Sonrai Memory Limited filed a complaint on Monday in the Western District of Texas against Dell Technologies Inc. alleging that the defendant infringed its patents-in-suit for products such as laptops, desktop computers, and servers.
The patents-in-suit are United States Patent Nos. 6,724,241 (the ’241 patent); 6,920,527 (the ’527 patent); and 7,436,232 (the ’232 patent), which “relate to improvements in charge pump circuits,” “portable memory devices with both volatile and non-volatile memory,” and “regenerative clock repeating.”
The plaintiff claimed that Dell’s purportedly infringing products include laptops, desktop computers, and servers “with SanDisk/Toshiba 64L 3D NAND flash chips.” They alleged the products infringe the ’241 patent, entitled “Variable Charge Pump Circuit with Dynamic Load.” According to the claim chart, claim 1 of the ’241 patent states: “A charge pump circuit for generating a charge pump voltage having minimal voltage ripples …” The claim chart included graphics that analyzed the flash chip’s charge pump system, finding that it provides for minimization of said voltage ripples. For its first claim, the plaintiff proffered that as described in the patent, the Accused Products have a pumping circuit with one or more operating stages, in this instance three stages, “to receive a supply voltage and generate a selected one of a plurality of pump voltages.”
Dell is accused of direct, induced, and contributory infringement. The plaintiff seeks declaratory judgment in its favor; an injunction; an award for damages, costs, and fees; pre and post judgment interest; and other relief.
Sonrai Memory Limited is represented by Russ August & Kabat.