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PLL Technologies v. Microsemi

PLL Technologies v. Microsemi

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00943-UNA: PLL Technologies Inc. v. Microsemi Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-laJj for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00943-UNA: PLL Technologies Inc. v. Microsemi Corporation. Filed in U.S. District Court for the District of Delaware, no judge yet assigned. See http://news.priorsmart.com/-laJj for more info.

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Published by: PriorSmart on Jul 20, 2014
Copyright:Public Domain

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07/20/2014

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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE
PLL TECHNOLOGIES, INC, Plaintiff, vs. MICROSEMI CORPORATION, Defendant.)) ) ) ) ) ) ) ) Case No.:
JURY TRIAL DEMANDED COMPLAINT FOR PATENT INFRINGEMENT
Plaintiff, PLL Technologies, Inc. (“PTI”), by and through its attorneys, files this Complaint for Patent Infringement against Defendant, Microsemi Corporation (“Microsemi”), and avers as follows:
PARTIES
1. PTI is a corporation formed and existing under the laws of Delaware, having its registered office at 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808. PTI is the owner, through assignment, of the entire right, title and interest in United States Patent No. 6,356,122, entitled “CLOCK SYNTHESIZER WITH PROGRAMMABLE INPUT-OUTPUT PHASE RELATIONSHIP” (“the ‘122 Patent”). 2. Microsemi is a corporation incorporated under the laws of Delaware, having its  principal place of business at One Enterprise, Aliso Viejo, California 92656. Microsemi’s registered agent for service of process in the State of Delaware is United States Corporation Company, 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808. 3. Upon information and belief, Microsemi is and has been engaged in the business of manufacturing, using, marketing, offering for sale, and/or selling in the United States, and/or
 
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importing into the United States, field-programmable gate array devices that employ clock circuits with programmable input-output phase relationships.
JURISDICTION AND VENUE
4. This action arises under the patent laws of the United States, 35 U.S.C. §§ 1 et seq. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and § 1338(a). 5. This Court has personal jurisdiction over Defendant in this district, in that Defendant, directly or through their agents, are residents of, and/or have regularly conducted  business activities in this district; have committed infringing activities in this district by manufacturing, using, marketing, offering for sale, selling and/or importing products and systems that infringe the ‘122 Patent; and/or have placed products and systems that infringe the ‘122 Patent in the stream of commerce with the knowledge and intent that they would be used, offered for sale and/or sold by others in this district. 6. Venue is proper pursuant to 28 U.S.C. §§ 1391(b) and 1400(b).
GENERAL ALLEGATIONS
7. The ‘122 Patent was duly and legally issued by the United States Patent and Trademark Office (“USPTO”) on March 12, 2002, naming Piyush Sevalia and Ken Fox as inventors, and Cypress Semiconductor Corp. as assignee. A true and correct copy of the ‘122 Patent is attached as Exhibit “A” hereto. 8. The ‘122 Patent relates to a phase-lock loop clock synthesizer circuit with a  programmable input-output phase relationship for generating output frequencies based on a reference clock input. 9. The ‘122 Patent as issued by the USPTO is valid and enforceable.
 
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10. The ‘122 Patent was ultimately assigned to PTI, and PTI is the exclusive and current owner of all rights, title and interest in the ‘122 Patent, and is entitled to enforce the ‘122 Patent against infringers, including by commencing the present action. 11. Microsemi has engaged and continues to engage in acts of infringement under 35 U.S.C. § 271,
inter alia
, by manufacturing, using, offering for sale and/or selling in the United States, field-programmable gate array devices comprising phase-locked loop clocking circuitry that embodies each element of at least one (1) claim of the ‘122 Patent, including, without limitation, Independent Claim 1, either literally or by equivalence. 12. By way of example only, one of the infringing products that Microsemi has specifically manufactured, used, offered for sale and/or sold in the United States, and/or imported into the United States for sale, and continues to manufacture, use, offer for sale and/or sell in the United States, and/or import into the United States for sale, is the IGLOO2 FPGA. 13. Microsemi does not have a license or other authorization to practice the claims set forth in the ‘122 Patent.
CLAIM FOR PATENT INFRINGEMENT
 14. PTI incorporates by reference and in their entirety the averments set forth is  paragraphs 1 through 13, inclusive, of this Complaint. 15. Microsemi has manufactured, used, offered for sale, sold and/or imported into the United States for sale, and continues to manufacture, use, offer for sale, sell and/or import into the United States for sale, field-programmable gate array devices that infringe at least Claim 1 of the ‘122 Patent. 16. Microsemi has caused and will continue to cause PTI substantial damage by virtue of its infringing activities.

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