DCT

7:26-cv-00364

Vicor Corp v. Monolithic Power Systems Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 7:26-cv-00364, W.D. Tex., 09/08/2026
  • Venue Allegations: Plaintiff alleges venue is proper for the foreign defendants as they are not U.S. residents. For the domestic defendant, Monolithic Power Systems, Inc., venue is alleged based on acts of infringement in the district and the maintenance of a regular and established place of business, evidenced by the presence of multiple employees who solicit and support customer accounts within the district.
  • Core Dispute: Plaintiff alleges that Defendant’s vertical power delivery modules infringe a patent related to stacked power conversion and interconnection modules for powering semiconductor loads.
  • Technical Context: The technology addresses the challenge of efficiently delivering high-current, low-voltage power to modern, high-performance semiconductors, which is critical for demanding applications such as artificial intelligence processing and datacenter infrastructure.
  • Key Procedural History: The asserted patent is a continuation-in-part of two prior patent applications, both of which have issued as U.S. patents. The complaint does not mention any prior litigation, inter partes review proceedings, or licensing history related to the patent-in-suit.

Case Timeline

Date Event
2016-04-05 Earliest Priority Date for U.S. Patent No. 10,903,734
2021-01-26 U.S. Patent No. 10,903,734 Issued
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"

  • Patent Identification: U.S. Patent No. 10,903,734 ("the '734 Patent"), titled "Delivering Power to Semiconductor Loads", issued on January 26, 2021.

The Invention Explained

  • Problem Addressed: The patent's background describes the difficulty of supplying very high electrical currents (e.g., exceeding 500 amps) to modern, large-scale semiconductor dies like CPUs and GPUs '734 Patent, col. 1:35-39 Traditional power delivery methods using connections on a printed circuit board (PCB) face challenges with space constraints, power loss, and thermal management, creating a bottleneck for high-performance chips '734 Patent, col. 1:24-40
  • The Patented Solution: The invention proposes a vertically stacked modular system to deliver power directly to a semiconductor load, a concept the complaint refers to as Vertical Power Delivery or "VPD" Compl. ¶26 The solution involves a "power conversion module" stacked on top of an "interconnection module" '734 Patent, col. 1:53-64 The power conversion module converts a higher input voltage to the low voltage required by the chip '734 Patent, col. 1:60-64 The interconnection module then acts as a mechanical and electrical translator, taking power from the converter's relatively coarse output terminals and mapping it to a fine-pitch grid of contacts that aligns directly with the power inputs of the semiconductor device below '734 Patent, col. 2:1-18 This stacked "module sandwich" creates a short, direct vertical path for current, minimizing impedance and power distribution losses '734 Patent, col. 18:1-18
  • Technical Importance: This vertical architecture aims to overcome the "last inch problem" of lateral power delivery on a crowded PCB, enabling the higher current density, power density, and efficiency required by the next generation of processors for applications like artificial intelligence Compl. ¶26 Compl. ¶28

Key Claims at a Glance

  • The complaint asserts independent claims 1, 20, 40, 45, 53, 67, and 68 Compl. ¶34
  • Independent claim 1, a method claim, includes the following essential elements:
    • Providing a "power conversion module" with a multi-cell structure to convert voltage.
    • The converter has output terminals arranged in a "first pattern" with a "first spacing."
    • Providing an "interconnection module" with "x-input terminals" and "x-output terminals."
    • The x-output terminals are arranged in a "second pattern" with a "second spacing" different from the first.
    • Assembling the power conversion module to the interconnection module.
    • The interconnection module provides "electrical and mechanical translation" between the first and second patterns.
    • The two modules are stacked to form a "module sandwich" consisting of three layers: the power conversion module, electrical connections, and the interconnection module.
  • The complaint also asserts dependent claims 2, 8, 40, 67, 68, 81, 83, 84, and 90, and reserves the right to assert additional claims Compl. ¶34

III. The Accused Instrumentality

Product Identification

The complaint identifies the accused products as the "MPC2M110-L and/or MPC22166" and the vertical power delivery systems containing them Compl. ¶31 Compl. ¶34

Functionality and Market Context

  • The complaint alleges the MPC2M110-L is a "ZPD inter-connection module that uses vertical power delivery" Compl. ¶32 It is described as a printed circuit board to which the "MPC22166 module and/or other compatible modules may be attached" Compl. ¶32 This assembly allegedly provides interconnects between the power module (e.g., MPC22166) and the device requiring power Compl. ¶32
  • The complaint places the accused products within the market for high-performance power solutions for applications including cloud computing and telecom infrastructures Compl. ¶2

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart attached as Exhibit 3, which was not provided with the publicly filed document Compl. ¶34 In the absence of the claim chart, the infringement theory is summarized below based on the narrative allegations.

The complaint alleges that the combination of Defendant's MPC2M110-L and MPC22166 products directly infringes the '734 Patent, either literally or under the doctrine of equivalents Compl. ¶34 The central theory appears to be that the MPC22166 functions as the claimed "power conversion module" and the MPC2M110-L functions as the claimed "interconnection module" Compl. ¶32 When assembled, these two components allegedly form a stacked structure for vertical power delivery that meets the limitations of the asserted claims, including the three-layer "module sandwich" structure recited in claim 1 Compl. ¶34 '734 Patent, col. 18:8-18 The complaint provides a diagram from the patent, FIG. 11, which illustrates an exemplary 2x2 array of vertical power delivery modules arranged to power a semiconductor device Compl. ¶27 Compl. p. 9, FIG. 11

  • Identified Points of Contention:
    • Scope Questions: A potential issue for the court may be whether the accused MPC2M110-L component meets the definition of an "interconnection module" as claimed. The analysis may focus on whether it performs the required "electrical and mechanical translation" from the converter's output pattern to a different pattern for the semiconductor load '734 Patent, col. 18:3-7
    • Technical Questions: The complaint does not provide specific technical evidence, such as cross-sectional diagrams of the accused products. This raises the question of what evidence Plaintiff will present to demonstrate that the physical assembly of Defendant's products forms the specific three-layer "module sandwich" structure required by claim 1, which includes the power conversion module in a first layer, the interconnection module in a third layer, and the electrical connections between them in a second layer '734 Patent, col. 18:8-18

V. Key Claim Terms for Construction

  • The Term: "interconnection module"

    • Context and Importance: This term is foundational to the asserted claims, defining one of the two key components of the stacked system. Its construction will be critical to determining whether the accused MPC2M110-L falls within the claim scope. Practitioners may focus on this term because the dispute could hinge on what specific functions and features are required for a component to qualify as an "interconnection module."
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification suggests the module's primary function is to provide "electrical and mechanical translation" between the converter's output terminals and the semiconductor's input terminals, which are arranged in different patterns '734 Patent, col. 2:15-18 This could support a broad interpretation covering a range of interface adapters.
      • Evidence for a Narrower Interpretation: The patent also describes specific embodiments where the "interconnection module" contains additional components, such as "filter circuitry" including a "plurality of capacitors" '734 Patent, col. 2:25-33 Language in the abstract also describes it being used to provide power "through a semiconductor power grid having a small pitch" '734 Patent, abstract This may support an argument that the term is limited to modules incorporating such features or intended for such specific applications.

  • The Term: "module sandwich"

    • Context and Importance: Claim 1 requires the power conversion and interconnection modules be "stacked to form a module sandwich" with a specific three-layer structure. The physical arrangement is a key limitation, and its definition will directly impact the infringement analysis.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A party could argue that "sandwich" is a general descriptor for any layered assembly and that the "electrical connections" layer is simply the solder or pillars joining the two primary modules, without requiring a more complex or integrated structure.
      • Evidence for a Narrower Interpretation: The patent's detailed description of the manufacturing process shows a "panel sandwich" being formed by aligning and bonding two entire panels of modules before they are separated ("singulated") '734 Patent, FIG. 9 '734 Patent, col. 13:55-60 This may support a narrower interpretation requiring a more integrated, co-fabricated assembly, as opposed to the simple stacking of two finished, independent components.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges that MPS induces infringement by providing marketing materials, datasheets, technical manuals, and support that instruct customers on how to use the accused products in an infringing manner Compl. ¶35 It also alleges contributory infringement, asserting that the accused components are especially made for an infringing use and are not staple articles of commerce with substantial non-infringing uses Compl. ¶36
  • Willful Infringement: Willfulness is alleged based on Defendant’s knowledge of the '734 Patent as of the filing and service of the complaint Compl. ¶35 The plaintiff seeks a declaration of willful infringement and enhanced damages Compl. Prayer ¶C

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

  1. A core issue will be one of definitional scope: How will the term "interconnection module" be construed? Will its definition be limited to the primary function of electrical and mechanical translation, or will it be narrowed to require additional features described in the patent’s embodiments, such as integrated filter capacitors? This construction will be pivotal in determining whether the accused MPC2M110-L infringes.
  2. A key evidentiary question will be one of structural correspondence: Does the physical assembly of Defendant’s separate MPC22166 and MPC2M110-L products result in the integrated, three-layer "module sandwich" structure recited in claim 1, or is there a technical mismatch between the claimed architecture and the accused implementation?
  3. A third question relates to indirect infringement: Assuming direct infringement by customers who combine the accused components, the court will need to determine whether the components are "staple articles of commerce suitable for substantial non-infringing use" Compl. ¶36 The viability of the contributory infringement claim may depend on whether the accused modules have significant uses outside of the allegedly infringing combination.