Vicor Corp v. Flex Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Vicor Corporation (Delaware)
  • Defendant: Flex Ltd. (Singapore)
  • Plaintiff’s Counsel: Cherry Johnson Siegmund James PLLC; Susman Godfrey LLP; Buchanan Ingersoll & Rooney PC
• Case Identification: 7:26-cv-00365, W.D. Tex., 09/08/2026
• Venue Allegations: Venue is alleged to be proper because the defendant is a foreign corporation not resident in the United States, making venue appropriate in any judicial district. In the alternative, venue is alleged based on the defendant having its corporate headquarters and a regular and established place of business within the Western District of Texas.
• Core Dispute: Plaintiff alleges that Defendant’s vertical power delivery systems, and computing systems containing them, infringe a patent related to methods and apparatuses for delivering power to semiconductor loads.
• Technical Context: The technology addresses the challenge of efficiently delivering very high electrical currents to modern, power-hungry semiconductor devices, such as CPUs and GPUs used in datacenters and artificial intelligence applications.
• Key Procedural History: The asserted patent is a continuation-in-part of two earlier patent applications, which may be relevant for determining the effective filing date and assessing prior art. No prior litigation or post-grant proceedings are mentioned in the complaint.

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 Issues
2026-09-08	Complaint Filed

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

• 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 section describes the significant challenges in supplying increasingly high currents (e.g., over 500 amps) to large, complex semiconductor chips like CPUs and GPUs. Conventional power delivery methods face limitations due to space constraints on circuit boards, power dissipation, and the difficulty of creating a large number of power connections to the chip package '734 Patent, col. 1:23-52 This is referred to in the complaint as the "last inch problem" of power delivery Compl. ¶16
• The Patented Solution: The patent proposes a vertically stacked, two-part power delivery system. The solution involves a "power conversion module" that converts voltage, and a separate "interconnection module" stacked underneath it '734 Patent, abstract '734 Patent, col. 2:1-24 The key function of the interconnection module is to act as a translator: it receives power from the converter's output terminals, which are arranged in one pattern, and reroutes it through a dense grid of output terminals arranged in a second, different pattern designed to mate directly with the power input grid of the semiconductor load '734 Patent, col. 1:53-col. 2:12 This stacked "module sandwich" architecture enables efficient, high-current power delivery directly vertical to the semiconductor device '734 Patent, col. 2:20-24
• Technical Importance: This vertical power delivery architecture allows for higher current density and efficiency compared to traditional lateral power distribution methods, which is critical for enabling the performance of advanced processors used in high-performance computing and AI applications Compl. ¶16 Compl. ¶18

Key Claims at a Glance

• The complaint asserts infringement of claims 1–8, 11–14, 18–26, 40–56, 65–71, 80, 81, 83, 84, 90–93, and 95, with a specific focus on independent method claim 1 Compl. ¶22
• The essential elements of independent claim 1 include:
  • Providing a power conversion module with a multi-cell structure and converter output terminals in a "first pattern."
  • Providing an "interconnection module" with x-input terminals that align with the converter's first pattern and x-output terminals in a "second pattern" that is different from the first.
  • "Assembling" the power conversion module to the interconnection module.
  • The interconnection module is configured to provide "electrical and mechanical translation" between the two patterns.
  • The stacked components form a "module sandwich" comprising the power conversion module, electrical connections, and the interconnection module in three distinct layers.
• The complaint also asserts numerous dependent claims, suggesting that more specific features of the invention are also at issue Compl. ¶22

III. The Accused Instrumentality

Product Identification

• The accused instrumentalities are identified as "Flex VPD modules and/or computing systems containing VPD modules" Compl. ¶22 These are broadly defined as "vertical power delivery systems, components thereof, and computing systems containing the same" ("Accused Products") Compl. ¶4

Functionality and Market Context

• The complaint alleges that Defendant Flex is a "global leader in advanced power conversion solutions" that provides "high-efficiency DC/DC converters" Compl. ¶2 The complaint does not provide a detailed technical description of how the accused Flex VPD modules operate. However, by labeling them with the same "VPD" (Vertical Power Delivery) acronym used to describe the patented technology, the complaint implies that the accused products perform a similar function of delivering power vertically to high-performance processors Compl. ¶16 Compl. ¶22 The complaint provides a reproduction of the patent’s Figure 11, which illustrates a 2x2 array of stacked power delivery modules mounted over a semiconductor component, showing the layered and vertical nature of the power delivery system Compl. ¶17

IV. Analysis of Infringement Allegations

The complaint references an exemplary claim chart in Exhibit 3 detailing infringement of claim 1; however, this exhibit was not attached to the publicly filed document Compl. ¶22 In the absence of a claim chart, the infringement theory is based on the narrative allegations in the complaint.

Vicor's infringement theory appears to be that Flex's "VPD modules" practice the method of claim 1 of the ’734 patent Compl. ¶22 The complaint alleges that Flex makes, uses, or sells products that embody the patented stacked architecture for vertical power delivery Compl. ¶¶20-22 The core of the allegation is that the accused products contain both a power conversion component and an interconnection component that translates the electrical outputs from the converter into a different pattern suitable for a semiconductor load, all within a compact, stacked "module sandwich" structure as claimed in the ’734 Patent.

• Identified Points of Contention:
  • Structural Questions: A primary point of contention may be whether the accused "Flex VPD modules" are constructed as a "module sandwich" by "assembling" two distinct components (a power conversion module and an interconnection module), as recited in claim 1. The defense may argue that the accused products are manufactured as a single, integrated unit that does not meet the claim's structural and assembly-step limitations.
  • Functional Questions: The claim requires the "interconnection module" to provide "electrical and mechanical translation" between a "first pattern" and a "second pattern" where the "second spacing [is] different than the first spacing" '734 Patent, cl. 1 A key factual dispute may arise over whether the accused product's internal connections actually perform this specific re-mapping of terminal patterns and spacing, or if they employ a different technical configuration.

V. Key Claim Terms for Construction

The Term: "interconnection module"

• Context and Importance: This term is central to the invention's novelty, defining the component that bridges the power converter and the semiconductor load. The outcome of the case may depend on whether the accused product contains a structure that falls within the construed scope of this term.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The specification provides a high-level functional description, stating the module is "configured to provide electrical and mechanical translation" '734 Patent, col. 2:15-19 This could support an interpretation covering any component that serves this translational purpose.
  • Evidence for a Narrower Interpretation: The patent also describes specific embodiments where the interconnection module "further include[s] filter circuitry" and comprises a "multilayer printed circuit board ('PCB')" '734 Patent, col. 2:25-31 This language could be used to argue that the term requires these more specific structural features.

The Term: "assembling"

• Context and Importance: As claim 1 is a method claim, the active step of "assembling" is a critical limitation. Practitioners may focus on this term because if the defendant only manufactures an integrated unit without performing a distinct assembly of two separate modules, it may not be a direct infringer of the method claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent does not explicitly define the term, which could allow for an argument that it covers any manufacturing process that joins the two functional components, even if highly integrated.
  • Evidence for a Narrower Interpretation: The detailed description and Figure 9 illustrate a manufacturing process where a "Power Converter Panel" and an "Interconnection Panel" are fabricated on separate paths before being "Align[ed]" and joined '734 Patent, FIG. 9 '734 Patent, col. 15:5-40 This may support a narrower construction requiring the joining of two pre-fabricated, distinct articles.

VI. Other Allegations

• Indirect Infringement: The complaint alleges both induced and contributory infringement.
  • Inducement is alleged based on Flex knowingly encouraging infringement by providing customers with "marketing, distribution of datasheets and technical product manuals" that instruct on the use of the Accused Products Compl. ¶23
  • Contributory infringement is alleged on the basis that the accused components are "especially made or especially adapted for uses that infringe" and are not "staple articles or commodities of commerce suitable for substantial non-infringing use" Compl. ¶24
• Willful Infringement: Willfulness is alleged based on knowledge of the ’734 Patent and the infringing nature of the Accused Products, with knowledge established "No later than as of the filing and service of this Complaint" Compl. ¶23 This allegation appears to be based on potential post-suit infringement.

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

This dispute will likely center on fundamental questions of claim scope and technical implementation. The key questions for the court appear to be:

1. A core issue will be one of structural definition: Can the term "module sandwich," which the patent describes as being formed by "assembling" a distinct "power conversion module" and an "interconnection module," be construed to read on the physical construction of the accused "Flex VPD modules," which may be more integrated in design?

2. A key evidentiary question will be one of infringing acts: For the asserted method claims, what evidence will show that the defendant, Flex, performs the claimed step of "assembling" the two modules, as opposed to simply manufacturing and selling a completed product to customers who then use it?

3. A central question of technical mapping will be whether the internal circuitry of the accused products performs the specific "electrical and mechanical translation" between two different terminal patterns as required by the claims, or if there is a fundamental mismatch in technical operation that places the products outside the scope of the patent.