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Marvell Semiconductor et. al. v. Freescale Semiconductor

Marvell Semiconductor et. al. v. Freescale Semiconductor

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00005-LY: Marvell Semiconductor, Inc. et. al. v. Freescale Semiconductor, Inc. Filed in U.S. District Court for the Western District of Texas, the Hon. Lee Yeakel presiding. See http://news.priorsmart.com/-l7q6 for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:13-cv-00005-LY: Marvell Semiconductor, Inc. et. al. v. Freescale Semiconductor, Inc. Filed in U.S. District Court for the Western District of Texas, the Hon. Lee Yeakel presiding. See http://news.priorsmart.com/-l7q6 for more info.

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Published by: PriorSmart on Jan 05, 2013
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03/22/2014

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IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF TEXASAUSTIN DIVISION
MARVELL SEMICONDUCTOR, INC.;MARVELL INTERNATIONAL LTD.;MARVELL WORLD TRADE LTD.,Plaintiffs,v.FREESCALE SEMICONDUCTOR, INC.,Defendant.§§§§§§§§§§§§§§CIVIL ACTION NO. 1:13-CV-_________JURY TRIAL DEMANDED
COMPLAINT FOR PATENT INFRINGEMENT
Plaintiffs Marvell Semiconductor, Inc., Marvell International Ltd., and Marvell WorldTrade Ltd. (together,
“Marvell”
) hereby file this Complaint against Defendant FreescaleSemiconductor, Inc. (
Freescale
) for infringement of U.S. Patent Nos. 6,903,448 (the
“’
448Patent
);
7,216,276 (the “’276(I) Patent”
); 7,379,718 B2 (the
“’
718 Patent
); 7,444,571 (the
“’571 Patent”); 7,496,818 (the “’818 Patent”
); 7,562,
276 (the “’276(II) Patent”
); and 7,573,249B2 (the
“’
249 P
atent”) (collectively, “
Patents-In-Suit
).
PARTIES
1.
 
Marvell Semiconductor, Inc. is a California Corporation with its principal placeof business at 5488 Marvell Lane, Santa Clara, California 95054.2.
 
Marvell International Ltd. is a Bermuda Corporation with its principal place of business at Canon's Court, 22 Victoria Street, Hamilton HM 12, Bermuda.3.
 
Marvell World Trade Ltd. is a Barbados Corporation with its principal place of business at
L’Hori
zon, Gunsite Road, Brittons Hill, BB14027, St. Michael, Barbados.
5
 
24.
 
Upon information and belief, Defendant is a corporation organized under thelaws of Delaware, and maintains its principal place of business at 6501 William Cannon DriveWest, Austin, Texas 78721.
JURISDICTION AND VENUE
5.
 
This lawsuit is an action for patent infringement arising under the patent laws of the United States, 35 U.S.C. §§ 1,
et seq
. This Court has jurisdiction over this action pursuantto 28 U.S.C. §§ 1331 and 1338.6.
 
Upon information and belief, Defendant is subject to personal jurisdiction inthis Court because it does and has done substantial business in this judicial district, including:(i) maintaining its principal place of business in this judicial district; (ii) employing numerousemployees in this judicial district; (iii) designating an agent for service of process in this judicial district; (iv) regularly receiving shipments of infringing display devices within this judicial district; (v) committing acts of patent infringement and/or contributing to or inducingacts of patent infringement by others in this judicial district and elsewhere in Texas and theUnited States; and (vi) regularly doing business or soliciting business, engaging in otherpersistent courses of conduct, and/or deriving substantial revenue from products and/orservices provided to individuals in this judicial district and in this State.7.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 and1400(b) because Defendant regularly conducts business in this judicial district, has regular andestablished places of business in this judicial district, and/or because certain of the actscomplained of herein occurred in this judicial district.
 
3
U.S. PATENT NO. 6,903,448
8.
 
On June 7, 2005, the United States Patent and Trademark Office duly and
legally issued the ’
448 Patent,
High Performance Leadframe in Electronic Package,
to SehatSutardja, Vincent Kao, and Hendrick Santo. A true and correct copy of the
448 Patent isattached as Exhibit 1.9.
 
Marvell International Ltd. is the sole owner and assignee of all right, title, and
interest in and to the ’
448 Patent and possesses all rights of recovery under the
448 Patent,including the right to recover damages for past infringements.10.
 
The
448 Patent is valid and enforceable.
U.S. PATENT NO. 7,216,276
11.
 
On May 8, 2007, the United States Patent and Trademark Office duly and
legally issued the ’276(I) Patent, “Apparatus and Method for Testing and Debugging anIntegrated Circuit,” to Saeed Azimi and Son Ho. A true and correct copy of the ’276(I) Patent
is attached as Exhibit 2.12.
 
Marvell International Ltd. is the sole owner and assignee of all right, title, and
interest in and to the ’276(I) Patent and possesses all rights of recovery under the ’276(I)
Patent, including the right to recover damages for past infringements.13.
 
The ’276(I) Patent is valid and enforceable.
 
U.S. PATENT NO. 7,379,718 B2
14.
 
On May 27, 2008, the United States Patent and Trademark Office duly andlegally issued the
718 P
atent, “
Method and Apparatus to Manage Power Consumption of aSemiconductor Device
,”
to Amit Dor, Charles Roth, and Mark Fullerton. A true and correct
copy of the ’
718 Patent is attached as Exhibit 3.

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