WILMINGTON (LN) — A Delaware federal judge on Monday denied WT Microelectronics' bid to escape Monolithic Power Systems' patent infringement lawsuit over power conversion circuitry, concluding the Taiwan-based distributor's pleading challenges were colorable but unpersuasive, and ordering jurisdictional discovery to resolve a factual standoff over the company's ties to Delaware.
Monolithic Power, which according to its complaint designs, develops, manufactures, and sells power management solutions including power converters used in consumer electronics, sued five defendants alleging infringement of U.S. Patent No. 10,075,078. WT Microelectronics and its wholly owned subsidiary NuVision Technology — both organized under Taiwanese law — moved to dismiss, arguing Monolithic's allegations were too thin to establish either personal jurisdiction or a cognizable infringement claim.
Judge Murphy rejected both arguments, but the personal jurisdiction question produced the opinion's most pointed analysis. WT Microelectronics submitted two declarations flatly denying any Delaware contacts — including a sworn statement that its products are never used or consumed in Delaware. The court was unimpressed. "That claim strikes us as facially speculative and hyperbolic," Murphy wrote, noting that at oral argument WT Microelectronics conceded it has no ability to track where its products end up and therefore cannot affirmatively say they never reach Delaware.
The judge also flagged that the two declarations — one from Ching-Yuan and one from Jen-Chieh — were "nearly identical," a detail the court said gave it "some reason to doubt the credibility of the affidavits employed to deny the factual allegations."
On the jurisdictional theory, Murphy applied Delaware's dual-jurisdiction stream-of-commerce doctrine, which requires partial satisfaction of two subsections of the Delaware long-arm statute rather than full satisfaction of either one. The court acknowledged the doctrine is not perfectly settled but concluded it was persuasive authority for patent infringement cases involving imported manufactured goods. The court held that Monolithic's allegations — that WT Microelectronics coordinated with Taiwanese contract manufacturer Accton to supply products to U.S.-based HPE Aruba through a so-called design-in process — were enough to survive at the pleading stage. The touchstone of the stream-of-commerce analysis, the court noted, is intent and purpose to serve the Delaware market, a standard drawn from Power Integrations, Inc. v. BCD Semiconductor.
On the merits, WT Microelectronics argued that Monolithic's direct infringement allegations were conclusory because they merely labeled the company a channel partner of co-defendant Reed Semiconductor. The court disagreed, pointing to complaint paragraphs that alleged WT Microelectronics itself sells the accused products — enough under 35 U.S.C. § 271(a). For induced and contributory infringement, Murphy followed the line of Delaware decisions holding that the initial complaint can supply the required knowledge for post-suit indirect infringement claims, and concluded that Monolithic's allegations that WT Microelectronics distributed datasheets and technical materials encouraging infringing use were sufficient to survive dismissal.
On willful infringement, Murphy noted Chief Judge Connolly's view that such allegations may not even be susceptible to a motion to dismiss, but ruled for Monolithic on the merits regardless, concluding there is no requirement to plead facts beyond knowledge of the patent.
The court granted Monolithic's alternative request for jurisdictional discovery, giving the company a chance to test whether WT Microelectronics' supply-chain activities actually reached Delaware — and to probe the credibility of the denials the company's own affiants could not substantiate at argument.
Monolithic's complaint describes this as one of several patent infringement cases on the court's docket about power management circuitry. The remaining three defendants — Reed Semiconductor Corp. and two Nengda entities — remain in the case regardless of the outcome of WT Microelectronics' motion.