DCT

4:26-cv-01105

Near Field Electronics LLC v. Travismathew LLC

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Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 4:26-cv-01105, E.D. Tex., 08/19/2026
  • Venue Allegations: Venue is based on Defendant having a regular and established place of business within the Eastern District of Texas, and on allegations that Defendant sells and solicits business in the district.
  • Core Dispute: Plaintiff alleges that Defendant's use of Near Field Communication (NFC) front-end components for contactless payment processing infringes five patents related to integrated circuit design, multi-protocol bus interfacing, and power management.
  • Technical Context: The patents-in-suit relate to foundational technologies for creating flexible, cost-effective, and power-efficient integrated circuits for communication between devices and peripherals.
  • Key Procedural History: All five asserted patents have expired or will expire by the complaint's filing date. Plaintiff explicitly limits its claims for damages to a period starting August 19, 2020 (exactly six years prior to the filing date, corresponding to the statute of limitations for patent damages) and ending on the respective expiration date of each patent.

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
2020-08-19 Asserted liability period begins for all patents
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
2026-08-19 Complaint Filing Date

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

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

  • Patent Identification: U.S. Patent No. 6,691,201, "Dual Mode USB-PS/2 Device," issued February 10, 2004 Compl. ¶8

The Invention Explained

  • Problem Addressed: The patent describes that peripheral devices supporting multiple communication standards, such as both the legacy PS/2 and the then-emerging USB protocols, required costly additional external components, increased circuit board space, and complex firmware to manage the different protocols Compl. ¶11 '201 Patent, col. 1:28-51
  • The Patented Solution: The invention is a single integrated circuit for a peripheral device that can automatically detect and select between multiple signaling protocols (e.g., USB or PS/2) using a single, shared set of input/output (I/O) pins Compl. ¶10 '201 Patent, abstract '201 Patent, col. 2:44-49 This "single chip solution" aims to eliminate the need for external components, simplify firmware, and reduce board space and cost Compl. ¶12 '201 Patent, col. 1:52-61
  • Technical Importance: The technology offered a more integrated and cost-effective way for manufacturers to produce computer peripherals (like keyboards and mice) that were compatible with both older and newer computer systems, easing the market transition from PS/2 to USB interfaces.

Key Claims at a Glance

  • The complaint asserts independent claim 14 Compl. ¶31
  • The essential elements of claim 14 are:
    • (A) detecting a signaling protocol of a bus connected to an integrated circuit that operates in a plurality of signaling protocols; and
    • (B) configuring said integrated circuit to communicate in one of said plurality of signaling protocols in response to said detected signaling protocol of said connected bus,
    • wherein each of said selected protocols operate over said connected bus through a single set of pins.
  • The complaint reserves the right to amend or supplement its infringement analysis Compl. ¶32

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

  • Patent Identification: U.S. Patent No. 6,742,071, "Real-time I/O Processor Used to Implement Bus Interface Protocols," issued May 25, 2004 Compl. ¶13

The Invention Explained

  • Problem Addressed: The patent addresses the rigidity of conventional bus interfaces. Protocol-specific interfaces lacked flexibility, while user-programmable interfaces were often too simplistic to handle complex signaling requirements for evolving bus standards '071 Patent, col. 1:13-48
  • The Patented Solution: The patent teaches a programmable, real-time input/output (I/O) processor, referred to as a general-purpose interface (GPIF), designed to replace protocol-specific hardware Compl. ¶16 This processor uses a limited instruction set to generate interface-specific waveforms and respond to external events, allowing control outputs and data path decisions to be changed on each clock cycle '071 Patent, col. 4:66-5:11 '071 Patent, abstract Compl. ¶15 Compl. ¶16
  • Technical Importance: This architecture provides a flexible and high-speed solution for a single chip to communicate over multiple, complex bus protocols without requiring a redesign of the hardware for each protocol, thereby accelerating product development and adaptation '071 Patent, col. 2:53-61

Key Claims at a Glance

  • The complaint asserts independent claim 15 Compl. ¶36
  • The essential elements of claim 15 are:
    • (A) receiving a clock signal;
    • (B) progressing to a next state based on said current state, at least one internal control signal of said first control signals and an input signal received from said external bus;
    • (C) driving at least one output control signal of said first controls signals onto said external bus; and
    • (D) updating said current state to said next state.
  • The complaint reserves the right to amend or supplement its infringement analysis Compl. ¶37

Multi-Patent Capsule: U.S. Patent No. 6,959,350 - "Configurable USB Interface With Virtual Register Architecture"

  • Patent Identification: U.S. Patent No. 6,959,350, "Configurable USB Interface With Virtual Register Architecture," issued October 25, 2005 Compl. ¶17
  • Technology Synopsis: The patent addresses the problem of inflexible, hard-coded endpoint configurations in USB interface controllers, which required fabricating different versions of the controller for different endpoint needs Compl. ¶20 '350 Patent, col. 1:17-28 The invention provides a configurable interface controller that uses a hardware description language (HDL)-based package to generate the necessary configuration circuitry, allowing the controller to be flexibly configured for different endpoints without requiring new hardware designs Compl. ¶19 Compl. ¶21 '350 Patent, abstract
  • Asserted Claims: Independent claim 10 is asserted Compl. ¶41
  • Accused Features: The complaint alleges that NFC Front-end components perform the claimed method during contactless payment transactions Compl. ¶41

Multi-Patent Capsule: U.S. Patent No. 6,996,727 - "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor"

  • Patent Identification: U.S. Patent No. 6,996,727, "Power Supply for Universal Serial Bus Interface with Programmable Bus Pullup Resistor," issued February 7, 2006 Compl. ¶22
  • Technology Synopsis: The patent addresses the lack of a low-power mode in conventional USB power supplies, which provided a constant voltage Compl. ¶25 '727 Patent, col. 1:16-44 The invention is a power supply architecture with a standard operating mode and a power-down (standby) mode. In standby mode, the main supply is turned off, and a low-power programmable resistor is used to maintain the bus pullup function, significantly reducing current consumption Compl. ¶24 '727 Patent, abstract
  • Asserted Claims: Independent claim 18 is asserted Compl. ¶46
  • Accused Features: The complaint alleges that NFC Front-end components perform the claimed method during contactless payment transactions Compl. ¶46

Multi-Patent Capsule: U.S. Patent No. 7,373,531 - "Signal Detection Method...and Electronic Apparatus"

  • Patent Identification: U.S. Patent No. 7,373,531, "Signal Detection Method...and Electronic Apparatus," issued May 13, 2008 Compl. ¶26
  • Technology Synopsis: The patent discloses methods and devices for detecting signals and their states (e.g., presence, frequency) to control power consumption Compl. ¶28 The solution involves applying a signal to the gates of connected transistors and determining the signal's state by detecting whether a "through current" flows in the circuit; this detection can then be used to initiate power-saving actions Compl. ¶28 Compl. ¶29 '531 Patent, abstract
  • Asserted Claims: Independent claim 2 is asserted Compl. ¶51
  • Accused Features: The complaint alleges that NFC Front-end components perform the claimed method during contactless payment transactions Compl. ¶51

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "NFC Front-end components, including without limitation the NXP PN512 NFC Front-End," as well as other components with "functionality materially similar" Compl. ¶31 Compl. ¶36 Compl. ¶41 Compl. ¶46 Compl. ¶51

Functionality and Market Context

The complaint alleges that Defendant uses or causes these components to be used to process contactless credit card payment transactions at a point of sale Compl. ¶31 The use is described as being in the "regular course of its business operations for processing NFC payment transactions," suggesting the components are integral to Defendant's commercial activities Compl. ¶33 The complaint does not provide further technical details on how the accused components operate.

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint alleges that the accused NFC Front-end components directly infringe the asserted claims of the patents-in-suit when used to process contactless payments Compl. ¶31 Compl. ¶36 Compl. ¶41 Compl. ¶46 Compl. ¶51 For each asserted patent, the complaint states that an "Exemplary infringement analysis" is provided in a corresponding exhibit (e.g., Exhibit A-1, B-1) Compl. ¶32 Compl. ¶37 Compl. ¶42 Compl. ¶47 Compl. ¶52 However, these exhibits were not filed with the complaint, and the complaint body itself contains no narrative explanation or mapping of the accused product's features to the specific limitations of the asserted claims. As such, a detailed claim chart summary cannot be constructed from the provided document.

  • Identified Points of Contention:
    • '201 Patent: A primary question may be one of claim scope. The patent is framed around detecting and switching between computer peripheral protocols like USB and PS/2. The infringement analysis will need to address whether the various communication modes of an NFC device (e.g., reader/writer, card emulation) can be considered a "plurality of signaling protocols" and whether the accused device's operation constitutes "detecting" and "configuring" in a manner consistent with the claim language and specification.
    • '071 Patent: The infringement analysis for the '071 patent will likely face an evidentiary question regarding technical operation. The claim requires a specific method of "progressing to a next state" based on a current state and inputs. The plaintiff may need to demonstrate through discovery that the internal architecture of the accused NFC chip functions as a programmable, instruction-driven I/O processor, rather than as a fixed-function, hardwired logic circuit.

V. Key Claim Terms for Construction

  • Term from '201 Patent, Claim 14: "plurality of signaling protocols"

    • Context and Importance: This term is central because the patent's specification is heavily focused on the USB and PS/2 protocols. The accused technology is NFC. The viability of the infringement claim may depend on whether this term can be construed broadly enough to encompass the different operational modes of an NFC interface.
    • Intrinsic Evidence for a Broader Interpretation: The claim language itself is not explicitly limited to any specific protocols. The patent refers generally to "a method and/or architecture for peripheral devices" '201 Patent, col. 1:4-8, which may support an interpretation not strictly tied to the examples provided.
    • Intrinsic Evidence for a Narrower Interpretation: The patent is titled "Dual Mode USB-PS/2 Device," and the background, summary, and detailed description sections are exclusively dedicated to solving problems related to supporting both USB and PS/2 '201 Patent, col. 1:9-61 This pervasive context may be used to argue that the term should be limited to host-peripheral communication protocols of that type.

  • Term from '071 Patent, Claim 15: "progressing to a next state based on said current state"

    • Context and Importance: This term defines the core operational step of the claimed method. Practitioners may focus on this term because its construction will determine whether any clocked digital circuit that changes state infringes, or if infringement requires the specific instruction-based processor architecture described in the patent.
    • Intrinsic Evidence for a Broader Interpretation: On its face, the language is high-level and could arguably describe the fundamental operation of many types of finite state machines used in digital logic. The patent mentions the goal is to allow "decisions to be made and output to be changed once per clock cycle" '071 Patent, col. 2:65-col. 3:1, a general description.
    • Intrinsic Evidence for a Narrower Interpretation: The specification provides a detailed embodiment of a "specialized input-output processor with two instructions" ("branch on signal" and "wait N clocks") '071 Patent, col. 5:5-8 '071 Patent, col. 8:13-22 An argument could be made that "progressing to a next state" should be construed in light of this specific processor-based implementation, requiring an instruction-driven operation rather than just any state transition.

VI. Other Allegations

The complaint does not contain explicit allegations of indirect or willful infringement. It does, however, request a declaration that the case is "exceptional" under 35 U.S.C. § 285 and an award of attorneys' fees Compl., Prayer for Relief ¶C

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

  1. Technological Scope: A core issue will be one of analogical interpretation: can claim terms rooted in the technical context of early 2000s PC peripheral interfaces (e.g., "plurality of signaling protocols" for USB/PS/2) be construed to cover the distinct functionalities and operational modes of a modern NFC front-end used for contactless payments?

  2. Evidentiary Sufficiency: The complaint makes conclusory infringement allegations without providing a technical basis. A key question for the litigation will be one of evidentiary proof: what evidence can the plaintiff obtain and present to demonstrate that the internal microarchitecture and real-time operation of the accused NFC chips map onto the specific, step-by-step methods recited in the asserted claims, particularly the state-based processing of the '071 patent?