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G. DALE BRITTON, Cal. Bar No. 171844 KLINEDINST PC 501 West Broadway, Suite 600 San Diego, California 92101 (619) 239-8131 (619) 238-8707 Fax DBritton@KlinedinstLaw.com GREGORY C. SCHODDE WAYNE H. BRADLEY RYAN J. JUNGELS McANDREWS, HELD & MALLOY, LTD. 500 West Madison Street, 34th Floor Chicago, Illinois 60661 (312) 775-8000 General (312) 775-8100 Fax gschodde@mcandrews-ip.com wbradley@mcandrews-ip.com rjungels@mcandrews-ip.com Attorneys for Plaintiff MAXLINEAR, INC. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA MAXLINEAR, INC., a Delaware corporation Plaintiff, v. SILICON LABORATORIES INC., a Delaware corporation Defendant. COMPLAINT FOR PATENT INFRINGEMENT CASE NO.

'13 CV1164 BTM BLM

JURY TRIAL DEMANDED

Complaint for Patent Infringement

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Plaintiff MaxLinear, Inc. (“MaxLinear”) hereby complains of Defendant Silicon Laboratories Inc. (“Silicon Labs”), and by this Complaint alleges as follows: THE PARTIES 1. Plaintiff MaxLinear is a Delaware corporation with its principal place

of business and corporate headquarters at 2051 Palomar Airport Road, Suite 100, Carlsbad, California 92011. 2. MaxLinear is a leading provider of integrated radio frequency (RF)

analog and mixed-signal integrated circuits for broadband communication applications. MaxLinear’s products enable the display of broadband video in a wide range of electronic devices, including cable and terrestrial set top boxes, digital televisions, mobile handsets, personal computers, netbooks and in-vehicle entertainment devices. MaxLinear combines high performance RF and mixed signal semiconductor design skills with expertise in digital communications systems, software and embedded systems to provide highly integrated semiconductor devices that are manufactured using low-cost complementary metal oxide semiconductor, or CMOS, process technology. 3. On information and belief, Defendant Silicon Labs is a Delaware

corporation with its principal place of business at 400 West Cesar Chavez, Austin, Texas 78701. On information and belief, Silicon Labs also has an office in Sunnyvale, California where it performs research and development and employs approximately 80 scientists, engineers, and other personnel. JURISDICTION AND VENUE 4. This Complaint arises under the patent laws of the United States, Title

35 of the United States Code. This Court has subject matter jurisdiction over this action under 35 U.S.C. §§ 271 et seq., 28 U.S.C. §§ 1331 and 1338(a). 5. Silicon Labs and MaxLinear have both filed complaints against each

other in two other actions that were consolidated and that are currently pending in

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this District. See Case Nos. 3:12-cv1161-H-MDD and 3:12-cv-1765-H-MDD. By filing a complaint against MaxLinear in this District, Silicon Labs has subjected itself to the personal jurisdiction of this Court. 6. Additionally, the Court may exercise personal jurisdiction over

Silicon Labs because Silicon Labs has continuous and systematic contacts with the State of California and, on information and belief, does business in this District. 7. Silicon Labs conducts business within California by maintaining an

office located at 940 Steward Drive, Sunnyvale, California 94085. Silicon Labs also regularly conducts business in this District and has offered for sale and sold products and systems within this judicial district. 8. Silicon Labs has also committed and continues to commit acts of

patent infringement in this District and has harmed and continues to harm MaxLinear in this district by, among other things, offering for sale and selling infringing products and systems in this judicial district. 9. Because Silicon Labs has availed itself of the privileges of conducting

activities in this District, it is subject to personal jurisdiction in this district. Given that MaxLinear is headquartered in Carlsbad, this District and the State of California has a sufficient interest in resolving this dispute. 10. Venue is proper in this judicial district pursuant to 28 U.S.C. §§

1391(b), (c), (d), and/or 1400(b) because, inter alia, Silicon Labs is subject to personal jurisdiction in this District, Silicon Labs has committed acts of patent infringement in this District and continues to commit acts of infringement in this District, Plaintiff MaxLinear is headquartered in this District, and key witnesses reside in this District. FACTUAL BACKGROUND 11. MaxLinear engages in the design, development and manufacture of

radio frequency and mixed-signal semiconductor solutions for broadband communications applications, and more particularly for use in complementary

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metal-oxide-semiconductor (CMOS) silicon integrated circuits. MaxLinear has invested significant time, financial resources, and efforts in the research and development of its technology. These research and development efforts have resulted in numerous fundamental patents and hundreds of pending United States and foreign patent applications. 12. MaxLinear is the owner by assignment of U.S. Patent No. 8,374,568

(“the ‘568 patent”), U.S. Patent No. 8,374,569 (“the ‘569 patent”), U.S. Patent No. 8,374,570 (“the ‘570 patent”), U.S. Patent No. 8,253,488 (“the ‘488 patent”), and U.S. Patent No. 8,427,232 (“the ‘232 patent”) (collectively “Asserted Patents”). 13. Silicon Labs has infringed and continues to infringe one or more

claims of the Asserted Patents by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2140, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2170, Si2171, Si2172, Si2173, Si2176, Si2178, Si2185, Si2190, and Si2196 TV Tuner ICs (the “Accused Products”), without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the Asserted Patents pursuant to 35 U.S.C. § 271(a). 14. A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the Asserted Patents and that the Accused Products, on their own and/or when incorporated into devices, such as televisions, infringe the Asserted Patents. Accordingly, Silicon Labs knows that the Accused Products, and devices that incorporate the Accused Products, infringe the Asserted Patents. Silicon Labs has induced and encouraged the direct infringement of the Asserted Patents by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the Asserted Patents and that incorporate the Accused

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Products identified above. Silicon Labs is, therefore, liable for indirect infringement of the Asserted Patents pursuant to 35 U.S.C. § 271(b). 15. Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the Asserted Patents. The claims of the Asserted Patents are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users use the Accused Products to practice the inventions of the Asserted Patents. The Accused Products embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing use. Silicon Labs knows that devices incorporating the products identified above infringe the Asserted Patents. Silicon Labs knows that use of those devices infringes the Asserted Patents. Silicon Labs is, therefore, liable for indirect infringement of the Asserted Patents pursuant to 35 U.S.C. § 271(c). 16. Unless enjoined by this Court, Silicon Labs will continue to infringe

the Asserted Patents, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 17. As a result of Silicon Labs’ infringement of the Asserted Patents,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. COUNT I (Infringement of U.S. Patent No. 8,374,568) 18. MaxLinear repeats and realleges the allegations of paragraphs 1

through 17 in their entirety.

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19.

On February 12, 2013, the United States Patent and Trademark Office

duly and legally issued U.S. Patent No. 8,374,568 (“the ‘568 patent”), entitled “Harmonic Reject Receiver Architecture And Mixer,” to Kishore Seendripu, Raymond Montemayor, Sheng Ye, Glenn Chang, and Curtis Ling. At all relevant times, MaxLinear has been the owner, by valid assignment, of all right, title, and interest in and to the ‘568 patent. A true and correct copy of the ‘568 patent is attached hereto as Exhibit 1. 20. Silicon Labs has infringed and continues to infringe one or more

claims of the ‘568 patent by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2140, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2170, Si2171, Si2172, Si2173, Si2176, Si2178, Si2185, Si2190, and Si2196 TV Tuner ICs, without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the ‘568 patent pursuant to 35 U.S.C. § 271(a). 21. A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the ‘568 patent and that the products identified in the preceding paragraph, on their own and/or when incorporated into devices, such as televisions, infringe the ‘568 patent. Accordingly, Silicon Labs knows that the identified products, and devices that incorporate them, infringe the ‘568 patent. Silicon Labs has induced and encouraged the direct infringement of the ‘568 patent by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the patented invention and that incorporate the products identified above. Silicon Labs is, therefore, liable for indirect infringement of the ‘568 patent pursuant to 35 U.S.C. § 271(b).

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22.

Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the ‘568 patent. The claims of the ‘568 patent are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users use the products identified above to practice the inventions of the ‘568 patent. The products identified above embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing use. Silicon Labs knows that devices incorporating the products identified above infringe the ‘568 patent. Silicon Labs knows that use of those devices infringes the ‘568 patent. Silicon Labs is, therefore, liable for indirect infringement of the ‘568 patent pursuant to 35 U.S.C. § 271(c). 23. Unless enjoined by this Court, Silicon Labs will continue to infringe

the ‘568 patent, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 24. As a result of Silicon Labs’ infringement of the ‘568 patent,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. COUNT II (Infringement of U.S. Patent No. 8,374,569) 25. MaxLinear repeats and realleges the allegations of paragraphs 1

through 24 in their entirety. 26. On February 12, 2013, the United States Patent and Trademark Office

duly and legally issued U.S. Patent No. 8,374,569 (“the ‘569 patent”), entitled “Harmonic Reject Receiver Architecture And Mixer,” to Kishore Seendripu,

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Raymond Montemayor, Sheng Ye, Glenn Chang, and Curtis Ling. At all relevant times, MaxLinear has been the owner, by valid assignment, of all right, title, and interest in and to the ‘569 patent. A true and correct copy of the ‘569 patent is attached hereto as Exhibit 2. 27. Silicon Labs has infringed and continues to infringe one or more

claims of the ‘569 patent by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2140, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2170, Si2171, Si2172, Si2173, Si2176, Si2178, Si2185, Si2190, and Si2196 TV Tuner ICs, without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the ‘569 patent pursuant to 35 U.S.C. § 271(a). 28. A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the ‘569 patent and that the products identified in the preceding paragraph, on their own and/or when incorporated into devices, such as televisions, infringe the ‘569 patent. Accordingly, Silicon Labs knows that the identified products, and devices that incorporate them, infringe the ‘569 patent. Silicon Labs has induced and encouraged the direct infringement of the ‘569 patent by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the patented invention and that incorporate the products identified above. Silicon Labs is, therefore, liable for indirect infringement of the ‘569 patent pursuant to 35 U.S.C. § 271(b). 29. Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the ‘569 patent. The claims of the ‘569 patent are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users

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use the products identified above to practice the inventions of the ‘569 patent. The products identified above embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing use. Silicon Labs knows that devices incorporating the products identified above infringe the ‘569 patent. Silicon Labs knows that use of those devices infringes the ‘569 patent. Silicon Labs is, therefore, liable for indirect infringement of the ‘569 patent pursuant to 35 U.S.C. § 271(c). 30. Unless enjoined by this Court, Silicon Labs will continue to infringe

the ‘569 patent, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 31. As a result of Silicon Labs’ infringement of the ‘569 patent,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. COUNT III (Infringement of U.S. Patent No. 8,374,570) 32. MaxLinear repeats and realleges the allegations of paragraphs 1

through 31 in their entirety. 33. On February 12, 2013, the United States Patent and Trademark Office

duly and legally issued U.S. Patent No. 8,374,570 (“the ‘570 patent”), entitled “Harmonic Reject Receiver Architecture And Mixer,” to Kishore Seendripu, Raymond Montemayor, Sheng Ye, Glenn Chang, and Curtis Ling. At all relevant times, MaxLinear has been the owner, by valid assignment, of all right, title, and interest in and to the ‘570 patent. A true and correct copy of the ‘570 patent is attached hereto as Exhibit 3.

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34.

Silicon Labs has infringed and continues to infringe one or more

claims of the ‘570 patent by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2140, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2170, Si2171, Si2172, Si2173, Si2176, Si2178, Si2185, Si2190, and Si2196 TV Tuner ICs, without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the ‘570 patent pursuant to 35 U.S.C. § 271(a). 35. A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the ‘570 patent and that the products identified in the preceding paragraph, on their own and/or when incorporated into devices, such as televisions, infringe the ‘570 patent. Accordingly, Silicon Labs knows that the identified products, and devices that incorporate them, infringe the ‘570 patent. Silicon Labs has induced and encouraged the direct infringement of the ‘570 patent by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the patented invention and that incorporate the products identified above. Silicon Labs is, therefore, liable for indirect infringement of the ‘570 patent pursuant to 35 U.S.C. § 271(b). 36. Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the ‘570 patent. The claims of the ‘570 patent are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users use the products identified above to practice the inventions of the ‘570 patent. The products identified above embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing

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use. Silicon Labs knows that devices incorporating the products identified above infringe the ‘570 patent. Silicon Labs knows that use of those devices infringes the ‘570 patent. Silicon Labs is, therefore, liable for indirect infringement of the ‘570 patent pursuant to 35 U.S.C. § 271(c). 37. Unless enjoined by this Court, Silicon Labs will continue to infringe

the ‘570 patent, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 38. As a result of Silicon Labs’ infringement of the ‘570 patent,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. COUNT IV (Infringement of U.S. Patent No. 8,253,488) 39. MaxLinear repeats and realleges the allegations of paragraphs 1

through 38 in their entirety. 40. On August 28, 2012, the United States Patent and Trademark Office

duly and legally issued U.S. Patent No. 8,253,488 (“the ‘488 patent”), entitled “Self-Calibrating Gain Control System,” to James Qiu and Sridhar Ramesh. At all relevant times, MaxLinear has been the owner, by valid assignment, of all right, title, and interest in and to the ‘488 patent. A true and correct copy of the ‘488 patent is attached hereto as Exhibit 4. 41. Silicon Labs has infringed and continues to infringe one or more

claims of the ‘488 patent by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2173, Si2176, Si2178, Si2185, Si2190,

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and Si2196 TV Tuner ICs, without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the ‘488 patent pursuant to 35 U.S.C. § 271(a). 42. A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the ‘488 patent and that the products identified in the preceding paragraph, on their own and/or when incorporated into devices, such as televisions, infringe the ‘488 patent. Accordingly, Silicon Labs knows that the identified products, and devices that incorporate them, infringe the ‘488 patent. Silicon Labs has induced and encouraged the direct infringement of the ‘488 patent by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the patented invention and that incorporate the products identified above. Silicon Labs is, therefore, liable for indirect infringement of the ‘488 patent pursuant to 35 U.S.C. § 271(b). 43. Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the ‘488 patent. The claims of the ‘488 patent are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users use the products identified above to practice the inventions of the ‘488 patent. The products identified above embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing use. Silicon Labs knows that devices incorporating the products identified above infringe the ‘488 patent. Silicon Labs knows that use of those devices infringes the ‘488 patent. Silicon Labs is, therefore, liable for indirect infringement of the ‘488 patent pursuant to 35 U.S.C. § 271(c).

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44.

Unless enjoined by this Court, Silicon Labs will continue to infringe

the ‘488 patent, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 45. As a result of Silicon Labs’ infringement of the ‘488 patent,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. COUNT V (Infringement of U.S. Patent No. 8,427,232) 46. MaxLinear repeats and realleges the allegations of paragraphs 1

through 45 in their entirety. 47. On April 23, 2013, the United States Patent and Trademark Office

duly and legally issued U.S. Patent No. 8,427,232 (“the ‘232 patent”), entitled “Self-Calibrating Gain Control System,” to James Qiu and Sridhar Ramesh. At all relevant times, MaxLinear has been the owner, by valid assignment, of all right, title, and interest in and to the ‘232 patent. A true and correct copy of the ‘232 patent is attached hereto as Exhibit 5. 48. Silicon Labs has infringed and continues to infringe one or more

claims of the ‘232 patent by making, using, selling, offering for sale, and/or importing into the United States products and systems including, but not limited to the Si2111, Si2113, Si2115, Si2128, Si2136, Si2138, Si2143, Si2145, Si2146, Si2148, Si2153, Si2155, Si2156, Si2158, Si2173, Si2176, Si2178, Si2185, Si2190, and Si2196 TV Tuner ICs, without the permission of MaxLinear. Silicon Labs is, thus, liable for direct infringement of the ‘232 patent pursuant to 35 U.S.C. § 271(a).

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49.

A reasonable opportunity for discovery is likely to show that Silicon

Labs knew and by virtue of this Complaint does now know of the ‘232 patent and that the products identified in the preceding paragraph, on their own and/or when incorporated into devices, such as televisions, infringe the ‘232 patent. Accordingly, Silicon Labs knows that the identified products, and devices that incorporate them, infringe the ‘232 patent. Silicon Labs has induced and encouraged the direct infringement of the ‘232 patent by its customers, resellers, and end users by directing them and encouraging them to make, use, sell, and offer to sell within the United States and/or to import into the United States one or more devices that embody the patented invention and that incorporate the products identified above. Silicon Labs is, therefore, liable for indirect infringement of the ‘232 patent pursuant to 35 U.S.C. § 271(b). 50. Silicon Labs has and continues to contributorily infringe, and will

continue to contributorily infringe, one or more claims of the ‘232 patent. The claims of the ‘232 patent are directly infringed by Silicon Labs’ customers, resellers, and end users within the United States. These customers and end users use the products identified above to practice the inventions of the ‘232 patent. The products identified above embody all, or a majority, of the elements of the infringed claims and are thus a material part of the patented invention and are not staple articles or commodities of commerce suitable for substantial noninfringing use. Silicon Labs knows that devices incorporating the products identified above infringe the ‘232 patent. Silicon Labs knows that use of those devices infringes the ‘232 patent. Silicon Labs is, therefore, liable for indirect infringement of the ‘232 patent pursuant to 35 U.S.C. § 271(c). 51. Unless enjoined by this Court, Silicon Labs will continue to infringe

the ‘232 patent, and MaxLinear will continue to suffer irreparable harm for which there is no adequate remedy at law. Accordingly, MaxLinear is entitled to

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preliminary and/or permanent injunctive relief against such infringement pursuant to 35 U.S.C. § 283. 52. As a result of Silicon Labs’ infringement of the ‘232 patent,

MaxLinear has been and continues to be irreparably injured in its business and property rights, and is entitled to recover damages for such injuries pursuant to 35 U.S.C. § 284 in an amount to be determined at trial. PRAYER FOR RELIEF WHEREFORE, Plaintiff MaxLinear requests entry of judgment in its favor and against Defendant Silicon Labs as follows: a. Declaring that the Asserted Patents are valid and enforceable, and that

Silicon Labs has infringed one or more claims of the Asserted Patents; b. Preliminarily and/or permanently enjoining Silicon Labs, its officers,

partners, employees, agents, parents, subsidiaries, attorneys, and anyone acting in concert or participation with any of them, from further infringing, contributing to and/or inducing the infringement of the Asserted Patents, in accordance with 35 U.S.C. § 283; c. Awarding MaxLinear damages in an amount adequate to compensate

MaxLinear for Silicon Labs’ infringement, in accordance with 35 U.S.C. § 284; and d. appropriate. Granting such other and further relief as this Court may deem just and

May 16, 2013

/s/ Gregory C. Schodde Gregory C. Schodde Wayne H. Bradley Ryan J. Jungels McANDREWS, HELD & MALLOY, LTD. 500 West Madison Street, 34th Floor Chicago, Illinois 60661 (312) 775-8000 General (312) 775-8100 Fax G. Dale Britton

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KLINEDINST PC 501 West Broadway, Suite 600 San Diego, California 92101 (619) 239-8131 (619) 238-8707 Fax Attorneys for Plaintiff MAXLINEAR, INC.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 May 16, 2013 /s/ Gregory C. Schodde Gregory C. Schodde Wayne H. Bradley Ryan J. Jungels McANDREWS, HELD & MALLOY, LTD. 500 West Madison Street, 34th Floor Chicago, Illinois 60661 (312) 775-8000 General (312) 775-8100 Fax G. Dale Britton KLINEDINST PC 501 West Broadway, Suite 600 San Diego, California 92101 (619) 239-8131 (619) 238-8707 Fax Attorneys for Plaintiff MAXLINEAR, INC. DEMAND FOR JURY TRIAL Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff MaxLinear demands a trial by jury of this action.

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