UNITED STATES DISTRICT COURT FOR THEMIDDLE DISTRICT OF NORTH CAROLINANVIDIA CORPORATION,Plaintiff,v.RAMBUS, INC.Defendant.______________________________________))))))))))Civil Action No.1:08-CV-473
JURY TRIAL DEMANDED
Plaintiff NVIDIA Corporation, upon personal knowledge as to itself and uponinformation and belief as to all other matters, by and through its undersigned attorneys,brings this complaint against Defendant Rambus, Inc. and its agents, and in supportthereof hereby alleges as follows:
INTRODUCTION
1. This action arises from Rambus Inc.’s (“Rambus” or “Defendant”)anticompetitive acts and practices whereby Rambus, through deliberate and intentionalmeans, shoplifted an industry standard relating to the manufacture of common forms of dynamic random access memory (“DRAM”) with the intent of engaging inmonopolistic conduct with regard to DRAM technologies. By putting together amemory architecture portfolio and purposefully withholding information regarding thescope of its patents from the relevant standard setting organizations, Rambusaffirmatively acted to anticompetitively bias the DRAM standard-setting process and,subsequently, illegitimately profit from technologies over which it now claims patent
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