COUNT I: INFRINGEMENT OF U.S. PATENT NO. 5,686,738
’738 patent, titled “Highly Insulating Monocrystalline Gallium Nitride ThinFilms,” issued on November 11, 1997
. A true and correct copy of the
738 patent is attachedhereto as Exhibit A.10.
Theodore D. Moustakas, Ph.D., Professor of Electrical and Computer Engineeringat BU
, is the named inventor of the ’
738 patent. The University owns by assignment the entireright, title, and interest in and to the
738 patent, including the sole right to sue for past and present patent infringements thereof.11.
Several of Defendants
products, including the LG LED Lamp A19 12.5W product bearing part numbers 47JC E334432 and A1912FD1CE1 and the LG LED High Power product bearing part number LEMWS51R80JZ31A0 include a gallium nitride thin filmsemiconductor device claimed by the
738 patent and thus infringe one or more claims of the
738 patent. The University is informed and believes, and further alleges, that additional productsof Defendants also constitute and/or include the claimed gallium nitride thin film semiconductor device and also infringe one or more claims of the
738 patent, including light emitting diodes
products bearing LEDs (all products covered by this paragraph are collectively
referred to as “Accused Products”)
The University is informed and believes, and thereon alleges, that the applicablerequirements of 35 U.S.C. § 287 have been satisfied.13.
The University is informed and believes, and thereon alleges, that Defendantshave infringed, and continue to infringe, one or m
ore claims of the ’
738 patent, in violation of 35U.S.C. § 271(a), by, among other things, making using, offering to sell, selling and/or importingin and/or into the United States, without authority or license from the University, the AccusedProducts falling within the scope of one or more claims of the