DCT

4:26-cv-00747

Near Field Electronics LLC v. Knitwell Group LLC

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-00747, E.D. Tex., 09/14/2026
  • Venue Allegations: Venue is based on Defendants allegedly maintaining regular and established places of business for their retail store brands within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendants’ use of Near Field Communication (NFC) components in point-of-sale systems for contactless payments infringes five patents related to semiconductor interface technology, power management, and configuration.
  • Technical Context: The patents-in-suit relate to foundational technologies in semiconductor chip design for managing communication protocols, power consumption, and flexible configuration in peripheral devices.
  • Key Procedural History: The complaint alleges that all five patents-in-suit have expired. Plaintiff seeks damages only for a specific, closed time period beginning on June 12, 2020, and ending on the respective expiration date of each patent. No other significant procedural events are mentioned.

Case Timeline

Date Event
2000-06-21 ’201 Patent Priority Date
2000-07-25 ’071 Patent Priority Date
2000-08-28 ’727 Patent Priority Date
2002-06-28 ’350 Patent Priority Date
2004-02-10 ’201 Patent Issue Date
2004-05-25 ’071 Patent Issue Date
2005-01-11 ’531 Patent Priority Date
2005-10-25 ’350 Patent Issue Date
2006-02-07 ’727 Patent Issue Date
2008-05-13 ’531 Patent Issue Date
2020-06-12 Alleged Infringement Period Begins
2021-11-21 ’071 Patent Expiration Date
2022-01-31 ’201 Patent Expiration Date
2022-04-14 ’727 Patent Expiration Date
2023-08-12 ’350 Patent Expiration Date
2026-03-19 ’531 Patent Expiration Date
2026-09-14 Complaint Filing Date

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

U.S. Patent No. 6,691,201 - "Dual Mode USB-PS/2 Device," issued February 10, 2004

The Invention Explained

  • Problem Addressed: The patent describes that, at the time of invention, peripheral devices supporting multiple communication protocols (e.g., USB and PS/2) required additional external components, increased circuit board space, and dedicated microcontroller I/O pins, which increased cost and design complexity Compl. ¶12 ’201 Patent, col. 1:28-41
  • The Patented Solution: The invention is an integrated circuit that can automatically detect which signaling protocol a connected bus is using and configure itself to operate with that protocol through a single, shared set of I/O pins Compl. ¶11 ’201 Patent, abstract This "single chip solution" is intended to eliminate the need for external components and simplify firmware Compl. ¶13 ’201 Patent, col. 2:5-10
  • Technical Importance: This approach allowed manufacturers of computer peripherals to reduce costs, simplify designs, and maximize connectivity by supporting multiple legacy and modern interface standards with a single component Compl. ¶13

Key Claims at a Glance

  • The complaint asserts at least independent method claim 14 Compl. ¶32
  • Key elements of claim 14 include:
    • detecting a signaling protocol of a bus connected to an integrated circuit that operates in a plurality of signaling protocols; and
    • configuring said integrated circuit to communicate in one of said plurality of signaling protocols in response to said detected signaling protocol, wherein each of said selected protocols operate over said connected bus through a single set of pins.
  • The complaint reserves the right to assert additional claims Compl. ¶33

U.S. Patent No. 6,742,071 - "Real-time I/O Processor Used to Implement Bus Interface Protocols," issued May 25, 2004

The Invention Explained

  • Problem Addressed: Traditional I/O systems used rigid, protocol-specific hardware designs, which were inflexible for supporting multiple or evolving bus standards and were limited in operational speed Compl. ¶17 ’071 Patent, col. 1:31-48
  • The Patented Solution: The ’071 patent discloses a real-time I/O processor architecture that acts as a master device, using a programmable general-purpose interface (GPIF) with a limited instruction set Compl. ¶16 This processor can generate interface-specific waveforms and change control outputs on each clock cycle, replacing inflexible hardware with a more adaptable, software-driven approach Compl. ¶17 ’071 Patent, col. 2:52-65
  • Technical Importance: This invention provided a flexible and higher-speed solution for interfacing with various bus protocols, enabling faster development cycles and adaptation to new standards without requiring new hardware designs Compl. ¶17

Key Claims at a Glance

  • The complaint asserts at least independent method claim 15 Compl. ¶37
  • Key elements of claim 15 include:
    • generating a plurality of first control signals in response to a current state of a processor;
    • progressing to a next state based on said current state, at least one internal control signal, and an input signal from an external bus;
    • driving at least one output control signal onto the external bus; and
    • updating the current state to the next state.
  • The complaint reserves the right to assert additional claims Compl. ¶38

U.S. Patent No. 6,959,350 - "Configurable USB Interface With Virtual Register Architecture," issued October 25, 2005

  • Technology Synopsis: The patent addresses the problem of hard-coded USB endpoint configurations in interface controllers, which required writing and maintaining different hardware description language (HDL) code for each version Compl. ¶21 The solution is a configurable bus interface controller that uses an HDL-based configuration package to flexibly generate circuitry for different USB endpoint configurations without requiring separate code for each endpoint Compl. ¶¶20, 22
  • Asserted Claims: At least independent method claim 10 Compl. ¶42
  • Accused Features: The use of NFC Front-end components to perform the claimed method during contactless payment transactions Compl. ¶42

U.S. Patent No. 6,996,727 - "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor," issued February 7, 2006

  • Technology Synopsis: The patent addresses the inefficiency of conventional power supplies that provided a constant voltage with no low-power mode Compl. ¶26 The invention provides a power supply architecture for a bus interface that operates in two modes: a standard mode and a power-down standby mode that reduces current consumption by using a low-power programmable resistor to maintain the necessary bus pullup function Compl. ¶25
  • Asserted Claims: At least independent method claim 18 Compl. ¶47
  • Accused Features: The use of NFC Front-end components to perform the claimed method during contactless payment transactions Compl. ¶47

U.S. Patent No. 7,373,531 - "Signal Detection Method...and Electronic Apparatus," issued May 13, 2008

  • Technology Synopsis: The patent is directed to methods for reducing power consumption in an electronic device by detecting its operational state Compl. ¶¶29-30 The solution involves applying a signal to the gates of connected transistors and detecting the presence, frequency, or state of that signal by monitoring whether a "through current" flows in the circuit, which enables the apparatus to reduce power when a target is not in operation Compl. ¶29
  • Asserted Claims: At least independent method claim 2 Compl. ¶52
  • Accused Features: The use of NFC Front-end components to perform the claimed method during contactless payment transactions Compl. ¶52

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the accused products as "NFC Front-end components, including without limitation the NXP PN512 NFC Front-End" and any other NFC front-end components with "functionality materially similar" (collectively, the "Relevant Instrumentalities") Compl. ¶32 Compl. ¶37 Compl. ¶42 Compl. ¶47 Compl. ¶52

Functionality and Market Context

  • The complaint alleges that Defendants use these instrumentalities in the regular course of their business operations to process contactless credit card payment transactions at their retail point-of-sale locations Compl. ¶32 Compl. ¶34 The functionality at issue is the alleged performance of the patented methods when these NFC components are used for their intended purpose of facilitating contactless payments Compl. ¶34 No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references preliminary infringement analysis in Exhibits A-1, B-1, C-1, and D-1, but these exhibits were not filed with the complaint and are not available for analysis Compl. ¶33 Compl. ¶38 Compl. ¶43 Compl. ¶48 The infringement theory must therefore be summarized from the narrative allegations.

’201 Patent Infringement Allegations

  • Narrative Summary: The complaint alleges that by using the Relevant Instrumentalities to process contactless payments, Defendants perform the method of claim 14 Compl. ¶32 This theory suggests that the process of an NFC chip establishing a contactless communication link is analogous to the claimed method of "detecting a signaling protocol" and "configuring" an integrated circuit to communicate over a shared set of pins, as originally described in the context of USB and PS/2 devices (Compl. ¶¶11-12; Compl. ¶32).
  • Identified Points of Contention:
    • Scope Question: A central question will be whether the term "bus," as used in the patent, can be interpreted to cover a wireless, near-field communication link.
    • Technical Question: The analysis may focus on whether the initial handshake and protocol establishment in an NFC transaction constitutes "detecting a signaling protocol" and responsively "configuring said integrated circuit" in the manner required by the claim, or if the underlying technical operations are fundamentally different from the USB/PS/2 context described in the patent.

’071 Patent Infringement Allegations

  • Narrative Summary: The complaint alleges that the use of the Relevant Instrumentalities in contactless payment transactions constitutes performance of the method of claim 15 Compl. ¶37 This implies that the accused NFC chips operate as a real-time I/O processor, executing a sequence of states based on internal signals and external inputs to manage the communication protocol with a payment card or device Compl. ¶16 Compl. ¶37
  • Identified Points of Contention:
    • Technical Question: A key issue will be whether the internal architecture and operation of the accused NFC components map to the specific state-based processing method of claim 15, which requires "progressing to a next state" based on a combination of the current state, internal control signals, and an external bus signal.
    • Evidentiary Question: The complaint does not specify how the accused NFC components perform each step. A focal point of discovery will likely be to determine if the accused components function as the claimed specialized processor or as a more general-purpose state machine.

V. Key Claim Terms for Construction

’201 Patent

  • The Term: "configuring said integrated circuit to communicate... in response to said detected signaling protocol" (from claim 14).
  • Context and Importance: This term is central to infringement, as the case depends on whether the accused NFC chip's operation during a transaction can be characterized as this type of responsive configuration. Practitioners may focus on whether this requires an active selection between distinct, pre-existing modes (like USB vs. PS/2) or can read on the establishment of a standard NFC link.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification refers to the invention as an interface circuit that can "automatically select" a protocol without user input, which could be argued to encompass any automated protocol establishment ’201 Patent, col. 2:52-54
    • Evidence for a Narrower Interpretation: The embodiments and detailed description focus exclusively on switching between USB and PS/2 protocols by detecting specific signal states (e.g., a "long low state") on the data lines, which may support an interpretation limited to that specific context ’201 Patent, col. 2:56-64

’071 Patent

  • The Term: "progressing to a next state based on said current state, at least one internal control signal... and an input signal received from said external bus" (from claim 15).
  • Context and Importance: This limitation defines a specific, multi-factor logic for state transitions. The infringement analysis will likely turn on whether the accused NFC chip operates according to this precise method.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent describes its solution as a "generic interface" intended to implement "changing and possibly future unknown standards," suggesting the invention was not meant to be limited to the specific protocols discussed (’071 Patent, col. 1:40-41; col. 2:58-60).
    • Evidence for a Narrower Interpretation: The claim language recites a specific combination of inputs for state progression. The specification's figures and description detail a particular architecture involving a finite state machine, a lookup table, and logic function blocks, which could be used to argue that the claim requires a similar structure and operational flow (’071 Patent, Fig. 6; col. 6:21-38).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that Defendants have infringed by "using and/or causing to be used" the Relevant Instrumentalities Compl. ¶32 Compl. ¶37 However, the complaint does not plead specific facts to support the knowledge and intent elements required for a claim of induced or contributory infringement.
  • Willful Infringement: The complaint does not contain an explicit allegation of willful infringement. It does, however, request a declaration that the case is "exceptional under 35 U.S.C. § 285" and seeks an award of attorneys' fees Compl. p. 13, Prayer C No specific facts alleging pre- or post-suit knowledge of the patents are included.

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

  1. Technological Analogy: A central issue will be whether the claims, drafted in the context of wired computer peripheral interfaces (e.g., USB, PS/2, EIDE), can be construed to cover the distinct technology of wireless, contactless NFC payment systems. The resolution may depend on whether the court views NFC as a foreseeable evolution of the problems the patents sought to solve or as a fundamentally different technical field.

  2. Evidentiary Mapping of Infringement: With the complaint's infringement charts being unavailable, a primary task for the plaintiff will be to produce evidence mapping the specific operational steps of the accused NFC components to the detailed limitations of the asserted method claims. The case will likely involve a deep technical dispute over whether the accused devices actually "progress to a next state" or "configure... in response to" a detected protocol in the precise manner claimed.

  3. Scope of Damages: Since all asserted patents are alleged to be expired and damages are confined to a specific, pre-filing time window, the case will be sharply focused on the discovery of Defendants' sales, usage, and revenue associated with the accused contactless payment systems during that defined period (June 12, 2020, to each patent's expiration).