of the tunable oscillator.	The oscillator controller in the accused HP laptops allegedly uses the external crystal's signal to continuously adjust the internal oscillator's frequency throughout its operation to maintain accuracy.	¶26	col. 10:1-4

U.S. Patent No. 8,261,072 Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A computer system comprising: one or more central processing units... random access memory... a trusted platform module...	The accused HP laptops are computer systems that include standard components and a Trusted Platform Module (TPM).	¶¶38, 72	col. 4:20-30
receiving a secure access code from a remote device outside of the trusted platform module	The TPM in the accused HP laptops is allegedly configured to receive a secure access code from an external component or peripheral.	¶37	col. 6:1-10
receiving usage authorization information generated by a secure generator, the usage authorization information being attached to the secure access code	The TPM allegedly receives usage authorization information that is attached to the secure code, originating from a secure generator.	¶37	col. 6:1-6
recognizing the secure access code	The TPM in the accused laptops is allegedly configured to recognize the received secure access code.	¶37	col. 6:7-8
and using the secure access code as a parameter for various trusted platform module commands.	The TPM in the accused laptops allegedly uses the recognized secure access code as a parameter to execute various secure commands.	¶37	col. 9:1-4

Identified Points of Contention

• Scope Questions: For the '012 patent, a key question will be the scope of the phrase "during the entire operation." The analysis may turn on whether the accused devices use the external crystal for continuous adjustment, as the claim requires, or only for initial calibration or intermittent checks. For the '072 patent, the definition of "remote device outside of the trusted platform module" will be critical. The court may need to determine if this term can read on integrated components on the motherboard or if it requires a physically separate peripheral.
• Technical Questions: A central technical question for the '012 patent is what evidence demonstrates that the accused laptops' clock management system performs the specific feedback loop of phase detection and frequency adjustment described in the claim. For the '072 patent, a key question is whether the security architecture of the accused laptops implements the specific claimed flow of receiving a "secure access code" and attached "usage authorization information" from a "secure generator."

V. Key Claim Terms for Construction

For the '012 Patent:

• The Term: "during the entire operation of the tunable oscillator"
• Context and Importance: This term appears in claim 19 and defines the temporal scope of the frequency adjustment process. Practitioners may focus on this term because its interpretation will be central to the infringement analysis. A narrow interpretation (requiring uninterrupted adjustment) may make infringement harder to prove, while a broader interpretation (allowing for any adjustment while the oscillator is active) may favor the plaintiff's case.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The claim language itself states the adjustment occurs "during the entire operation," and the patent's goal of maintaining accuracy suggests an ongoing process may be necessary Compl. ¶28 The patent describes the system as one that "may be adjusted so as to track the crystal resonance" '012 Patent, col. 7:9-10
  • Evidence for a Narrower Interpretation: The patent discusses achieving a "locked frequency" state, which could imply periods where active adjustment is not occurring '012 Patent, col. 7:36-39 A defendant may argue that once a phase lock is achieved, the adjustment is no longer actively happening "during the entire operation" but is rather in a maintenance state.

For the '072 Patent:

• The Term: "remote device outside of the trusted platform module"
• Context and Importance: This term from claim 1 defines the source of the "secure access code". Its construction is critical because it determines what system architectures can infringe. Practitioners may focus on this term to dispute whether the accused functionality, which may involve components on the same motherboard as the TPM, qualifies as originating from a "remote device."
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The background of the invention discusses the security risks posed by "devices external to the TPM," a broad description that may support an interpretation covering any component not part of the TPM's trusted boundary, even if physically integrated on the same board Compl. ¶36
  • Evidence for a Narrower Interpretation: The specification includes figures depicting the "secure generator" as a distinct block separate from the main computing platform, which a defendant may argue implies a physically separate peripheral like a smart card or biometric reader '072 Patent, Fig. 4, item 420

VI. Other Allegations

• Willful Infringement: The complaint alleges that HP's infringement was and continues to be willful for all four asserted patents. The basis for these allegations is HP's alleged continued infringement after receiving actual notice from Crestone. The complaint provides specific dates for these notices: on or about July 29, 2025, for the '012 patent; on or about December 17, 2025, for the '072 patent; on or about March 26, 2026, for the '534 patent; and on or about June 26, 2026, for the '231 patent Compl. ¶65 Compl. ¶75 Compl. ¶85 Compl. ¶95

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

• A primary issue will be one of claim construction: whether the temporal limitation "during the entire operation" in the '012 patent requires continuous, uninterrupted frequency adjustment, and whether the structural term "remote device" in the '072 patent can be construed to cover software or hardware components integrated within the accused laptops, as opposed to requiring a physically separate peripheral.
• A key evidentiary question will be one of technical implementation: what evidence will be presented to demonstrate that the accused HP products' clocking systems and TPM security protocols perform the specific, multi-step logical functions recited in the asserted claims, versus performing a functionally similar but technically distinct operation not contemplated by the patents.
• A significant procedural question will be venue: The court will need to determine if Plaintiff's allegations regarding HP's physical presence in Plano, Texas, and its litigation history in the district are sufficient to establish a "regular and established place of business" under current legal standards, an issue the complaint heavily emphasizes.