Hedge Fund-Backed Irish NPEs Hit 2021 Ground Running

April 18, 2021

This year is off to an active start for a web of Irish NPEs litigating former operating company patents picked up from various sources. In February, Sonraí Memory Limited began two litigation campaigns, a first hitting Oracle over a former HP patent (development work having occurred before the split into HP Enterprise (HPE) and HP Inc.) and a second accusing Alphabet (Google), LG Electronics (LGE), and Samsung of infringing one former Atmel patent and another patent originally developed at HP. Last week, the same Irish NPE added a suit against Dell (6:21-cv-00361) to the latter campaign, accusing it of infringing that Atmel patent, as well as two additional patents, also acquired through Microchip Technology. Meanwhile, Arigna Technology Limited amended its Texas complaint against a fleet of automakers to assert a second former Mitsubishi Electric patent, as well as to add GM as a defendant, and Solas OLED Limited has followed up its recent East Texas trial win against Samsung with a new suit asserting two former Casio patents against BOE Technology (2:21-cv-00121).

Sonraí Memory Limited

The patent now at issue across all four complaints in Sonraí’s second campaign (6,724,241) generally relates to a memory system that includes a “charge pump circuit for generating a charge pump voltage having minimal voltage ripples”. It issued to Atmel in April 2004, passing through Microchip (which acquired Atmel in 2016) to Sonraí as part of a 50-asset transfer in February 2020. The plaintiff accuses the defendants of infringement through the provision of laptops, desktops, and servers that contain a “SanDisk/Toshiba 64L 3D NAND flash chips”, calling out the Dell/EMC XPS 15 2-in-1 9575 in the new complaint.

Those same Dell products are also targeted with a second patent (7,436,232) that followed that same path into the plaintiff’s hands. Issuing to Atmel in October 2008, the ‘232 patent generally relates to a “clock repeater for regenerating a clock signal on a clock distribution line”. It has not been asserted against Google, LGE, or Samsung.

Sonraí’s new complaint debuts a second patent in the campaign (6,920,527), accusing Dell of infringement through the provision of laptops, desktops, and servers with SSDs including Silicon Motion SSD Controllers, naming in the complaint the Dell/EMC Vostro 15 5568 P62F. The ‘527 patent is broadly directed to a portable memory device, having issued to Standard Microsystems in January 2003. (Microchip acquired Standard Microsystems in August 2012.) It was one of the 50 assets moved to Sonraí in February of last year.

Those Microchip assets were joined in April of last year by 17 US patents transferred from HP Enterprise to Sonraí; the transacted assets are generally related to a range of technologies, including system firmware, memory systems, and microprocessors. Sonraí has since moved patents back and forth with sister entity Arigna (through nunc pro tunc assignments), which itself also received assets from outside the Irish assertion enterprise, through a February 2020 assignment of just over 30 patents from Mitsubishi Electric.

Sonraí’s earlier suits—against Oracle in the first campaign and against Google, LGE, or Samsung in the second—are all in the Western District of Texas, where District Judge Alan D. Albright has granted extensions of the various deadlines to respond to the operative complaint well into May or June.

Arigna Technology Limited

Arigna began litigating one of its former Mitsubishi assets (the 7,397,318 patent, generally related to a “voltage-controlled oscillator”) this past February in a single Eastern District of Texas complaint filed against automakers BMWDaimler (Mercedes-Benz), NissanTeslaToyota, and Volkswagen. The plaintiff amended its complaint in March 2021 to assert a second of those former Mitsubishi assets (the 8,247,867 patent, broadly directed to a particular semiconductor device) and to add GM as a defendant.

All of the defendants are accused of infringing the ‘318 patent, while only BMW, GM, and Volkswagen are accused of infringing the ‘867 patent, with Arigna pleading that joinder in a single complaint is warranted because “each Defendant designs, manufactures, assembles, imports, offers for sale, and/or sells automotive vehicles and components thereof that incorporate the NXP Semiconductors MR2001 chip package”.

Early housekeeping issues (notices of attorney appearances and extensions of the deadline to respond to the amended complaint) have dominated the docket since.

Solas OLED Limited

Meanwhile, Solas OLED continues to file new lawsuits in the display panel campaign begun in 2019 over patents received from either Microchip or Casio. The most recent defendant is BOE Technology (2:21-cv-00121), sued in the Eastern District of Texas, where in early March a jury returned a $62.7M verdict against Samsung in a case filed by Solas OLED. 2021 has seen multiple dismissals in cases in this campaign, brought earlier against Apple, Dell, Lenovo (Motorola Mobility), and LGE, with a case against HP dismissed without prejudice last August.

As covered in more detail here, in January 2021 BOE Technology ended separate litigation, begun last summer, over display panels provided for Motorola Mobility devices. The plaintiff there was “Japan-based research and development company” Semiconductor Energy Laboratory Co., Ltd. (SEL), which has kept its campaign alive after BOE Technology’s exit with a second suit, recently filed against TCL.

More on this Web of Irish NPEs

These NPEs are backed by the hedge fund Magnetar Capital, with connections to still more Irish entities, including Data Scape Limited (litigating patents originating with Sony), Neodrón Limited (asserting patents received from Microchip) and Scramoge Technology Limited, which received over 120 US patent assets from LG Innotek in February of this year. A closer look at these NPEs’ corporate ties can be found at “More Hedge Fund-Backed Irish NPEs Launch US Litigation” (February 2021).