DCT

2:26-cv-00796

Vicor Corp v. Delta Electronics Inc

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Key Events
Complaint
complaint Intelligence

I. Executive Summary and Procedural Information

Case Timeline

Date Event
2012 Quanta Computer Inc. launches Quanta Cloud Technology subsidiary.
2016-04-05 Earliest Priority Date for U.S. Patent No. 10,903,734.
2021-01-26 U.S. Patent No. 10,903,734 issues.
2023 Alleged Delta revenue from sales of accused VPD products (pleaded "since 2023").
2025-10 Luxshare-Tech attends OCP Global Summit to advertise products.
2026-09-08 Complaint filed.

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

U.S. Patent No. 10,903,734, "Delivering Power to Semiconductor Loads," issued January 26, 2021

The Invention Explained

  • Problem Addressed: The patent's background describes the challenge of efficiently supplying increasingly high currents (e.g., over 500 amps) to very large-scale integrated ("VLSI") semiconductor dies like CPUs and GPUs, where power connections to the package or substrate demand a large number of pins and can suffer from significant power dissipation '734 Patent, col. 1:24-52
  • The Patented Solution: The invention proposes a "Vertical Power Delivery" (VPD) architecture that stacks a power converter directly with an "interconnection module" '734 Patent, col. 1:56-2:24 This interconnection module acts as a translator, taking power from the converter's relatively wide-spaced output terminals and delivering it to the semiconductor die's densely packed, fine-pitch power input grid '734 Patent, col. 12:45-50 By placing the power conversion stage vertically aligned with and in close proximity to the load, this "module sandwich" structure is designed to minimize the connection length and associated power losses, overcoming what the complaint terms the "last inch problem" of lateral power delivery Compl. ¶78 '734 Patent, abstract The complaint includes a figure from the patent illustrating this stacked arrangement of multiple converter assemblies on a semiconductor package Compl. ¶79
  • Technical Importance: This vertical, stacked approach to power delivery is designed to enable greater current density, power density, and efficiency, which are critical for meeting the extreme power demands of modern AI processors and high-performance computing systems Compl. ¶78 Compl. ¶80

Key Claims at a Glance

  • The complaint asserts independent claims 1, 2, 40, 45, 49, 53, 67, and 68, among other dependent claims Compl. ¶88
  • Independent Claim 1 (a method claim) requires, in essence:
    • Providing a power conversion module with a multi-cell structure and converter output terminals in a "first pattern" with a "first spacing."
    • Providing an "interconnection module" with "x-input terminals" on one side and "x-output terminals" on the opposite side in a "second pattern" with a "second spacing" that is different from the first.
    • Assembling the two modules to form a three-layer "module sandwich," where the interconnection module provides "electrical and mechanical translation" between the converter's wide pattern and the semiconductor's fine pattern.
  • Independent Claim 40 (an apparatus claim) recites the structural components of the system described in method claim 1, including the semiconductor device, the power conversion module, and the interconnection module with their respective terminal patterns and spacings.
  • Beyond the independent claims, the complaint affirmatively alleges direct infringement of numerous dependent claims—identifying at least claims 1-8, 11-14, 18-26, 40-56, 65-71, 80, 81, 83, 84, 90-93, and 95 of the ’734 Patent Compl. ¶88

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are "vertical power delivery systems, components thereof, and/or computing systems containing the same" Compl. ¶82 Specific products identified include Delta VPD modules, Luxshare VPD modules, and the Infineon TDM24545S VPD module Compl. ¶88 Compl. ¶93 Compl. ¶98

Functionality and Market Context

  • The accused products are described as DC-DC power converters that enable Vertical Power Delivery (VPD) for high-performance computing applications Compl. ¶78 Compl. ¶80 Compl. Ex. 7, p. 2 They allegedly function by taking a higher input voltage and converting it to a much lower voltage at extremely high currents to power advanced processors Compl. ¶79
  • The complaint alleges that all named defendants participate in the same supply chain, which provides VPD solutions for Google's Tensor Processing Units (TPUs) used for artificial intelligence computing Compl. ¶85 Compl. ¶86 The defendants are categorized as either "module manufacturers" (Delta, Luxshare, Infineon) who design and build the accused power modules, or "contract manufacturers" (Quanta, Celestica, Foxconn) who integrate these modules—and infringing VPD modules made by other third parties such as Monolithic Power Systems, Inc. and Flex Ltd.—into larger systems Compl. ¶83 Compl. ¶84 Compl. ¶103 Compl. ¶108 Compl. ¶113 The complaint includes a photograph from a trade show display illustrating how Delta's power conversion modules are used in a data center context to power components like GPUs, TPUs, and CPUs Compl. Ex. 3, p. 2

IV. Analysis of Infringement Allegations

The complaint provides partial claim chart exhibits that map elements of the asserted claims to features of the accused products from several defendants. The analysis below summarizes the allegations against the Delta and Infineon products. The complaint also pleads direct, induced, and contributory infringement against Luxshare and attaches an exemplary claim chart comparing independent claims 1, 2, 40, 45, 53, 67, and 68 of the ’734 Patent to the Luxshare VPD module Compl. Ex. 5

10,903,734 Patent Infringement Allegations (vs. Delta)

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
providing a power conversion module having conversion circuitry arranged in a multi-cell structure having a plurality of conversion cells, The Delta VPD Module is alleged to be a power conversion module with multiple conversion cells. A provided image shows an "Example of a conversion cell" as part of a larger module. Ex. 3, pp. 3-5 col. 9:50-57
the converter output terminals being arranged in a first pattern having a first spacing between the converter output terminals The converter output terminals are allegedly arranged in a pattern with a spacing greater than 1mm. Ex. 3, pp. 8-9 col. 11:9-17
providing an interconnection module having x-input terminals arranged on a first side... and x-output terminals arranged on a surface of a second opposite side... in a second pattern... having a second spacing between x-output terminals, Delta's interconnection module allegedly has a grid of output terminals on its second side arranged in a second pattern with a spacing of 1mm or less. An exhibit image depicts a "Low Profile for Vetical Power Design" showing a stacked structure with a "Passive Embedded Packaging Platform." Ex. 3, p. 11 col. 12:61-13:3
the second spacing being different than the first spacing... The second spacing (around 1mm or less) is alleged to be smaller and thus different than the first spacing (greater than 1mm). Ex. 3, pp. 11-12 col. 12:24-29
wherein the power conversion module and the interconnection module are stacked to form a module sandwich including the power conversion module in a first layer, electrical connections... in a second layer, and the interconnection module in a third layer. The Delta VPD Module is alleged to be a stacked "module sandwich" with the power conversion module as a first layer, electrical connections as a second layer, and the interconnection module as a third layer. Ex. 3, pp. 14-16 col. 2:19-24

10,903,734 Patent Infringement Allegations (vs. Infineon)

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
providing a power conversion module having conversion circuitry arranged in a multi-cell structure having a plurality of conversion cells, The accused Infineon TDM24545S is identified as a "Quad-phase power module" containing four smart power stages, which the complaint maps to the claimed "plurality of conversion cells." Ex. 7, pp. 3-4 col. 9:50-57
providing an interconnection module having x-input terminals arranged on a first side... and x-output terminals arranged on a surface of a second opposite side... The complaint alleges the Infineon VPD includes an interconnection module with x-input terminals on a first side and x-output terminals on an opposite side. An exploded-view diagram shows a power module, an intermediate board, and a motherboard substrate, illustrating the alleged stacked arrangement. Ex. 7, pp. 7-9 col. 12:55-13:3
the second spacing being different than the first spacing, the x-input terminals being electrically connected to the x-output terminals; The complaint alleges the second spacing (on the x-output side) is different from the first spacing (on the x-input side) and that the terminals are electrically connected. A diagram illustrates this concept with colored arrows indicating different spacings and electrical connections between layers. Ex. 7, pp. 10-12 col. 12:24-29
assembling the power conversion module to the first side of the interconnection module with each converter output terminal mated with and electrically connected to a respective x-input terminal; The complaint alleges the power conversion module is assembled to the first side of the interconnection module, with the respective terminals mated and connected. A diagram shows the power conversion module positioned above the interconnection module, with arrows indicating the assembly and connection. Ex. 7, p. 13 col. 12:30-33
wherein the power conversion module and the interconnection module are stacked to form a module sandwich including the power conversion module in a first layer, electrical connections... in a second layer, and the interconnection module in a third layer. The accused products are alleged to form a stacked "module sandwich" with the power conversion module as the first layer, electrical connections as the second, and the interconnection module as the third. A diagram illustrates this layered structure, labeling the "SOC substrate" and "Motherboard" below the power module. Ex. 7, p. 15 col. 2:19-24

Identified Points of Contention

  • Scope Questions: A central dispute may arise over the definition of "interconnection module." The defendants may argue that their accused products use a standard printed circuit board (PCB) or substrate, not a distinct "module" as claimed. The question for the court will be whether a PCB that performs the alleged function of translating terminal patterns falls within the scope of this claim term.
  • Technical Questions: The claims require a "second spacing being different than the first spacing" '734 Patent, col. 17:57-58 A key factual question will be whether the accused products exhibit two distinct terminal patterns with different spacings that map onto this limitation. Evidence will likely focus on the physical layout of the converter-side contacts versus the semiconductor-side contacts on the accused intermediate board or substrate.
  • Functional Questions: The claims require the interconnection module to "provide electrical and mechanical translation" '734 Patent, col. 17:65-18:2 A point of contention may be whether routing traces on a PCB from a coarse-pitch array to a fine-pitch array constitutes "translation" in the specific sense covered by the patent, or if it is merely conventional circuit board design.

V. Key Claim Terms for Construction

  • The Term: "interconnection module"

  • Context and Importance: This term is the technological core of the asserted independent claims, describing the component that bridges the power converter and the semiconductor die. Its construction will be critical, as it may determine whether the defendants' use of PCBs or substrates in their assemblies constitutes infringement. Practitioners may focus on this term because its definition could either broadly cover any intermediate substrate that connects two components with different terminal pitches or be narrowly limited to a specific structure disclosed in the patent.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The specification describes the module's function as providing "electrical and mechanical translation between the converter output terminals arranged in a first pattern and the power input terminals of the semiconductor device arranged in a second pattern" '734 Patent, col. 12:45-50, suggesting that any component performing this function could be an "interconnection module."
    • Evidence for a Narrower Interpretation: The patent's detailed description and figures show the interconnection module as a distinct, fabricated component, often including its own PCB, embedded capacitors, and encapsulant, which is then assembled into a "module sandwich" with the converter '734 Patent, FIG. 5A '734 Patent, col. 12:30-36 This could support an argument that the term is limited to such a specifically constructed and integrated component, not just any substrate.

  • The Term: "a second spacing being different than the first spacing"

  • Context and Importance: This limitation captures a key aspect of the invention—bridging two different connection densities. The infringement analysis will turn on whether the accused products exhibit this structural characteristic.

  • Intrinsic Evidence for Interpretation:

    • Evidence for a Broader Interpretation: The plain language suggests that any measurable difference in the pitch of the terminal patterns on the two sides of the interconnection module would satisfy the limitation.
    • Evidence for a Narrower Interpretation: The specification repeatedly contrasts the "natural contact structure of the multi-cell power converter" with the "closely-spaced, e.g. on a 1 mm or less pitch" grid of the semiconductor '734 Patent, col. 11:67-12:29 This context suggests the "different" spacing is not incidental but is a functionally significant difference between a coarse-pitch converter array and a fine-pitch die array.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that defendants induce infringement by actively encouraging and instructing customers and end users to use the accused products in an infringing manner. This is allegedly done through marketing materials, the distribution of datasheets and technical product manuals, and technical support Compl. ¶89 Compl. ¶94 Compl. ¶99 Contributory infringement is also alleged, on the basis that the accused components are especially made for an infringing use and are not staple articles of commerce Compl. ¶90 Compl. ¶95 Compl. ¶100 The complaint pleads parallel inducement and contributory-infringement allegations against the contract-manufacturer defendants Quanta, Celestica, and Foxconn Compl. ¶105 Compl. ¶106 Compl. ¶110 Compl. ¶111 Compl. ¶115 Compl. ¶116
  • Willful Infringement: Willfulness is alleged on the basis that each defendant has had knowledge of the '734 patent and the infringing nature of its products "No later than as of the filing and service of this Complaint" Compl. ¶89 Compl. ¶94 Compl. ¶99, with parallel knowledge allegations pleaded against the remaining contract-manufacturer defendants Quanta, Celestica, and Foxconn Compl. ¶105 Compl. ¶110 Compl. ¶115 Plaintiff seeks treble damages as a result Compl., Prayer for Relief ¶C

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

  1. A Definitional Scope Question: A central issue will be the construction of the term "interconnection module." Can this term, described in the patent as a specific component providing "electrical and mechanical translation," be construed to cover the printed circuit boards and substrates that defendants allegedly use to connect their power converters to semiconductor loads?
  2. A Factual Mismatch Question: The case will likely depend on a factual and technical comparison of terminal patterns. Does the evidence show that the accused products have a converter-side terminal pattern with a "first spacing" and a semiconductor-side pattern with a "second spacing" that is demonstrably "different," as required by the claims, or will defendants be able to argue that their products use a uniform or non-differentiated connection scheme?
  3. A Supply Chain Liability Question: Given the number of defendants, a key aspect of the case will be untangling liability across the supply chain. The court will need to determine which defendants are responsible for direct infringement by making and selling the allegedly infringing modules, and which may be liable for indirect infringement by integrating those modules into larger systems for end-customers like Google.