COMPLAINT FOR PATENT INFRINGEMENT
of Texas and in the Eastern District of Texas; Philips regularly conduct and solicit businesswithin the State of Texas and within the Eastern District of Texas; and causes of action arisedirectly from Philips
business contacts and other activities in the State of Texas and in theEastern District of Texas.
COUNT IINFRINGEMENT OF U.S. PATENT NO. 7,723,829
7. NCKU is the owner of all rights, title and interest to United States Patent No.7,723,829
Patent”) entitled “
Embedded Metal Heat Sink For Semiconductor
Patent was issued on May 25, 2010 after a full and fair examination by the United StatesPatent and Trademark Office. The application leading to the
Patent was filed on June 10,2008.
Attached as Exhibit “A” is a copy of the ‘829
Patent is generally an embedded metal heat sink for a semiconductor device.9. On information and belief, Philips have been and now are infringing the
Patent in the State of Texas, in this judicial district, and elsewhere in the United States bymaking, using, importing, selling or offering to sell devices having an embedded heat sink in asemiconductor device, according to the
Patent. On information and belief, examples of Philips
products that infringe the
Patent include, but are not limited to, all Philips
productshaving an embedded metal heat sink for a semiconductor device, including the Phillips
LuxeonLumileds. Philips are thus liable for infringement of the
Patent pursuant to 35 U.S.C. §271.