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Cypress Semiconductor v. Silego Technology

Cypress Semiconductor v. Silego Technology

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Published by PatentBlast
Cypress Semiconductor v. Silego Technology
Cypress Semiconductor v. Silego Technology

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Published by: PatentBlast on Sep 26, 2013
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05/28/2014

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12345678910111213141516171819202122232425262728Michael J. Malecek (StateEmail address: michael.Marisa Armanino WilliaEmail address: marisa.ar Robert S. Magee (State BEmail address: robert.maKAYE SCHOLER LLPTwo Palo Alto Square, S3000 El Camino RealPalo Alto, California 943Telephone: (650) 319-45Facsimile: (650) 319-47Terence P. Woodsome (SEmail address: twde@cyCYPRESS SEMICOND198 Champion CourtSan Jose, California 9513Telephone: (408) 544-10Facsimile: (408) 456-182Attorneys for Plaintiff CYPRESS SEMICONDCYPRESS SEMICONDCORPORATION,Plav.SILEGO TECHNOLOGDe
COMPLAINT FOR PATENT INFRINGEMENT
Bar No. 171034)alecek@kayescholer.coms (State Bar No. 264907)anino@kayescholer.comr No. 271443)ee@kayescholer.comite 4000600ate Bar No. 240908)ress.comCTOR CORPORATION51CTOR CORPORATION
UNITED STATES DISTRICT COURTORTHERN DISTRICT OF CALIFORNIA
CTOR ntiff,, INC.endant.Case No.
COMPLAINT FINFRINGEMEJURY TRIAL DR PATENTTMANDED
 
12345678910111213141516171819202122232425262728Plaintiff Cypress1. Cypress isDelaware with its principCalifornia. Cypress is a s provide customers with rainnovations are used in atelecommunication equipas well as in military com2. On informcorporation organized anheadquarters located at 173. As furthemultiple Cypress patents.4. This actio
 seq
. This Court has subje1338(a).5. This Court Northern District of Calif headquartered in this Distand offers infringing prodsignificant revenue from tand/or expects or should r and derives substantial re
1COMPLAINT FOR PATENT INFRINGEMENT
emiconductor Corporation (“Cypress” or “Plai
PARTIES
a corporation organized and existing under the ll place of business located at 198 Champion C pplier of high-performance, mixed-signal, pro pid time-to-market and exceptional system valuide variety of consumer electronics, such as nent, touchscreen devices, mobile handsets, vidunication devices.tion and belief, Defendant Silego Technology,existing under the laws of the State of Delawa15 Wyatt Drive, Santa Clara, CA 95054.
 
described below, Silego designs, uses, and sells
JURISDICTION AND VENUE
arises under the patent laws of the United Statect matter jurisdiction over this action under 28has personal jurisdiction over Silego and venuernia pursuant to 28 U.S.C. § 1391(b) and (c) aict, transacts business involving infringing proucts for sale in this District. On information anhe sale of infringing products distributed and useasonably expect its actions to have consequenenue from interstate and international commer tiff”) alleges:aws of the State of urt, San Jose,rammable solutions thate. Cypress’stworking andeo and imaging devices,nc. (“Silego”) is ae with its corporate products that infringes, 35 U.S.C. § 100,
et 
.S.C. §§ 1331 andis proper in thed § 1400(b). Silego isucts within this District, belief, Silego derivesed within this District,es within this District,e.
 
123456789101112131415161718192021222324252627286. This is an pursuant to Civil Local R 7. For over thsemiconductor technologPSoC® 5 Programmableuser interface solutions intrackpad solutions for notuniversal serial bus (“USrange of consumer and inaccess memory (“SRAM”8. To develocontinuous investments in been essential to its succeorganization works closelsemiconductor designs an9. To protectintellectual property. Cypvariety of semiconductor- patent applications. Cypr applications directed towa10. To protectleading-edge technologymarketplace, Cypress can11. On June 21issued United States Pate
2
COMPLAINT FOR PATENT INFRINGEMENT
INTRADISTRICT ASSIGNMENT
ntellectual Property Action to be assigned on ale 3-2(c).
BACKGROUND
irty years, Cypress has been a pioneer and mar . Cypress products include the PSoC® 1, PSoystem-on-Chip families, and Cypress is the wo
 
cluding CapSense® touch sensing, TrueTouch book PCs and peripherals. Cypress is also the”) controllers, which enhance connectivity andustrial products. Cypress is also the world lea) and nonvolatile RAM memories.its industry-leading products, Cypress has madresearch and development (“R&D”). Cypress’s as a supplier of semiconductor solutions. Cywith its manufacturing facilities, suppliers and lower manufacturing costs.these critical R&D efforts, Cypress places a higress has applied for and received over 2000 patelated technologies, and has more than 800 pess has over 250 issued U.S. patents and over 5rds PSoC® and other programmable mixed-sigthe interests of Cypress’s customers, who benend rely upon Cypress's proprietary solutions toot allow unauthorized use of its intellectual pr 
CYPRESS PATENTS
, 2005, the United States Patent and Trademark t No. 6,910,126 (“the ’126 patent”), entitled “Pdistrict-wide basiset innovator in® 3, PSoC® 4, andrld leader in capacitivetouchscreens, andorld leader in performance in a wideer in static randome extensive ands R&D efforts haveress’s R&Dcustomers to improveh value on itsnts worldwide in ading U.S. and foreign pending U.S. patental array technology.
 
it from Cypress’scompete in the perty.Office duly and legallyogramming

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