COMPLAINT FOR PATENT INFRINGEMENT
Nichia have purposefully availed themselves of the privileges of conducting business in the Stateof Texas and in the Eastern District of Texas; Nichia regularly conduct and solicit businesswithin the State of Texas and within the Eastern District of Texas; and causes of action arisedirectly from Nichia
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 (“the ‘829 Patent”) entitled “Embedded Metal Heat Sink For Semiconductor.” The‘829 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 ‘829 Pa
tent was filed on June 10,
2008. Attached as Exhibit “A” is a copy of the ‘829 Patent.
Patent is generally an embedded metal heat sink for a semiconductor device.9. On information and belief, Nichia 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 a
semiconductor device, according to the ‘829 Patent. On
information and belief, examples of Nichia
products that infringe
the ‘829 Patent include
, but are not limited to, all Nichia
products having an embedded metal heat sink for a semiconductor device, including the Nichiathe Nichia 219 LED. Nichia are thus liabl
e for infringement of the ‘829 Patent pursuant to 35
U.S.C. § 271.