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Power Management Enterprises v. Dell

Power Management Enterprises v. Dell

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00639: Power Management Enterprises LLC v. Dell Inc. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8WL for more info.
Official Complaint for Patent Infringement in Civil Action No. 2:13-cv-00639: Power Management Enterprises LLC v. Dell Inc. Filed in U.S. District Court for the Eastern District of Texas, no judge yet assigned. See http://news.priorsmart.com/-l8WL for more info.

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Published by: PriorSmart on Aug 20, 2013
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04/16/2014

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8261627 v3
IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF TEXASMARSHALL DIVISION
POWER MANAGEMENT ENTERPRISES, LLC, aTexas Limited Liability Company,Plaintiff,v.DELL INC., a Delaware corporation,Defendant.))))))))))Civil Action No.
COMPLAINT
Plaintiff Power Management Enterprises, LLC
(“
PME
”) files this, its Complaint againstDell Inc. (“Dell”), showing this Honorable Court as follows.
 
N
ATURE OF THE
A
CTION
 
1.
This is an action for patent infringement, arising out of Defendant’s infringement
of two U.S. patents relating to the art of managing cache memory containing data that has not been committed to persistent storage. Specifically, this Complaint asserts claims againstDefendant arising from its infringement of various claims in U.S. Pat. No. 5,895,485, issued on
April 20, 1999, and entitled “METHOD AND DEVICE USING A REDUNDANT CACHE FOR PREVENTING THE LOSS OF DIRTY DATA” (the “‘485 Patent”) and U.S. Pat.
 No.
5,895,488, issued on April 20, 1999, and entitled “CACHE FLUSHING METHODS ANDAPPARATUS” (the “‘488 Patent”) (collectively, “Patents
-in-Suit
”). [True and correct copies of the ‘485 Patent and ‘488 Patent are attached hereto as Exhibits A and B, respectiv
ely.]
 
- 2 -
8261627 v3
T
HE
P
ARTIES
 
2. Plaintiff is a limited liability company, organized and existing under the laws of Texaswith its principal place of business in this District.3. Upon information and belief, Defendant Dell is a corporation organized and existing
under the laws of the state of Delaware. Upon information and belief, Dell’s principal place of 
 business is located in Round Rock, Texas. Dell may be served through its registered agent for service of process, Corporation Service Company, 211 E. 7th Street, Suite 620, Austin, Texas78701-3218.
J
URISDICTION AND
V
ENUE
 
4. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C.§§ 1331 and/or 1338.5. This Court has personal jurisdiction over the Defendant. Defendant has conducted anddoes conduct business within the State of Texas, including within this District. Defendant offersfor sale, sells, and advertises its products and services within the State of Texas, including withinthis District. Defendant has committed the tort of patent infringement within the State of Texas,including within this District.6. Venue is proper in this Court pursuant to 28 U.S.C. §§ 1391 and/or 1400.
O
PERATIVE
F
ACTS
 
T
HE
P
ATENTS
-I
 N
-S
UIT
 7. PME is the owner by assignment of all right, title, and interest in the Patents-in-Suit.8.
The ‘485 Patent describes a novel method and device using redundant cache for 
 preventing the loss of data that has not been committed to persistent memory. The deviceincludes first and second controllers, each including cache memory, arranged between a client
 
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8261627 v3
host and a persistent memory device. When operating in write-back mode, the write-back cachedoes not immediately commit the data to persistent storage. In a single cache system, the data isexposed to loss if the cache system fails. However, to prevent memory failure in write-back mode, data is transmitted to the second redundant cache. After dirty data is stored on the persistent memory device, the stored data is cleared from both caches.9.
Claim 6 of the ‘485 P
atent provides:6. A system for providing storage for a client, the system comprising:a) a mass storage device; b) a first controller, including a cache, for controlling the mass storage device in responseto requests from the client; andc) a second controller, including a cache, for controlling the mass storage device inresponse to requests from the client,wherein one of the first and second controllers responding to an I/O request,sends dirty data to the cache of another of the first and second controllers.
‘485 Patent, Col. 11, ll. 40
-51.10.
The ‘488 Patent describes a novel method and device for managing a cache containing
data that has not been committed to persistent storage. The invention determines when to flushcache lines containing such uncommitted data. The device flushes the data when the devicedetermines that its system state is idle. This state is based upon at least two of the followingindicators: (i) CPU idle percentage, (ii) data bus busyness percentage, (iii) percentage of dirtylines, and (iv) I/Os per second.11.
Claim 8 of the ‘488 Patent provides:
 8. In a system having a host computer and a mass storage device, a mass storage controller comprising:

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