DCT

7:26-cv-00079

Nextech Semiconductor LLC v. Micron Technology Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-00079, W.D. Tex., 06/01/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Defendant Micron maintains a "regular and established place of business" in Austin, Texas, and has employees in Austin responsible for marketing, sales, and work on the Accused Products.
  • Core Dispute: Plaintiff alleges that Defendant's Solid-State Drive (SSD), 3D NAND, and DDR SDRAM products infringe six patents related to fundamental semiconductor circuit technologies, including electrostatic discharge protection, charge pumps, regulators, and oscillators.
  • Technical Context: The technologies at issue involve foundational circuit designs for managing power, protecting against electrostatic discharge, and generating clock signals, which are critical for the reliability, performance, and power efficiency of modern semiconductor memory products.
  • Key Procedural History: Plaintiff filed this First Amended Complaint to address issues raised in a pending Motion to Dismiss. The complaint alleges that the original patent owner, NXP Semiconductors N.V., provided Defendant with pre-suit notice of infringement of all Asserted Patents, including claim charts, on September 13, 2022, but that Defendant did not take a license. The patents were subsequently assigned from NXP to Plaintiff Nextech.

Case Timeline

Date Event
2006-10-05 '601 Patent Priority Date
2007-05-03 '202 Patent Priority Date
2007-11-16 '889 Patent Priority Date
2009-08-02 '108 Patent Priority Date
2009-09-22 '202 Patent Issue Date
2011-08-16 '601 Patent Issue Date
2012-05-15 '108 Patent Issue Date
2012-07-23 '587 Patent Priority Date
2012-09-28 '591 Patent Priority Date
2013-10-15 '591 Patent Issue Date
2013-12-10 '889 Patent Issue Date
2014-04-22 '587 Patent Issue Date
2022-09-13 Pre-Suit Notice of Infringement to Defendant
2026-06-01 Complaint Filing Date

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

U.S. Patent No. 7,593,202 - "Electrostatic Discharge (ESD) Protection Circuit for Multiple Power Domain Integrated Circuit," issued September 22, 2009

The Invention Explained

  • Problem Addressed: The patent addresses the difficulty of providing effective electrostatic discharge (ESD) protection in complex integrated circuits (ICs) that use multiple, distinct power domains. Interspersing I/O buffers from different power domains complicates the design of ESD protection and can consume significant chip layout area '202 Patent, col. 1:41-48
  • The Patented Solution: The invention proposes an ESD protection architecture where a bank of I/O cells is coupled to two different power domains. The solution utilizes a "first plurality of active clamps" for the first domain and a "second plurality of active clamps" for the second domain, with the key feature being that these pluralities of clamps "overlap along said bank of I/O cells" '202 Patent, abstract This distributed, overlapping structure allows for more efficient and compact ESD protection in multi-domain ICs '202 Patent, col. 9:1-10
  • Technical Importance: This approach provided a way to integrate robust ESD protection into increasingly complex, power-managed ICs without demanding excessive layout area, a critical consideration in semiconductor design.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 Compl. ¶213
  • The essential elements of Claim 1 are:
    • An integrated circuit comprising:
    • a first power domain;
    • a second power domain;
    • a bank of input/output (I/O) cells coupled to said first and second power domains, including a first plurality of active clamps for said first power domain and a second plurality of active clamps for said second power domain;
    • wherein said first and second pluralities of active clamps overlap along said bank of I/O cells.
  • The complaint reserves the right to assert other claims Compl. ¶211

U.S. Patent No. 7,999,601 - "Charge Pump and Control Scheme," issued August 16, 2011

The Invention Explained

  • Problem Addressed: When activating power to different parts of a circuit, using a charge pump alone can be slow, while using a primary power source (like a battery) may not achieve a high enough voltage or can be inefficient for the entire process '601 Patent, col. 3:28-41
  • The Patented Solution: The patent describes a two-stage method for energizing an output channel. First, a primary "power source connection" (e.g., a battery) pre-charges the channel to a second, intermediate voltage. Subsequently, a "charge pump" takes over to boost the channel to the final, higher "first charge voltage" '601 Patent, abstract '601 Patent, col. 3:30-41
  • Technical Importance: This hybrid approach combines the speed of a high-current source for initial charging with the voltage-boosting capability of a charge pump, enabling faster and more efficient power-gating in complex chips.

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 Compl. ¶254
  • The essential elements of Claim 1 are:
    • A switch controller comprising:
    • a charge pump configured to provide a first charge voltage;
    • a selector switch with an input connected to the charge pump, operable to connect to an output channel;
    • a power source connection providing a second charge voltage (less than the first) to the selector switch's input;
    • wherein, during enablement, the selector switch first provides power from the power source connection to partially charge the channel, and subsequently provides power from the charge pump to charge the channel to the first charge voltage.
  • The complaint reserves the right to assert other claims Compl. ¶252

U.S. Patent No. 8,179,108 - "Regulator Having Phase Compensation Circuit," issued May 15, 2012

  • Technology Synopsis: The patent describes a voltage regulator designed to maintain stability across a wide range of output currents. It employs a phase compensation circuit with a variable resistor, which adjusts the output impedance of a differential amplifier based on the output current, thereby improving the regulator's phase margin and stability '108 Patent, abstract Compl. ¶287
  • Asserted Claims: Claim 1 Compl. ¶294
  • Accused Features: The complaint accuses regulators within Micron's DDR SDRAM Products, such as those in the D9XPC memory chip, of infringement Compl. ¶¶296-299

U.S. Patent No. 8,558,591 - "Phase Locked Loop with Power Supply Control," issued October 15, 2013

  • Technology Synopsis: The patent discloses a phase-locked loop (PLL) architecture that improves noise immunity by using separate, isolated analog power supplies for its key components: the phase frequency detector, the charge pump, and the voltage-controlled oscillator (VCO). A supply voltage provider generates these distinct supply voltages from a single external source '591 Patent, abstract Compl. ¶327
  • Asserted Claims: Claim 1 Compl. ¶334
  • Accused Features: The complaint targets PLLs within Micron's SSD Products, specifically identifying the "PCIe PLLa" in the Micron 2300 SSD Compl. ¶¶336-339

U.S. Patent No. 8,604,889 - "Tunable LC Oscillator with Common Mode Voltage Adjustment," issued December 10, 2013

  • Technology Synopsis: The invention aims to improve phase noise in LC oscillators by actively managing the common mode voltage. A control circuit adjusts this voltage in response to frequency changes, which reduces undesirable state transitions in the oscillator's MOS switches and thereby minimizes phase noise degradation '889 Patent, abstract Compl. ¶377
  • Asserted Claims: Claim 1 Compl. ¶384
  • Accused Features: The adjustable frequency oscillator within the "PCIe PLLa" of the Micron 2300 SSD is accused of infringement Compl. ¶¶389-390

U.S. Patent No. 8,704,587 - "Configurable Multistage Charge Pump Using a Supply Detect Scheme," issued April 22, 2014

  • Technology Synopsis: This patent describes a charge pump that adapts to wide variations in input voltage. Control logic detects the input voltage level and configures the charge pump by enabling or bypassing pumpcell stages as needed, ensuring efficient operation across the entire input voltage range '587 Patent, abstract Compl. ¶426
  • Asserted Claims: Claim 1 Compl. ¶433
  • Accused Features: The complaint alleges that configurable multistage charge pumps found within the 3D NAND chips of Micron's 2300 SSD infringe this patent Compl. ¶¶438-439

III. The Accused Instrumentality

  • Product Identification: The complaint accuses Micron's SSD Products, 3D NAND Products, and DDR SDRAM Products Compl. ¶53 Specific representative products identified are the Micron 2300 SSD and products using the D9XPC memory chip Compl. ¶217 Compl. ¶298
  • Functionality and Market Context: The Accused Products are semiconductor memory devices central to the data storage and computing industries. The complaint alleges these products incorporate a range of specific infringing circuit functionalities, including electrostatic discharge (ESD) protection circuits, switch controllers, phase-locked loops, configurable charge pumps, and regulators Compl. ¶¶46-51 The complaint provides an annotated photograph of the Micron 2300 SSD's printed circuit board (PCB) to identify the controller that allegedly contains the infringing circuits Compl. ¶219 The complaint frames Defendant as a major semiconductor "holdout" that declined to take a license from the patents' original owner, NXP Compl. ¶16

IV. Analysis of Infringement Allegations

'202 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
An integrated circuit comprising: The Micron 2300 SSD includes an integrated circuit. ¶219 col. 1:10-11
a first power domain; The Accused Products include a first power domain, identified as VDDa/VSSa. ¶222 col. 1:11-12
a second power domain; The Accused Products include a second power domain, identified as VDDc/VSSa. ¶223 col. 1:11-12
a bank of input/output (I/O) cells coupled to said first and second power domains, The Micron 2300 SSD comprises a bank of I/O cells, with each I/O cell coupled to both the VDDa/VSSa and VDDc/VSSa power domains. An annotated die layout shows the bank of I/O cells Compl. ¶225 ¶¶224-226 col. 1:12-13
including a first plurality of active clamps for said first power domain and a second plurality of active clamps for said second power domain The Micron 2300 SSD comprises a first plurality of active clamps (identified as ESDb) for the first power domain and a second plurality of active clamps (identified as ESDa) for the second power domain. ¶228 col. 1:13-16
wherein said first and second pluralities of active clamps overlap along said bank of I/O cells. The complaint provides an annotated die layout showing that the ESDb clamps (for the first domain) and ESDa clamps (for the second domain) physically overlap along the bank of I/O cells. ¶228 col. 1:16-18
  • Identified Points of Contention:
    • Scope Questions: A likely point of dispute will be the construction of the term "active clamp." The court will need to determine if the circuits identified by Plaintiff as "ESDa" and "ESDb" Compl. ¶228 meet the patent's definition of an "active clamp."
    • Technical Questions: The infringement allegation hinges on the claim that the identified "ESDa" and "ESDb" circuits are associated with different power domains and "overlap." A central question will be whether the physical interspersion of these circuits along the I/O bank, as shown in the complaint's die layout diagrams Compl. ¶228, satisfies the "overlap" limitation as it is defined and enabled by the patent.

'601 Patent Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
A switch controller comprising: The Accused Products, such as the Micron 2300 SSD, include switch controllers in their 3D NAND chips. ¶¶255-259 col. 2:2-3
a charge pump configured to provide a first charge voltage; The Micron 2300 SSD includes a charge pump (CP_UNITx) that provides a first charge voltage, alleged to be approximately 2 * VDDy. A circuit diagram illustrates this functionality Compl. ¶261 ¶¶260-261; ¶268 col. 2:2
a selector switch, an input of the selector switch connected to the charge pump and the selector switch operable to connect to an output channel for charging the output channel; The Micron 2300 SSD includes a selector switch (WL_SW) whose input is connected to the charge pump and which connects to an output channel. ¶¶262-264 col. 2:3-5
and a power source connection communicating with the input to the selector switch, wherein the power source connection provides power at a second charge voltage, wherein the second charge voltage is less than the first charge voltage, The Micron 2300 SSD includes a power source connection that provides a second charge voltage (VDDy), which is less than the first charge voltage (2 * VDDy). The complaint provides an annotated circuit diagram showing the first and second charge voltages Compl. ¶266 ¶¶265-269 col. 2:5-9
wherein during an enablement of the channel from a disabled state, the selector switch provides power from the power source connection to charge the output channel from a disabled state to a voltage below the first charge voltage and subsequently provides power from the charge pump to charge the output channel to the first charge voltage. The complaint alleges the selector switch first provides power from the power source connection to pre-charge the output channel to the second charge voltage, and subsequently provides power from the charge pump to complete charging to the first charge voltage. ¶270 col. 2:11-17
  • Identified Points of Contention:
    • Scope Questions: The analysis may turn on whether the accused "WL_SW" circuit Compl. ¶263 functions as the claimed "selector switch." A question is whether a single component performs the sequential connection to both the power source and the charge pump as required by the claim.
    • Technical Questions: A key evidentiary question will be whether the accused product performs the specific two-step charging sequence recited in the final "wherein" clause. The complaint alleges this sequence occurs Compl. ¶270, but the analysis will require evidence confirming that the selector switch first connects the "power source connection" for an initial charge and then connects the "charge pump" for a final charge, as opposed to a different operational flow.

V. Key Claim Terms for Construction

  • For the '202 Patent:

    • The Term: "active clamp"
    • Context and Importance: This term is the core protective element of the invention. Whether the accused ESDb and ESDa circuits Compl. ¶228 infringe depends entirely on whether they fall within the legal scope of an "active clamp." Practitioners may focus on this term because the patent's definition will determine if a broad class of ESD circuits or only a specific implementation is covered.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification refers to the element more generally as a "shunting device" or a "gated-on MOSFET" triggered during an ESD event, which could support a construction that is not limited to a specific circuit topology '202 Patent, col. 3:1-4
      • Evidence for a Narrower Interpretation: The patent illustrates the active clamp with specific embodiments, such as transistor 140 in FIG. 1, which is part of a trigger circuit arrangement. A party could argue the term should be construed more narrowly to require a similar triggered shunting transistor configuration.

  • For the '601 Patent:

    • The Term: "wherein during an enablement ... the selector switch provides power from the power source connection ... and subsequently provides power from the charge pump"
    • Context and Importance: This lengthy clause defines the specific, sequential two-step operation that is the essence of the invention. The infringement case rests on proving the accused device performs this exact sequence. Practitioners may focus on this phrase because it dictates the functional evidence required; merely having a charge pump and a power source is insufficient.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party might argue that any system that uses a primary source for an initial charge followed by a charge pump for a final charge meets the limitation, focusing on the functional outcome rather than the precise switching mechanism.
      • Evidence for a Narrower Interpretation: The claim language recites that the "selector switch" itself performs this sequential action. This could support a narrower construction requiring a single switching element or a tightly integrated block that is directed to perform both steps in sequence, as described in the detailed description '601 Patent, col. 3:30-41

VI. Other Allegations

  • Indirect Infringement: For all asserted patents, the complaint alleges induced infringement. The stated basis is that Defendant publishes and provides "specifications, datasheets, instruction manuals, support materials, developer materials, marketing materials, and user guide materials" that instruct and encourage third parties (such as customers and platform suppliers) to make, use, and sell the Accused Products in an infringing manner Compl. ¶¶235-237 Compl. ¶¶275-277 The complaint also advances theories of vicarious liability based on the actions of Defendant's affiliates and subcontractors Compl. ¶¶152-204
  • Willful Infringement: The complaint alleges willful infringement for all asserted patents. The primary factual basis for this allegation is Defendant's alleged pre-suit knowledge of the patents and infringement. The complaint specifically alleges that on September 13, 2022, NXP (Plaintiff's predecessor-in-interest) sent Defendant a notice letter identifying all of the Asserted Patents and providing "evidence of use documents or claim charts demonstrating the alleged infringement" Compl. ¶139 Compl. ¶141 Compl. ¶239 Compl. ¶279

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

  1. Willfulness and Pre-Suit Knowledge: A central issue will be the allegation of willful infringement, which is grounded in a specific claim of pre-suit notice with detailed infringement contentions Compl. ¶139 The court's analysis will likely focus on the evidence surrounding the September 13, 2022 communication from NXP to Micron and Micron's conduct thereafter, which will be critical in determining intent and potential for enhanced damages.

  2. Claim Scope and Functional Equivalence: The case will likely involve significant disputes over both claim construction and functional operation. A core question for the '202 patent will be one of definitional scope: does the term "active clamp", in the context of the patent, read on the specific "ESDa" and "ESDb" protection circuits used in the accused SSD? For the '601 patent, a key evidentiary question will be one of functional correspondence: does the accused product's circuitry perform the specific two-step sequence of pre-charging from a power source and then completing the charge with a charge pump, as strictly required by Claim 1?

  3. Liability for Distributed Infringement: The complaint includes extensive allegations of vicarious liability for the actions of Defendant's affiliates and subcontractors Compl. ¶¶152-204 A key legal question will be whether Plaintiff can successfully attribute the actions of these other entities to the named Defendants under theories of agency or the principles articulated in Akamai v. Limelight, particularly for acts of making, using, or selling that may occur across different corporate entities or geographies.

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