IP Law Daily, PATENT—D. Mass.: Summary judgment of non-infringement granted in semiconductor manufacturing dispute, (Jul 16, 2025)

By Kevin M. Finson, J.D.

Claims relating to filtering data in semiconductor manufacturing were not infringed because the patent language required the relabeling of existing data when certain conditions were met while the accused product simply gathered new data and never relabeled already-collected datasets.

A manufacturer of semiconductors was entitled to summary judgment of non-infringement of a patent directed to filtering data in the semiconductor device manufacturing environment, the U.S. District Court in Boston has held. After claim construction, even the opposing party’s expert testimony showed the accused product did not practice all of the limitations of the asserted claims (Ocean Semiconductor LLC v. Analog Devices, Inc., No. 1:20-cv-12310-PBS (D. Mass. July 15, 2025)).

Ocean Semiconductor, LLC (Ocean), a non-practicing entity, was the owner of U.S. Patent No. 6,836,691 (the ’691 patent), entitled “Method and Apparatus for Filtering Metrology Data Based on Collection Purpose,” which related to filtering data in the semiconductor device manufacturing environment. Ocean brought suit for infringement against Analog Devices, Inc. (ADI), alleging that ADI infringed claims 4 and 5 of the ’691 patent through the use of non-party Inficon, Inc.’s FabGuard software in ADI’s manufacturing of semiconductor chips.

ADI moved to dismiss on the grounds that Ocean relied on new infringement theories that were not timely disclosed, that there was no evidence that ADI actually used the FabGuard software, that the infringement theories did not satisfy all of the claim limitations, and that the ’691 patent was directed to patent-ineligible subject matter. The court found it necessary to consider only the question of whether Ocean’s infringement theories satisfied the claim limitations.

Non-infringement. The parties disputed the meaning of the term “changing the collection purpose data” as it appeared in claims 4 and 5. ADI argued that it referred to changing a tag associated with an already-collected dataset, while Ocean argued for a more expansive definition which would allow this limitation to be met by collecting a new dataset using a new collection purpose tag. Reviewing the grammar of the claim language and the use of the term in the specification, the court agreed with ADI that this limitation was met only if the system went back and changed the collection purpose data associated with data that had already been collected. Ocean’s own expert had testified that the FabGuard system did not reassign or relabel data already collected, but instead simply collected new data when a new trigger prompted a change in collection purpose. Accordingly, no reasonable juror could find that ADI infringed the ’691 patent by using the FabGuard software.

The court granted the motion for summary judgment.

The Case is No. 1:20-cv-12310-PBS.

Judge: Saris, P.

Attorneys: Joseph J. Gribbin (Devlin Law Firm LLC) for Ocean Semiconductors LLC. John Christopher Moulder (Perkins Coie LLP) for Analog Devices, Inc.

Companies: Ocean Semiconductors LLC; Analog Devices, Inc.

Cases: Patent MassachusettsNews