S27A550H, UN22D5003BF, T248350ND, SGH-T779, 303C12-A01, NP510R5E-A02UB, NP540UC3-A03UB, and NP700Z7C-
S01UB (“Samsung Accused Products”)
, include a galliumnitride thin film semiconductor device claimed
by the ’
738 patent and thus infringe one or moreclaims of the
38 patent. The University is informed and believes, and further alleges, thatadditional products used, sold, offered for sale, and/or imported by Defendant also constituteand/or include the claimed gallium nitride thin film semiconductor device and also infringe one
or more claims of the ’
738 patent including, but not limited to,
light emitting diodes (“LEDs”)
(products included in 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.11.
The University is informed and believes, and thereon alleges, that Defendant hasinfringed, and continues to infringe,
one or more 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
acts of infringement have caused and will continue to causesubstantial and irreparable damage to the University.13.
As a res
ult of the infringement of the ’
738 patent by Defendant, the Universityhas been damaged. The University is therefore entitled to such damages pursuant to 35 U.S.C. §284 in an amount that presently cannot be pled but that will be determined at trial.14.
TAKE NOTICE that the University reserves the right to further allege indirectinfringement, contributory infringement, inducing infringement, and/or willful infringement, andamend, supplement, or modify its allegations of infringement as facts regarding such allegationsarise during the course of this case.