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Maxlinear v. Silicon Laboratories

Maxlinear v. Silicon Laboratories

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01164-BTM-BLM: Maxlinear, Inc. v. Silicon Laboratories Inc. Filed in U.S. District Court for the Southern District of California, the Hon. Barry Ted Moskowitz presiding. See http://news.priorsmart.com/-l8rf for more info.
Official Complaint for Patent Infringement in Civil Action No. 3:13-cv-01164-BTM-BLM: Maxlinear, Inc. v. Silicon Laboratories Inc. Filed in U.S. District Court for the Southern District of California, the Hon. Barry Ted Moskowitz presiding. See http://news.priorsmart.com/-l8rf for more info.

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Published by: PriorSmart on May 17, 2013
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05/18/2013

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Complaint for Patent Infringement
 
G. DALE BRITTON, Cal. Bar No. 171844
KLINEDINST PC
501 West Broadway, Suite 600San Diego, California 92101(619) 239-8131(619) 238-8707 FaxDBritton@KlinedinstLaw.comGREGORY C. SCHODDEWAYNE H. BRADLEYRYAN J. JUNGELS
McANDREWS, HELD & MALLOY, LTD.
500 West Madison Street, 34th Floor Chicago, Illinois 60661(312) 775-8000 General(312) 775-8100 Faxgschodde@mcandrews-ip.comwbradley@mcandrews-ip.comrjungels@mcandrews-ip.com
 Attorneys for Plaintiff  MAXLINEAR, INC.
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF CALIFORNIA
MAXLINEAR, INC., a DelawarecorporationPlaintiff,v.SILICON LABORATORIES INC., aDelaware corporationDefendant.CASE NO.COMPLAINT FOR PATENTINFRINGEMENT
JURY TRIAL DEMANDED
'13
CV1164
BLM
BTM
 
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Complaint for Patent Infringement
 
- 1 -
 
Plaintiff MaxLinear, Inc. (“MaxLinear”) hereby complains of DefendantSilicon Laboratories Inc. (“Silicon Labs”), and by this Complaint alleges asfollows:
THE PARTIES
1.
 
Plaintiff MaxLinear is a Delaware corporation with its principal placeof business and corporate headquarters at 2051 Palomar Airport Road, Suite 100,Carlsbad, California 92011.2.
 
MaxLinear is a leading provider of integrated radio frequency (RF)analog and mixed-signal integrated circuits for broadband communicationapplications. MaxLinear’s products enable the display of broadband video in awide range of electronic devices, including cable and terrestrial set top boxes,digital televisions, mobile handsets, personal computers, netbooks and in-vehicleentertainment devices. MaxLinear combines high performance RF and mixed signal semiconductor design skills with expertise in digital communicationssystems, software and embedded systems to provide highly integrated semiconductor devices that are manufactured using low-cost complementary metaloxide semiconductor, or CMOS, process technology.3.
 
On information and belief, Defendant Silicon Labs is a Delawarecorporation with its principal place of business at 400 West Cesar Chavez, Austin,Texas 78701. On information and belief, Silicon Labs also has an office inSunnyvale, California where it performs research and development and employsapproximately 80 scientists, engineers, and other personnel.
JURISDICTION AND VENUE
4.
 
This Complaint arises under the patent laws of the United States, Title35 of the United States Code. This Court has subject matter jurisdiction over thisaction under 35 U.S.C. §§ 271
et seq.
, 28 U.S.C. §§ 1331 and 1338(a).5.
 
Silicon Labs and MaxLinear have both filed complaints against eachother in two other actions that were consolidated and that are currently pending in
 
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Complaint for Patent Infringement
 
- 2 -
 
this District.
See
Case Nos. 3:12-cv1161-H-MDD and 3:12-cv-1765-H-MDD. Byfiling a complaint against MaxLinear in this District, Silicon Labs has subjected itself to the personal jurisdiction of this Court.6.
 
Additionally, the Court may exercise personal jurisdiction over Silicon Labs because Silicon Labs has continuous and systematic contacts with theState of California and, on information and belief, does business in this District.7.
 
Silicon Labs conducts business within California by maintaining anoffice located at 940 Steward Drive, Sunnyvale, California 94085. Silicon Labsalso regularly conducts business in this District and has offered for sale and sold  products and systems within this judicial district.8.
 
Silicon Labs has also committed and continues to commit acts of  patent infringement in this District and has harmed and continues to harmMaxLinear in this district by, among other things, offering for sale and sellinginfringing products and systems in this judicial district.9.
 
Because Silicon Labs has availed itself of the privileges of conductingactivities in this District, it is subject to personal jurisdiction in this district. Giventhat MaxLinear is headquartered in Carlsbad, this District and the State of California has a sufficient interest in resolving this dispute.10.
 
Venue is proper in this judicial district pursuant to 28 U.S.C. §§1391(b), (c), (d), and/or 1400(b) because, inter alia, Silicon Labs is subject to personal jurisdiction in this District, Silicon Labs has committed acts of patentinfringement in this District and continues to commit acts of infringement in thisDistrict, Plaintiff MaxLinear is headquartered in this District, and key witnessesreside in this District.
FACTUAL BACKGROUND
11.
 
MaxLinear engages in the design, development and manufacture of radio frequency and mixed-signal semiconductor solutions for broadband communications applications, and more particularly for use in complementary

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