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UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN

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RICKY D. HANGARTNER,

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Cause No. 13-cv-663

Plaintiff,

COMPLAINT FOR PATENT
INFRINGEMENT

v.
INTEL CORPORATION

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JURY TRIAL DEMANDED

Defendant.

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Plaintiff Ricky D. Hangartner complains of Defendant Intel Corporation as follows:
NATURE OF LAWSUIT

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1.

This is a claim for patent infringement arising under the patent laws of the

United States, Title 35 of the United States Code.
THE PARTIES

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2.

Plaintiff Ricky D. Hangartner (“Dr. Hangartner”) is an individual residing in

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Corvallis, Oregon. Dr. Hangartner is the named inventor in, and owner of, U.S. Patent No.

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6,463,422 (the '422 Patent) issued October 8, 2002 and entitled “Probabilistic Computing

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Methods and Apparatus” (copy attached as Exhibit A). Dr. Hangartner owns all right, title,

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and interest in, and has standing to sue for infringement of U.S. Patent No. 6,463,422.

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3.

On information and belief, Defendant Intel Corporation (“Intel”) is a Delaware

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Corporation having a principal place of business at 2200 Mission College Boulevard, Santa

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Clara, California 95054-1549 .

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COMPLAINT - 1

MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, WA 98101
TELEPHONE: 206-436-0900

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JURISDICTION AND VENUE
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This is an action for patent infringement arising under the patent laws of the

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United States of America, Title 35 U.S.C. This Court has jurisdiction over the subject matter

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of the Complaint under 28 U.S.C. §§ 1331 and 1338(a).

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5.

Personal Jurisdiction over the defendant is proper in this Court in that

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Defendant Intel has done, and continues to do business in this district. Venue in this judicial

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district is proper under 28 U.S.C. §§ 1391(b), (c) and/or 1400(b) in that a substantial part of

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the events giving rise to the patent infringement claims herein have taken place and may still

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be taking place in this judicial district.

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THE SUBJECT PATENT
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Dr. Hangartner is a research scientist with a doctorate in computer science and

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considerable experience in the fields of communications and control theory as well as

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probability and statistics. Utilizing his knowledge and experience, Dr. Hangartner conceived

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and developed a unique and highly effective way of generating truly random sequences of

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digital boolean values.

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Dissertation, is highly useful in generating random numbers extensively used in computing

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and other systems.

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7.

This technology, which grew out of Dr. Hangartner's Ph.D.

In 1994, shortly after receiving his doctorate, Dr. Hangartner applied for, and

later received, the '422 patent claiming various aspects of his original technology.
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The ‘422 patent is directed to a probabilistic computing method and apparatus

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wherein random numbers are generated as part of proposed solutions to computing problems.

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One key feature of the method and apparatus includes the generation of truly random numbers

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through use of a cross-coupled pair of transistor inverter circuits. When power is removed

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and reapplied, the circuit will assume one of two opposite states depending on intrinsic circuit

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noise. Because such noise is inherently random, the resulting circuit state is, itself, inherently

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random. Additional circuitry is provided to ensure that charges on the gates of the inverters in

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the cross-coupled circuit are equalized when power is removed. Still further circuity is

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COMPLAINT - 2

MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, WA 98101
TELEPHONE: 206-436-0900

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included for synchronizing operation of the power control and charge equalization circuitry

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in embodiments with one or more than one pair of cross-coupled inverters.

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9.

In early 1997, while interviewing for possible employment with Intel, Dr.

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Hangartner met with Intel's Strategic CAD group, including Dr. Carl-Johan Seger, and

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discussed in great detail the technology Dr. Hangartner had developed and was then patenting.

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As a result of these discussions and disclosures, Intel had knowledge, at least as early as 1997,

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of Dr. Hangartner's technology and potential patent rights.

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DEFENDANT'S ACTS OF PATENT INFRINGEMENT
10.

Dr. Hangartner restates and incorporates by reference paragraphs 1 through 9

above as if fully re-stated herein.
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Defendant Intel is a leading manufacturer of semiconductor chips used in

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computers, mobile devices, and other systems distributed and used throughout the world. In

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or about April, 2012, Intel introduced to the marketplace an updated series of microprocessors

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it code named, “Ivy Bridge.” Upon information and belief, Intel has subsequently introduced

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additional processors under the names, “Haswell” and “Silvermont.”

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Incorporated into the Ivy Bridge, Haswell and Silvermont series of processors

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are circuitry and an instruction set that, among other things, enable users of the processors to

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generate truly random numbers.

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importance to users of the processors and is a valuable feature of the Ivy Bridge series of

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processors.

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Silvermont series of processors is made available to users through the so-called, “RDRAND”

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instruction incorporated into the processors.

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The ability to generate truly random numbers is of

The generation of such random numbers in the Ivy Bridge, Haswell and

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In the Ivy Bridge, Haswell and Silvermont series of processors made, sold,

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offered for sale and used by Intel, the RDRAND instruction that generates random numbers is

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implemented through use of circuitry and techniques developed by Dr. Hangartner and

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disclosed and claimed in his '422 Patent. In the Haswell series of processors, an additional

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COMPLAINT - 3

MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, WA 98101
TELEPHONE: 206-436-0900

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instruction named “RDSEED” is also implemented through use of circuitry and techniques

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developed by Dr. Hangartner and disclosed and claimed in his '422 Patent.

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Intel has been and is infringing Dr. Hangartner's '422 Patent by making, using,

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offering for sale, selling and/or importing processors incorporating the RDRAND and/or

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RDSEED instructions and including circuitry constructed in accordance with the '422 Patent.

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In particular, Defendant Intel Corporation has been and is directly infringing at least Claim 1

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of the ‘422 Patent under 35 U.S.C. §271(a) by providing to customers, including customers in

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this judicial district, processors that include probabilistic computing methods and apparatus

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constructed in accordance with that claim. Defendant Intel Corporation has also been, and is,

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directly infringing at least Claim 1 of the ‘422 Patent under 35 U.S.C. §271(a) by making,

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offering for sale, selling, using and/or importing such processors in and/or into the United

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States. Upon information and belief, infringing devices made, offered for sale, sold, or

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imported into the United States by Defendant Intel Corporation include, by way of example

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but not limitation, the “Ivy Bridge,” “Haswell” and “Silvermont” series of processors as well

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as any other processors that include the “RDRAND” or “RDSEED” instructions.

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Corporation has also infringed the ‘422 patent under 35 U.S.C. §271(b) by knowingly and

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actively inducing others to infringe through the sale, distribution and use of such processors

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incorporating such probabilistic computing methods and apparatus. By way of example, not

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limitation, a representative claim chart showing how the processors made, sold, offered for

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sale, used or imported into the United States by Intel Corporation infringe at least Claim 1 of

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the '422 Patent is attached as Exhibit B.

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Intel

Intel Corporation's direct infringement and inducement to infringe have been

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willful and have deliberately injured and will continue to injure Dr. Hangartner unless and

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until the Court enters an injunction prohibiting further infringement and, specifically,

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enjoining further manufacture, use, importation, sale and/or offer for sale of products that fall

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within the scope of the ‘422 patent claims.

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COMPLAINT - 4

MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, WA 98101
TELEPHONE: 206-436-0900

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PRAYER FOR RELIEF

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WHEREFORE, Dr. Hangartner asks this Court to enter judgment against Defendant

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and against its subsidiaries, affiliates, agents, servants, employees and all persons in active

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concert or participation with them, granting the following relief:

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A.

An award of damages adequate to compensate Dr. Hangartner for the

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infringement that has occurred, together with prejudgment interest from the date infringement

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of the '422 Patent began;

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B.

Increased damages as permitted under 35 U.S.C. § 284;

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C.

A finding that this case is exceptional and an award to Dr. Hangartner of his

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attorneys’ fees and costs as may be appropriate and as provided by 35 U.S.C. § 285;
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A permanent injunction prohibiting further infringement, inducement and

contributory infringement of the '422 Patent.
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Pre-judgment interest calculated from the time of the first occurrence of any

infringing activity through and until entry of judgment; and
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Such other and further relief as this Court or a jury may deem proper and just.

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JURY DEMAND

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Dr. Hangartner demands a trial by jury on all issues presented in this Complaint.

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Dated: September 19, 2013.

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Respectfully submitted,
/Philip P. Mann
Philip P. Mann, WSBA No: 28860
MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, Washington 98101
Phone (206) 436-0900
Fax (866) 341-5140
phil@mannlawgroup.com

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Attorneys for Plaintiff Ricky D.
Hangartner

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COMPLAINT - 5

MANN LAW GROUP
1218 Third Avenue, Suite 1809
Seattle, WA 98101
TELEPHONE: 206-436-0900

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